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VIEWS: 57 PAGES: 162

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									   Public Health Assessment



ValAdCo Confined Livestock Operation
           Renville County, Minnesota



                   July 2003




                     Prepared by:


        The Minnesota Department of Health
       Under Cooperative Agreement with the
   Agency for Toxic Substances and Disease Registry
                                           FOREWORD
This document summarizes public health concerns at the ValAdCo confined animal feeding
operation facilities in Minnesota. It is based on a formal site evaluation prepared by the
Minnesota Department of Health (MDH). A number of steps are necessary to do such an
evaluation:

?      Evaluating exposure: MDH scientists begin by reviewing available information about
       environmental conditions at the site. The first task is to find out how much
       contamination is present, where it is found on the site, and how people might be exposed
       to it. Usually, MDH does not collect its own environmental sampling data. We rely on
       information provided by the Minnesota Pollution Control Agency (MPCA), U.S.
       Environmental Protection Agency (EPA), and other government agencies, private
       businesses, and the general public.

?      Evaluating health effects: If there is evidence that people are being exposed—or could be
       exposed—to hazardous substances, MDH scientists will take steps to determine whether
       that exposure could be harmful to human health. The report focuses on public health—
       the health impact on the community as a whole—and is based on existing scientific
       information.

?      Developing recommendations: In the evaluation report, MDH outlines its conclusions
       regarding any potential health threat posed by a site, and offers recommendations for
       reducing or eliminating human exposure to contaminants. The role of MDH in dealing
       with individual sites is primarily advisory. For that reason, the evaluation report will
       typically recommend actions to be taken by other agencies—including EPA and MPCA.
       If an immediate health threat exists, MDH will issue a public health advisory warning
       people of the danger, and will work to resolve the problem.

?      Soliciting community input: The evaluation process is interactive. MDH starts by
       soliciting and evaluating information from various government agencies, the owner of the
       site, and the community members living near the site. Any conclusions about the site are
       shared with the individuals, groups and organizations that provided the information.
       Once an evaluation report has been prepared, MDH seeks feedback from the public. If
       you have questions or comments about this report, we encourage you to contact us.

       Please write to:      Community Relations Coordinator
                             Site Assessment and Consultation Unit
                             Minnesota Department of Health
                             121 East Seventh Place/Suite 220
                             Box 64975
                             St. Paul, MN 55164-0975

       OR call us at:        (651) 215-0916 or 1-800-657-3908
                             (toll free call—press "4" on your touch tone phone)
                                    Table of Contents
Section                                                          Page
Foreword                                                           2
Table of Contents                                                  3
Executive Summary                                                  4

Section I – Background and History
       A. Background                                                5
              1. Areas of Health Concern                           7
                       a. Air Quality                               7
                       b. Waste Storage                            9
                       c. Land Application                         10
                       d. Dead Animal Disposal                     11
              2. Regional Geology and Hydrogeology                 12
       B. History
              1. Site Visits                                       12
              2. Site Investigation                                13

Section II – Facility Specific Information
       Farm 1/Breeding, Gestation and Farrowing                    13
       Farm 1/Nursery and Finishing                                18
       Farm 2/Breeding, Gestation and Farrowing                    23
       Farm 2/Nursery and Finishing                                28
       Farm 3/Breeding, Gestation and Farrowing                    36
       Farm 4/Breeding, Gestation and Farrowing                    41
       Commercial Nursery                                          45

Section III – Discussion
       Air Quality                                                 48
       Ground Water                                                54
       Surface Water                                               56
       Land Application                                            56
       ATSDR Childrens Health Initiative                           58

Section IV – Conclusions                                           60
Section V – Recommendations                                        61
Section VI – Public Health Action Plan                             63
Section VII – References                                           63

Figures

Appendix A – Water Quality Data Tables
Appendix B – Laboratory Report On Bacteria In County Ditch 124
Appendix C – Citizen Complaints Regarding Feedlots
Appendix D – Comments Received from Other Agencies
Appendix E – Comments Received from the Public




                                            3
                                  Executive Summary
The U.S. Agency for Toxic Substances and Disease Registry (ATSDR) and the Minnesota
Department of Health (MDH) have written a Public Health Assessment of the former ValAdCo
livestock feeding facilities [ValAdCo] in Renville County, in response to a citizen petition. The
assessment evaluates whether residents living near the facilities have been exposed to harmful
substances related to activities at the facility and, if so, whether these exposures may have
caused negative health effects. The environmental media that were evaluated for possible
exposure were:
    • air
    • ground water
    • surface water
Dead animal disposal was also considered, but no specific information was available to allow for
an actual assessment of potential exposures to infectious agents or other toxins associated with
dead animals.

It was determined that residents have been exposed to air emissions that exceed state air quality
and health standards. Physical symptoms reported by residents are consistent with these
exposures and suggest that adverse health effects may have occurred as a result of these
exposures. The air emissions from the ValAdCo facility in section 27 of Norfolk Township
(F2/NF) shown to pose a public health risk. The health risks from air emissions at the other
ValAdCo sites were found to be indeterminate, although it is possible that they too may have
been in violation of Minnesota Ambient Air Quality Standards and may also pose health risks.
These facilities have undergone, or are undergoing, modifications that may correct the air quality
problems. Additional monitoring will be needed to verify compliance with standards.

Evidence of ground water contamination was identified, but no conclusive evidence was found
that residents have been exposed to the contaminated ground water. Moreover, the
contamination detected in monitoring wells does not appear to exceed any state or federal
drinking water standard, except for occasional elevated concentrations of nitrate and bacteria.
However, the data were not adequate to evaluate all of the potential ground water impacts. For
example, several improperly abandoned wells were located in land application areas, and
evidence of others was found, but the wells could not be located. These wells could act as
conduits for contamination to enter the ground water, but there is no information regarding
whether this has occurred. In addition, one facility is located in close proximity to two shallow,
municipal water supply wells and residential wells, but no ground water sampling has been done
to determine whether contamination exists. In addition, most of the facilities have shallow water
supply wells that may act as a potential exposure pathway for workers at the facilities, but no
monitoring data were available for those wells. At this time, it is not possible to determine
whether residents or workers have been exposed to contaminated ground water at any of the
facilities. Therefore, the risk associated with ground water contamination is classified at this
time as “indeterminate.”

Surface water monitoring has been limited at the facilities and is non-existent at the areas where
animal waste is land applied, but there are some sampling results suggesting significant bacterial
contamination of surface waters near at least one facility. The information was not adequate to
determine the source of the bacteria, however. In addition, the surface water sampling was



                                                4
suspended before the projected dates for breakthrough of the lagoon liners. There also is no
information regarding whether residents come in direct contact with surface waters near the
facilities. Therefore, the risk associated with surface water contamination is classified at this
time as “indeterminate.”

Residents reported observing dead animals from the facilities being scavenged by wild and
domestic animals, and the bags in which they were disposed were reportedly observed blowing
across farm fields. Residents also reported seeing liquids seeping from dead animal disposal
containers. ATSDR and MDH staff were unable to obtain any information to evaluate these
concerns, although MDH staff did observe plastic bags in farm fields which residents claimed
were disposal bags. Therefore, the risk associated with dead animal disposal is classified at this
time as “indeterminate”.

Based on these findings, ATSDR and MDH recommend that:
   1.) actions be taken to reduce air emissions from the facilities,
   2.) additional environmental monitoring be conducted at the sites to further evaluate the
       potential for exposure to contamination in the ground water and surface water in the area
       of the facilities, and
   3.) actions be taken to prevent scavenging of dead animals and wind dispersal of the plastic
       bags in which they are disposed.

The former ValAdCo facilities were purchased by Christensen Family, LLC (CFL), after the
report for these sites was completed. In the spring and summer of 2003, CFL upgraded waste
storage at six of the facilities and undertook actions to address some of the concerns identified by
the report. In particular, they have or will: upgraded the waste storage facilities in an effort to
reduce air emissions; installed monitoring wells at the facility located in Crooks Township
section 29; and upgraded the dead animal storage boxes to prevent access of scavengers. These
changes are discussed more fully in Appendix E.

It is important to note that many of the recommendations contained in this report apply
generically to confined livestock feeding operations. The former ValAdCo facilities are not the
only ones in Minnesota where residents have complained of adverse health effects as a result of
exposure to air emissions from the barns, waste storage systems, and land application sites.



                              I. Background and History
A. Background

The U.S. Agency for Toxic Substances and Disease Registry (ATSDR) received a citizen
petition dated May 25, 2001 to conduct a Public Health Assessment for the ValAdCo facilities in
Norfolk Township, Minnesota. The petition specifically cited air and water quality concerns. In
August 2001, the ATSDR tasked the Minnesota Department of Health (MDH), under their
Cooperative Agreement, to conduct the assessment.




                                                 5
ValAdCo is a cooperatively owned hog production business with seven separate facilities located
near the towns of Renville and Olivia, in Renville County, in southwestern Minnesota (Figure 1).
The various facilities began operations between 1993 and 1995. Based upon an initial site visit
by MDH staff, it was determined that routes of exposure may exist at all of these facilities, so it
was decided that the assessment should include all seven facilities.

This public health assessment is based on:
       •       Discussions with ValAdCo, MPCA staff, and Renville County residents;
       •       Site visits conducted by MDH staff in August through October 2001;
       •       Private water supply well sampling conducted by MDH staff in December of
               2001;
       •       Sampling data and other information provided to MDH by the MPCA and
               ValAdCo.

The health assessment focuses on two major areas of concern:

   •   Air emissions from the barns and lagoons, and
   •   Water quality impacts from the storage and land application of large volumes of animal
       waste.

The seven ValAdCo facilities are identified as follows (Figure 1):

Farm 1/Breeding, Gestation, and Farrowing (F1/BGF): Located in the southwest quarter of
Section 34 in Crooks Township of Renville County (Figure 2), MPCA permits indicate this
facility houses up to 1,248 sows and 66 boars. It has two lagoons with a total waste storage
capacity of 868,500 cubic feet (ft3), or approximately 6.5 million gallons (Figure 3; Mensch,
1991). The facility was permitted by the Minnesota Pollution Control Agency (MPCA) in 1992
and began operations in 1993.

Farm 1/Nursery and Finishing (F1/NF): Located in the southeast quarter of Section 29 in
Crooks Township of Renville County (Figure 4), MPCA permits indicate this facility houses
3,840 nursery pigs and 3,840 finishing hogs. It has two lagoons with a total waste storage
capacity of up to 2.36 million ft3, or approximately 17.6 million gallons (Figure 5; Mensch,
1991). The facility was permitted by the MPCA in 1992 and began operations in 1993.

Farm 2/Breeding, Gestation, and Farrowing (F2/BGF): Located in the northeast quarter of
Section 29 in Norfolk Township of Renville County (Figure 6), MPCA permits indicate this
facility houses 2,316 gilts, 480 sows, and 130 boars. It has two lagoons with a total waste
storage capacity of up to 3.47 million ft3, or approximately 25.9 million gallons (Figure 7). The
facility was permitted by the MPCA in 1993 and began operations in 1994.

Farm 2/Nursery and Finishing (F2/NF): Located in the northwest quarter of Section 27 in
Norfolk Township of Renville County (Figure 8), MPCA permits indicate this facility houses
7,680 nursery pigs, 2,880 grower/feeder pigs, and 4,800 finishing hogs. It has two lagoons with
a total waste storage capacity of 4.8 million ft3, or approximately 36 million gallons (Figure 9).
The facility was permitted by the MPCA in 1994 and began operations that same year.




                                                6
Farm 3 (F3): Located in the southwest quarter of Section 5 in Flora Township of Renville
County (Figure 10), MPCA permits indicate this facility houses 5,760 nursery pigs, 480 sows,
2,116 gilts, and 130 boars. It has two lagoons with a total waste storage capacity of up to 3.57
million ft3, or approximately 26.7 million gallons (Figure 11). This facility began operations in
1995.

Farm 4/Breeding, Gestation and Farrowing (F4/BGF): Located in the southwest quarter of
Section 31 in Emmet Township of Renville County (Figure 12), MPCA permits indicate this
facility houses 5,760 nursery pigs, 480 sows, 2,116 gilts, and 130 boars. It has two lagoons with
a total waste storage capacity of up to approximately 3.57 million ft3, or approximately 26
million gallons (Figure 13). The facility began operations in 1995.

Commercial Nursery: Located in the southeast quarter of Section 7 in Flora Township of
Renville County (Figure 14), ValAdCo documents indicate this facility houses 15,360 nursery
pigs and has two earthen basins with a total waste storage capacity of up to approximately
500,000 ft3, or approximately 4 million gallons (Figure 15). The facility was permitted by the
MPCA in 1995 and began operations in 1996.

On December 21, 2002, it was announced that the ValAdCo facilities had been purchased by
Christensen Farms corporation. Christensen Farms intends to upgrade the waste storage systems
at six of the facilities by replacing the clay-lined lagoons with covered, circular, concrete-lined
lagoons. Waste from the existing lagoons will be removed and properly disposed. Construction
of the new waste storage lagoons is slated to begin in the spring of 2003.


1. Areas of Health Concerns:

Residents in Renville county identified four major areas of health concern regarding the
operations at the ValAdCo facilities. These were: air quality, waste storage, land application,
and dead animal disposal. Background information for each of these areas of concern is
provided below:


a) Air Quality

Since ValAdCo began operations there have been hundreds of complaints regarding the
facilities. These complaints were filed with the state Duty Officer, Renville County Public
Health, the Renville County Environmental Officer, and the MPCA. Most of these complaints
regard air quality concerns. The two ValAdCo facilities most often cited are F2/NF and
F2/BGF. As a result, most of the air quality sampling data have been collected at and near these
facilities and most of the discussion in this report focuses on these two facilities.

The ValAdCo group first contacted the Minnesota Pollution Control Agency (MPCA) during the
fall of 1991 about the construction of Breeding and Finishing Units in Sections 27 and 29 of
Norfolk Township in Renville County, and the potential need to complete an Environmental
Assessment Worksheet (EAW). An EAW is required by Minnesota Statutes for large feedlots to
determine need for an Environmental Impact Statement. In August of 1993 the EAW was



                                                7
completed and MPCA’s Citizen’s Board granted ValAdCo approval to proceed with
construction. As part of the EAW process, contingency plans for “Odor Events” and “Surface
and Groundwater Contamination Events” were drafted and operation commenced in 1994. The
Odor Event Contingency Plan did not provide the needed relief from odors, and complaints
began shortly after ValAdCo was granted their permit to operate in September of 1994.

Residents have reported a variety of health effects that they attribute to exposure to the air
emissions from the barns and waste storage lagoons, including respiratory irritation, persistent
cough, headache, burning eyes, nose and throats, nausea, weakness, dizziness, diarrhea, and
fainting. These health effects are consistent with reports of health effects from neighbors of
large-scale swine operations in Iowa (Thu et al, 1997). The Iowa researchers found significantly
higher rates of symptoms associated with chronic bronchitis and hyper-reactive airways and
nausea, weakness, dizziness, and fainting.

These health effects are consistent with health effects in workers at confined animal operations
(VonEssen et al, 1999). These symptoms may be associated with inhalation exposure to
agricultural dust, volatile organic acids, and irritating gases such as hydrogen sulfide (H2S) and
ammonia. While over 160 different gases have been identified in the ambient air of confinement
barns, most are present only in trace amounts and most have no health effects criterion. For
other substances, the levels of gases and dust often do not exceed standards. However, the
multiple exposures to toxic substances from these facilities could reduce the threshold at which
adverse health effects are experienced, as compared to exposure from any single toxic substance.

Citizens began conducting their own air quality sampling for H2S in 1995 using a Jerome 631-X
Gold Film analyzer (Arizona Instrument, Inc), or “Jerome meter.” Sampling protocols for
citizen monitoring were developed and citizens tested for airborne H2S emissions at 18 separate
sites, some of which included ValAdCo facilities. While times and places for the grab sampling
were not chosen in an entirely consistent manner, an MDH review of the data concluded that the
citizen monitoring provided “…a reasonable approximation of results that would have been
obtained through continuous monitoring over a one-hour period” (MDH, 1996a). For citizen’s
monitoring that occurred between May 16 and 31, 1996, hourly averages taken with the Jerome
meter exceeded 50 ppb at the F2/NF (Norfolk 27) and F1/BGF (Crooks 34) sites.

Shortly following the citizen’s monitoring efforts, the Renville County Board approved money
for a pilot study of H2S concentrations in air. Renville County staff used the Jerome meter to
monitor air near city wastewater treatment plants with open lagoons; beef dairy, poultry and
swine operations; and a beet processing plant. Both citizen and county monitoring pulled
samples for either 30 minute or 60 minute sessions. The MDH reviewed the data and concluded
that the levels of H2S detected in the citizen monitoring “…are not of emergency proportions but
are of public health concern” (MDH, 1996a). The MDH recommended that MPCA proceed with
further monitoring activities including continuous monitoring and efforts to further evaluate and
interpret the results of those monitoring efforts.

Over time, air sampling has been conducted by variety of parties, including: Renville County
citizens, Renville County employees, the Minnesota Pollution Control Agency (MPCA) staff and
representatives of the Minnesota Attorney General’s Office.




                                                8
In addition to the Jerome meter citizen sampling, sampling done by Renville County included
odor testing performed by a trained odor tester1 whose job was to record odor intensity levels at
each site. The results of odor testing demonstrated that odor could be detected even when H2S
was not present, indicating that other substances were present. However, if H2S was present,
there was sure to be odor associated with it.

The preliminary sampling with the Jerome meter led to MPCA placement of a continuous air
monitor (CAM) approximately one mile from the F2/NF facility from November of 1996
through November of 1997. This site has had continuous air monitors located at the fence line
since the spring of 1998.

At the F2/NF facility, between April 23, 1998 and the summer of 2002, there were 254 violations
of the 30 ppb H2S Minnesota standard and 290 violations of the 50 ppb H2S Minnesota standard,
all logged on the CAMs.2 The standards for H2S emissions to air are part of the Minnesota
ambient air quality standards set forth in Minnesota Rules 7009.0080.3 Violations have accrued
over the springs and summers of 2001 and 2002, despite ValAdCo’s efforts to control emissions
by placement of a cover over the lagoons and ozonation of the air emissions from under those
covers. When problems continued after the installation of the ozone system, it was determined
that the ozonation system was not working according to the design parameters. At the other
ValAdCo facilities, the lagoons and basins were covered by impermeable membranes to address
air quality issues. There is no data available to document the effectiveness of these covers in
reducing odors or gas emissions.

ValAdCo was required to take grab samples with a Jerome meter as part of the agreement
resulting from violations at the continuous monitoring site (F2/NF facility). Other than
occasional grab samples, air monitoring data are not available for the other five ValAdCo
facilities (ie. F1/BGF, F1/NF, F3/BGF, F4/BGF, or the commercial nursery).


b.) Waste Storage

Many of the public health concerns regarding the ValAdCo facilities, including air quality
concerns, center on the storage and disposal of large volumes of animal waste. These facilities
use open, two-cell lagoon or holding basin systems where waste mixed with water is stored until
it can be land applied on nearby farm fields. Animal wastes (urine, manure, and birthing wastes
such as blood and placentas) in the barns drop through slats in the floors of the animal
confinement areas or onto concrete floors and bedding (in the case of birthing facilities). It is
then removed from the barns by the addition of water that creates a slurry which is piped to the

1
  A trained odor tester is a person who has experience in detecting odors and rating the odors on a scale of 1-5 with
“5” being noxious odor. Trained odor testers know about the various factors that might affect his/her ability to
provide objective data such and must adhere to behaviors that may cause interference such as avoidance of
smoking, and avoidance of various foods.
2
  Complaint filed by the State of Minnesota in the Eighth Judicial District against ValAdCo Corporation to seek to
recover penalties for hundreds of violations of state air standards resulting from the operation of ValAdCo. Mike
Hatch, Attorney General, 6-11-02.
3
  Minn. R. 7009.0080 is a one-half hour average of 0.05 parts per million (ppm), or 50 ppb. which is not to be
exceeded over two times per year. The 30 ppb standard is a half-hour standard not to be exceeded over two times in
any five consecutive days.



                                                         9
first of a series of two settling cells (Figure 16), where it is further diluted with water. In both
the lagoon and basin systems, the first cell has an overflow pipe that leads to the second cell.
Water from near the surface of the second cell is re-circulated through the barns as flush water.
The cell design calls for at least 2 feet of freeboard to allow for snow and rainfall accumulations.

The cells are constructed with compacted clay liners at least two feet thick, which are specified
to achieve permeabilities of 1 x 10-7 centimeters per second or less. This is comparable to the
requirements for human sewage treatment lagoons.

The object of the system is to break down the waste solids as much as possible before applying
the waste to nearby agricultural fields. It is estimated that approximately 15 to 30 percent of the
nitrogen in the waste is lost during storage, through bacterial degradation and volatilization of
ammonia. It is during this degradation process that much of the H2S and other emissions are
generated. It is also estimated that 90 to 99 percent of the bacteria die during storage. However,
Cole, et. al. (1999, p. 437) note that the initial concentrations of bacteria are so great that
significant bacteria remain in the waste even after storage.

The system is intended to operate so that a one-foot thick “sludge” layer develops at the base of
the lagoon, composed of undigested solids from the swine waste. In a lagoon system, this layer
is maintained throughout the year, while in a basin system, all the waste is removed in the fall for
land application.

Without adequate dilution of the waste, odor generation becomes excessive. Both near-surface
aerobic and below-surface anaerobic bacterial degradation of the waste occurs, generating a wide
array of gases, many of which are odorous and physically irritating. O’Neill & Phillips (1992)
report that over 160 chemicals have been detected in emissions from livestock wastes for which
odor thresholds have been established. Additional gases may be emitted from lagoons as the
various components of the waste undergo bacterial degradation.

Waste storage for large-scale animal confinement and feeding operations may engender potential
exposure pathways. Emissions of irritating and potentially toxic gases are the most immediately
obvious. Leakage of the waste lagoons, if it occurs, may result in infiltration of contaminants
and bacteria to the ground water or surface water. Ground water monitoring data are available
only for four of the facilities (F2/NF, F2/BGF, F3, and F4/BGF), where National Pollutant
Discharge Elimination System (NPDES) permits were required by the MPCA.


c.) Land Application

In the fall of each year, the waste and water mixture is piped out of the primary lagoon cell. The
volume removed should approximately equal the volume of waste, flush water, and rainwater
and/or snow meltwater added during the year. Citizens report that odors associated with the
facilities are worst during the pumping of the lagoons and land application. By statute the
facilities are exempt from compliance with air quality standards during those times.

Several feet of wastewater and sludge are left in the cells over the winter, to prevent the freezing
and/or dehydration of the lagoon liner. In contrast, the earthen basins employed at the



                                                10
Commercial Nursery facility are pumped out completely every year, creating the potential for
frost damage to the clay liner.

Samples of the waste and water mixture in the lagoons are collected and analyzed for nutrient
content. This information, combined with soil samples or published soil nutrient data and the
type of crops scheduled to be planted in the fields, is used to calculate the agronomic rate at
which waste should be applied to agricultural fields and how many acres are needed to
accommodate all of the waste. If the agronomic rates are exceeded, excess nutrients may be
carried by runoff water into surface water bodies or may infiltrate into the ground water. It
appears that for most of the ValAdCo facilities, only one or two samples are collected from each
lagoon prior to land application; further, published soil nutrient data were used exclusively,
rather than soil samples, to calculate the application rates.

Application of the waste involves either “knifing” the manure slurry into the soil as it is applied
or broadcasting the manure on the surface and tilling it into the upper soil layer. According to
the permits for the facilities, incorporation is to occur within 48 hours of application, whenever
possible. Land application poses several potential exposure pathways via infiltration to ground
water, run-off to surface water, and direct exposure to waste in the fields if not properly
incorporated or if excessive amounts of waste are applied. In some instances, improperly
abandoned wells present in fields where land application occurs may also be acting as conduits
for contamination to enter the ground water.


d.) Dead animal disposal

Another exposure pathway not mentioned in the citizen petition, but raised by residents during a
site visit, is by disposal of dead animals. Animals are placed, some in plastic bags, in enclosures
located away from the farm buildings along the township roads to await pick-up and disposal.
This is common practice in rural areas of Minnesota and is intended to isolate dead animals from
the herd until they can be properly disposed, to prevent the spread of diseases. The enclosures
are open on top and most have open space at the bottom, through which scavenging animals may
enter.

Residents report seeing animals carrying off small carcasses and the plastic bags blowing across
fields near the facilities. Residents also reported seeing fluids from the decaying animals
seeping from under the enclosures during warm weather. MDH staff observed plastic bags in the
fields, which residents claimed were dead animal disposal bags.

This disposal method may create pathways for exposure to pathogens, if people come into
contact with animals that have scavenged carcasses or if they pick up the plastic bags. For
example, Cole, et. al., (1999, p.427-428) reported that some diseases, such as Leptospirosis, can
have a complicated pathway from swine to humans, involving rodents or pets that interact with
the swine or their wastes and then act as reservoirs for the disease before bringing it into contact
with humans. Other enteric pathogens of concern and which are found more often in swine than
in humans include Salmonella sp., Yersinia, Giardia, and Cryptosporidium (Olson, M.E.,
website).




                                                11
2. Regional Geology/Hydrogeology

The geology of Renville County consists of approximately 200 to 300 feet of glacial till and
outwash deposits which thin to the south and west towards the Minnesota River. The glacial
deposits overlie approximately 100 feet of Cretaceous shale and sandstone. These in turn are
underlain by Precambrian granitic bedrock (Figures 17). The glacial drift deposits are composed
of stratified clay, silt, sand, and gravel that were deposited in distinct layers by glacial melt
water. The glacial tills, in contrast, were deposited by moving glacial ice as non-stratified
mixtures of clay, silt, sand, gravel, and boulders. The sand and gravel layers in the glacial drift
deposits, although usually thin and discontinuous, provide the majority of drinking water in the
region. The Cretaceous sedimentary formations generally have only thin sandstone lenses that
provide drinking water only locally (Van Voast, et. al., 1972).

The ValAdCo facilities are all located within the Hawk Creek Watershed, part of the larger
Minnesota River Watershed. Ground water flow directions, regionally, are to the south and
southwest toward the Minnesota River (Figure 17). However, local shallow ground water flow
directions are strongly influenced by the extensive network of drainage ditches and tile-lines that
transect the agricultural fields in this area. Water quality in the region has been degraded to
varying degrees by nitrate associated with agricultural activities, with the highest concentrations
detected in shallower aquifers where oxygen stabilizes nitrification. At depth, free ammonia
concentrations are higher due to reduction of the nitrate by bacteria (Van Voast, et. al., 1972).

More detailed geologic and hydrogeologic information is provided for each facility in section II
of this report.



B. History

1. Site Visits

On August 7, 20001, Rita Messing, Kathleen Norlien, and Ginny Yingling of the MDH toured
each of the facilities with Mr. Eddie Crum, CEO of the ValAdCo corporation. A subsequent
visit was conducted on September 5, 2001 by Norlien and Yingling to monitor downwind H2S
concentrations at or near the property boundary of each of the facilities. Additional site visits
were conducted by Yingling in October 2001 to observe land application of wastes on nearby
fields and in November to observe abandoned wells that had been located by MDH staff and
residents in land application fields. A final visit was conducted by Yingling on December 26,
2001 to collect water samples from nearby residential wells.




2. Site Investigation

MDH staff visited the facilities on several occasions to evaluate air quality and to observe land



                                               12
application of animal waste. However, the primary investigation activities involved review of
available documents and data related to the ValAdCo facilities. For each facility where
sufficient information was available, staff attempted to assess the following areas of concern:

Air Quality – Air quality monitoring data were reviewed to evaluate possible exposures to
nearby residents and to assess the adequacy of the air monitoring systems. Citizen complaint
records were also reviewed to determine the frequency and severity of experienced exposures
and to identify reported health effects.

Groundwater – Ground water monitoring and water level data were reviewed to determine
whether leakage from the waste storage lagoons is occurring and, if so, the level of impact to
ground water quality and the potential for impacts to nearby private water supply wells. Private
well nitrate and bacteria testing data were reviewed to determine whether actual impacts may
have occurred. Lagoon construction reports and manure management records were reviewed to
determine the potential for leakage from the waste storage lagoons. Aerial photographs and
other historical information were used to identify potential pathways for contamination to enter
the ground water.

Surface Water – Potential pathways for contaminant migration to surface waters were assessed.
Reports of ditch water samples and waste spills were reviewed to determine if any direct impacts
to surface water have occurred.

Land Application – Land application reports were reviewed to evaluate the volume of waste
applied and the rate at which it was applied to determine whether land application may represent
a pathway for contamination of either surface or ground water.

The results of each of these assessments are detailed by facility in Section II, below.

Dead Animal Disposal – Staff did not have any way to evaluate this concern, beyond observing
the storage structures for the dead animals and noting the presence of plastic bags in fields that
residents stated were used for dead animal disposal.



                          II. Facility Specific Information

Farm 1/Breeding, Gestation, and Farrowing (F1/BGF):

This facility is located in Crooks Township, Section 34, approximately one mile northeast of the
town of Renville and immediately north of the Southern Minnesota Sugar Beet Coop (SMSBC)
(Figure 2). Golden Oval, an egg processing plant, is located approximately one-half mile
southwest of the facility. MDH staff visited the F1/BGF facility on August 7, 2001. It consists
of three buildings housing up to 1,248 sows and 66 boars, and two waste storage lagoons with
capacity to store up to approximately 6.5 million gallons of waste and water (Figure 3).

Air Quality:



                                                13
The first monitoring for H2S emissions from this facility was completed between May 16 and
May 31 of 1996. This monitoring was done by a group of Renville County citizens using a
Jerome meter. Monitoring was conducted downwind of the facility at areas to which the public
had access, generally within three-quarters of a mile or less from the potential source of H2S
emissions. The citizens, with the help of a consultant, developed a protocol for their monitoring
to assure uniformity of testing procedures and objectivity of their measurements. Jerome meter
readings were taken at five-minute intervals over a one-hour period to obtain reasonable
estimations of one-hour average H2S concentrations in air. On May 22, 1996, the one-hour
average H2S concentration was found to be 78 parts per billion (ppb) with a maximum reading of
140 ppb during this monitoring session.

Later that summer, on July 19 and 30, additional sampling was performed as part of a study
funded by the Renville County Board of Commissioners. For this study, the Jerome meter was
used to measure concentrations of H2S in a 30-minute time frame. On July 19, 1996, the 30-
minute average for H2S was 0.8 ppb with a maximum reading of 4 ppb. On July 30, 1996, the
30-minute average for H2S was 0.3 ppb with a maximum concentration of 1 ppb.

Samples taken on September 5, 2001 by MDH using a Jerome meter yielded H2S readings of 2
ppb for each of 2 grab samples.

To the best of our knowledge, no additional air quality data exist for this facility. It is important
to note that it may be difficult to determine whether odors and H2S emissions in this area are
related to the F1/BGF facility, the Southern Minnesota Sugar Beet Cooperative (SMSBC), or the
Golden Oval Egg processing facility. H2S data collected by Renville County found H2S air
concentrations (associated with the beet plant) from 56-86 parts per billion (ppb) for the four
monitoring periods during the summer of 1996.


Geology/hydrogeology:
The drilling logs for a SMSBC water supply well located immediately east of the F1/BGF
facility (unique well number 616894), and two Minnesota Department of Natural Resources
(MDNR) monitoring wells located immediately northwest of the facility (unique well numbers
617722 and 617735) indicate that the area is underlain by 3 to 8 feet of sandy clay that is
underlain by a sand and gravel layer between 24 to 48 feet thick, which in turn is underlain by 64
feet of clay. However, the “Site Work/Waste Handling” report from ValAdCo (Mensch, 1991)
indicates that borings drilled prior to construction of the lagoons encountered “uniform clay
material”, with only one sandy clay lens being encountered in one boring (B-3) at 16 to 19 ft.
below grade, approximately 3.5 feet below the base of lagoon #2. The MDNR and SMSBC
wells with thick sand layers likely are completed in a buried glacial outwash channel sand that
approximately follows the course of County Ditch 37. The ValAdCo facility appears to be
located just south of this buried channel, which would account for the absence of the thick sand
sequence in the borings drilled on the property.

Monitoring wells were not required by the MPCA at this facility, so no information is available
regarding local ground water flow directions. It is likely that near surface ground water flow is
to the north or northeast, toward county ditch number 37. The on-site water supply wells are



                                                14
completed at 35 – 36 feet below grade. The only conclusion that may be drawn regarding the
surface of the water table is that it is located at less than 35 feet below the ground surface, and
likely is at approximately the same elevation as the water level in ditch number 37.
Ground water:

Because no monitoring wells were installed at this facility, there are no data available regarding
water quality beneath or adjacent to the waste storage lagoons. Moreover, no leakage rate
calculations were available from either MPCA or ValAdCo files, so there are no estimates
regarding the timeframe in which it would be expected that liquid would begin to pass through
the liner of the lagoons (larger particles may never pass through the liner). However, if the
minimum permeability of 1 x 10-7 cm/sec was achieved in construction of the clay liners, and
assuming an operating head of 12 to 15 feet of waste in the lagoons, breakthrough of the liners
would occur in approximately 1.1 to 1.4 years (the higher the head value, the faster the
breakthrough time). This would be an extremely conservative estimate, because the permeability
of the liners reported for the other ValAdCo facilities ranged from 1.2 to 4.9 x 10-8 cm/sec. If
these values are used, and again assuming an operating head of 12 to 15 feet of waste in the
basins, the liner breakthrough time would range from approximately 2.4 to 12.5 years (again, the
faster breakthrough time reflects the higher head and permeability values). This means the liners
could be expected to experience breakthrough sometime between 1998 and 2008.

There are a number of residential properties near the facility, the nearest approximately ¼ mile
to the northwest (Figure 2). A review of the County Well Index maintained by the Minnesota
Geologic Survey revealed that well logs are not available for the properties nearest the facility.
There are water supply wells owned by ValAdCo at the facility, which are completed at 35 and
36 feet below grade and are identified in the well logs as “domestic” wells (unique well no.
463506 and 482758). No information was provided in the well logs regarding the geologic
formations encountered when the wells were drilled.

The next nearest private well for which a geologic log is available is approximately one mile
southwest of the facility and is completed at a depth of 229 feet below grade (unique well no.
161624). Another well is located in section 27, north of the facility and is completed at 195 ft.
below grade, beneath 187 feet of clay (unique well no. 148846; this well is not shown on Figure
2 because location information was not provided on the well log). Two more wells, classified as
“public supply/non-community” and owned by SMSBC, are located approximately ¾ to 1 mile
south of the facility and are completed at 65 and 80 ft. below grade, beneath alternating layers of
clay and sand (unique well no. 102100 and 214209, respectively). At least nine more wells are
registered to SMSBC in the section immediately south of the facility, ranging in depth from 43 to
90 feet deep and reportedly all are used for industrial purposes (i.e. they are not used as drinking
water sources).

Most of the water supply wells in the area are likely protected from contamination by the layers
of clay above their screens and the distance from the facility, although without detailed well
depth and geologic information for many of these wells, it is impossible to draw any final
conclusions regarding risk to the wells. The shallow water supply wells on the ValAdCo
property may be the most at risk for contamination. No stratigraphic information was provided
in the drilling logs for these wells, so it is not possible to evaluate the potential risk. Also of
concern is the potential for any ground water contamination from the F1/BGF facility to enter



                                                15
the buried stream channel aquifer immediately north of the facility, which is a major source of
drinking water in the area.

Surface water:
No surface water quality data were available from MPCA or ValAdCo files. During site visits in
the fall of 2001, staff did not observe any instances of land applied waste encroaching upon or
entering nearby ditches.

ValAdCo reported two spills at this facility. The first spill occurred on December 24 or 25, 1995
and involved approximately 3,000 gallons of recycle flush water (i.e. water that is circulated
from the waste lagoons to the barns to flush waste into the lagoons). The water reportedly froze
in a 4 foot by 200 foot by 6 inch layer of ice which was removed and placed in the lagoons. The
second spill occurred on August 3, 1999 and involved approximately 300 to 400 gallons of waste
that came out of an obstructed clean out standpipe. The waste was collected and disposed in the
lagoons. This spill was investigated by MPCA staff and they reported finding no residual
manure on the ground nor any visible stress to vegetation in the area of the spill.

Land Application:

The manure management plan for this facility, dated September 13, 1991 (Gislason, et. al, 1991)
and the Project Manual (Mensch, 1991), estimated approximately 660,000 gallons of manure
annually from the facility, of which approximately 10,000 – 27,000 pounds of organic nitrogen,
10,000 pounds of phosphate, and 38,000 pounds of potassium would be available to crops.
Based on these calculations, it was estimated that to use all of these nutrients as fertilizer,
approximately 55 - 180 acres of corn or soybean cropland would be needed to use all of the
nitrogen, 133 acres of corn or 236 acres of soybeans would be needed to use all of the phosphate,
and 176 acres of corn or 473 acres of soybeans would be needed to use all of the potassium.
While adequate acreages were used for uptake of the projected mass of nitrogen, it appears that
at no time were large enough acreages used for uptake of the projected mass of phosphate and
potassium. However, the actual volume of waste produced was as much as 600% larger than
estimated, without a corresponding increase in acreage for land application, suggesting that over-
application of nutrients may have occurred.

Actual application rates were based on laboratory analysis of manure samples collected prior to
application and estimated and published soil nutrient data, to determine the nutrient content of
the manure and the nutrient requirements for the specific fields. Generally, only one or two
samples of the waste were analyzed (five samples were analyzed for the spring applications in
1997). There is no evidence that soil samples were ever analyzed to determine the actual
nutrient content of the soils at the land application sites, although the permit for this facility
requires that the soil be tested at each land application prior to spreading the waste. There also
are no records kept of waste levels in the lagoons throughout the season and after land
application, making it difficult to evaluate the actual waste input into the lagoons and to compare
them to the amounts land applied.

The land application reports for this facility state that the manure management plan projected
only 10,620 pounds of nitrogen production annually from the facility, which is at the low end of
the range projected in Gislason, et. al (1991) and Mensch (1991). No details are provided on



                                               16
how this figure at the low end of the range was derived, nor whether this refers to total nitrogen
or only crop available organic nitrogen. Samples of the land-applied waste collected by
ValAdCo indicate a total nitrogen content of 5 to 8.9 pounds per 1000 gallons of waste. The
original estimates of nutrient production (Gislason, et. al., 1991; Mensch, 1991) would have
equaled approximately 15 to 41 pounds of nitrogen per 1000 gallons of waste.

No explanation was provided in the MPCA or ValAdCo files for this discrepancy, but two
possibilities present themselves. Either the original reports grossly over-estimated the nitrogen
content of the waste, or the waste sampling method did not account for all of the nitrogen. While
the first explanation is possible, it seems unlikely that two separate estimates would be in
relatively close agreement and both project the higher rates of nitrogen production. The latter
explanation seems more likely. As noted above, only one or two samples of the waste were
collected in any given year. Dou, et. al. (2001) observed 20 to 30 percent variability in sample
results for non-agitated swine waste and concluded that many more samples were necessary to
adequately characterize the waste. Moreover, if samples were collected primarily from near the
surface of the lagoon, where the waste would be the most dilute due to precipitation and settling,
this would tend to underestimate the total nutrient content. If the second explanation is the
correct one, this raises the question of whether land application activities have resulted in
elevated rates of nitrogen application. If so, this could have significant consequences for both
surface and ground water quality.

Land application of wastes from this facility began in 1996, with two applications, 1.67 million
gallons on 35 acres in May and 2.97 million gallons on 80 acres in November.

In April 1997, heavy rains caused water levels in the lagoons to rise to near overflowing,
resulting in an emergency application of 854,000 gallons of waste on approximately 30 acres of
property leased by SMBSC. Later that same month, 4.03 million gallons were applied to 80
acres, followed in October 1997 by 2.28 million gallons applied on 73 acres.

In November 1998, only 27,000 gallons of waste were applied, on 78 acres. No explanation was
contained in MPCA or ValAdCo files regarding the significant drop in waste generation that
year.

In October 1999, 2.35 million gallons of waste were applied to 73.5 acres. A similar volume of
waste, 2.66 million gallons, was applied to 80 acres in October 2000, the last year for which
there were reports at the time the file review was completed. Again, these volumes are
significantly smaller than those reported in earlier years.

Analysis of all the land application areas did not reveal any instances of reapplication to fields,
which could lead to excessive nutrient build-up in the soils.

A review was completed of historical aerial photographs for the land application areas. These
revealed the presence of a homestead dating at least from 1938 through 1967 in the eastern half
of the northwest quarter of section 34 (aerial photo BJK-7-57, location marked on figure 2).
This same homestead was not present in the 1992 aerial photograph of that location. It is likely
that a water supply well was present at that homestead and may still be present, although no
longer visible. If so, such a well could provide a conduit for land applied waste to migrate to the



                                                17
ground water. This area reportedly was used for land application in 1996 and 2000.

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--

Farm 1/Nursery and Finishing (F1/NF):

This facility is located in Crooks Township, Section 29, approximately 1.5 mile north of the
town of Renville (Figure 4). MDH staff visited the facility on August 7, 2001. It consists of five
buildings housing up to 3,840 nursery pigs and 3,840 finishing hogs, and two waste storage
lagoons with capacity to store up to approximately 17.6 million gallons of waste and water
(Figure 5).

Air Quality:

The first monitoring for H2S emissions from this facility was completed on May 30 of 1996.
Monitoring was done by a group of Renville County citizens using a Jerome meter. Monitoring
data were collected at areas to which the public had access, generally within three-quarters or
less of a mile from the potential source of H2S emissions. The citizens, with the help of a
consultant, developed a protocol for their monitoring to assure uniformity of testing procedures
and objectivity of their measurements. Jerome meter readings were taken at five-minute
intervals over a one-hour period to obtain reasonable estimations of one-hour average H2S
concentrations in air (see p. 51, Table VIII).

On May 30, 1996, the one-hour average H2S concentration was found to be 9 parts per billion
(ppb) with a maximum reading of 22 ppb during this monitoring session.

On August 14 and 19, 1996, additional sampling was performed by Renville County citizens.
Hourly averages for H2S concentrations were found to be 17.9 ppb, 18.4 ppb, and 19.5 ppb with
maximum readings of 37 ppb, 27 ppb, and 48 ppb respectively.

As part of a study funded by the Renville County Board of Commissioners, 30-minute averages
were obtained with the Jerome meter. On July 22, 1996, the 30-minute average for H2S was 8.5
ppb with a maximum reading of 16 ppb.

On July 30, 1996, the 30-minute average for H2S was 3.8 ppb with a maximum concentration of
9 ppb.

On September 5, 2001, MDH staff measured H2S concentrations by taking grab samples using a
hand-held Jerome meter. Measurements taken at 5:25 pm ranged from 3 ppb to 4 ppb, while
those taken at 7:15 pm ranged from 4 ppb to 7 ppb.

To the best of our knowledge, no additional air quality data exist for this facility. It is important
to note that odors and H2S concerns in this area may also be related to the ValAdCo F1/BGF
facility located approximately 1 mile, the SMSBC plant located approximately 1.5 miles, or the
Golden Oval egg processing facility approximately 2 miles to the southeast. H2S data collected
by Renville County found H2S near the beet processing plant ranged from 56-86 parts per billion



                                                       18
(ppb) in air for the four sampling periods monitored during the summer of 1996.



Geology/hydrogeology:

Nearby well logs indicate that most of the area near the F1/NF facility is underlain by up to 200
feet of clay. However, immediately south of the facility the geology is quite different, with a
very thin layer of clay above a 50 foot thick layer of sand. The sand layer is a buried outwash
channel sand that trends northwest-southeast. The City of Renville municipal wells #5 and #6,
are located approximately 1,200 feet south of the southern lagoon (Figures 4 and 18) and are
completed at 56 and 53 feet deep, respectively. The casings for the wells extend only to 41 and
38 feet below grade, respectively. Both wells draw water from the buried outwash channel sand
deposits, which in that location extend from 4 to 53 feet below grade (Figure 19). The MDH
Wellhead Protection Program has determined this outwash channel sand to be highly vulnerable
to contamination from surficial and near-surface sources (Figure 20).

Private wells in the area of the facility range in depth from 35 to 219 feet below grade. The
nearest are three wells that are located on ValAdCo property. They are registered with the state
as domestic wells (unique well numbers 483884, 483885, 525595). According to the County
Well Index, the wells are located approximately 1/2 mile west of the facility and are completed
at depths of 35 to 57 feet below grade, beneath 26 - 30 feet of clay.

Four residences are located near the facility. Two homes are located less than 1,000 feet east
and southeast of the facility. A well log is available only for the home to the southeast; the well
is completed at 44 feet below grade, beneath 28 feet of clay (unique well number 483882). It
does not appear, given the reported location of this well and the geology reported in the well log,
that it is completed in the buried channel sand. However, it is possible, given the proximity of
this well to Renville city wells #5 and #6 and the similarity in depths, that it draws water from a
sand layer that may be hydraulically connected to the sand in which the city wells are completed.
The third residential well, located approximately ¾ mile northwest of the facility is completed at
219 feet below grade, beneath 203 feet of clay (unique well number 545477). The fourth
residential well is located approximately 1 mile north-northwest of the facility and is completed
at 230 feet below grade, beneath 160 feet of clay (unique well number 649130). The County
Well Index also indicates the presence of three monitoring wells and three test wells south of the
F1/NF facility. The test wells have been sealed. According to the well logs, the monitoring
wells are not owned by either the city of Renville or ValAdCo. They were not observed during
site visits, suggesting they may have been sealed.

The Project Manual for Site Work and Waste Handling (Mensch, 1991) indicates that borings
drilled prior to construction of the waste storage lagoons encountered “uniform clay material”,
but the log for B-4, which was advanced through the area where lagoon cell #2 (the southern
lagoon) was later constructed, encountered silty sand at 14.5-18 ft. That would place the sand
layer approximately 4 to 5 ft. below the bottom of the lagoon. The elevation of this silty sand
layer is 2.5 feet higher than the elevation of the top of the sand in which the city wells are
completed. Although it is unlikely that this sand was deposited at the same time or in the same
environment as the buried channel sand in which the city wells are completed, it is possible that



                                               19
this silty sand may be connected horizontally with that sand unit (Figure 19). Information
regarding the geology between the two areas is not adequate to evaluate this possibility.

Monitoring wells were not required by the MPCA at this facility, so no information is available
regarding local ground water flow directions. It is likely that near surface ground water flow is
to the south and southwest, toward county ditch number 37.

Ground water:

No monitoring wells were installed at this facility. As a result, there are no data available
regarding water quality beneath or adjacent to the waste storage lagoons. Moreover, no leakage
rate calculations were available from either MPCA or ValAdCo files, so there are no estimates
regarding the timeframe in which it would be expected that waste would begin to pass through
the liner of the lagoons. However, if the minimum permeability of 1 x 10-7 cm/sec was achieved
in construction of the clay liners, and assuming an operating head of 10 to 13 feet of waste in the
basins, breakthrough of the liners would occur in approximately 1.3 to 1.6 years (the higher the
head value, the faster the breakthrough time). This would be an extremely conservative
estimate, as the permeability of the liners reported for the other ValAdCo facilities ranged from
1.2 to 4.9 x 10-8 cm/sec. If these values are used, and again assuming an operating head of 10 to
13 feet of waste in the basins, the liner breakthrough time would range from approximately 2.7
to 14.2 years (the faster breakthrough time reflects a higher head and higher permeability
values). This means the liners could be expected to experience breakthrough sometime between
1998 and 2009.

The proximity to the facility of two public water supply wells has prompted additional ground
water assessment in this area. Based on ground water level monitoring and pump tests, MDH
determined that the ValAdCo facility is located within the Drinking Water Supply Management
Area for wells #5 and #6 (Figure 20). According to a letter from MDH to MPCA, dated August
23, 1993, a pumping test of the city wells “…indicated an aquifer response in a monitoring well
located on the north side of county ditch no. 37” (MDH, 1993). The monitoring well was
located near the ValAdCo property and MDH staff concluded “…the ditch may not act as a
hydraulic barrier between the ValAdCo facility and the city wells” (MDH, 1993). In that same
letter, MDH requested that MPCA require ground water monitoring at the facility.

Similar concerns were raised by a consultant for the city of Renville, who wrote in a letter dated
October 17, 1991, “…it is our opinion that the City wells are very susceptible to surface
contamination”, and concluded that “…it would not be a prudent decision to locate the proposed
wastewater treatment system in close proximity to the City wells” (Bolton & Menk, 1991). The
wastewater treatment system referred to in the letter is the ValAdCo lagoons at the F1/NF
facility.

The MPCA permit for the facility (p. 10) requires that a monitoring plan be developed for the
facility “…if the aquifer beneath the facility is shown to be vulnerable and/or is in the recharge
areas of the aquifer serving the city wells.” The MDH Drinking Water Supply Management
Area delineation (MDH, 1996) determined that the F1/NF facility is within the recharge are of
the aquifer serving the city wells and that the area beneath the facility is considered to be
“moderately vulnerable” to surficial and near-surface contamination sources (Figure 20). To



                                                20
date, no monitoring plan has been developed for the facility.

Water quality data specifically from wells #5 and #6 are limited, particularly for the period
following construction of the facility (see Table 1, Appendix A). The city wells nearest the
facility are not sampled individually. Instead, most sampling involves the combined influent and
effluent for the city water supply system. Because it represents the combined water from several
wells, this does not provide an adequate measure of water quality in wells #5 and #6. However,
there has been a slight increase in nitrate concentrations in the water system effluent since the
early 1990s. This may reflect general degradation of ground water in the area, or increased
nitrate concentrations in one or more wells in the system. A 1976 study of the groundwater
quality and quantity in the area of Renville city wells #5 and #6 found low concentrations of
chloride (10-50 parts per million, ppm), nitrate nitrogen (0.1 – 1.6 ppm), and nitrite nitrogen (0.0
ppm) in test wells screened from 40 to 50 feet below grade (Leisch, 1976). No information is
available regarding the ground water quality in this area since the waste lagoons were installed.

Most of the private wells in the area are likely protected from any possible ground water
contamination by both their distance from the F1/NF facility and layers of clay present above the
sand layers from which they draw water. However, the shallow water supply wells on the
ValAdCo property, the nearby city wells, and the private wells located immediately east and
southeast of the facility may be at risk if ground water contamination occurred.


Surface water:
No surface water quality data were available from MPCA or ValAdCo files. During site visits in
the fall of 2001, staff did not observe any instances of land applied waste encroaching upon or
entering nearby ditches. No spills have been reported at this facility.


Land application:

The manure management plan for this facility, dated September 13, 1991 (Gislason, et. al, 1991)
and the Project Manual (Mensch, 1991), estimated the facility would produce approximately 2
million gallons of manure annually, of which approximately 18,000 – 70,000 pounds of organic
nitrogen, 19,000 pounds of phosphate, and 68,000 pounds of potassium would be available to
crops. Based on these calculations, it was estimated that to use all of these nutrients as fertilizer,
approximately 100 - 470 acres of corn or soybean cropland would be needed to use the projected
mass of nitrogen, 239 acres of corn or 425 acres of soybeans would be needed to use the
projected mass of phosphate, and 317 acres of corn or 852 acres of soybeans would be needed to
use the projected mass of potassium. While adequate acreages appear to have been used for
uptake of nitrogen at the lower end of the projected range, it appears that at no time were large
enough acreages used for uptake of the projected phosphate, potassium, or the nitrogen volumes
at the upper end of the projected range. Also, in most years, the actual volume of waste
produced was approximately 50 percent larger than estimated, but no comparable increase in
acreage used for land application appears to have occurred. Finally, in some years, the acreage
for land application may have been overstated (see below).

Actual application rates were based on laboratory analysis of manure samples collected prior to



                                                 21
application and estimated and published soil nutrient data, to determine the nutrient content of
the manure and the nutrient requirements for the specific fields. Generally, only one or two
samples of the waste were analyzed. There is no evidence that soil samples were ever analyzed
to determine the actual nutrient content of the soils at the land application sites, although the
permit for this facility requires that the soil be tested at each land application site prior to
spreading the waste. With the exception of 1997, the estimated amount of acreage has never been
used. There apparently are no records kept of waste levels in the lagoons throughout the season
and after land application, making it difficult to evaluate the actual waste input into the lagoons
and to compare them to the amounts land applied.

The earliest records available regarding land application of animal wastes from this facility are
from November 1996, when 3 million gallons of waste were applied to 40 acres of land in the
northeast quarter of Section 29 in Crooks Township.

No land application report was found for 1997, but an undated, hand written note in the MPCA
files (Appendix B) indicates that waste from the facility waste land applied on 491 acres in
sections 20, 28, and 29 of Crooks Township. The note did not calculate the total gallons of
waste, but did estimate a total of 117,720 pounds of nitrogen originally in the waste and 52,970
pounds of nitrogen in the waste that was applied. Normally, only 15 to 30 percent of the
nitrogen is expected to be lost to volatilization and bacterial degradation during storage and
application, so the latter number seems to be low. However, this is consistent with the volume of
nitrogen projected in the manure management plan for this facility (Gislason, et. al., 1991), and
amounts to 108 pounds of nitrogen per acre, which MPCA deemed an acceptable application
rate.

Subsequent land applications from this facility occurred on much smaller total acreages (80 –
160 acres). The land application reports for those years did not indicate any change in the
number of animals at the facility, so presumably the 1997 application did not involve
significantly larger volumes of waste than subsequent years. However, the land application
reports for those subsequent years state that the manure management plan projected only 18,374
pounds of nitrogen production annually from the facility. This figure appears to have been
derived using a worksheet included in the 1998 land application report, which assumed a total
waste production of 500,000 gallons, but then reported that a total of 3.2 million gallons of waste
were applied that year. The 1998 land application report makes no comment on this ten-fold
reduction in the projected volume of nitrogen to be produced by the facility compared to the
1991 management plan projections. This raises the question of whether land application
activities in the years after 1997 resulted in substantially higher application rates of nitrogen. If
so, this could have significant consequences for both surface and ground water quality.

In October 1998, 3.04 million gallons of waste were land applied to 80 acres. In November
1999, 2.96 million gallons of waste were reportedly land applied to 156 acres. However, the
reported acreage is not consistent with information from the aerial photographs nor from the
reported location of the land (see below). In October 2000, 2.41 million gallons were applied to
160 acres.

A review was completed of historical aerial photographs for the reported land application areas.
No abandoned homesteads were detected during the review. However, it was noted that the land



                                                22
in the western ½ of the northwest ¼ of Section 28 and the western ½ of the northwest ¼ of Sect.
29, where was applied in 1998 and 1999, respectively, there are farms and buildings. This
means that the full 80 acres reported in the 1998 land application report were not available for
land application. Even more notable is that the 1999 land application report states that waste
was applied to 156 acres, but then specifies the location of only 80 acres of land (half of a
quarter section), in which the full 80 acres were not available.

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Farm 2/Breeding, Gestation, and Farrowing (F2/BGF):

This facility is located in Norfolk Township, Section 29, approximately 8 miles south of the
town of Olivia (Figure 6). MDH staff visited the facility on August 7, 2001. It consists of four
buildings, housing up to 1,498 sows and 65 boars and has two earthen basin lagoons with a
capacity to store up to approximately 25.9 million gallons of waste and water (Figure 7).


Air Quality:

The first monitoring for H2S emissions from this facility was completed on May 16, 1996. This
monitoring was done by a group of Renville County citizens using a Jerome meter. Monitoring
data were collected at areas to which the public had access, generally within three-quarters or
less of a mile from the lagoons. The citizens, with the help of a consultant, developed a protocol
for their monitoring to assure uniformity of testing procedures and objectivity of their
measurements. Jerome readings were taken at five-minute intervals over a one-hour period to
obtain reasonable estimations of one-hour average H2S concentrations in air.

On May 16, 1996, the one-hour average H2S concentration was found to be 7 parts per billion
(ppb) with a maximum reading of 8 ppb. On May 20, 1996, citizens returned to this site and
found H2S concentrations averaging 9 ppb with a maximum concentration of 15 ppb recorded
during this monitoring session.

Later that summer, on August 12, 1996, additional sampling was performed as part of a study
funded by the Renville County Board of Commissioners. For this study, the Jerome meter was
used to obtain air concentrations of H2S in a 30-minute time frame. Both 30-minute average
concentrations for H2S were 0.7 ppb with maximum readings of 1 ppb and 3 ppb.

Citizens returned to Norfolk Township, Section 29 on August 13, 1996, to find the 60-minute
average for H2S was 6 ppb with a maximum concentration of 22 ppb.

During part of the spring and summer of 1998 the MPCA had a continuous air monitor located at
the F2/BGF site to measure total reduced sulfur (TRS). Averages for April through July 7th, by
month, were 0.76 ppb, 2.82 ppb, 3.58 ppb, and 3.09 ppb. The monitor was removed in lieu of
placement of more specific H2S monitors at the F2/NF site.




                                                       23
MDH staff also measured H2S concentrations downwind of this facility on September 5, 2001
using a hand-held Jerome meter and collecting grab samples. The site was visited twice that day,
in the morning and evening. The morning samples were taken at 10:30 a.m. and measured H2S
concentrations ranging from 2ppb to 51 ppb. Staff experienced minor throat irritation while
collecting the samples. That evening, MDH revisited the site after 9 p.m. and found H2S
concentrations ranging from 2ppb to 5 ppb. Again, staff experienced minor throat irritation
while collecting the samples.

During the morning sampling session by MDH staff, the highest readings from this facility were
detected in a very narrow band approximately 2-3 feet wide within the H2S plume. This suggests
that under certain conditions, if an air quality monitor is located even a few feet away from the
center of the plume, an exceedence of the H2S standard may not be recorded.


Geology/Hydrogeology:

Nearby well logs indicate the area near this facility is underlain primarily by clay till deposits,
with no major sand layers above 40 ft. below grade. Several water supply wells are located
within a one-mile radius of the F2/BGF facility. Those wells for which drilling logs are
available range in depth from 95 – 713 ft. below grade. The nearest wells are those on the
ValAdCo property, which are completed at 102 and 100 feet below grade, and are completed
below approximately 90 feet of clay (unique well numbers 525599 and 525600, respectively).

The nearest residential wells are located approximately 1/3 mile to the northeast and are
completed at 713 and 718 feet below grade (unique well numbers 148806 and 209538,
respectively). The drilling log for one of these wells indicates that it was cased to 145 feet below
grade, with the remainder of the borehole left as an open hole in granite. It is likely that the
other well was completed in a similar manner. Three wells are located approximately ¾ mile to
the southwest of the facility. Only one has a drilling log (unique well number 208080), which
indicates that the well is 95 feet deep and draws water from Cretaceous bedrock beneath
alternating layers of sand and clay. Three other residences are located near the facility (two are
approximately ½ mile southwest and one is approximately 1/3 mile southeast), but no
information is available regarding the wells that supply water to these homes.

Borings advanced at the site prior to construction of the facility encountered primarily clay till
deposits. Boring BB-3, located in the area of the northern lagoon, encountered coarse alluvium
(sand, gravel, and cobbles) at 18 to 20 feet below grade. The actual thickness of this coarse layer
is unknown, as the boring was terminated at 20 feet below grade. A boring log for BB-3A,
which was presumably advanced adjacent to boring BB-3, but was not located on any site maps,
also encountered a coarse alluvium layer at 18 feet and extending to 27.5 feet below grade. The
boring log also indicated that the water table intersected this sand and gravel layer. Boring BB-
2, in the area of the southern lagoon, encountered a sandy lean clay with lenses of sand from 15
to 36 feet below grade, at which point the boring was terminated.

Water level measurements in the monitoring wells at the facility indicate that ground water is
flowing to the southwest towards county ditch number 124 (Figure 7; Table 2, Appendix A).
The monitoring wells appear to be placed in the correct locations with respect to the lagoons, but



                                                 24
may not be screened properly. An MPCA staff memo dated July 5, 1994, noted that the screens
in the monitoring wells did not intersect the sand and gravel layers. The memo cites an earlier
letter, dated April 6, 1994, from the MPCA to ValAdCo, specifically requesting that the
monitoring wells be screened at depths that would intercept the sand lenses. Logs for the
monitoring wells were not available in either the MPCA or ValAdCo files, therefore it is not
possible to evaluate this concern. By not intersecting the sand and gravel layers with the well
screens, these wells may not be able to detect releases to these higher permeability layers from
the lagoons. This is problematic, because it appears that the south lagoon was constructed only
one foot above the top of the sand and gravel layer.

Water levels measured in the monitoring wells are approximately 4 to 12 feet below grade,
assuming the tops of the well casings are two feet above grade. Exact depths to the water
surface could not be determined from the information in the files because the water level
measurements were made from the top of the casing of the monitoring wells and no information
was available regarding how high above ground level the well casings stand. An undated figure
prepared by Bonnema Surveys showing as-built elevations for the lagoons and monitoring wells
was used to compare the water levels in the wells to the base of the lagoons.

The water levels measured in the wells appear to represent the actual elevation of the top of the
water table, based on water levels measured in soil borings at the site. The Environmental
Assessment Worksheet (EAW) for this facility, prepared in August 1993, notes that in borings
drilled prior to construction, “…water was observed in each hole at approximately five to eleven
feet below the surface” (p. 16). If the water level measurements in the monitoring wells do
mark the top of the water table, then it is located near or even above, the base of the lagoons.
The measured water levels, when compared to the lagoon elevations, are located approximately
0.5 to 2 feet above the base of the northern lagoon and 1.5 to 6 feet below the base of the
southern lagoon. The presence of perimeter drain tiles around the lagoon may keep the water
table at elevations below those of the lagoon bottoms. However, the area of influence of the
perimeter tiles does not appear to extend to the monitoring wells located approximately 20-30
feet from the lagoons, so it is unclear whether the perimeter tiles would affect the water table
elevations near the centers of the lagoons.


Ground water Quality:

Based on the logs from borings BB-3 and BB-3A and reported depths of the lagoons, it appears
that the bottom of the south lagoon is only 1 ft. above a sand and gravel layer. Manure was first
added to the lagoons in August 1994. While the files did not contain a lagoon construction
report, there was a calculation of the estimated leakage rate. These calculations estimate a rate
of leakage of 150 gal/day/acre in the south lagoon and 42 gal/day/acre in the north lagoon, and
conclude that breakthrough of the liners will occur in 6.7 and 25 years, respectively. If accurate,
this means that the south lagoon could have started to experience breakthrough of its liner in
2001. The north lagoon, according to these calculations, would not be expected to experience
breakthrough until 2019.

No significant trends were observed in the water quality data from the site (Table 2, Appendix
A; Figures 21, 22, 23, and 24). In fact, the first round of samples collected from the




                                               25
downgradient wells (MW-3 and MW-4) before manure was added to the lagoons detected
generally higher concentrations of chloride and sulfate than subsequent measurements (Figures
21 and 23). Some interesting trends were noted in the data, however. MW-2, located
approximately 50 feet from the southwest corner of the northern lagoon, shows an annual
“spike” in chloride and nitrate in the April sampling events (Figures 21 and 22). This was also
observed in the sample collected before manure was added to the pits. Sulfate and ammonia
nitrogen levels in MW-3 and MW-4 are elevated above the upgradient well, MW-1, but these
two wells exhibited higher levels of these compounds than the other monitoring wells before
manure was added to the lagoons (Figures 23 and 24).

Inorganic compounds, such as chloride, sulfate, nitrate, and ammonia are monitored near animal
waste storage lagoons because they are present at high concentrations in animal wastes. These
inorganic compounds have the added advantage over bacteria as indicators of groundwater
contamination in that they are not as readily adsorbed onto soil particles as bacteria. While
chloride and sulfate can occur naturally in the groundwater, if the concentrations downgradient
of a lagoon are found to be elevated relative to the concentrations detected upgradient, it is an
indicator that leakage is occurring from the lagoon. Nitrate is commonly present in ground water
in rural areas as a result of fertilizing of agricultural fields. Again, it is the relative upgradient
and downgradient concentrations of nitrate that provide an indication of contamination.
However, the oxygen-depleted environment typical beneath most waste lagoons often means that
nitrogen beneath and near a lagoon is present as ammonia, not nitrate, and so ammonia is also
tested for and used as an indicator of contamination.

At this time, the data do not indicate that contamination from the lagoons has entered the ground
water. However, as noted above, the well screens do not intersect the sand layers that may be
the most likely pathways for contaminant migration if there is a leak from the lagoons.


Surface Water:

Perimeter tiles around the lagoons were monitored to determine if waste was leaking from the
sides of the lagoons (Table 3, Appendix A). No significant trends were observed in most of the
parameters, but fecal coliform rose significantly to 70 colony forming units per 100 milliliters
(CFU/100ml) in 1997. Previous samples had ranged from <1 to 4 CFU/100 ml. In 1997-2000,
tile samples routinely detected elevated bacteria counts, as high as 120 CFU/100 ml, but these
concentrations have decreased since 1998. Water from the tile line was sampled only once for E.
coli bacteria, but none were detected. Elevated chloride concentrations were also routinely
detected, as high as 124 ppm, but they fluctuated and no clear trend was observed.

The 1995 ValAdCo water quality report for this facility (ESC, 1996a) includes surface water
samples from four ditch locations (Table 4, Appendix A; locations shown on Figure 6). The
water quality measurements were generally consistent with those measured in monitoring wells
at the facility. However, between June 1994 and July 1995, fecal coliform counts tripled in three
of the sample locations (SW-1B, SW-2B, and SW-4B) and nitrate concentrations increased by 6-
8 mg/l at all four locations. The sample locations with the elevated bacterial counts were located
both upgradient and downgradient of the F2-BGF facility, suggesting a source other than the
ValAdCo facility itself. However, all three locations are adjacent to or downgradient of land



                                                26
application areas for the facility. Surface water sampling appears to have been discontinued in
1995; no subsequent reports contain such data.

A letter in the MPCA files dated October 3, 1995 from a local citizen to the Birch Cooley
Township board mentions samples from county ditch 124 collected by the Minnesota
Department of Natural Resources (MDNR) in July 1995 that detected “extremely high
concentrations of contaminants”. No additional information could be obtained regarding the
DNR samples.

A sample collected on October 6, 1997 from county ditch 124 in section 5 of Birch Cooley,
south of the F2/BGF facility, was found to contain 3,000 CFU/100 mL of fecal coliform and
30,000 CFU/100 mL of streptococci virus (see copy in Appendix B). It is not clear whether the
sample was collected by the MPCA, MDNR or another agency. The report was mailed to the
MPCA from the testing laboratory, but a hand written note on the report says: “taken in 97 by?
DNR” [sic]. However, without water quality data from upstream of the ValAdCo facility, it is
not possible to draw any conclusions regarding the source of the bacteria.

A Renville County resident also pointed out a drain tile that discharges to county ditch 124 and
allegedly runs directly beneath the F2-BGF lagoons. At the time it was observed by MDH staff,
there did not appear to be any discharge from the tile. The approximate location of the outlet of
this drain tile is indicated on the site map (Figure 6).

A letter dated December 2, 1999, from Renville County to ValAdCo, discusses a spill that
reportedly occurred during land application activities on November 29, 1999. The release
occurred in a roadway ditch and near a county drainage ditch near the F2 facilities. A site
investigation by Renville County staff found “excessive liquid manure had pooled at the edge of
both ditches”, but the letter also notes that no actual violation had occurred.


Land application:

The EAW for this facility, prepared in August 1993, indicated that 506 acres of land would be
required for land application of the waste from this facility and F2/NF. However, the largest
land area used for the combined facility waste applications was 381 acres in 1999. A manure
management spreadsheet for this facility by Baumgartner Environics, Inc, dated October 24,
1996, projected the two F2 facilities would produce a combined total of approximately 3.7
million gallons of manure annually, of which approximately 177,000 pounds of organic nitrogen,
157,000 pounds of phosphate, and 169,000 pounds of potassium would be available to crops.
Based on these calculations, it was estimated that to utilize all of these nutrients as fertilizer,
approximately 1,180 acres of corn cropland would be needed to use the projected mass of
nitrogen, 2,609 acres of corn or 4,348 acres of soybeans would be needed to use the projected
mass of phosphate, and 3,756 acres of corn or 3,018 acres of soybeans would be needed to use
the projected mass of potassium. At no time were large enough acreages used for uptake of this
higher projection of nutrients produced by the two F2 facilities. Also, in most years, the actual
volume of waste produced was approximately 35 percent larger than projected, but no
comparable increase in acreage used for land application appears to have occurred.




                                               27
Actual application rates were based on laboratory analysis of manure samples collected prior to
application. Generally, only one or two samples of the waste were analyzed (four samples were
analyzed in 1997). There is no evidence that soil samples were ever analyzed to determine the
actual nutrient content of the soils at the land application sites, although the permit for this
facility requires that the soil be tested at each land application site prior to spreading the waste.
There also are no records kept of waste levels in the lagoons throughout the season and after land
application, making it difficult to evaluate the actual waste input into the lagoons and to compare
them to the amounts land applied.

Land application of animal wastes from this facility began in 1996. In October 1996, 4.9 million
gallons of waste were applied to 100 acres. There is no information in the files regarding how
waste was managed or disposed of in 1995, even though waste was first placed in the lagoons in
August 1994.

In September 1997, 5.13 million gallons of waste were applied to 100 acres. In October 1998,
4.1 million gallons were applied to 160 acres. In November 1999, 4.05 million gallons of waste
were applied to 190 acres. In 2000, no land application was made due to an early snowfall and
freezing of the ground. Presumably the waste was applied in the spring of 2001, but no report
was available for 2001 waste management at the time the file review was conducted.

A review was completed of historical aerial photographs for the land application areas. These
revealed the presence of a former homestead (1960 photo, NE ¼ of NW ¼, S 28) and a former
school (1938 photo, SW ¼ of NW ¼, S 28) in the 1998 land application areas (see Figure 6), and
a former homestead in the 1999 land application area (1960 photo, NW ¼ of NE ¼, S 27). The
homesteads and school are no longer present. This raised concern that abandoned water supply
wells may be present in these locations. MDH staff, with the assistance of the property owner,
located the two wells in section 28, which were cut off at depths of 16 to 18 inches below grade.
The wells will be sealed during the winter of 2002-2003. The third well, in section 27, has not
been located. Because land applied waste is disked into the ground to depths of about 12 inches,
the three abandoned wells may have acted as conduits for waste applied in these areas to migrate
to the ground water.


--------------------------------------------------------------------------------------------------------------------
-
Farm 2/Nursery and Finishing (F2/NF):

This facility is located in Norfolk Township, Section 27, approximately 8 miles southeast of the
town of Olivia (Figure 8). MDH staff visited the facility on August 7, 2001. It consists of five
buildings, housing up to7,680 nursery pigs, 2,880 grower/feeder pigs, and 4,800 finishing hogs
and has two lagoons with a capacity to store up to approximately 36 million gallons of waste and
water (Figure 9). Manure was first added to the lagoons in September 1994.


Air Quality:

This facility has been the source of the most citizen complaints (see Appendix C). ValAdCo has
tried numerous methods to either control or mask the air emissions at this site. One method



                                                       28
incorporated the use of Pit Remedy, a concentrated bacterial product made up of 46 different
strains of bacteria engineered specifically for manure decomposition. Other methods used in an
attempt to control odors include the use of a peppermint scented masking chemical, addition to
the lagoons of chemicals such as ferrous sulfate heptahydrate, covering the lagoons with a felt
cover and blowing straw on top, and finally, a more permanent cover combined with a system to
collect emissions and route the collected air through a box where ozonation takes place.

The first monitoring for H2S emissions from this facility was completed in May, 1996, by a
group of Renville County citizens using a Jerome meter. Monitoring data were collected at areas
to which the public had access, generally within three-quarters or less of a mile from the
potential source of H2S emissions. Jerome meter readings were taken at five-minute intervals
over a one-hour period to obtain reasonable estimations of one-hour average H2S concentrations
in air. The one-hour average H2S concentrations recorded in May of 1996 were:


Table I: Citizen Hydrogen Sulfide Monitoring Data, May 1996

                      60-minute average (ppb)      Maximum concentration (ppb)
May 16                       74                         111
May 17                      134                         280
May 18                       27                          52
                             89                         170
May 31                       12                          17


Later that summer, on July 20 and August 1, 1996, additional sampling was performed as part of
a study funded by the Renville County Board of Commissioners. For this study, the Jerome
meter was used to obtain air concentrations of H2S in a 30-minute time frame. Both 30-minute
average concentrations for H2S were 5.8 ppb with a maximum reading of 13 ppb, and 3.6 ppb
with maximum reading of 24 ppb.

Citizens returned to Norfolk Township, Section 27 in August 1996 to collect additional
measurements. Sixty-minute averages for H2S were found to be:

Table II: Citizen Hydrogen Sulfide Monitoring Data, August 1996

                      60-minute average (ppb)      Maximum concentration (ppb)
August 11                   41.4                        71
                            15                          39
August 12                   12.6                        38
                            23.3                        41
August 16                   34.8                        47
August 17                   24.2                        70


On September 5, 2001, MDH staff also measured H2S concentrations downwind of this facility
using a hand-held Jerome meter. The site was visited in the morning and in the evening. The



                                             29
lagoons were both covered and the ozonation equipment appeared to be operating at the time of
our visits. The morning measurements were taken shortly after 10:00 a.m. and ranged from 2
ppb to 13 ppb. The evening measurements were taken at approximately 9:30 pm and ranged
from 3 ppb to 13 ppb.

In 1998, the MPCA installed a continuous air monitor (CAM) at the northwest corner of the
property, to provide continuous data collection of air quality. In 2001 the Attorney General’s
Office placed additional CAMs at the site although there were problems with those CAMs and
data were only available from the 2002 Attorney General’s monitoring. The CAMs have been
located at the fence line adjacent to the lagoon. Violations of the Minnesota Ambient Air
Quality Standard (MAAQS) for H2S as provided to MDH by the MPCA, is shown in the Figure
I, below. Additional discussion of the MAAQS can be found in the “Discussion” section of this
report (Section III, page 48).

In addition to monitoring for H2S at the CAM site, the MPCA also had continuous monitors to
record the temperature, relative humidity, wind direction and wind speed. The meterological
parameters were taken to help MPCA ensure that the H2S was coming from the source it was
intended to measure and to help MPCA identify conditions conducive to high H2S emissions.
Not surprisingly, the highest H2S measurements occurred when the wind was blowing in the
direction of the CAM (approximately 135° relative to the location of the CAM). Winds not in
the direction of the CAM resulted in lower readings. Temperature inversion situations, such as
occur in the cooling of a summer evening after a hot summer day, can also increase the
probability of the CAM recording elevated concentrations of H2S.

                                                             Figure I
                                                       Exceedances of MAAQS
                  Number of Exceedances




                                          200                               30 ppb standard
                                                                            50 ppb standard
                                          150
                                          100
                                           50
                                            0
                                                1998     1999    2000       2001      2002
                                                                     Year




The number of “violations” does not provide a full picture of the actual H2S emissions related to
this site. When the wind is not blowing in the direction of the monitors, the CAMs may fail to
record that the standards have been exceeded because the monitors are fixed in location, but the
emission plumes are not. As a result of the exemptions allowed by the State of Minnesota, the
number of exceedances is greater than the number of recorded violations. Figure II (page 31)
provides the number of recorded exceedances of the 30 ppb and 50 ppb benchmarks.




                                                                30
                                                           Figure II

                                           30-Minute Monitored Concentrations of
                                                 Hydrogen Sulfide - F2/NF
                                     250
                                                                          Greater than 30 ppb.
                                                                          Greater than 50 ppb.
             Number of Exceedances




                                     200


                                     150


                                     100


                                     50


                                      0
                                            1998    1999     2000      2001         2002
                                                             Year

Note that the 2002 data are a compilation of 4 different monitors placed around the lagoon including 1 MPCA and 3
Attorney General monitors, whereas data from the other years are from a single MPCA monitor located North West
of the lagoon. The 2001 data are likely artificially low because the monitors were not operating much of the
summer while the cover and ozonation system was being installed at the site.



Geology/Hydrogeology:

Nearby well logs indicate the area around the site is underlain by clay till deposits, with no major
sand layers above 40 feet below grade. Several private water supply wells are located near the
facility, ranging in depth from 60 to 731 feet below grade. The closest residential well is located
at the house less than 1,000 feet south of the facility. No well log is available for this well,
which appears to be fairly shallow, based on MDH staff observations in 2001. ValAdCo owns
two wells (unique well numbers 525601 and 525602) located approximately ½ mile northwest of
the facility. They are 109 and 125 feet deep, respectively. No geologic information is available
for either of these wells. Three other residences are located near the ValAdCo facility, less than
¼ mile north, approximately ¾ mile south, and approximately 1 mile southwest. No information
is available regarding the wells that supply water to these homes.

One soil boring, BF-1, advanced in the area of the southern lagoon prior to its construction,
encountered sandy lean clay with small lenses of sand from 17 to 32 feet below grade. No
boring or construction logs were provided for the monitoring wells installed at the site.

Ground water flow direction is to the southeast, towards county ditch #85A (Figure 9). The
surface of the water table is approximately located between 4.5 to 14 feet below grade, assuming
the tops of the well casings are two feet above grade (Table 5, Appendix A). Exact depths to
ground water could not be determined because the water level measurements were made from



                                                             31
the top of the casing of the monitoring wells and no information was available regarding how
high above ground level the well casings stand. An undated figure prepared by Bonnema
Surveys, showing as-built elevations for the lagoons and monitoring wells, was used to compare
the water levels in the wells to the base of the lagoons.

The water levels measured in the wells may represent the actual elevation of the top of the water
table, based on water levels measured in soil borings at the site. The EAW for this facility,
prepared in August 1993, notes that in borings drilled prior to construction, “…water was
observed in each hole at approximately three to five feet below the surface” (p. 16). If the water
level measurements in the monitoring wells do mark the top of the water table, then it is located
near or even above, the base of the lagoons. The measured water levels, when compared to the
lagoon elevations, are located approximately 0.3 to 8 feet above the base of the northern lagoon
and 0.1 feet below to 3.4 feet above the base of the southern lagoon. The presence of perimeter
drain tiles around the lagoon may keep the water table at elevations below those of the lagoon
bottoms. However, the area of influence of the perimeter tiles does not appear to extend to the
monitoring wells located approximately 20-30 feet from the lagoons, so it is unclear whether the
perimeter tiles would affect the water table elevations near the centers of the lagoons.

Based on the ground water flow directions (Figure 9), it appears that the monitoring wells at the
site were placed in the appropriate locations with respect to the lagoons. No boring logs were
available for the monitoring wells, so it is not possible to evaluate whether the wells were
screened properly.


Ground Water Quality:

Ground water monitoring at this facility indicates that leakage has occurred from one or both of
the lagoons, as indicated by increasing chloride concentrations in the downgradient monitoring
wells. Between 1997-2000, chloride concentrations in two of the downgradient monitoring
wells, MW-2 and MW-3, experienced a five-fold and four-fold increase, respectively (Figure
25). Chloride and nitrate concentrations in the third downgradient monitoring well, MW-4,
remained essentially constant during that same period (Figures 25 and 27). The significant
increase in chloride concentrations since 1997 in wells MW-2 and MW-3 suggest that waste may
have broken through the liner of the northern lagoon.

Well MW-3 exhibits seasonal “spikes” of nitrate and chloride in the fall and well MW-4 exhibits
similar seasonal “spikes” in chloride (Figures 25 and 27). Both wells exhibited fall “spiking” of
sulfate between 1994 and 1998, but that trend has not been observed since then (Figure 26).
Ammonia concentrations do not exhibit any clear trends at this site (Figure 28).

No lagoon liner breakthrough calculations were found in the files for this facility, so there are no
estimates regarding the timeframe in which it would be expected that liquid would begin to pass
through the liner of the lagoons. However, if the minimum required permeability of 1 x 10-7
cm/sec was achieved in construction of the clay liners, and assuming an operating head of 12 to
15 feet of waste in the lagoons, breakthrough of the liners would occur in approximately 1.1 to
1.4 years (the higher the head value, the faster the breakthrough time). This would be an
extremely conservative estimate, as the permeability of the liners reported for the other ValAdCo



                                               32
facilities ranged from 1.2 to 4.9 x 10-8 cm/sec. If these values are used, and again assuming an
operating head of 12 to 15 feet of waste in the basins, the liner breakthrough time would range
from approximately 2.4 to 12.5 years (the faster breakthrough time reflects the higher head and
permeability values). This means the liners could be expected to experience breakthrough
sometime between 1998 and 2008.

Residents near this facility tested their wells for bacteria, nitrate, and sulfate in 1995 and 2001
(Table III). On December 26, 2001, MDH staff collected samples from eight private water wells
to evaluate bacterial concentrations (Table IV, all sample locations are shown on Figure 29).


Table III: Citizen Water Well Testing Results, 1995 and 2001

                                                      Sample Location Number
                                      1*         2*        3**      4**        5**     6**
Coliform (CFU/100ml)                  14        53.5      <1        35         78    <1
Fecal coliform (CFU/100ml)            ?         53.5      <1         ?          ?    <1
E. coli                             positive   negative negative negative negative negative
Fecal streptococci (CFU/100ml)       70          NA       NA         NA        NA    NA
Nitrate (mg/l)                       3.06        3.82     0.53      3.64      0.46    0.31
Sulfate (mg/l)                        NA          NA      95.18     33.71    354.13  0.12

* sample collected in 2001
** sample collected in 1995


Table IV: MDH Water Well Testing Results, December 2001

                                       Resident Identification Number
                           1           2      3       4      5    6         7       8      9
Total coliform (CFU/100ml) 7           NS     19    <1       NS <1          3      120    <1
E. coli (CFU/100ml)        <1          NS    <1     <1       NS   <1       <1      <1     <1


Coliform bacteria are ubiquitous in the environment and are not necessarily an indication of
human- or animal-caused contamination. Its presence in a well may indicate that the well is
open to the environment, allowing surface water or soil to enter the well. Fecal coliform, fecal
streptococci, and E. coli bacteria are found in the intestines of animals and their presence in a
well indicates human or animal waste contamination of the water. These bacteria were detected
in one well (sample location #1, Table III) in a 2001 sample. That well was reportedly
disinfected and subsequent samples collected by MDH staff did not detect E. coli.

The residential well sampling indicates that the private wells near the ValAdCo facilities in
Norfolk Township have not been affected by bacterial contamination that can be linked to the
facilities. The absence of fecal coliform in the wells tested, however, does not rule out the
possibility that the ground water in this area has been contaminated either by leakage of the




                                               33
lagoons or through the abandoned wells identified near both Norfolk township facilities (see the
“land application” sections for both facilities).


Surface Water:

No lagoon construction report was available in either the MPCA or ValAdCo’s files. An
inspection report by Mr. Randy Ellingboe of the MPCA noted the presence of a small seep in the
ditch east of the lagoons, at about 6 to 8 feet below grade. He suspected that this seep might
indicate a small sand or gravel layer at that depth, which would be at an elevation approximately
halfway down the side of the lagoons.

A memo dated March 7, 1996 in the MPCA files mentions an “alleged leaking lagoon”. The
lagoon in question was apparently at the F2/NF facility, as the memo mentions ditch 85A, which
is located immediately east of the lagoons at this facility. The memo suggests that no indication
of a problem or abnormally low water/ice levels were observed. The memo also cites a ditch
sample that had high bacteria counts (reportedly 1,000 to 1,200 colonies, but the actual results
were not found in the MPCA files). However, no upstream samples were collected from the
ditch, making it impossible to draw any definite conclusions regarding the source of the bacteria.

Sampling of perimeter tiles at the site revealed no clear trends, except that sulfate concentrations
and bacterial counts dropped significantly between May and June 1995 (Table 6, Appendix A).
In 1997-2000 elevated chloride concentrations and bacterial counts were detected (up to 61 ppm
and 68 CFU/100 ml, respectively), but nitrate concentrations remained generally at local
“background” levels (8-11 mg/l). This is not unexpected. The anaerobic environment typically
found in and beneath animal waste lagoons would prevent any nitrogen leaking from the lagoons
from oxidizing to nitrate; instead it would be present as ammonia, which has occasionally been
elevated in the perimeter tiles at this site (Table 6, Appendix A).

The 1995 ValAdCo water quality report for this facility (ESC, 1996b) includes surface water
samples from three ditch locations (Table 7, Appendix A; sample locations shown on Figure 8).
No clear trends could be observed in the data. The concentrations of sulfate, chloride, nitrate,
ammonia, and coliform bacteria were fairly similar between sample locations and no indication
of significant increases in any of these parameters in the water downstream from the ValAdCo
facility. No reports subsequent to 1995 contain surface water data.

A 1995 letter from a local citizen to the Norfolk Township Board mentions a “dark colored dam-
like mess in ditch 85A in the NE ¼ of the W ½ of Section 27 in Norfolk Twshp”. No
information regarding follow-up to these concerns was obtained.

A letter dated November 12, 1999, from the law firm of Bonner, Dawson, Borhart LLP to Mr.
Michael Olafson of Lindquist & Vennum LLP, attorneys for ValAdCo, mentions a 1997 incident
when a manure transfer pipe burst and manure sprayed 200 feet into the air. No record was
found of that incident, nor any information regarding clean-up of the alledged spill, and
representatives from ValAdCo report that the incident did not occur.




                                                34
A letter dated December 2, 1999, from Renville County to ValAdCo, discusses a spill that
reportedly occurred during land application activities on November 29, 1999. The release
occurred in a roadway ditch and near a county drainage ditch near the F2 facilities. A site
investigation found “excessive liquid manure had pooled at the edge of both ditches”, but the
letter also notes that no violation had occurred.


Land application:

The EAW for this facility, prepared in August 1993, indicated that 506 acres of land would be
required for land application of the waste from this facility and F2/NF. However, the most land
area used for the combined facility waste applications was 381 acres in 1999. A manure
management spreadsheet for this facility by Baumgartner Environics, Inc, dated October 24,
1996, projected the two F2 facilities would produce a combined total of approximately 3.7
million gallons of manure annually, of which approximately 177,000 pounds of organic nitrogen,
157,000 pounds of phosphate, and 169,000 pounds of potassium would be available to crops.
Based on these calculations, it was estimated that to use all of these nutrients as fertilizer,
approximately 1,180 acres of corn cropland would be needed to use the projected mass of
nitrogen, 2,609 acres of corn or 4,348 acres of soybeans would be needed to use the projected
mass of phosphate, and 3,756 acres of corn or 3,018 acres of soybeans would be needed to use
the projected mass of potassium. At no time were large enough acreages used for uptake of this
higher projection of nutrients produced by the two F2 facilities, even though the combined
volumes of waste were approximately 35 percent larger than projected.

Actual application rates were based on laboratory analysis of manure samples collected prior to
application. Generally, only one or two samples of the waste were analyzed (four samples were
analyzed in 1997). There is no evidence that soil samples were ever analyzed to determine the
actual nutrient content of the soils at the land application sites, although the permit for this
facility requires that the soil be tested at each land application site prior to spreading the waste.
There also are no records kept of waste levels in the lagoons throughout the season and after land
application, making it difficult to evaluate the actual waste input into the lagoons and to compare
them to the amounts land applied.

Land application of animal wastes from this site began in 1996. There is no information in the
files regarding how waste was managed or disposed in 1995, even though waste was first placed
in the lagoons in September 1994.

In 1996, a total of 4.9 million gallons of waste were applied to 160 acres, but no dates were
provided for the applications. In 1997, 1.86 million gallons of waste were applied to 47 acres in
August and another 6.35 million gallons were applied to 160 acres in September and October. In
1998, 10 million gallons of waste were applied to 125 acres in October and November. In
November 1999, 6.1 million gallons of waste were applied to 191 acres.

In 2000, 3.23 million gallons were applied to 80 acres in July and August, and another 5 million
gallons were applied to 160 acres in October.




                                                35
No explanation is provided in the files regarding the wide variation of land application volumes,
which have ranged from 5 to 10 million gallons.

During a site visit by MDH staff on October 18, 2001, small pools of waste were observed
standing in tire ruts in the fields where land application was occurring in the SE ¼ of the SE ¼ of
section 23 (see Figure 30). MPCA staff confirmed that this was one area where ValAdCo had
land applied waste.

A review was completed of historical aerial photographs for the land application areas. These
revealed the presence of a former homestead (1960 photo, NW ¼ of NE ¼, S 27), where waste
was land applied in 1999 and, reportedly, 2001. The homestead is no longer present, raising the
concern that an abandoned water supply well may be present in these locations. A fax dated
October 29, 1999, from ValAdCo to the MPCA, regarding the land application agreement for
this particular property had a copy of an aerial photo attached with an “x” marking the location
of an “old well” in this same location. Residents in the area have indicated that there may even
be two wells on the property. If present, this well (or wells) could act as a conduit for land
applied wastes to migrate to the ground water.


--------------------------------------------------------------------------------------------------------------------
-
Farm 3/Breeding, Gestation, and Farrowing (F3/BGF):

This facility is located in Section 5 of Flora Township, approximately 5 miles south of the town
of Renville (Figure 10). MDH staff visited the facility on August 5, 2001. It consists of four
buildings, housing up to 2,596 sows, 760 nursery pigs and 130 boars, and has two waste storage
lagoons with approximately 26.7 million gallons of waste and water capacity (Figure 11).


Air Quality:

The first monitoring for H2S emissions from this facility was completed on May 22nd and May
26th of 1996. This monitoring was done by a group of Renville County citizens using a Jerome
meter. Monitoring data were collected at areas to which the public had access, generally within
three-quarters or less of a mile from the potential source of H2S emissions. The citizens, with
the help of a consultant, developed a protocol for their monitoring to assure uniformity of testing
procedures and objectivity of their measurements. Jerome meter readings were taken at five-
minute intervals over a one-hour period to obtain reasonable estimations of one-hour average
H2S concentrations in air.

On May 22, 1996, the one-hour average H2S concentration was found to be 19 parts per billion
(ppb) with a maximum reading for 45 ppb during this monitoring session. The hourly average
concentration monitored on May 26th was 8 ppb and 26 ppb with maximum readings of 13 ppb
and 35 ppb.

Later that summer, on July 31st, additional sampling was performed as part of a study funded by
the Renville County Board of Commissioners. For this study, the Jerome meter was used to



                                                       36
obtain air concentrations of H2S in a 30-minute time frame. That sampling measured two 30-
minute averages for H2S of 0.3 ppb and 0.4 ppb, with maximum readings of 1 ppb and 4 ppb.

In 1999, Mr. Scott Refsland, of ValAdCo used two Jerome meters to sample air at the property
boundary of Flora Township, section 5. Duplicate readings were taken simultaneously. Eight
H2S monitoring events were completed in 1999. There were no recorded exceedences of the H2S
ambient air quality standard, 30-minute averages for H2S ranged from 3 to 21 ppb. The results
of this sampling are as follows:


Table V: Hydrogen Sulfide Measurements Collected By ValAdCo Staff, 1999

DATES      7/12/99    9/3/99      9/15/99    9/28/99     10/5/99    10/13/99 10/16/99 10/19/99
Meter 1    11 ppb     21 ppb      3 ppb      9 ppb       14 ppb     3 ppb    7 ppb    3 ppb
Meter 2    11 ppb     20 ppb      3 ppb      9 ppb       12 ppb     3 ppb    7 ppb    3 ppb


The majority of sampling was done at dusk during low wind conditions. One might expect
higher emissions of H2S during the hot mid-summer months.

Finally, grab samples were taken on September 5, 2001 by MDH staff using a hand-held Jerome
meter. Monitoring was done at about 8 p.m. in a roughly downwind location, at the cemetery
located approximately one-third mile northeast of the facility. Under calm conditions, H2S
concentrations were found to range from 2 ppb to 3 ppb.


Geology/Hydrogeology:

Local well logs indicate the area near this facility is underlain primarily by clay, with no major
sand layers less than 42 ft. below grade. According to ESC (1995), there are eight active and
one inactive private wells located within a one mile radius of this facility, but only two of these
wells have construction records on file in the County Well Index (unique numbers 617709 and
649135; Figure 10). The boring for well 617709 encountered 147 feet of clay before
intercepting a water-bearing sand layer that is at least 7 feet thick (the boring terminated at 154
feet). The boring for well 649135 encountered 139 feet of clay before intercepting a water-
bearing sand layer that is at least 10 feet thick (the boring terminated at 149 feet). No
information is available regarding the depth of the other wells or the geologic formations they
encountered during drilling. It is assumed that there is a water supply well for this facility,
although no information was found regarding such a well.

Soil boring logs from the site indicate there are at least two relatively thick sand layers beneath
the site in the area of the west lagoon. The boring for BH-1, located in the north half of the west
lagoon, encountered a 7 foot thick, fine, water-bearing sand layer from 10 to 17 feet below
grade. Boring SB-1, located approximately 50 feet from the west edge of the west lagoon (and
immediately adjacent to well MW-2), encountered two thick layers of coarse sand, from 4.5 to
24.5 feet and from 34.5 to 44 feet below grade, at which point the boring terminated. Well MW-
2 was screened in the upper sand. Well MW-3, located approximately 30 feet north of the west



                                                37
lagoon, encountered 4 feet of clayey sand with gravel, from 6 to 10 feet below grade. Soil
borings in the area of the east lagoon did not encounter sand layers.

Ground water flow direction is to the northwest, towards county ditch #45 (Figure 11). The
surface of the water table is located between approximately 6 to 13 feet below grade (Table 8,
Appendix A). The exact depth to ground water cannot be determined because the water level
measurements are taken from the top of the well casing and MDH could not obtain information
regarding the height of the well casing above the ground surface. No information could be
obtained regarding the elevations of the borings and monitoring wells relative to the elevations
of the base of the lagoons, with the exception of boring SB-1. Based on the water level data
(Table 8, Appendix A; Figure 11), it appears that the monitoring wells at this site were installed
in the proper locations with respect to the lagoons.


Ground water:

Ground water sampling at the site indicates that some leakage is occurring from one or both of
the waste lagoons, as indicated by increasing chloride concentrations in the downgradient
monitoring wells (Figure 31).

Monitoring wells MW-1, MW-2, MW-3, and MW-4 were installed prior to commencement of
operations at the facility and were sampled to provide baseline information on water quality at
the site. Well MW-5 was installed in July 1995, shortly after the facility began operating. Initial
sampling detected much higher sulfate concentrations and slightly lower nitrate concentrations in
the upgradient well, MW-1, than the other monitoring wells.

Sampling conducted after operations at the facility began indicates that ground water
downgradient of the lagoons has become increasingly contaminated with chloride over time
(Table 8, Appendix A; Figure 31). In contrast, nitrate and ammonia concentrations have shown
no clear trend (Figure 33 and 35) and sulfate concentrations have remained fairly constant
(Figure 34).

Since 1997, higher concentrations of chloride have consistently been detected in the
downgradient monitoring well, MW-5, than have been detected in the upgradient (MW-1) and
side-gradient wells (MW-3 and MW-4, Figure 31). The chloride concentrations in MW-5
increased significantly in 1998 to 4,270 ppm and then decreased to a range of 58-86 ppm (Figure
32). These concentrations are approximately four times higher than the chloride concentrations
detected in the upgradient well, MW-1. The 2000 concentrations in MW-5 represent an eight-
fold increase over the chloride concentrations detected in 1995 when the facility began
operations.

Two other monitoring wells, MW-3 and MW-4, showed relatively steady, eightfold increases in
chloride concentrations from 1999 to 2000 (Figure 31). The chloride concentrations in these
wells are also about four times higher than those in MW-1. MW-2, the only well screened in the
sand layer that underlies the west lagoon, apparently was sampled only in January and February
1995, prior to operations commencing at the facility (Table 8, Appendix A), even though water
levels are measured quarterly and sufficient water is present in the well to collect a sample.



                                               38
The site has also had a history of high bacterial counts in the ground water (Table 8, Appendix
A). Baseline sampling detected fecal coliform bacteria only in one sample from well MW-2, at
concentrations of 5 CFU/ 100ml. In 1997, fecal coliform was detected at 14 CFU/100 ml and
170 CFU/100 ml in well MW-5. In an attempt to confirm these bacterial concentrations,
ValAdCo’s consultant, collected split samples on July 14, 1997 and sent them to two
laboratories. One lab detected >50 total coliform and the other detected >250 total coliform.
One of the labs tested only for E. coli, which was not found. The other tested for fecal coliform
and found 161 colonies. The well was re-sampled on July 31, 1997 and again the two labs
detected high concentrations of bacteria: >50 and 3,400 total coliform colonies and 170 – 210
fecal coliform colonies, but again no e. coli. The well was treated with chlorine bleach and re-
sampled, and was found to contain no bacteria (letter from Mr. Eddie Crum of ValAdCo to
MDH, dated March 12, 2002). No bacteria were detected again until 1999, when two samples
detected 28 CFU/100 ml and 7 CFU/100 ml. The latter sample consisted entirely of E. coli
colonies. No bacteria were detected in 2000, the latest results available.

The impacts to ground water may be the result of the relative location of the west lagoon with
respect to the sand layers encountered by borings at the site. The bottom of the west lagoon is
completed at an elevation that places the base of the clay liner four feet into the water-bearing
sand layer that was encountered in boring BH-1 and 0.5 feet above the upper sand layer
encountered in boring SB-1 and well MW-2. This sand layer could act as a conduit for
migration of any contaminants that may leak from the lagoon.

No information could be obtained regarding the elevations of the monitoring wells relative to the
elevations of the base of the lagoons, making comparison of water levels to the lagoons difficult.
However, a drawing in the MPCA file indicates that the top of the upper water-bearing sand
encountered in boring SB-1 is at an elevation approximately 0.5 feet below the base of the west
lagoon. Well MW- 2 was constructed immediately adjacent to boring SB-1 and encountered this
same sand at the same depth, so it was assumed that the ground elevation of SB-1 and MW-2
were the same. Thus, the water level measurements in MW-2 may be compared to the elevation
of the west lagoon. Doing so indicates that the water levels measured in well MW-2, which
range from approximately 6 to 8 feet below grade (assuming the casing sticks up 2 feet above the
ground surface), are approximately 2 to 4 feet below the bottom of the west lagoon. The
perimeter tile lines at this facility appear to have been placed at approximately 2 feet below the
elevation of the base of the lagoons, so it is possible that the water table is present to within 2
feet below the base of the lagoons.

A calculation worksheet estimated the rate of leakage through the lagoon liners at 194
gal/day/acre (east lagoon) and 120 gal/day/acre (west lagoon), which yielded estimates of
breakthrough times of 5.2 and 8.4 years, respectively. If correct, this means that the east lagoon
should have begun to experience breakthrough of its liner in 2000 and the west lagoon should
begin to experience breakthrough of its liner in 2003 or 2004. However, if the chloride and
bacterial data from MW-3, 4, and 5 are, indeed, indications of leakage from the lagoons, it
appears that the breakthrough has already occurred in one or both of the lagoons.




                                               39
Surface Water:

No surface water data are available for this facility. During site visits in the fall of 2001, staff
did not observe any instances of land applied waste encroaching upon or entering nearby ditches.
No spills have been reported at this facility.


Land application:

A “waste generation” worksheet, dated February 13, 1995 projected that the facility would
produce approximately 4 million gallons of manure annually, with a total of 22,401 pounds of
available organic nitrogen, 76,519 pounds of phosphate, and 76,519 pounds of potassium
(allowing for loses during storage and land application). Based on these nutrient values, it was
calculated that 150 acres of corn cropland would be needed for uptake of the projected mass of
nitrogen, 1,275 acres of corn or 2,126 acres of soybeans would be needed for uptake of the
projected mass of phosphate, and 1,700 acres of corn or 1,366 acres of soybeans would be
needed for uptake of the projected mass of potassium. While the volume projections were
consistent with the actual volume of waste produced (except in 1996, when the volume was
nearly double that projected), the acreage of land used for land application met only the uptake
needs for the available nitrogen.

Actual application rates were based on laboratory analysis of manure samples collected prior to
application. Generally, only one or two samples of the waste were analyzed (four samples were
analyzed in 1997). There is no evidence that soil samples were ever analyzed to determine the
nutrient content of the soils at the land application sites, although the permit for this facility
requires that the soil be tested at each land application prior to spreading the waste. There also
are no records kept of waste levels in the lagoons throughout the season and after land
application, making it difficult to evaluate the actual waste input into the lagoons and to compare
them to the amounts land applied.

Land application of animal waste from this facility began in 1996, when 4.9 million gallons were
applied to 40 acres in June and another 4.02 million gallons were applied to 40 acres in August
and September. It is not clear why such a large volume of waste was generated and applied in
1996, compared to subsequent years. There was no land application report available for 1997.
In November 1998, 5.03 million gallons were applied to 115 acres. In September 1999, 4.13
million gallons were applied to 152 acres. In September 2000, 3.37 million gallons were applied
to 120 acres.

A review was completed of historical aerial photographs for the land application areas. No
evidence was found of former homesteads or other buildings where water supply wells may have
been located.

--------------------------------------------------------------------------------------------------------------------
--




                                                       40
Farm 4/Breeding, Gestation and Farrowing (F4/BGF):

This facility is located in Emmet Township, Section 31, approximately 4 miles south of the town
of Renville (Figure 12). MDH staff visited the facility on August 7, 2001. It consists of four
buildings, housing up to 1,298 sows, 5,760 nursery pigs and 65 boars, and has two earthen basin
lagoons with a total storage capacity of up to 26 million gallons of waste and water (Figure 13).
Waste was first added to the lagoons in August 1995.


Air Quality:

Initial monitoring for H2S emissions from this facility was completed on May 23rd
and May 26th of 1996. This monitoring was done by a group of Renville County citizens using a
Jerome meter. Monitoring data were collected at areas to which the public had access, generally
within three-quarters or less of a mile from the potential source of H2S emissions. The citizens,
with the help of a consultant, developed a protocol for their monitoring to assure uniformity of
testing procedures and objectivity of their measurements. Jerome readings were taken at five-
minute intervals over a one-hour period to obtain reasonable estimations of one-hour average
H2S concentrations in air.

On May 23, 1996, the one-hour average H2S concentration was found to be 18 parts per billion
(ppb) with a maximum reading of 39 ppb. The average hourly concentration for H2S on May
28th was 12 ppb with a maximum of 27 ppb.

Later that summer, on July 19th, additional sampling was performed as part of a study funded by
the Renville County Board of Commissioners. The Jerome meter was used to obtain air
concentrations of H2S in a 30-minute time frame. On July 19, 1996, the 30-minute average for
H2S was 0.5 ppb with a maximum reading of 5 ppb. An additional sampling session carried out
by Renville County Citizens on August 17, 1996 found H2S concentrations of 41.8 ppb with a
maximum reading of 53 ppb.

Mr. Scott Refsland of ValAdCo conducted four 30-minute H2S monitoring events at this facility
during 2000. There were no recorded exceedances of the H2S ambient air quality standard
during the monitoring. Results are as follows:


Table VI: Hydrogen Sulfide Measurements Collected by ValAdCo Staff, 2000

                   6/26/00             7/14/00             7/19/00             8/29/00
Sample #1          4 ppb               4 ppb               4 ppb               12 ppb
Sample #2          4 ppb               5 ppb               2 ppb               10 ppb


Samples taken at 7:45 p.m. on September 5, 2001 by MDH using a hand-held Jerome meter
detected H2S concentrations ranging from 2 ppb to 13 ppb for grab samples collected along a



                                              41
220th Street, south of its intersection with County Road 17. To the best of our knowledge, no
additional air quality data exist for this facility.


Geology/Hydrogeology:

Local well logs indicate the area of the site is underlain primarily by clay, with the first major
sand layer encountered at 32 ft. below grade. The nearest wells are on the facility property,
belong to ValAdCo (unique numbers 545500 and 545501), and are completed at 250 ft. Their
locations with respect to the waste storage lagoons are unknown. Three other private wells near
the facility also have well logs on record. Well unique number 649107 is located approximately
½ mile northwest of the facility and is 52 feet deep, but draws water from a sand that begins at
32 feet below grade. Well unique number 161704 is located one mile north of the facility and is
55 feet deep, but the log for this well does not provide any geologic information. Well unique
number 649135 is located approximately ¾ mile southeast of the facility and is 149 feet deep,
drawing water from a sand layer that starts at 139 feet below grade.

Soil borings advanced at the site prior to construction and during installation of the monitoring
wells encountered sand at 19.5 to 21 feet below grade (boring B-2, adjacent to well MW-2), at
20.5 to 21 feet below grade (well MW-3), and at 35-49.5 feet below grade (boring B-1, adjacent
to well MW-1).

Water level measurements (Table 9, Appendix A) indicate that ground water flow direction is
primarily to the northwest, towards an unnamed ditch that drains into Sacred Heart Creek at a
point approximately 2 miles northwest of the facility (Figure 13). Occasionally, the water levels
indicate a northeast ground water flow direction.

The surface of the water table is located between 4.5-17 feet below grade (assuming that the top
of the well casings from which the measurements were made are two feet above grade). This
would place the top of the water table at approximately 10 feet below to 3 feet above the bottom
of the lagoons. The presence of perimeter drain tiles around the lagoon may keep the water table
at elevations below those of the lagoon bottoms. The area of influence of the perimeter tiles is
not known, but does not appear to extend to the monitoring wells located approximately 20-30
feet from the lagoons, so it is unclear whether the perimeter tiles would affect the water table
elevations near the centers of the lagoons. The exact depth of the water table cannot be
determined because no information was available regarding the height of the well casings above
ground level and all water level readings were taken from the top of the casings.


Ground Water:

Ground water sampling at the facility may indicate that leakage is occurring from one or both of
the lagoons, based on increasing concentrations of chloride in one of the downgradient
monitoring wells (Figure 35). However, this is a fairly recent occurrence and it may be too early
to determine whether an actual concentration trend has been established.

The downgradient wells, MW-2, MW-3, and MW-4, at this site have high chloride and nitrate



                                               42
values that are approximately four to six times the concentrations detected in the upgradient
well, MW-1 (Table 9, Appendix A; Figures 36 and 37). However, this was true before the
lagoons were filled and appears to be a pre-existing condition of the site. Concentrations of
nitrate in all of the wells have remained fairly constant since manure was first added to the
lagoons in August 1995, except for slight decreases in wells MW-2, MW-3 and MW-4 (Figure
37). Similarly, sulfate concentrations have remained fairly constant in the downgradient wells,
but have decreased by approximately 50 percent in MW-1 (Figure 38). Chloride concentrations
have also remained fairly constant with the exception of well MW-2, which has shown a 60
percent increase between July 1999 and July 2000 (the latest date for which data were available,
Figure 36). This may indicate that waste has broken through the liner in the west lagoon, but
further sampling data would be required to confirm this. Ammonia concentrations have not
exhibited any clear concentration trends (Figure 39).

The pre-existing differences in water chemistry led the MPCA staff, in a letter dated September
20, 1995, to raise questions about MW-1 intercepting a different “flow system” than the other
wells and to suggest that another upgradient well may be needed. There was no record in the
files regarding any follow-up to this concern.

Elevation information from Figure 1 of the 1996 annual ground water monitoring report (ESC,
1997) allowed for approximate comparisons to be made between the soil boring logs and the
lagoons. Direct comparisons cannot be made because no information is available regarding the
height above the ground surface of the well casings, where the elevations were measured. If it is
assumed that each well casing is approximately 2 feet above the ground surface, this would place
the shallowest sand horizons encountered while drilling the borings adjacent to these wells at
approximately 24 to 26 feet below the base of the lagoons. This would make it unlikely that any
waste leaking from the lagoons would reach the sand horizons. However, this hypothesis cannot
be checked because none of the monitoring wells installed at the site were screened across the
sand units.

Water level data (Table 9, Appendix A) from the site indicate that the monitoring wells are
generally in the correct locations with respect to the lagoons. However it would be helpful to
have a fifth well near the northwest corner of the western lagoon (lagoon #1) to ensure adequate
coverage downgradient of that lagoon. Also, MW-1 is more side-gradient than upgradient of
lagoons.

A leakage rate calculation worksheet estimated the rate of leakage to be 240 gal/day/acre for the
west lagoon and 217 gal/day/acre for the east lagoon. Based on these rates, the estimated time of
breakthrough of waste through the liners of the lagoons would be 4.2 and 4.6 years, respectively.
If correct, this means that the west lagoon should have experienced breakthrough of waste in
1999 and the east lagoon in 2000. This is consistent with the appearance of increasing chloride
concentrations in MW-2 since 1999 (Figure 36).


Surface water:

Sampling of perimeter tile lines at the site has been sporadic, as water is often not present in the
lines. The sampling that has been done suggests that most of the parameters analyzed (sulfate,



                                                43
chloride, and nitrate) have decreased in concentration since 1995 (Table 10, Appendix A). The
exception to this is fecal coliform, which was not detected in the earliest samples, but has been
detected in five out of six samples collected since October 1996. The highest bacterial count
was 100 CFU/100 ml.


Land application:

It is not clear when land application of waste from this facility began. Waste was first added to
the lagoons in 1995, but the 1996 report indicated that no land application occurred that year and
no report from 1997 was found in either the MPCA or ValAdCo files. No estimates were found
in the files regarding projected waste production or acreage needed for proper disposal.

Actual application rates were based on laboratory analysis of manure samples collected prior to
application. Generally, only one or two samples of the waste were analyzed (four samples were
analyzed in 1997). There is no evidence that soil samples were ever analyzed to determine the
actual nutrient content of the soils at the land application sites, although the permit for this
facility requires that the soil be tested at each land application prior to spreading the waste. There
also are no records kept of waste levels in the lagoons throughout the season and after land
application, making it difficult to evaluate the actual waste input into the lagoons and to compare
them to the amounts land applied.

In November 1998, 19,353 gallons of waste were applied to 171 acres.

In August and September 1999, 4.76 million gallons of waste were applied to 46.4 acres.
However, the area of land appears to have been over-estimated. The report indicates the waste
was applied to one quarter of a quarter section, which would only equal 40 acres. Moreover, the
parcel where the application reportedly occurred has a drainage ditch. The ditch and
accompanying required setbacks would further reduce the area of land available for land
application to less than 40 acres. ValAdCo facilities F1/BGF and F3/BGF generated similar
volumes of waste, but land application occurred on two to four times as many acres, suggesting
that over application of waste from the F4/BGF facility may have occurred in 1999.

Likewise, in October and November 2000, 5.27 million gallons of waste were reportedly applied
to 173 acres. However, the location information for the land application area is confusing and
the acreage appears to have been over-estimated. The report indicates the waste was applied to
the “NE ¼ E ½ of NW ¼ of Section 30”, which is not an accurate description of any land parcel.
If the waste were applied to one half of a quarter section, the area would be only 80 acres. If the
waste were applied to one half of a quarter section plus another quarter section, the area would
be 240 acres. Neither possibility correlates with the reported acreage. In addition, the presence
of a homestead in the northwest quarter of section 30 would further reduce the available acreage
in this section.

There is no explanation in the files regarding the significant decrease in acreage used for land
application after 1998. The manure sampling data indicate that the 1998 waste actually had
lower nutrient concentrations than those in 1999 and 2000, raising the concern that the 1999 and
2000 applications resulted in over-application of nutrients.




                                                44
A review was completed of historical aerial photographs for the land application areas. No
evidence was found of former homesteads or other buildings where abandoned water supply
wells may be located.

--------------------------------------------------------------------------------------------------------------------
Commercial Nursery (Comm. Nurs.) :

This facility is located in Section 7 of Flora Township, approximately 6 miles south of the town
of Renville (Figure 14). MDH staff visited the facility on August 7, 2001. It consists of four
buildings, housing up to 15,360 nursery pigs and has two earthen holding basins with a total
waste storage capacity of approximately 4.2 million gallons, based on the basin dimensions
provided in the 1995 interim permit (Figure 15). Unlike the clay-lined lagoons at the other six
facilities, both of these basins are pumped out completely each year.

Air Quality:

Initial monitoring for H2S emissions from this facility was completed on May 23rd of 1996.
Monitoring was done by a group of Renville County citizens using a Jerome meter. Monitoring
data were collected at areas to which the public had access, generally within three-quarters or
less of a mile from the potential source of H2S emissions. The citizens, with the help of a
consultant, developed a protocol for their monitoring to assure uniformity of testing procedures
and objectivity of their measurements. Jerome readings were taken at five-minute intervals over
a one-hour period to obtain reasonable estimations of one-hour average H2S concentrations in
air. On May 23, 1996, the one-hour average H2S concentration was found to be 5 parts per
billion (ppb) with a maximum reading of 7 ppb during this monitoring session.

As part of a study funded by the Renville County Board of Commissioners, 30-minute averages
were obtained with the Jerome meter. On July 19, 1996, the 30-minute average for H2S was 0.5
ppb with a maximum reading of 1 ppb. On July 31, 1996, the 30-minute average for H2S was
1.0 ppb with a maximum concentration of 7 ppb.

An additional sampling session carried out by Renville County Citizens on August 13, 1996
found H2S concentrations of 11 ppb with a maximum reading of 22 ppb.

Mr. Scott Refsland of ValAdCo conducted four 30-minute H2S monitoring events at this facility
during 2000. There were no recorded exceedances of the H2S ambient air quality standard
during the monitoring. Results are as follows:

Table VII: Hydrogen Sulfide Measurements Collected by ValAdCo staff, 2000

                       6/26/00                 7/14/00                 7/19/00                 8/29/00
Sample #1              7 ppb                   6 ppb                   11 ppb                  9 ppb
Sample #2              7 ppb                   5 ppb                   10 ppb                  7 ppb


Measurements taken on September 5, 2001 by MDH staff using a hand-held Jerome meter
detected H2S concentrations ranging from 8 ppb to 10 ppb. The measurements were taken at



                                                       45
approximately 8:15 p.m. along County Road 62, approximately ¾ mile northwest of the facility.
At the time of sampling, the wind was from the SE and estimated at 5-8 mph. It can reasonably
be assumed that the concentrations at the property boundary were higher. To the best of our
knowledge, no additional air quality data exist for this facility.


Geology/Hydrogeology:

Nearby well logs indicate the area of this facility is underlain primarily by clay deposits, with no
major sand layers above 52 feet below grade. Soil borings advanced prior to construction of the
lagoons encountered up to 30 feet of clay, sandy clay, and clayey sand (Mensch Engineering,
1995). The nearest private wells are those owned by ValAdCo, located on the facility property
(Figure 15). A well located on the south side of 780th Ave, immediately south of the facility, also
reportedly provides water to the Commercial Nursery facility. No information regarding the
depth or construction of these wells is available. Well unique number 209564 is located
approximately 2/3 mile west of the facility and is 355 feet deep, drawing water from the
Precambrian metamorphic bedrock. Other wells undoubtedly are present at farms located near
the site, but no information is available regarding them.

Monitoring wells were not required by the MPCA at this facility, so no information is available
regarding local ground water flow directions or water quality. It is likely, based on the local
topography and drainage system, that surficial ground water flows to the northwest toward
county ditch number 45 (Figure 14). According to a figure provided by ValAdCo, the water
supply wells for the facility are located in an area likely to be downgradient of the lagoons
(Figure 15). There are no drilling logs on record at the Minnesota Geologic Survey for these
wells, so the stratigraphy encountered during drilling and the depth at which they were
completed is unknown.


Ground water:

As noted above, no monitoring wells were installed at this facility. As a result, there are no data
available regarding water quality beneath or adjacent to the waste storage lagoons. Moreover,
no leakage rate calculations were available from either MPCA or ValAdCo files, so there are no
estimates regarding the timeframe in which it would be expected that waste would begin to pass
through the liner of the lagoons. However, if the minimum required permeability of 1 x 10-7
cm/sec was achieved in construction of the clay liners, and assuming an operating head of 10 to
14 feet of waste in the basins, breakthrough of the liners would occur in approximately 1.2 to 1.6
years (the higher the head value, the faster the breakthrough time). This would be an extremely
conservative estimate, as the permeability of the liners reported for the other ValAdCo facilities
ranged from 1.2 to 4.9 x 10-8 cm/sec. If these values are used, and again assuming an operating
head of 10 to 14 feet of waste in the basins, the liner breakthrough time would range from
approximately 2.5 to 14.2 years (the faster breakthrough time reflects a higher head and higher
permeability values). This means the liners could be expected to experience breakthrough
sometime between 1998 and 2009.

Surface Water:



                                                46
No surface or tile line water quality data were available from MPCA or ValAdCo files. During
site visits in the fall of 2001, staff did not observe any instances of land-applied waste
encroaching upon or entering nearby ditches. No spills have been reported at this facility.


Land Application:

The Project Manual for this facility (Mensch, undated) estimated the facility would produce
approximately 3.36 million gallons of manure each year, of which approximately 64,000 pounds
of organic nitrogen, 67,000 pounds of phosphate, and 67,000 pounds of potassium would be
available to crops. Based on these calculations, it was estimated that to utilize all of these
nutrients as fertilizer, approximately 426 acres of corn cropland would be needed to use the
projected mass of nitrogen, 1,121 acres of corn or 1,869 acres of soybeans would be needed to
use the projected mass of phosphate, and 1,495 acres of corn or 1,201 acres of soybeans would
be needed to use the projected mass of potassium. Only in 2000 did the acreages actually used
approach the projections of what was needed for the uptake of the available nitrogen, and they
never approached the projected acreages needed for uptake of the phosphate and potassium.
However, in 2000, the volume of waste produced was approximately 79 percent larger than
projected.

Actual application rates were based on laboratory analysis of manure samples collected prior to
application and estimated and published soil nutrient data, to determine the nutrient content of
the manure and the nutrient requirements for the specific fields. Generally, only one or two
samples of the waste were analyzed (five samples were analyzed for the spring applications in
1997). There is no evidence that soil samples were ever analyzed to determine the actual
nutrient content of the soils at the land application sites, although the permit for this facility
requires that the soil be tested at each land application site prior to spreading the waste. There
also are no records kept of waste levels in the lagoons throughout the season and after land
application, making it difficult to evaluate the actual waste input into the lagoons and to compare
them to the amounts land applied.

Land application of waste from this site began in August 1996, when 422,000 gallons of waste
were applied to 24 acres. No land application report was available for 1997. In November 1998,
1 million gallons of waste were applied to 76 acres. In October 1999, 2.25 million gallons of
waste were applied to 153 acres. In April 2000, 1.6 million gallons of waste were applied to 120
acres, and in October of that year, another 4 million gallons of waste was applied to 276 acres.

Based on the location information provided in the land application reports, it appears that waste
from the Commercial Nursery was applied to the same area, SE ¼ of SE ¼ of Sect. 7, Flora
Twp., three times within four years (in 1996, 1998, and 2000). Waste was also applied twice
within two years (1998 and 2000) to the same area, S ½ of S ½ of SW ¼ of Sect. 8, Flora
Township, although the 2000 land application report stated that this land had not received any
manure since 1996.

A review was completed of historical aerial photographs for the land application areas. No
evidence was found of former homesteads or other buildings where abandoned water supply



                                               47
wells may be located.



                                      III. Discussion

Air Quality

The primary exposure pathway related to the ValAdCo facilities is inhalation of H2S and other
gases emitted from the lagoons and barns. The following section explains air concerns from
feedlot emissions and findings from the air monitoring completed at the fence line, primarily at
the F2/NF facility.

                        Violations of Regulations and Standards at F2/NF

To date, regulatory and enforcement actions at the ValAdCo facility have focused on compliance
with the Minnesota Ambient Air Quality Standard (MAAQS) for H2S. The MAAQS was
promulgated in 1969 and originated from scientific literature of that time and was patterned on
regulation of H2S by the City of St. Louis, Missouri. The standard is based on an odor detection
threshold and was intended to protect against both acute and chronic symptoms and
physiological changes for both healthy and sensitive individuals; also, exposure to H2S at
concentrations above the MAAQS could interfere with the enjoyment of life and property. The
standard is 50 parts per billion (ppb) for 30 minutes, not to be exceeded over two times per year,
and 30 ppb for 30 minutes, not to be exceeded over 2 times in any 5 consecutive days.

Other states, such as California, have currently revisited hydrogen sulfide standards. The
California Ambient Air Quality Standard (CAAQS) for hydrogen sulfide of 30 ppb for one hour
was adopted in 1969 and reviewed but not changed in 1980 and 1984. A year 2000 review states
the purpose of the standard was to decrease odor annoyance from industry rather than CAFOs
and notes that significant adverse health effects might occur at levels of exposure below the
CAAQS. (Iowa State University, February 2002)

The MAAQS for H2S has been used as a proxy measure for odor in Minnesota. This approach
can be problematic because there is no one-to-one correspondence between odors perceived to
be foul and H2S concentrations. When feedlot odors are offensive one may not be able to detect
H2S concentrations exceeding the MAAQS. However, when H2S exceeds the ambient air quality
standard, generally the air emissions from the feedlot will be offensive.

H2S is used as a surrogate for odor at feedlots because there are:
        •       a MAAQS for H2S which is based on a mean odor detection value;
        •       more than one relatively simple method available to measure concentrations of
                H2S in air;
        •       good toxicological data for H2S exposures as compared with other reduced sulfur
                compounds; and
        •       a history of monitoring and regulating H2S emissions at various point sources



                                               48
                                   and area sources within Minnesota.

Farm F2/NF, Norfolk 27 is the only site where continuous monitoring has occurred for the
purpose of determining compliance with ambient air quality standards. The data do not include
times when the lagoons were being pumped out, because the facilities are exempted from
compliance with the MAAQS during these times and no violations are recorded, even if the
standards are exceeded. In addition, the data do not capture exceedances that could have
occurred during the times when the monitors were not operating. Equipment failure occurred
frequently during the summer of 2001. Nevertheless, as demonstrated in Figs I and II (pages 30-
31) high levels of hydrogen sulfide have frequently been detected at this site, often in violation
of the MAAQS. Furthermore, the more monitoring points used, the greater the detection of
MAAQS violations, as illustrated by the 2002 data (Figs I and II, pages 30-31).

In addition to the MAAQS, the MDH has a health-based number in Minnesota Rule to ensure
protection of humans from adverse health effects caused by inhalation exposures to H2S. This
health-based number is known as a Health Risk Value (HRV) for H2S. The HRV for H2S is 7
parts per billion (ppb) or 10 micrograms per cubic meter of air (µg/m3). This subchronic HRV is
based on the Environmental Protection Agency’s (EPA’s) Integrated Risk Information System
database file for H2S and is intended on protecting even sensitive populations from exposures of
up to 3 months in duration.
                                                             Figure III

                                               Hydrogen Sulfide Concentrations
                                                              Monthly Means
                              12
                                                                                                      1998
                                                                                                      1999
                              10
    Average Concentration




                                                                                                      2000
    Parts Per Billion (PPB)




                                                                                                      2001
                               8                                                                      2002


                               6

                               4

                               2

                               0
                                       April     May        June        July   Aug.   Sept.   Oct.   Nov.
                                                                           Month




                                                                49
Figure III (page 49) plots the mean recorded hydrogen sulfide concentrations by month. There
have been some months where records indicate the 7 ppb mean over 3 months was approached.
In fact, because of monitoring equipment failures, and the fixed locations of the monitors (which
may not be at the location of maximum air concentrations) it is possible that the HRV could have
been exceeded. Furthermore, the 3 months averaging time does not have to be determined by
calendar month; calculation of 3-month rolling averages might have revealed exceedances of the
HRV. Because these lagoons cover a large area, often acres, it is impossible to accurately
monitor for exceedances of an H2S standard around the periphery of the lagoon with a single
monitor or even with several monitors. Therefore, periods of high emissions are greater than
indicated by the CAMs. In general, the CAMs are only capable of picking up exceedances when
the wind is blowing in the direction of the CAM and the H2S is not excessively dispersed by high
wind speeds.


                              Findings from other ValAdCo sites

With the exception of ValAdCo site F2/NF located in Section 27 of Norfolk Township, air
monitoring most often has consisted of spot monitoring using the Jerome hand-held monitor. In
addition to spot checks by MPCA, non-continuous monitoring was completed by Citizens of
Renville County, Renville County employees, Minnesota Department of Health and ValAdCo.
This sampling measured many cases in which H2S apparently exceeded the Minnesota Ambient
Air Quality Standard.

Table VIII (page 51) provides the “high” and “average” values for the grab sampling that has
been completed with the Jerome monitor at various ValAdCo farm sites.

Overall, the monitoring completed by the citizens of Renville County detected higher
concentrations of H2S over 30-minute and 60-minute sampling events. This is most likely due to
the fact that the citizens, many of whom live downwind of the ValAdCo facilities, initiated
monitoring sessions at times when strong odors were detected. In addition, the citizens
collected their air samples at locations that they considered to be the center of the plume of
emissions, where the greatest odors were detected. Other air samplers tended to collect their air
samples at random times and fixed locations. As noted earlier, higher odors generally correlate
with higher H2S concentrations; sampling when and where the odors are the strongest favors the
detection of higher concentrations.

Detection of H2S levels approaching 30 ppb, some samples exceeding 30 and 50 ppb, together
with our knowledge of monitoring site F2/NF, indicate that H2S could exceed the MAAQS at
other feedlot sites belonging to ValAdCo.




Table VIII: High and Average Hydrogen Sulfide Measurements At ValAdCo Facilities
Collected By Various Citizens and Agencies



                                              50
                    Citizen’s          Renville            Citizen’s         ValAdCo            MDH
                    monitoring         County              monitoring        compliance         Grab
                    Spring “96*        monitoring          Late summer       monitoring         sampling
                                       Summer              “96*              1999 and           Sept. 2001
                                       “96**                                 2000**
                    HP       HA        HP      HA          HP      HA        HP     HA          HP        HA
F1-BGF              140      78        4       0.8         NS      NS        NS     NS          2         NA
(Crooks 34)
F1-NF               22       9         16       8.5        48      20        NS        NS       7         NA
(Crooks 29)
F2-BGF              15       9         3        0.7        22      6         NS        NS       56        NA
(Norfolk 29)
F2-NF               280      134       24       5.8        71      41        NS        NS       15        NA
(Norfolk 27)
F3-BGF              45       26        4        0.4        NS      NS        31        21       3         NA
(Flora 5)***
F4-BGF              39       18        5        0.5        53      42        21        12       13        NA
(Emmet 31)
Commercial          7        5         7        1          22      11        22        11       10        NA
Nursery
(Flora 7)
HP= Highest Peak Measure in parts per billion (ppb)
HA= Highest Average in parts per billion (ppb)
NS= Not Sampled
NA= No Average available – sampling event consisted of only several grab samples
* 60-minute averages
** 30-minute averages
*** Flora 5 was sampled 8 times, 7 of those sampling events occurred during the fall months of September and
October of 1999.




                                               Health Effects

Substantial data correlate H2S exposures with adverse health effects and even death at exposures
of 100 parts per million (ppm) and higher (NIOSH, IDLH values as of 3/1/95). According to
Glass (1990), it is generally accepted that there is little evidence of persistent or cumulative
effects where exposures to H2S are kept below 20 ppm.

To date, most research has focused on exposures in the range of “parts per million” versus “parts
per billion.” A notable exception to this is a preliminary report from an ATSDR epidemiological
investigation (ATSDR, 2001). That report cites Kathman, et. al. (2001) who, studying
hospitalization rates of children and adults in Nebraska, found exposures to a “daily rolling
average” of 30 parts per billion (ppb) or more of total reduced sulfur (TRS) could be positively
correlated to increased hospital visits for asthma or respiratory illness the following day. The
correlation was highest for children with asthma or other respiratory illnesses, but was also
observed in adults with asthma. A similar positive correlation was observed between exposures



                                                      51
and hospital visits for children exposed to a “daily rolling average” of 30 ppb or more of H2S and
TRS, but was not observed in adults. This led Kathman, et. al. (2001) to speculate that elevated
levels of TRS or H2S may be associated with exacerbation of asthma or other respiratory
diseases, particularly among children. However, the highest concentrations measured for TRS
were 2,226 ppb (30-minute sampling period) and H2S were 1,375 ppb (15-minute sampling
period). Data was not provided on how often high concentrations were reached, nor averages for
high and low concentrations.

MDH has no data indicating that residents in the vicinity of the ValAdCo sites have been
exposed to H2S or TRS concentrations as high as 1,375 ppb, but it cannot be ruled out. The
continuous air monitor (CAM) used was unable to record concentrations exceeding 90 ppb.

Investigation of people living in the vicinity of swine Concentrated Animal Feeding Operations
(CAFOs) have shown more adverse health effects for residents living near these facilites.
Studies by Thu, et. al. (1997) and Wing and Wolf (2000) determined that rates of reported
illnesses among rural residents within two miles of a swine confined feeding operation mimic
those observed in the workers at those operations, and are higher than in control groups not
located near such facilities and populations living near large dairy facilities.

In 2002, research conducted by the schools of Agriculture and Public Health at Iowa State
University and the University of Iowa, examined the air quality near CAFOs. They concluded:

   “Extensive literature exists documenting acute and chronic respiratory diseases and
   dysfunction among workers. Symptoms include sinusitis, chronic bronchitis, inflamed
   mucous membranes of the nose, irritation of the nose and throat, headaches, muscle aches and
   pains. Asthma and acute (cross-shift) declines in lung function have been documented with
   progressive declines in lung function over years.”

The researchers also concluded that H2S, ammonia and odors should be regulated (Iowa State
University, 2002). While they acknowledged that occupational health risks among workers
inside feedlot facilities cannot be directly extrapolated to community health risks that may arise
from feedlot emissions, the Iowa researchers justified their recommendations for regulating H2S,
ammonia and mixed exposures (including odor) arising from CAFOs as follows:

   “Studies done in North Carolina have shown more negative mood states among individuals
   exposed to feedlot odors, and increases of headaches, runny nose, sore throat, excessive
   coughing, diarrhea, burning eyes and reduced quality of life for residents living in proximity
   to livestock operations. H2S and ammonia are found in feedlot emissions that contribute to
   ambient community exposures although no specific diseases among community residents can
   be confirmed to arise from a specific chemical, bacteria or aromatic cause. Feedlot air
   emissions may constitute a public health hazard and therefore, precautions should be taken to
   minimize both specific chemical exposures and mixed exposures, including odors arising
   from feedlots.”

This is consistent with other information gathered throughout the years. Ammonia, methane,
and H2S are the gases from feedlots most commonly tested. Other gases that highly contribute to
feedlot odors include volatile organic acids such as acetic acid, propanoic, butyric, and valeric
acids, phenol and para-cresol. These are rarely measured. MPCA has focused on emissions of
H2S from swine feedlots because of the availability of health-related data, the ease and past



                                                  52
experience of monitoring for H2S, and the fact that MPCA has a MAAQS for it.

In addition to the gases emitted from swine feedlots, dusts and particles are also of concern.
Dusts from swine CAFOs may contain a number of biological components including fungi
bacteria, viruses, spores, and parts of bacterial cell components such as endotoxins. More
recently, concerns have been raised about exposures to 1-3 glucans found in the water insoluble
cell wall components of fungi, bacteria and plants. Both endotoxins and 1-3 glucans have been
implicated in causing inflammatory responses that result in respiratory symptoms.

The symptoms found in nearby residents are similar to workers who have been exposed to many
of the biological contaminants, or bioaerosols, found in the dust and particulate of swine
feedlots. Yet, little is known about the distances that these bioaerosols are able to travel away
from the point of generation. A study that looked at the air transport of these components to
adjacent areas was completed by Thorne et. al., 2001, found that endotoxin concentrations 500
feet downwind of a facility were found to be at a “no effect threshold.” Additional data need to
be collected regarding the offsite transfer of bioaerosols from CAFOs.

Measurements of H2S concentrations that exceed the MAAQSs support the claims of nearby
residents complaining of headaches, nausea, vomiting, conjunctivitis, diarrhea, and fatigue.
Even though airborne concentrations of H2S may not be found at levels that could cause
permanent injury or serious harm, the H2S concentrations found near the ValAdCo facilities
themselves are capable of causing discomfort and short-term illnesses, including psychological
stress effects. Further, high H2S measurements may very well be indicative of presence of
numerous other emissions that taken together may cause health effects.


     Sources and Control of Hydrogen Sulfide and other Contaminants from ValAdCo

As documented in the EPA report, Emissions From Animal Feeding Operations (EPA, 2001),
animal feeding operations most often emit ammonia, nitrous oxide, H2S, carbon dioxide,
methane, total reduced sulfur (TRS) compounds, volatile organic compounds, hazardous air
pollutants, and particulate matter. The substances emitted and the quantity of those emissions
can vary substantially depending on the design and operation of each facility. Factors that
influence emissions include the feeding regimen, the type of confinement facility, the type of
manure management system (storage, handling, and stabilization), and the method of land
application. Microbial breakdown of manure can occur in an aerobic (with oxygen) or anaerobic
(without free oxygen) environment. Airborne particulates from waste operations could
conceivably spread infectious microbes; however, this has not been well documented.

ValAdCo is a feedlot that illustrates trends of the past several decades. Consolidation of hog
operations has decreased the total number of swine operations and increased the amount of hogs
raised at each operation. With the increased numbers of hogs raised at each site, an increased
amount of hog waste is also generated.

Sources of H2S and other reduced chemicals at ValAdCo include the manure that is
decomposing anaerobically. According to EPA (2001), the two primary sources of sulfur in
animal manure are sulfur amino acids contained in feed and inorganic sulfur compounds, such as



                                              53
copper or zinc sulfate, used as feed additives to supply trace mineral and serve as growth
stimulants. Sulfur compounds are also present as trace minerals in the ground water. Under
anaerobic conditions, sulfur will be reduced by microbes to H2S and can then be emitted to the
air. Temperature and pH affect the solubility of H2S in water.

The EPA (2001) also states that, “Manure storage tanks, ponds, anaerobic lagoons, and land
application sites are primary sources of hydrogen sulfide emissions whenever sulfur is present in
manure. Confinement facilities with manure flushing systems that use supernatant from
anaerobic lagoons are also sources of hydrogen sulfide emissions.” Formation of H2S, other
reduced sulfur compounds, methane, and volatile organic compounds (VOCs) requires an
anaerobic environment. Therefore, the potential to emit these substances is greatest when
manure is handled as a liquid or slurry. Manure residence time also can affect potential
emissions of ammonia, H2S, methane and VOC. Ammonia will be generated in both wet and dry
manure. Nitrous oxide will be formed only when manure that is handled in a dry state becomes
saturated, thus forming transient anaerobic conditions. Emissions of H2S, some VOCs and
ammonia are expected to be greater during periods of higher temperatures; ValAdCo data are
consistent with this expectation.

Many studies are currently being carried out to determine the byproducts of decomposition and
to better understand the chemistry related to manure and agricultural operations. Investigations
are providing information that will be helpful to the agricultural community in targeting
solutions to odor and air emissions from swine facilities (e.g. Zahn et al., 2001, and Clanton et
al., 2000). Although our knowledge base continues to grow and expand, it may take many years
before there are good solutions to the problems of air emissions and odors from concentrated
animal feeding operations (large feedlots) such as ValAdCo. Until that time, feedlots must rely
on good operating procedures and best management practices, along with a variety of reduction
techniques to minimize air emissions from these facilities.


Ground Water

Ground water contamination does not appear to be a major exposure pathway for the public near
the ValAdCo facilities at this time. However, there are areas where ground water contamination
may be of potential concern. These include:
     • The F1/NF facility located near the Renville City wells and at least one shallow private
         well, where no ground water monitoring data are available;
     • The F1/BGF, F2/BGF, and F2/NF facilities where improperly abandoned wells were
         located (or evidence of their existence was identified) in the associated land application
         areas; and
     • The F1/BGF, F1/NF, Commercial Nursery facilities where the water for the facilities is
         supplied by wells that are very shallow and/or located near the waste storage lagoons.
Because no information regarding the water supply wells for the F3-BGF facility was available,
it is not possible to determine whether there is cause for concern regarding water quality at that
facility.

Elevated and increasing concentrations of chloride in downgradient monitoring wells at farms
F2/NF, F3/BGF, and F4/BGF suggests that break through of the lagoon liners at has apparently



                                               54
occurred. This indicates that ground water has been contaminated by waste from the lagoons at
these facilities. However, this contamination does not appear to represent a public health risk.
Interestingly, neither nitrate nor ammonia contamination appear to have occurred to any
significant degree near the lagoons.

Bacteria generally have not been detected in any of the monitoring wells at the facilities. The
main exception was observed at F3/BGF, where one monitoring well (MW-5) has had a history
of very elevated bacteria concentrations. However, this appears to have been the result of
contamination introduced into the well from the surface rather than from the ground water; a
series of chlorine treatments to the well appears to have eliminated the bacteria. The absence of
significant bacterial contamination of the ground water is consistent with unpublished findings
by Fonstad, et. al. (2001), who found that coliform transport is limited to a zone within one meter
from the storage basin or lagoon. However, according to Feachem, et.al. (1983; p. 112), bacteria
and viruses may travel up to 30 meters in sand and fine soils and up to several hundred meters in
gravel or fractured bedrock. Viruses tend to adsorb to soil particles, but still may travel further
than bacteria. Survival times in groundwater tend to be longer than in surface water (up to 5
months), and bacteria such as fecal coliform may reproduce there.

At this time, ground water contamination from leakage of the lagoons does not appear to pose a
risk to the health of residents in the areas surrounding the ValAdCo facilities. Private water
supply wells in these areas generally are completed at depths of 80 to 300 feet below the ground
surface, below layers of clay that would act to retard migration of the contaminants. It is
unlikely that the observed contamination from leakage of the lagoons could create a completed
exposure pathway by entering these wells.

However, three potential ground water contamination concerns do exist. The first concern is for
the water supply wells on several of the ValAdCo properties. These wells are completed at
depths of only 35 to 55 feet below ground surface. In the case of the F1/BGF, F1/NF, and
Commercial Nursery facilities, these wells are located in what appears to be a downgradient
direction from the two lagoons. If workers at the facilities are using this water for drinking
purposes, they may be potentially exposed to elevated levels of organic and inorganic
contaminants.

The second concern for ground water is the identification of several unsealed wells in the areas
used for land application. The wells actually located were cut off at approximately 18 inches
below the ground surface, just six inches below the depth at which waste is knifed into the soil.
These wells, and others that may be present but have not yet been located, may act as direct
conduits for contamination to enter the ground water. In this case, nearby residential wells may
be at risk for contamination not only from chemical contaminants such as nitrate and chloride,
but also bacteria. This makes it imperative that all potential unsealed wells in areas used for land
application be identified and sealed as soon as possible. Minnesota Rules Chapter 4725.3850,
Subpart 6 require that this be done.

The third concern is for the Renville city water supply. In terms of potential exposed
populations, the proximity of the two Renville city wells to the F1/NF facility is of great
concern. These shallow wells are completed in a buried sand aquifer that may be connected
hydraulically to a sand layer immediately beneath the waste lagoons at the facility. Water



                                               55
quality data specific to the two city wells generally were not available, but routine monitoring of
the entire water system has not detected any significant contamination concerns. However, the
facility permit mandates that groundwater monitoring be conducted at this site to ensure the city
wells are adequately protected. Should contamination reach the city wells, the city of Renville
may be able to rely on their other wells to supply the community, but depending on the ability of
the other wells to provide adequate volumes of water, this may not be a viable long-term option.
It is extremely important that monitoring of the ground water occur in this area to detect any
contamination before it reaches the city wells.


Surface Water

Surface water may pose a significant exposure pathway, particularly for children in the area who
may play in and along the drainage ditches. Waterborne bacteria are the main concern regarding
surface water contamination. A secondary concern is the potential for nutrients to promote toxic
algal blooms and fish kills.

Surface water data are limited at the ValAdCo facilities, consisting mainly of perimeter tile
monitoring at three facilities and ditch sampling at two facilities. None of these data indicate
significant transport of contaminants from the facilities to surface water. However, most of the
perimeter tile and surface water sampling was conducted between 1995 to 1997, prior to the time
most of the lagoons were expected to experience breakthrough of their liners. The ditch sample
collected in 1997 by the DNR near F2/BGF, however, raises serious concerns regarding very
high surface water concentrations of fecal coliform bacteria and streptococci virus (see page 26).
However, that sampling was not adequate to determine the source of the contamination.

No surface water sampling has been conducted near land application sites to assess whether
water quality is being negatively affected by land application activities. Several studies suggest
that significant surface water contamination may occur near land application sites as the result of
surface runoff. For example, Robbins, et. al, (1971) found runoff from fields where swine
lagoon effluent was applied contains 1.7x105 to 1.0x106 fecal coliform / 100 ml water, which
was ten to one hundred times higher than the control area where no effluent was applied.


Land Application

Land application of animal waste is a common agricultural practice and the potential public
health effects are an issue for the entire agricultural system, not just the ValAdCo facility. It has
become such a familiar activity that potential risks involved with this activity often may be
overlooked. However, animal waste contains high concentrations of bacteria and nutrients. If
the waste is improperly handled or over-applied to agricultural fields, contamination of surface
and ground water may occur.

According to Cole, et. al. (2000), one gram of swine waste contains one-hundred million
bacteria, many of which are transmissible to humans, including Erysipelothrix rhusiopathiae,
Yersinia, Salmonella, Streptococcus, and hepatitis E. Cole, et. al. (1999) report that between 90
to 99 percent of bacteria are killed during lagoon storage of waste, however they also note that



                                                56
the initial concentrations of bacteria are so great that a significant number of bacteria remain
after lagoon storage and thus are applied to fields.

Feacham, et. al. (1983, p.61) report that the survival times of bacteria in soil are affected by
many factors. Bacterial survival increases as moisture, pH and organic matter increase and as
temperature, soil microflora and sunlight exposure decrease. Viruses, however, appear to adsorb
onto soil particles and are more protected from environmental factors, although they do survive
longer in cooler temperatures. Specifically, they report that enteroviruses (i.e. viruses found in
the digestive systems of animals) may survive up to 100 days, but usually less than 20 days.
Similarly, fecal coliform and salmonellae may survive up to 70 days, but usually less than 20
days, although salmonellae have been found in soils up to 1 year after application. Protozoan
cysts and parasite eggs appear to be more resistant to environmental factors. Protozoan cysts
generally survive from 10 to 20 days, but helminths (intestinal flat worms) have been detected up
to 9 months and Ascaris (intestinal round worms) eggs more than 2 years after application.

Knifing in of waste may help to reduce run-off, but may create additional problems for near
surface ground water. Edmonds (1976) found that the surface soil zone is more effective than
subsurface soil layers in removing and immobilizing bacteria. He concludes that while sub-
surface injection would tend to completely eliminate bacterial losses via surface runoff, “…the
probability of movement with drainage water is greatly increased due to reduced contact with the
surface soil”, increasing the possibility of bacterial contamination of the ground water.

Land application also introduces large volumes of nutrients into the environment, which may
damage surface and ground water quality. Excessive nutrient levels in ground water are largely
a concern for infants and small children (see section on Children’s Health, below), but may
cause digestive problems for anyone who ingests the water. Excessive nutrient levels in surface
water have been linked to toxic algal blooms, particularly blue-green algae, and fish kills. Some
blue-green algae contain cyanotoxins in their cell walls, which may cause liver or neurological
damage if ingested or skin irritation if direct contact occurs.

Nutrient contamination of surface and ground water is generally not a problem if the rate of
nutrient application is kept to levels that will be utilized by the crops planted on the fields where
the waste is applied, known as the agronomic rate. However, at nearly every facility examined,
there is some indication that insufficient acreage was used for land application. As a result, the
animal waste may have been applied at rates that exceeded the nutrient needs of the crops later
planted on those fields. This was particularly true for phosphate and potassium, but also
appeared generally to be true for nitrogen.

Compounding the potential for over-application of waste to the farm fields was the failure to
sample the land application site soils to determine the nutrient needs of those fields. Without
this information, it is impossible to determine the true agronomic rates for nutrient application.

A further problem identified in the land application process was the inadequate number of
samples collected to evaluate the actual nutrient content of the waste. In most cases, only one or
two samples were collected to characterize several million gallons of waste. Dou, et. al. (2001)
evaluated how much variability there might be in nitrogen and phosphorous sample results from
animal waste in agitated and non-agitated storage systems and also how many samples are



                                                57
required to achieve an accuracy of +10% . They found variations of 6 to 8% for agitated storage
systems, but 20 to 30% for non-agitated storage systems. For the swine farm studied (which did
not use agitation), they found a 13.6 % variation in total nitrogen, 16.02% in ammonia nitrogen,
23.92% in phosphorous, and 22.52% in potassium. They also determined that 20 samples would
be required to achieve an accuracy of +10% for total nitrogen and 40 samples for phosphorous,
for swine waste. They note: “Inaccurate nutrient analysis resulting from inadequate sampling
can have serious agronomic production or environmental consequences.”

The combination of apparently insufficient acreage, lack of soil nutrient sampling, and
insufficient waste sampling raises a serious concern regarding the possibility that waste was
over-applied to farm fields near the ValAdCo facilities. Such over application could result in
contaminated run-off to surface waters and infiltration of nutrients and bacteria to the shallow
ground water. As noted above, no monitoring information is available for the surface or ground
water at the land application sites, so it is impossible to determine whether such contamination
has occurred.



Agency for Toxic Substance and Disease Registry (ATSDR) Child Health
Initiative

ATSDR’s Child Health Initiative recognizes that the unique vulnerabilities of infants and
children make them of special concern to communities faced with contamination of their water,
soil, air, or food. Children are at greater risk than adults from certain kinds of exposures to
hazardous substances at waste disposal sites. They are more likely to be exposed because they
play outdoors and they often bring food into contaminated areas. They are shorter than adults,
which means they breathe dust, soil, and heavy vapors close to the ground. Children also weigh
less, resulting in higher doses of chemical exposure per body weight. The developing body
systems of children can sustain permanent damage if toxic exposures occur during critical
growth stages. Most importantly, children depend completely on adults for risk identification
and management decisions, housing decisions, and access to medical care.

The area surrounding the ValAdCo facilities is agricultural, with widely scattered residential
properties. Several of the families near these facilities have young children, and at least one
licensed day care facility was located within 2 miles of the Norfolk Township farms (F2/NF and
F2/BGF). Children and adults from these homes report symptoms similar to those reported by
adults: headaches, dizziness, fatigue, joint pain, nausea, diahrrea, and frequent respiratory
infections.

Ground water contamination is another area of concern for childrens’ health. Although no
completed ground water contamination exposure pathways were identified, the potential for such
contamination exists at both the facilities and the associated land application areas. Of particular
concern is contamination of the ground water by nitrate nitrogen and/or fecal coliform bacteria.

Nitrate nitrogen contamination of ground water is a serious concern for children’s health.
Infants under six months of age are at the most danger from elevated levels of nitrates in
drinking water. A baby fed water high in nitrates (or fed formula made with high-nitrate water)



                                                58
may develop a condition called “methemeglobinemia” or “blue baby syndrome”. In this
condition, the baby’s blood is unable to carry enough oxygen. As a result, the baby’s skin turns
a blue color, particularly around the eyes, nose, and mouth. Death may follow, if oxygen
deprivation is severe and lengthy enough. Susceptibility to blue baby syndrome increases if
fecal coliform bacteria are also present in the baby’s drinking water. Fecal coliform bacteria
cause diarrhea and interfere with digestion, intensifying nitrate’s effects on the body (Fan and
Steinberg, 1996).

Any water nitrate-nitrogen level over 10 mg/L is considered too high for safe drinking by babies
under six months of age. This 10 mg/L limit is the Maximum Contaminant Level set by the U.S.
Environmental Protection Agency. Almost all adults may drink water with nitrate-nitrogen
levels higher than 10 mg/L. However, some hereditary disorders render some rare adults
susceptible to methemoglobinemia. Also, women who are pregnant should not drink water high
in nitrates. (MDH, 1999)

Similarly, the potential for surface water contamination exists, particularly near land application
sites if the waste is applied at rates higher than the nutrient needs of the crops. Contaminated
surface water could pose a health risk to children who might play along streams and ditches near
land application sites. Surface water samples collected from the ditches in this area did detect
high concentrations of bacteria, including fecal coliform, and streptococci virus.

Land application sites themselves are unlikely to pose significant risks to children. The odors
associated with land application are likely to create a sufficient deterrent to children playing in
these areas prior to the waste being “knifed into” the ground.

Dead animal disposal issues raised by residents may also pose a potential health risk to children.
Scavenging of dead animal carcasses by pets may result in pathogens being transmitted to
children. Children might also pick up the plastic animal disposal bags that residents reported
would occasionally blow across the fields and residential yards. Again, such contact may result
in exposure to pathogens.




                                                59
                                      IV. Conclusions

Based on a review of available information in MPCA, ValAdCo, and MDH files, site visits, and
analysis of private water supply samples, the MDH has concluded that the F2/NF site poses a
public health hazard. The hazards involve mainly chemical hazards from air emissions, most
notably H2S concentrations which exceed MAAQS. These conclusions are supported by the
symptoms reported by neighbors, the record of MAAQS violations and the totality of the
continuous air monitoring data. The health hazard is likely episodic and acute, and symptoms
rapidly disappear in the absence of an air contamination plume. However, there is an
indeterminate (potential) health risk from stress and other possible more subtle but long lasting
effects of episodic exposures.

The health risks from air emissions at the other ValAdCo sites are indeterminate at this time,
although it is possible that they too may be in violation of Minnesota Ambient Air Quality
Standards and may also pose health risks.

The potential health risks posed by ground water and surface water exposure pathways at the
ValAdCo facilities are indeterminate at this time, as are the potential health risks from exposure
to dead animals awaiting proper disposal. Additional site investigation would be necessary to
determine whether actual exposure pathways exist in the ground water and surface water, and to
determine whether these exposures are associated with the ValAdCo facilities or are part of a
more widespread problem associated with general agricultural activities in the study area.

The presence of waste storage lagoons within the Drinking Water Supply Management Area for
Renville city wells #5 and #6, poses another potential, but at this time indeterminate, health risk.
No ground water monitoring has been conducted near the F1/NF facility, so it cannot be
determined at this time whether the storage lagoons are leaking. Sampling of the city wells has
not been adequate to determine whether any organic or inorganic contaminants have entered the
wells. The city water system is sampled regularly for bacteria, nitrates, and other compounds
that might be related to agricultural contamination. It is likely that the city would detect any
serious contamination, should it occur, and could make adjustments to their supply using their
other wells. However, it would be better to detect any potential contamination problems before
they affect the city wells. Additional work should be conducted to further evaluate this health
risk.

It is our understanding that under the proposed new management of the ValAdCo properties, the
existing clay-lined lagoons at six of the seven facilities (excepting the Commercial Nursery) will
be replaced with covered, concrete-lined lagoons. We further understand that these new lagoons
will be completely emptied every year. This should significantly reduce air emissions and
should help to prevent future leakage of waste to the ground water, possibly addressing concerns
for these two exposure pathways. These facility upgrades will not address concerns for possible
exposure pathways associated with land application and associated runoff to surface waters.
These concerns will have to be addressed by proper waste management procedures and adhering
to permitted requirements regarding soil testing and agronomic rates of application.




                                                60
                                 V. Recommendations


It is important to note that many of the following recommendations apply generically to confined
livestock feeding operations. The former ValAdCo facilities are not the only ones in Minnesota
where residents have complained of adverse health effects as a result of exposure to air
emissions from the barns, waste storage systems, and land application sites. Those
recommendations that we believe have a more general application have been marked with an
asterisk (*).

1. * ValAdCo should move toward a system where the animal waste is contained and where air
   emissions from that waste can be controlled in order to meet the MAAQS for hydrogen
   sulfide. Upgrades of the waste storage systems planned by Christensen Farms should be
   implemented.

2. * Facilities should utilize a combination of emission reducing strategies to suppress and/or
   control emissions from swine facilities. These may be found in Table 1, pp. 210 of the Iowa
   report (Iowa State University, 2002) and in EPA’s Emissions From Animal Feeding
   Operations (EPA 2001).

3. * Best management practices should be included in each facility’s odor management plan.
   These practices should be used and their use documented.

4. * MPCA should ensure compliance with the MAAQS for hydrogen sulfide. Compliance
   should be verified by air quality monitoring at all of the former ValAdCo facilities.

5. * If violations of the MAAQS are detected, prompt action should be taken, using proven and
   effective technologies and/or reduction in animal numbers, in order to achieve compliance.

6. A network of monitoring wells should be installed around the waste storage lagoons at the
   F1/NF facility, to ensure that the quality of the ground water in the wellhead management
   area of the Renville city wells is not being compromised.

7. The city of Renville and the Minnesota Department of Health should sample the Renville
   city wells #5 and #6 at least annually for chloride, ammonia, nitrate, and coliform bacteria.

8. Monitoring wells should be installed at the F1/BGF facility, because of its proximity to the
   buried stream channel adjacent to the property, which is an important source for drinking
   water in the area.

9. * County ditches near the ValAdCo facilities and land application sites should be sampled
   for bacteria, chloride, and nitrates to determine whether waste storage and application
   activities are contaminating surface waters. Sampling should occur at locations upstream,
   adjacent to, and downstream of each facility where a ditch is present within 200 feet of the
   waste storage lagoons. At land application sites, the ditches should be sampled upstream,



                                               61
   adjacent to, and downstream of the application sites, both before and after land application
   occurs.

10. * Dead animal storage buildings and the lagoons should be upgraded to prevent access by
    scavenging animals.

11. * More samples should be collected from each lagoon for nutrient analysis before land
    application occurs and a protocol should be developed to ensure that the samples adequately
    characterize the nutrient content in the entire column of the waste within the lagoons, not just
    the surface concentrations.

12. * Soil samples should be collected from proposed land application areas and analyzed prior
    to land application events in order to provide assurance that MPCA permit requirements are
    met. This will help to ensure that excess nutrients do not accumulate.

13. * Records should be kept of the waste levels in the waste storage lagoons before and after
    fall pumping, in order to provide accurate estimates of waste volumes.

14. * A thorough aerial photo evaluation should be conducted for each land application site, in
    order to identify evidence of possible improperly abandoned wells. Where the potential
    exists for such wells to be present, every effort should be made to locate and seal them, in
    accordance with Minnesota state rules. Prior to sealing the well, where possible, a ground
    water sample should be collected to determine if contamination has occurred. If the well
    cannot be located, that area should be marked and no land application should occur there.

15. * The water supply wells at each facility should be sampled for bacteria, nitrates, ammonia,
    and chloride to determine if they have been contaminated. Annual samples should be
    collected for nitrate and bacteria to ensure safe water for workers in the buildings.

16. An additional monitoring well should be installed next to MW-3 at the F2/BGF facility. The
    new well should be screened across the sand layer encountered at 18-20 feet below grade in
    borings BB-3 and BB-3A (see p. 24)

17. An additional monitoring well should be installed near the northwest corner of the western
    lagoon at the F4/BGF facility, to provide better monitoring of the water quality downgradient
    of the lagoons at this site.

18. Sampling of monitoring well MW-2 should recommence at the F3/BGF facility, because this
    is the only well apparently screened in the sand layer beneath the lagoons.

19. * All residents in the area should sample their wells annually for nitrate and bacteria (this
    recommendation applies generally to anyone who owns a private well).




                            V. Public Health Action Plan


                                                62
MDH’s Public Health Action Plan for the site will include:

       1. Sending a letter to ValAdCo, Christensen Farms, interested Renville County
          residents, the MPCA, and city and county authorities advising them of our
          recommendations and including a copy of this report;
       2. Collaborating with MPCA, County officials, and others, to review future air, water,
          and soil sampling data as it becomes available and to provide recommendations to the
          appropriate parties;
       3. Reviewing and commenting on revised facility permits in 2003;
       4. Continuing to respond to citizen calls concerning the facilities.



                                     VI. References
American Thoracic Society. Respiratory Health Hazards in Agriculture. American Journal of
Respiratory and Critical Care Medicine, Part 2, Vol. 158:5, November 1998.

ATSDR (2001) Agency for Toxic Substances and Disease Registry Fiscal Year 2001 Profile and
Annual Report, October 2000 to September 2001, ATSDR, Atlanta, GA.

Baumgartner (1998) 1997 Annual Ground Water Monitoring Report, ValAdCo, Renville
County, Minnesota; a report prepared by Jon Folkedahl of Baumgartner Environics, May 1,
1998.

Baumgartner (1999) 1998 Annual Ground Water Monitoring Report, ValAdCo, Renville
County, Minnesota; a report prepared by Jon Folkedahl of Baumgartner Environics, February 15,
1999.

Baumgartner (2000) 1999 Annual Ground Water Monitoring Report, ValAdCo, Renville
County, Minnesota; a report prepared by Jon Folkedahl of Baumgartner Environics, February 10,
2000.

Baumgartner (2001) 2000 Annual Ground Water Monitoring Report, ValAdCo, Renville
County, Minnesota; a report prepared by Jon Folkedahl of Baumgartner Environics, July 18,
2001.

Bolton & Menck, Inc. (1991) Letter from Mr. Robert M. Brown of Bolton & Menck, Inc. to Mr.
Jim Norman, City Administrator, City of Renville, dated October 17, 1991.

Clanton, C.J. and Schmidt, D.R. (2000) Sulfur Compounds in Gases Emitted from Stored
Manure. Transactions of the American Society of Agricultural Engineers Vol. 43(5): 1229-
1239.




                                             63
Cole, D., Hill V., Humenik, F., and Sobsey, M. (1999) Health, safety, and environmental
concerns of farm animal waste, Occupational Medicine: State of the Art Reviews, vol. 14, no. 2,
p. 423-448

Cole, D., Todd, L., and Wing, S. (2000) Concentrated swine feeding operations and public
health: A review of occupational and community health effects, Environmental Health
Perspectives, vol. 108, no. 8, p. 685-699

Donham K.J., Chemical and Physical Parameters of Liquid Manure from Swine Confinement
Facilities: Health Implications for Workers, Swine and the Environment. Agricultural Wastes
14:97-113, 1985.

Dou, Z., et. al. (2001) Manure sampling for nutrient analysis: variability and sampling efficacy.
Jour. Env. Quality, v. 30, p. 1432-1437

Edmonds, R. (1976) Survival of coliform bacteria in sewage sludge applied to a forest clearcut
and potential movement into ground water. Applied Environ. Microbiol., vol. 32, p. 537-546.

ESC (1995) Ground Water Monitoring Results – Buschette Site, a report prepared by
Environmental Strategies Corporation, February 17, 1995.

ESC (1996a) 1995 Annual Report, CF2-BGF (Breeding) Site, Section 29 Norfolk Township,
Renville County, Minnesota; a report prepared by Environmental Strategies Corporation, 1996.

ESC (1996b) 1995 Annual Report, CF2-BGF (Breeding) Site, Section 29 Norfolk Township,
Renville County, Minnesota; a report prepared by Environmental Strategies Corporation, 1996.

ESC (1997a) 1996 Annual Report, CF2-BGF (Breeding) Site, Section 29 Norfolk Township,
Renville County, Minnesota; a report prepared by Environmental Strategies Corporation,
January 31, 1997.

ESC (1997b) 1996 Annual Report, CF2-NF (Finishing) Site, Section 27 Norfolk Township,
Renville County, Minnesota; a report prepared by Environmental Strategies Corporation, 1997.

ESC (1997c) 1996 Annual Report, Buschette Site, Section 5, Flora Township, Renville County,
Minnesota; a report prepared by Environmental Strategies Corporation, 1997.

ESC (1997d) 1996 Annual Report, Schemel Site, Section 31, Emmet Township, Renville
County, Minnesota; a report prepared by Environmental Strategies Corporation, 1997.

EPA (2001) Emissions From Animal Feeding Operations. U.S. Environmental Protection
Agency Report, Emission Standards Division, Office of Air Quality Planning and Standards,
EPA No. 68-D6-0011, August 15, 2001.

Fan, A.M. and Steinberg, V.E. (1996). Health Implications of Nitrate and Nitrite in Drinking
Water: An Update on Methemoglobinemia Occurrence and Reproductive and Developmental
Toxicity. Regulatory Toxicology and Pharmacology 23: 35-43.



                                               64
Feachem, R., et.al. (1983) Sanitation and disease: health aspects of excreta and wastewater
management. Chichester [West Sussex]; New York: Published for the World Bank by Wiley,
New York

Gislason, Dosland, Hunter & Malecki (1991) Letter signed by Mr. Reed Glawe transmitting to
the MPCA the manure management plan for the F1/BGF and F1/NF facilities, dated Sept. 13,
1991

Glass, D.C. (1990) A Review of the Health Effects of Hydrogen Sulphide Exposure. Ann.
Occup. Med. Vol. 34, No. 3, pp. 323-327.

Iowa State University (2002) and the University of Iowa Study Group. Iowa: Concentrated
Animal Feeding Operations Air Quality Study, Final Report. February 7, 2002.

Kathman, S., Campagna, D., Inserra, S. G., Phifer, B. L., Middleton, D. C., and White, M.C.
(2001) Impact of Ambient Hydrogen Sulfide and Total Reduced Sulfur Levels on Hospital Visits
for Respiratory Diseases in Dakota City and South Sioux City Nebraska. Abstract from the 129th
Annual Meeting of APHA, 2001.

Leisch (1976) “Ground Water Testing Program for Renville, Minnesota”, prepared by Bruce A.
Leisch, Consulting Hydrologist, Wayzata, MN

MDH (1993) letter from Patricia Bloomgren, Director of Environment Health Division of the
Minnesota Department of Health to Mr. Dave Nelson, Water Quality Division of the Minnesota
Pollution Control Agency, dated August 23, 1993.

MDH (1996a) Analysis of Citizen Hydrogen Sulfide Monitoring, Renville County, May, 1996,
unpublished report prepared by Minnesota Dept. of Health, July 16, 1996 (revised Nov. 18,
1996).

MDH (1996b) Renville Vulnerability Assessment and Drinking Water Supply Management Area
delineation, approved August 30, 1996.

MDH (1999), Nitrate in Well Water, informational brochure produced by the Minnesota
Department of Health, Division of Environmental Health, July 1999.

Mensch, R.L. (1991) Project Manual for Site Work and Waste Handling System for Breeding
Unit and Gilt Finishing Unit, a report to ValAdCo dated August 26, 1991.

Mensch, R.L. (1995) Soil Report, Specifications and Construction plans for Site Work and
Waste Handling System for Swine Unit in SE ¼, Section 7-114-36, Flora Township, Renville
County, prepared by Robert L. Mensch, February 14, 1995.

Mensch, R.L. (undated) Project Manual for Site Work and Waste Handling System for Swine
Unit in SE ¼, Section 7-114-36, Flora Township, Renville County, a report to Francis Buschette,
prepared by Robert L. Mensch, undated.



                                             65
Minnesota Environmental Quality Board (EQB). Generic Environmental Impact Statement on
Animal Agriculture. Minnesota Planning: September 14, 2002.
http://www.mnplan.state.mn.us/eqb/geis/

NIOSH. Documentation of Revised IDLH Values. March 1, 1995.

Olson, Merle E. Presentation on the “Risk for Disease Transmission From Manure to Humans.”
Dr. Olson is a professor of Microbiology and Infectious Diseases at the University of Calgary,
Ontario Canada.
http://www.gov.mb.ca/agriculture/livestock/livestockopt/presentations/olson.pdf

O’Neill, D. H. and Phillips, V. R. (1992) A review of the control of odor nuisance from livestock
buildings: Part 3, Properties of the odorous substances which have been identified in livestock
wastes or in the air around them. Journal of Agricultural Engineering Research, 34:23-50.

Reynolds S.J., Donham K.J, Whitten P., Merchant J.A., Burmeister L.F., and Popendorf W.J.
Longitudinal Evaluation of Dose-Response Relationships for Environmental Exposures and
Pulmonary Function in Swine Production Workers. American Journal of Industrial Medicine
29:33-40, 1996.

Reynolds S.J., Donham K.J., Stookesberry J., Thorne P.S., Subramanian P., Thu K., and Whitten
P. Air Quality Assessments in the Vicinity of Swine Production Facilities. Agricultural Health
and Safety: Recent Advances. Haworth Press, Inc. 1997 (pp. 37-45).

Robbins, J.W., Kriz, G.J., and Howells, D.H. (1971) Quality of effluent from farm animal
production sites. In: Livestock Waste Management and Pollution Abatement. Proc. 2nd Int.
Symp. on Livestock Wastes, ASAE Pub. Proc. 271, St. Joseph, MI, p. 166-169.

Sprince N.L., Lewis M.Q., Whitten P.S., Reynolds S. J., and Zwerling C. Respiratory
Symptoms: Associations With Pesticides, Silos, and Animal Confinement in the Iowa Farm
Family Health and Hazard Surveillance Project. American Journal of Industrial Medicine
38:455-462, 2000.

Thu, K., Donahm, K., Ziegenhorn, R., Reynolds, S., Thorne, P., Subramanian, P., Whitten, P.,
and Stookesberry, J. (1997) A control study of the physical and mental health of residents living
near a large-scale swine operation. Jour. Agric. Safety and Health, vol. 3, p. 13-26.

Van Voast, W.A., W.L. Groussard, and D.E. Wheat (1972) Water Resources of the Minnesota
River – Hawk Creek Watershed, Southwestern Minnesota, U.S. Geological Survey Hydrologic
Atlas HA-391, publ. Washington, D.C.

Von Essen, S., Donham K. (1999) Illness and Injury in Animal Confinement Workers.
Occupational Medicine: State of the Art Reviews, Vol 14, No. 2, April-June 1999, p. 337-350,
Philadelphian, Hanley & Belfus, Inc.




                                              66
Wing, S. and Wolf, S. (2000) Intensive livestock operations, health and quality of life among
eastern North Carolina residents. Environ. Health Perspect., vol. 108, p. 233-242.

Zahn, J.A., DiSpirito, A.A., Do, Y.S., Brooks, B.E., Cooper, E.E., and Hatfield, J.L. (2001)
Correlation of Human Olfactory Responses to Airborne Concentrations of Malodorous Volatile
Organic Compounds Emitted from Swine Effluent . J. Environ. Qual., Vol 30, p. 624-634.




                                              67
Figures




 68
                                     Chloride (ppm)




                   0
                       5
                           10
                                15
                                       20
                                              25
                                                      30
                                                           35
                                                                40
                                                                     45
        6/3/1994

        9/3/1994

       12/3/1994

        3/3/1995

        6/3/1995

        9/3/1995

       12/3/1995

        3/3/1996

        6/3/1996

        9/3/1996

       12/3/1996

        3/3/1997

        6/3/1997

        9/3/1997




Date
       12/3/1997

        3/3/1998

        6/3/1998

        9/3/1998

       12/3/1998
                                                                          Figure 21: F2-BGF Chloride Concentrations




        3/3/1999

        6/3/1999

        9/3/1999

       12/3/1999

        3/3/2000

        6/3/2000

        9/3/2000
                                      MW-4
                                      MW-3
                                      MW-2
                                      MW-1
                                   Nitrate (ppm)




                   0
                       2
                           4
                               6
                                        8
                                                   10
                                                        12
                                                             14
                                                                  16
        6/3/1994

        8/3/1994

       10/3/1994

       12/3/1994

        2/3/1995

        4/3/1995

        6/3/1995

        8/3/1995

       10/3/1995

       12/3/1995

        2/3/1996

        4/3/1996

        6/3/1996




Date
        8/3/1996

       10/3/1996

       12/3/1996

        2/3/1997

        4/3/1997

        6/3/1997
                                                                       Figure 22: F2-BGF Nitrate Concentrations




        8/3/1997

       10/3/1997

       12/3/1997

        2/3/1998

        4/3/1998

        6/3/1998
                                   MW-4
                                   MW-3
                                   MW-2
                                   MW-1
                                        Sulfate (ppm)




                       50
                            100
                                  150
                                             200
                                                        250
                                                              300
                                                                    350
                                                                          400




                   0
        6/3/1994

        9/3/1994

       12/3/1994

        3/3/1995

        6/3/1995

        9/3/1995

       12/3/1995

        3/3/1996

        6/3/1996

        9/3/1996

       12/3/1996

        3/3/1997

        6/3/1997

        9/3/1997




Date
       12/3/1997

        3/3/1998

        6/3/1998

        9/3/1998

       12/3/1998
                                                                                Figure 23: F2-BGF Sulfate Concentrations




        3/3/1999

        6/3/1999

        9/3/1999

       12/3/1999

        3/3/2000

        6/3/2000

        9/3/2000
                                        MW-4
                                        MW-3
                                        MW-2
                                        MW-1
                              Ammonia (mg/L)




                    0
                              1
                                               2




                        0.5
                                         1.5
                                                   2.5
        5/20/1994

        8/20/1994

       11/20/1994

        2/20/1995

        5/20/1995

        8/20/1995

       11/20/1995

        2/20/1996

        5/20/1996

        8/20/1996

       11/20/1996

        2/20/1997

        5/20/1997

        8/20/1997




Date
       11/20/1997

        2/20/1998

        5/20/1998

        8/20/1998

       11/20/1998

        2/20/1999
                                                         Figure 24: F2-BGF Ammonia Concentrations




        5/20/1999

        8/20/1999

       11/20/1999

        2/20/2000

        5/20/2000

        8/20/2000
                                MW-4
                                MW-3
                                MW-2
                                MW-1
                            Chloride (ppm)




                       50
                            100
                                        150
                                              200
                                                    250




                   0
        7/6/1994

       10/6/1994

        1/6/1995

        4/6/1995

        7/6/1995

       10/6/1995

        1/6/1996

        4/6/1996

        7/6/1996

       10/6/1996

        1/6/1997

        4/6/1997

        7/6/1997




Date
       10/6/1997

        1/6/1998

        4/6/1998

        7/6/1998

       10/6/1998

        1/6/1999
                                                          Figure 25: F2-NF Chloride Concentrations




        4/6/1999

        7/6/1999

       10/6/1999

        1/6/2000

        4/6/2000

        7/6/2000

       10/6/2000
                              MW-4
                              MW-3
                              MW-2
                              MW-1
                                   Sulfate (ppm)




                       100
                             200
                                        300
                                                   400
                                                         500
                                                               600




                   0
        7/6/1994

       10/6/1994

        1/6/1995

        4/6/1995

        7/6/1995

       10/6/1995

        1/6/1996

        4/6/1996

        7/6/1996

       10/6/1996

        1/6/1997

        4/6/1997

        7/6/1997




Date
       10/6/1997

        1/6/1998

        4/6/1998

        7/6/1998

       10/6/1998

        1/6/1999
                                                                     Figure 26: F2-NF Sulfate Concentrations




        4/6/1999

        7/6/1999

       10/6/1999

        1/6/2000

        4/6/2000

        7/6/2000

       10/6/2000
                                   MW-4
                                   MW-3
                                   MW-2
                                   MW-1
                            Nitrate (ppm)




                   0
                       5
                           10
                                        15
                                             20
                                                  25
        7/6/1994

        9/6/1994

       11/6/1994

        1/6/1995

        3/6/1995

        5/6/1995

        7/6/1995

        9/6/1995

       11/6/1995

        1/6/1996

        3/6/1996

        5/6/1996

        7/6/1996




Date
        9/6/1996

       11/6/1996

        1/6/1997

        3/6/1997

        5/6/1997
                                                       Figure 27: F2-NF Nitrate Concentrations




        7/6/1997

        9/6/1997

       11/6/1997

        1/6/1998

        3/6/1998

        5/6/1998

        7/6/1998
                            MW-4
                            MW-3
                            MW-2
                            MW-1
                                         Ammonia (mg/L)




                   0
                                                                             1




                       0.1
                             0.2
                                   0.3
                                         0.4
                                               0.5
                                                     0.6
                                                           0.7
                                                                 0.8
                                                                       0.9
        7/6/1994

       10/6/1994

        1/6/1995

        4/6/1995

        7/6/1995

       10/6/1995

        1/6/1996

        4/6/1996

        7/6/1996

       10/6/1996

        1/6/1997

        4/6/1997

        7/6/1997




Date
       10/6/1997

        1/6/1998

        4/6/1998

        7/6/1998

       10/6/1998

        1/6/1999
                                                                                 Figure 28: F2-NF Ammonia Concentrations




        4/6/1999

        7/6/1999

       10/6/1999

        1/6/2000

        4/6/2000

        7/6/2000

       10/6/2000
                                           MW-4
                                           MW-3
                                           MW-2
                                           MW-1
                                       Chloride (ppm)




                    0
                        10
                             20
                                  30
                                       40
                                             50
                                                   60
                                                        70
                                                             80
                                                                  90
                                                                       100
        1/18/1995

        4/18/1995

        7/18/1995

       10/18/1995

        1/18/1996

        4/18/1996

        7/18/1996

       10/18/1996

        1/18/1997

        4/18/1997

        7/18/1997

       10/18/1997




Date
        1/18/1998

        4/18/1998

        7/18/1998

       10/18/1998

        1/18/1999

        4/18/1999
                                                                             Figure 31: F3-BGF Chloride Concentrations




        7/18/1999

       10/18/1999

        1/18/2000

        4/18/2000

        7/18/2000

       10/18/2000
                                            MW-5
                                            MW-4
                                            MW-3
                                            MW-1
                                            Chloride (ppm)




                    0
                        500
                              1000
                                     1500
                                              2000
                                                     2500
                                                             3000
                                                                    3500
                                                                           4000
                                                                                  4500
        1/18/1995

        4/18/1995

        7/18/1995

       10/18/1995

        1/18/1996

        4/18/1996

        7/18/1996

       10/18/1996

        1/18/1997

        4/18/1997

        7/18/1997

       10/18/1997




Date
        1/18/1998

        4/18/1998

        7/18/1998

       10/18/1998

        1/18/1999

        4/18/1999

        7/18/1999

       10/18/1999
                                                                                         Figure 32: F3-BGF Chloride Concentrations Showing All MW-5 Data




        1/18/2000

        4/18/2000

        7/18/2000

       10/18/2000
                                             MW-5
                                             MW-4
                                             MW-3
                                             MW-1
                                    Nitrate (ppm)




                    0
                        2
                            4
                                6
                                    8
                                         10
                                                12
                                                     14
                                                          16
                                                               18
                                                                    20
        1/18/1995

        3/18/1995

        5/18/1995

        7/18/1995

        9/18/1995

       11/18/1995

        1/18/1996

        3/18/1996

        5/18/1996

        7/18/1996

        9/18/1996




Date
       11/18/1996

        1/18/1997

        3/18/1997

        5/18/1997

        7/18/1997
                                                                         Figure 33: F3-BGF Nitrate Concentrations




        9/18/1997

       11/18/1997

        1/18/1998

        3/18/1998

        5/18/1998

        7/18/1998
                                        MW-5
                                        MW-4
                                        MW-3
                                        MW-1
                                          Sulfate (ppm)




                    0
                        200
                              400
                                    600
                                           800
                                                   1000
                                                          1200
                                                                 1400
                                                                        1600
                                                                               1800
        1/18/1995

        4/18/1995

        7/18/1995

       10/18/1995

        1/18/1996

        4/18/1996

        7/18/1996

       10/18/1996

        1/18/1997

        4/18/1997

        7/18/1997

       10/18/1997




Date
        1/18/1998

        4/18/1998

        7/18/1998

       10/18/1998

        1/18/1999
                                                                                      Figure 34: F3-BGF Sulfate Concentratons




        4/18/1999

        7/18/1999

       10/18/1999

        1/18/2000

        4/18/2000

        7/18/2000

       10/18/2000
                                          MW-5
                                          MW-4
                                          MW-3
                                          MW-1
                                          Ammonia (mg/L)




                    0
                        0.1
                              0.2
                                    0.3
                                            0.4
                                                   0.5
                                                           0.6
                                                                 0.7
                                                                       0.8
                                                                             0.9
        1/18/1995

        4/18/1995

        7/18/1995

       10/18/1995

        1/18/1996

        4/18/1996

        7/18/1996

       10/18/1996

        1/18/1997

        4/18/1997

        7/18/1997

       10/18/1997




Date
        1/18/1998

        4/18/1998

        7/18/1998

       10/18/1998
                                                                                   Figure 35: F3-BGF Ammonia




        1/18/1999

        4/18/1999

        7/18/1999

       10/18/1999

        1/18/2000

        4/18/2000

        7/18/2000

       10/18/2000
                                          MW-5
                                          MW-4
                                          MW-3
                                          MW-2
                                          MW-1
                                       Chloride (ppm)




                    0
                        20
                             40
                                  60
                                         80
                                                100
                                                        120
                                                              140
                                                                    160
                                                                          180
        7/26/1995
        9/26/1995
       11/26/1995
        1/26/1996
        3/26/1996
        5/26/1996
        7/26/1996
        9/26/1996
       11/26/1996
        1/26/1997
        3/26/1997
        5/26/1997
        7/26/1997
        9/26/1997
       11/26/1997
        1/26/1998
        3/26/1998




Date
        5/26/1998
        7/26/1998
        9/26/1998
       11/26/1998
        1/26/1999
        3/26/1999
        5/26/1999
                                                                                Figure 36: F4-BGF Chloride Concentrations




        7/26/1999
        9/26/1999
       11/26/1999
        1/26/2000
        3/26/2000
        5/26/2000
        7/26/2000
        9/26/2000
                                        MW-4
                                        MW-1
                                        MW-3
                                        MW-2
                                       Nitrate (ppm)




                    0
                        20
                             40
                                  60
                                            80
                                                       100
                                                             120
                                                                   140
                                                                         160
        7/26/1995


        9/26/1995


       11/26/1995


        1/26/1996


        3/26/1996


        5/26/1996


        7/26/1996


        9/26/1996


       11/26/1996


        1/26/1997




Date
        3/26/1997


        5/26/1997


        7/26/1997


        9/26/1997
                                                                               Figure 37: F4-BGF Nitrate Concentrations




       11/26/1997


        1/26/1998

        3/26/1998


        5/26/1998


        7/26/1998
                                       MW-4
                                       MW-3
                                       MW-2
                                       MW-1
                                    Sulfate (ppm)




                    0
                        200
                              400
                                         600
                                                    800
                                                          1000
                                                                 1200
        7/26/1995
        9/26/1995
       11/26/1995
        1/26/1996
        3/26/1996
        5/26/1996
        7/26/1996
        9/26/1996
       11/26/1996
        1/26/1997
        3/26/1997
        5/26/1997
        7/26/1997
        9/26/1997
       11/26/1997
        1/26/1998
        3/26/1998




Date
        5/26/1998
        7/26/1998
        9/26/1998
       11/26/1998
        1/26/1999
        3/26/1999
                                                                        Figure 38: F4-BGF Sulfate Concentrations




        5/26/1999
        7/26/1999
        9/26/1999
       11/26/1999
        1/26/2000
        3/26/2000
        5/26/2000
        7/26/2000
        9/26/2000
                                    MW-4
                                    MW-3
                                    MW-2
                                    MW-1
                                    Ammonia (mg/L)




                    0
                        0.1
                              0.2
                                      0.3
                                              0.4
                                                     0.5
                                                           0.6
                                                                 0.7
        7/26/1995
        9/26/1995
       11/26/1995
        1/26/1996
        3/26/1996
        5/26/1996
        7/26/1996
        9/26/1996
       11/26/1996
        1/26/1997
        3/26/1997
        5/26/1997
        7/26/1997
        9/26/1997
       11/26/1997
        1/26/1998
        3/26/1998




Date
        5/26/1998
        7/26/1998
        9/26/1998
       11/26/1998
        1/26/1999
        3/26/1999
        5/26/1999
                                                                       Figure 39: B4-BGF Ammonia Concentrations




        7/26/1999
        9/26/1999
       11/26/1999
        1/26/2000
        3/26/2000
        5/26/2000
        7/26/2000
        9/26/2000
                                      MW-4
                                      MW-3
                                      MW-2
                                      MW-1
Appendix A – Water Quality Data Tables




                 69
Appendix B – Laboratory Report On Bacteria in County Ditch 124




                             70
              Table 1 – City of Renville Water Quality Sampling

Date       Sample Location               Coliform    Chloride   Nitrate/nitrite   Sulfate   Sodium
                                         bacteria    mg/L       mg/L              mg/L      mg/L
12/29/88   Wells #5 & #6                 ND          ---        ---               ---       ---
3/23/90    Well #5                       ND          ---        ---               ---       ---
3/23/90    City system influent          ND          ---        ---               ---       ---
4/9/91     Wells #3, #4, #5, #6          ND          ---        ---               ---       ---
           (combined sample)
1/15/92    City system influent?         ---         25-31      0.49 – 0.63       200-300   16-27
9/23/92    Wells #5 & #6                 ND          ---        ---               ---       ---
6/3/93     Wells #5 & #6 (combined       ---         ---        <0.01             230       16
           sample)
10/28/93   Wells #5 & #6                 ND          ---        ---               ---       ---
7/26/95    Well #5                       ND          ---        ---               ---       ---
3/10/97    Wells #4 & #5 (combined       ND          ---        ---               ---       ---
           sample)
9/20/98    Wells #3, #4, #5, #6          ND          ---        ---               ---       ---
           (combined sample)
9/30/98    Wells #3, #4, #5, #6          ND          ---        ---               ---       ---
           (combined sample)
7/6/00     City treatment plant          ---         ---        ---               240       80

--- indicates that sample was not analyzed for this parameter
ND indicates that this parameter was not detected
Data complied from public water supply records
                                                          Table 2
                                   Farm 2/BGF – Water Quality Data, Monitoring Well #1
                                  Section 29, Norfolk Township, Renville County, Minnesota
Sampling   Sulfate   Chloride   Nitrate+   Nitrite   Ammonia    Nitrate     Fecal    Temp.     Temp.        pH     DO     Measuring   Depth    Ground
                                                                                      o
  Date     (ppm)      (ppm)     Nitrite    (ppm)     Nitrogen   (ppm)     Coliform      C     Corrected                     Point       To      Water
                                (ppm)                 (ppm)               (CFU/100           Conductivity                 Elevation   Ground   Elevation
                                                                             ml)             (umhos/cm)                               Water
 5/20/94    NS         NS         NS        NS         NS         NS         NS       NS         NS         NS     NS       70.92      31.42    39.50
  6/3/94    288        32.0       9.40     0.11       0.13       9.27        <10      8.5       745         7.5    NA       70.92      14.05    56.87
  7/6/94     68        17.5       6.72     0.07       0.05       6.65        <1       9.0       792         7.1    NA       70.92      13.73    57.19
 7/25/94     67        18.6       7.30     0.09       0.08       7.21        <1       8.5       862         7.1    5.3      70.92      13.60    57.32
Manure     Added        To      Lagoons     In        Sept.      1994
11/30/94    67         21.9       6.84     0.09       0.21       6.75        <1       9.0       735         7.0    2.4      70.92      11.03    59.89
 2/10/95     68        21.4       6.54     0.05       0.07       6.49        <1       8.0       748         7.2    0.6      70.92      12.65    58.27
  5/8/95    113        26.8       9.51     0.06       <1.0       9.45        <1       8.5        745        6.9    1.45     70.92      9.48     61.44
  7/7/95     84        27.8       8.87     0.04       0.02       8.83        <1       8.5       847         6.8    1.25     70.92      10.58    60.34
10/12/95    82         37.3       9.14     0.12       0.08       9.02        <1      10.5       846         6.7    1.25     70.92      11.66    59.26
 1/11/96     79        26.4       9.03     0.07       0.03       8.96        <1      10.0       855         7.2    1.5      70.92      13.09    57.83
 4/22/96     79        27.6       8.41     0.04       0.03       8.37        <1       8.0       814         6.9    2.30     70.92      12.16    58.76
 7/15/96     40        26.7       11.5     0.01       <0.01      11.5        <1       9.5        866         6.9   2.65     70.92      11.57    59.35
 10/4/96    131        27.2       9.65     <0.01       0.06      9.65        <1       8.5        832        7.1    1.05     70.92      13.40    57.52
 4/23/97     47        25.7       8.27      0.2       0.02       8.07        <1      10.1       817         7.3     *        NA         NA      60.62
 7/30/97     52        29.5        6.5     0.02       <0.01      6.48        <1       9.8       1242        7.32     *       NA         NA      59.17
 10/7/97     62        27.5       6.65     0.02       <0.01      6.63        <1      11.4        751        7.18     *       NA         NA      57.62
  2/3/98     48        26.0       7.36     0.02       <0.01      7.34        <1       3.7        892        7.02     *      70.92      15.11    55.81
 4/30/98     50        34.1       6.77     0.03       0.34       6.74       <100     10.9       871         7.3     *       70.92      9.36     61.56
 7/29/98     30        27.8        7.1     0.02       <0.01      7.08        <1       14         873        7.16     *      70.92      10.70    60.22
10/30/98    51          <3        5.82       *        <0.08        *        <10       9.3       1004        7.08     *      70.92      14.00    56.92
 1/29/99     55        35.2       8.23       *        <0.08        *         <1       8.7        927        6.7      *      70.92      13.88    57.04
 4/29/99     48        32.9       8.60       *        <0.08        *         <1       9.7        916        7.06     *      70.92      10.20    60.72
 7/21/99     45        29.5       8.56       *        <0.01        *         <1      11.3        880        7.28     *      70.92       9.82    61.10
10/12/99    45         33.0       6.56       *        <0.01        *         <1      11.8        877        6.94     *      70.92      11.42    59.50
  1/6/00     58        31.4       6.74       *        <0.01        *         <1       8.0       1000        6.95     *      70.92      13.11    57.81
 4/27/00     48        37.4       8.51       *        0.28         *         <1      10.1       1072        7.23     *      70.92      12.29    58.63
 7/21/00    112        38.3       8.29       *        0.04         *        <10      10.7       1171        7.12    *       70.92      9.92     61.00
10/20/00    56         33.1       9.71       *        0.15         *         <1      10.0        929        6.91    *       70.92      13.89    57.03
                                                      Table 2 (continued)
                                   Farm 2/BGF – Water Quality Data, Monitoring Well #2
                                  Section 29, Norfolk Township, Renville County, Minnesota
Sampling   Sulfate   Chloride   Nitrate+   Nitrite   Ammonia    Nitrate     Fecal    Temp.     Temp.        pH     DO     Measuring   Depth    Ground
                                                                                      o
  Date     (ppm)      (ppm)     Nitrite    (ppm)     Nitrogen   (ppm)     Coliform      C     Corrected                     Point       To      Water
                                (ppm)                 (ppm)               (CFU/100           Conductivity                 Elevation   Ground   Elevation
                                                                             ml)             (umhos/cm)                               Water
 5/20/94    NS         NS         NS        NS         NS        NS          NS      NS          NS         NS     NS       53.25      6.14     47.11
  6/3/94    350        35.0       12.6      0.51      0.20       12.1        <10      7.5       871         7.4     *       53.25      6.29     46.96
  7/6/94     48        28.5       5.08     0.08       0.26        5.0        <1      11.0       764         7.2     *       53.25      7.04     46.21
 7/25/94     29        19.2       3.97     0.06       0.18       3.91        <1      10.0       855         7.1    1.25     53.25      7.54     45.71
Manure     Added        To      Lagoons      In       Sept.     1994
11/30/94    46          5.1       0.08     0.04       0.35      0.04         <1      10.0       688         7.3    1.90     53.25      8.13     45.12
 2/10/95     35         9.1       1.17     0.04       0.07      1.13         <1       7.5       732         7.4    0.50     53.25      8.41     44.84
  5/8/95    41         28.6       10.9     <0.01      <0.10      10.9        <1       7.0       808         7.0    1.50     53.25      5.93     47.32
  7/7/95     37        15.6       1.33     0.04       0.24      1.298        <1       9.0       807         7.0    1.60     53.25      7.06     46.19
10/12/95    30          5.7       0.31     0.01       0.10      0.30         <1      13.0       762         6.6    1.45     53.25      7.82     45.43
 1/11/96     18         3.5       0.11     0.01       0.42      0.10         <1      10.0       729         7.3    1.30     53.25      7.99     45.26
 4/22/96     51        33.7       13.5     <0.01       0.03      13.5        <1       7.0       1808         7.1   4.70     53.25       6.77    46.68
 7/15/96     50        25.8       3.00     0.02       <0.01      2.98        <2       9.5       788         7.6    0.80     53.25      7.12     46.13
 10/4/96     53        24.1       1.98     <0.01       0.04      1.98        <1      11.0       756          7.3   0.80     53.25       7.74    45.51
 4/23/97     25        16.3       3.38     <0.01       0.02      3.38        <1       9.8       927         7.2      *       NA         NA      47.35
 7/30/97     31        21.4       1.57     0.02       <0.01      1.55        <1      11.8       1057         7.3     *       NA         NA      45.77
 10/7/97    27          9.9       0.14     0.04       0.04       0.1         <1      12.0       840         7.4     *        NA         NA      44.48
  2/3/98     24        26.2       11.6      0.01      0.01       11.6        <1       3.9       919         6.9      *      53.25      8.77     44.48
 4/30/98     28        30.1       2.67     0.02       0.18       2.65       <100     10.3       785         7.4     *       53.25      6.30     46.95
 7/29/98     27        20.8       0.74     0.02       <0.01      0.72        <1      13.0       777         7.3      *      53.25       7.45    45.80
10/30/98    26         20.8       7.68        *       <0.08        *        <10      10.0       875          7.2     *      53.25       8.62    44.63
 1/29/99     34        27.0       12.8        *       <0.08        *         <1       8.2        848         7.7     *      53.25       8.37    44.88
 4/29/99     27        20.1       8.30        *       <0.08        *         <1       8.5       783         7.28     *      53.25       6.48    46.77
 7/21/99     34        19.2       4.55        *       <0.01        *         <1      11.4        750        7.51     *      53.25       6.94    46.31
10/12/99    22         13.0       3.72        *       0.01         *         <1      12.3       673         7.25    *       53.25      7.75     45.50
  1/6/00     23        12.2       4.42        *       0.01         *         <1       8.1       684         7.25    *       53.25      10.33    74.28
 4/27/00     24        20.5       9.08        *       0.08         *         <1       8.3       860         7.39    *       53.25      7.80     45.45
 7/21/00     36        21.0       4.86        *       <0.02        *        <10      10.8       869         7.46     *      53.25       7.36    45.89
10/20/00    21         12.5       4.15        *       <0.02        *         <1      11.8       663         7.23     *      53.25       8.41    44.84
                                                      Table 2 (continued)
                                   Farm 2/BGF – Water Quality Data, Monitoring Well #3
                                  Section 29, Norfolk Township, Renville County, Minnesota
Sampling   Sulfate   Chloride   Nitrate+   Nitrite   Ammonia    Nitrate     Fecal    Temp.     Temp.        pH     DO     Measuring   Depth    Ground
                                                                                      o
  Date     (ppm)      (ppm)     Nitrite    (ppm)     Nitrogen   (ppm)     Coliform      C     Corrected                     Point        To     Water
                                (ppm)                 (ppm)               (CFU/100           Conductivity                 Elevation   Ground   Elevation
                                                                             ml)             (umhos/cm)                               Water
 5/20/94    NS         NS         NS        NS         NS        NS          NS      NS          NS         NS     NS       50.45      25.91    24.54
  6/3/94    193        16.2       0.06     0.02       0.78      0.04         <10     8.0        1037        7.3     *       50.45      6.94     43.51
  7/6/94    135         2.0      <0.20     <0.01      0.88       0.19        <1      10.5        982        7.3     *       50.45       7.65    42.80
 7/25/94    140         1.4      <0.20     <0.01      1.07       0.19        <1      10.0       1079        7.2    1.80     50.45       8.04    42.41
Manure     Added        To      Lagoons     In        Sept.     1994
11/30/94    130        2.0        0.03     0.01       1.22      0.02         <1      10.0        967         7.3   2.45     50.45      8.03     42.42
 2/10/95    140         1.1       0.26     0.03       1.25      0.23         <1       7.5        946         7.5   0.35     50.45      8.59     41.86
  5/8/95    167         1.5       0.13     0.02       1.03      0.11         <1       7.5       1036         7.0   2.05     50.45      6.16     44.29
  7/7/95    144         0.7       0.03     0.01       1.19      0.02         <1       9.0       1066         7.0   1.30     50.45      7.31     43.14
10/12/95    142        <0.5      <0.20     <0.01      1.65      <0.2         <1      11.5       1030         6.7   0.95     50.45      8.09     42.36
 1/11/96    162        <0.5      <0.20     <0.01      1.36      <0.2         <1       9.5       1006         7.5   0.85     50.45      8.22     42.23
 4/22/96    145        <1.0       0.24     0.01       1.46      0.23         <1       7.5       1022         7.1   2.10     50.45      8.22     42.23
 7/15/96    130        <3.0       0.64     0.02       0.12      0.62         <1       9.5       1051         7.4   0.75     50.45      7.64     42.81
 10/4/96    139        <3.0       0.08     <0.01      1.22       0.08        <1       9.5        980         7.3   0.75     50.45      8.63     41.82
 4/23/97    145        <3.0      <0.2      0.10       0.66      <0.2         <1      10.2        988         7.3     *       NA        NA       43.44
 7/30/97    124        <3.0       0.01     0.01       0.68      0.00         <1      11.2       1491        7.48    *        NA        NA       42.71
 10/7/97    156        <3.0       0.15     0.01        0.8      0.14         <1      11.8       1029        7.47    *        NA        NA       41.28
  2/3/98    137        <3.0       0.03     0.02       1.38      0.01         <1       4.2        537        6.96    *       50.45      9.73     40.72
 4/30/98    123        <3.0       0.33     0.02       1.36      0.31        <100      9.4       1069         7.4    *       50.45      6.30     44.15
 7/29/98    146        <3.0      <0.01     <0.01      1.49      <0.01        <1      12.5       1045        7.16     *      50.45      7.75     42.70
10/30/98     99        <3.0       0.22       *        1.58        *         <10       9.7       1163        7.12     *      50.45      9.40     41.05
 1/29/99    117        <3.0       0.07       *        0.92        *          <1       8.3        994        7.50     *      50.45      9.42     41.03
 4/29/99    119        <3.0       0.05       *        0.89        *          <1       9.2        974        7.05     *      50.45      7.45     43.00
 7/21/99    100        <3.0      <0.05       *        0.94        *          <1      11.4        976        7.30     *      50.45      7.39     43.06
10/12/99     86        <3.0       0.09       *        0.14        *          <1      11.5        931        7.10     *      50.45      8.34     42.11
  1/6/00    107        <3.0      <0.2        *        1.12        *          <1       6.4        986        7.16     *      50.45      8.95     41.50
 4/27/00    107        <3.0      <0.2        *        1.32        *          <1       9.3       1073        7.29     *      50.45      8.36     42.09
 7/21/00    105        <3.0      <0.2        *        0.67        *         <10      10.6       1070        7.37     *      50.45      7.73     42.72
10/20/00    103        <3.0      <0.2        *        0.69        *          <1      11.4        922        7/13     *      50.45      9.71     40.74
                                                               Table 2 (continued)
                                            Farm 2/BGF – Water Quality Data, Monitoring Well #4
                                           Section 29, Norfolk Township, Renville County, Minnesota
Sampling   Sulfate   Chloride   Nitrate+      Nitrite   Ammonia    Nitrate     Fecal    Temp.      Temp.         pH    DO       Measuring   Depth    Ground
                                                                                         o
  Date     (ppm)      (ppm)     Nitrite       (ppm)     Nitrogen   (ppm)     Coliform      C      Corrected                       Point       To      Water
                                (ppm)                    (ppm)               (CFU/100            Conductivity                   Elevation   Ground   Elevation
                                                                                ml)              (umhos/cm)                                 Water
 5/20/94    NS         NS         NS           NS         NS        NS          NS       NS          NS          NS    NS         52.1       6.52      45.58
  6/3/94    293        14.8       0.19        <0.01      0.43       0.18        <10      8.5        847          7.5    *         52.1       5.79      46.31
  7/6/94    110         2.7      <0.20        <0.01       0.36      0.19        <1       11.0       874          7.3    *         52.1       6.22      45.88
 7/25/94    118         1.2      <0.20        <0.01       1.06      0.19        <1       10.0       1023         7.3   1.90       52.1       6.54      45.56
Manure     Added        To      Lagoons         In       Sept.     1994
11/30/94    122         2.1       0.03        0.02       1.20      0.01         <1       10.0         911       7.3    2.42       52.1       6.74     45.36
 2/10/95    124         2.0       0.06        0.02       1.33      0.04         <1        8.0         899       7.4    0.45       52.1       7.84     44.26
  5/8/95    136         1.4       0.03        <0.01      1.15       0.03        <1        7.5         916       7.1    1.45       52.1       5.02     47.08
  7/7/95    134         3.5      <0.20        <0.01       1.31     <0.01        <1        9.5         994        7.1   1.65       52.1       5.67     46.63
10/12/95    133        4.7       <0.20        <0.01       1.53     <0.20        <1       12.0         957        6.8   1.05       52.1       6.89     45.21
 1/11/96    132         1.2       0.03        0.03       1.39      <0.01        <1        9.0         907       7.4    0.95       52.1       7.25     44.85
 4/22/96     98        <1.0       0.55        <0.01       0.82      0.55        <1        8.0         918        7.1   1.65       52.1       7.03     45.07
 7/15/96     91         3.2       0.34        0.01       0.51      0.33         <2        9.5         958       7.4    0.70       52.1       6.32     45.78
 10/4/96     97        <3.0       0.06        <0.01      1.43       0.06        <1        9.5         878       7.3    0.85       52.1       7.87     44.23
 4/23/97    100        <3.0      <0.2         <0.01       0.65     <0.2         <1       10.0         957        7.2     *        NA         NA       46.03
 7/30/97     87        <3.0       0.04         0.02      0.78       0.02        <1       13.0         703       7.16    *         NA         NA       45.09
 10/7/97    97         <3.0       0.05        <0.01      0.85       0.05        <1       11.6         798       7.41    *         NA         NA       43.91
  2/3/98    101        <3.0      <0.01        <0.01       1.34     <0.01        <1        3.9        1000       6.94     *        52.1       9.45     42.65
 4/30/98     81        <3.0       0.05         0.01      1.46       0.04       <100       10          953       7.4     *         52.1       5.19     46.91
 7/29/98     90        <3.0       0.08        <0.01       0.77      0.08        <1        11          934       7.12     *        52.1       6.67     45.43
10/30/98     90        <3.0       0.26           *       1.06        *          40       8.3         1095       7.12    *         52.1       9.09     43.01
 1/29/99     96        <3.0       0.11           *       2.21        *          <1        8.0         945       7.40    *         52.1       9.25     42.85
 4/29/99     89        <3.0      <0.05           *       <0.08        *         <1        9.3         941       6.95     *        52.1       6.89     45.21
 7/21/99     81        <3.0      <0.05           *       0.89         *         <1       11.2         917       7.38     *        52.1       6.17     45.93
10/12/99    74         <3.0      <0.05           *       0.32         *         <1       11.2         883       7.06     *        52.1       7.20     44.90
  1/6/00     88        <3.0      <0.2            *       0.56         *         <1        5.0         855       7.09     *        52.1       8.23     43.87
 4/27/00     77        <3.0      <0.2            *       1.52         *         <1       10.0         989       7.24     *        52.1       7.75     44.35
 7/21/00     87        <3.0      <0.2            *       1.02         *        <10       10.6        1036       7.36     *        52.1       8.06     44.04
10/20/00    75         <3.0      <0.2            *       0.57         *         <1       10.8         842       7.04     *        52.1       9.91     42.19
   * Sample not analyzed for this parameter                 ppm = parts per million or milligrams per liter (mg/L)
   NA = No data available                                   DO = dissolved oxygen
   NS = No sample collected on this date                    Data sources: Baumgartner, 1998, 1999, 2000, 2001; and ESC, 1997a
                                                             Table 3
                                         Farm 2/BGF – Water Quality Data, Perimeter Tile Line
                                            Section 29, Norfolk Township, Renville County, Minnesota
 Sampling     Sulfate    Chloride       Nitrate+   Nitrite   Ammonia      Nitrate      Fecal            Total        Temp.      Temp.        pH     DO
                                                                                                                      o
   Date       (ppm)       (ppm)         Nitrite    (ppm)     Nitrogen     (ppm)      Coliform       Phosphorous         C      Corrected
                                        (ppm)                 (ppm)                  (CFU/100          (ppm)                  Conductivity
                                                                                        ml)                                   (umhos/cm)
  Manure      Added         To          Lagoons      In        Sept.       1994
   5/8/95      42          50.8           16.8      0.01       <0.1        16.8            1            <0.08           7.0       945         7.9   7.40
   6/9/95      38          48.9           16.1     <0.01        0.01       16.1            2             NA            10.0       967         7.2   11.2
   7/7/95      41          50.0           16.5     <0.01        0.01       16.5            4            <0.08          13.5      1,115        7.9   10.4
  10/13/95     38          50.6           13.8     <0.01        0.02       13.8          <1             <0.08          13.0       908         7.1   8.30
   1/11/96     NS           NS            NS        NS          NS          NS           NS              NS            NS         NS         NS     NS
   4/22/96     36          54.4           11.9      0.01        0.03       11.9          <1             <0.08           3.5      1,018        7.9   12.6
   7/15/96     37          53.9           14.0     0.01        <0.01       14.0           2             0.55           12.0      1,024       8.0    7.5
   10/4/96     37          67.9           12.7     <0.01        0.09       12.7          <1             <0.10          12.0      1,024        7.9    6.8
   7/30/97     50          32.2           15.2      0.01       <0.01       15.2           70             NA            11.7      1081        7.31   NA
   10/7/97     NA           NA            NA        NA          NA          NA            7              NA            NA         NA         NA     NA
   2/4/98      NS           NS            NS        NS          NS          NS           NS              NS            NS         NS         NS     NS
   4/30/98     NS           NS            NS        NS          NS          NS           NS              NS            NS         NS         NS     NS
   7/29/98     27          50.8           13.8     <0.01       <0.01       13.8            0             NA            15.0      1043        7.50   NA
   8/25/98     56          85.7           9.55     <0.01       <0.08       9.55          120             NA            NA         NA         NA     NA
   9/23/98     47          124.0          7.79     <0.01       <0.01       7.79            2             NA            14.0      1408        7.49   NA
  10/30/98     65           6.5           2.62      NA         <0.08        NA           <1              <1            11.0       825        7.47   NA
   1/29/99     NS           NS            NS        NS          NS          NS           NS              NS            NS         NS         NS     NS
   4/29/99     35          39.9           7.99      NA         <0.08        NA           <1             <0.1            6.5       914        7.42   NA
   7/21/99     42          46.0           9.48      NA         <0.01        NA            2             <0.1           13.3       927        7.69   NA
  10/12/99     24          107.0          9.45      NA          0.01        NA            3             <0.1           12.6      1220        7.44   NA
   1/6/00      NS           NS            NS        NS          NS          NS           NS              NS            NS         NS         NS     NS
   4/27/00     24           114           15.0      NA         <0.02        NA           <1             <0.2            6.9      1450        7.51   NA
   7/21/00     72          51.4           10.3      NA         <0.02        NA           <10            <0.2           13.8      1160        7.76   NA
  10/20/00     NS           NS            NS        NS          NS          NS           NS              NS            NS         NS         NS     NS

NA = No data available                              DO = dissolved oxygen
NS = No sample collected on this date               Data sources: ESC, 1997a (Table 2) and Baumgartner, 2000 (Table 5.0)
                                                           Table 4
                                    Farm 2/BGF – Surface Water Quality Data, County Ditch 124
                                           Section 29, Norfolk Township, Renville County, Minnesota
Sampling       Sampling    Sulfate      Chloride   Nitrate   Nitrite   Ammonia         Nitrate     Fecal        Total     Temp.     Temp.        pH    DO
                                                                                                                           o
Location         Date      (ppm)         (ppm)     +         (ppm)     Nitrogen        (ppm)     Coliform   Phosphorous      C     Corrected
                                                   Nitrite              (ppm)                    (CFU/100      (ppm)              Conductivity
                                                   (ppm)                                            ml)                           (umhos/cm)
  SW-1B         6/3/94         99         38.5       15.60     0.30       0.16         15.30        100         NA        16.5       967         8.2    NA
                7/6/94        102         34.3       7.28      0.34       0.01         6.94         72          NA        25.0       860         8.3    NA
                7/25/94       113         35.4       3.35      0.02       <0.01        3.33         160         NA        22.0       922         8.2   12.95
               11/30/94       NS          NS          NS       NS          NS           NS          NS          NS        NS          NS         NS     NS
                5/8/94        102         34.3       21.00     0.17       <0.1         20.80         94        <0.08      10.0       967         7.4    7.60
                7/7/95        104         34.8       23.20     0.22       0.04         23.00        370        0.15       16.5       1063        7.8   7.80

  SW-2B         6/3/94         97         34.7      16.70      0.24       0.12         16.50        92          NA        16.5       955         8.2    NA
                7/6/94        105         39.0      8.58       0.26       0.13         8.32        100          NA        23.0       914         7.9    NA
                7/25/94       110         37.1      4.68       0.16       <0.01        4.52        100          NA        21.5       932         8.3   12.60
               11/30/94       NS          NS         NS        NS          NS           NS         NS           NS        NS          NS         NS     NS
                5/8/94        99          34.5      21.90      0.16       <0.1         21.70       130         <0.08      10.0       567         7.8    8.60
                7/7/95        105         36.0      22.60       0.2       0.05         22.40       310         0.14       17.0       1074        7.9   10.10

  SW-3B         6/3/94         94         36.6      20.80      0.30       0.28         20.50       200         NA         20.5       934         8.3    NA
                7/6/94        102         35.5      8.08       0.51       0.51         7.57        110         NA         25.0       820         8.1    NA
                7/25/94       112         42.9      3.95       0.32       0.58         3.63        120         NA         23.0       936         8.0    9.10
               11/30/94       NS          NS         NS        NS         NS            NS         NS          NS         NS          NS         NS     NS
                5/8/94        100         34.6      26.90      0.25       <0.1         26.60       160         0.09       11.5       929         7.8    7.85
                7/7/95         88         33.6      27.30      0.29       0.12         27.00       230         0.13       18.0       1039        8.0   10.50

  SW-4B         6/3/94         98         34.7      16.00      0.06       0.05         15.90        48          NA        15.5       965         8.2    NA
                7/6/94         95         44.9      10.68      0.19       0.17         10.50       170          NA        18.0       1027        7.4    NA
                7/25/94       104          40       8.71       0.33       0.06         8.38        210          NA        19.5       1039        7.7   3.20
               11/30/94       NS          NS         NS        NS          NS           NS         NS           NS        NS          NS         NS     NS
                5/8/94         98         37.3      21.40      0.02       <0.10        21.40       170         <0.08       7.5       1006        7.9    9.25
                7/7/95        111         37.5      22.20      0.03       0.06         22.20        80         <0.08      16.0       1111        7.7   10.60

NA = No data available                             DO = dissolved oxygen
NS = No sample collected on this date              Data source: ESC, 1996a (Table 3)
                                                         Table 5
                                     Farm 2/NF – Water Quality Data, Monitoring Well #1
                                           Section 27, Norfolk Township, Renville County, Minnesota
Sampling   Sulfate   Chloride   Nitrate+    Nitrite   Ammonia    Nitrate     Fecal    Temp.     Temp.        pH     DO     Measuring   Depth    Ground
                                                                                       o
  Date     (ppm)      (ppm)     Nitrite     (ppm)     Nitrogen   (ppm)     Coliform      C     Corrected                     Point       To      Water
                                (ppm)                  (ppm)               (CFU/100           Conductivity                 Elevation   Ground   Elevation
                                                                              ml)             (umhos/cm)                               Water
  7/6/94     93        12.0       1.42        0.01     0.01       1.41        <1      10.5       941         7.0     *       56.91      13.69    43.22
 7/25/94     99        11.0       1.30       <0.01       0.2      1.29        <1       9.5       1065        7.0    3.25     56.91      13.29    43.62
 8/16/94    102         6.2       1.45       0.02      0.13       1.43        <1      9.0        951         7.1    1.60     56.91      13.78    43.13
Manure     Added        To      Lagoons        In      Sept.      1994
11/30/94     99         8.5       0.64       0.03       0.2       0.61       <1        9.0       922         7.1    2.35     56.91      13.54    43.37
 2/13/95    105        12.0       0.88        0.03     0.16       0.85       <1        8.0        963        7.0    0.85     56.91      13.78    43.13
  5/8/95    133        10.4       1.13        0.02     <0.10      1.11       <1        8.0       1007         6.8   1.75     56.91      13.07    43.84
  7/7/95    108         9.6       0.95       0.02      0.04       0.93       <1        9.0       1023        6.8    1.15     56.91      13.68    43.23
10/12/95    117        11.4       1.27       0.01      0.26       1.26       <1       11.0        980        6.6    0.90     56.91      15.00    41.91
 1/11/96    122        12.4       1.59        0.01     0.09       1.58       <1        9.0        965        7.2    1.35     56.91      15.08    41.83
 4/22/96    124        13.4       1.05        0.01     0.05       1.04       <1        8.0        992        6.9    1.55     56.91      15.77    41.14
 7/15/96     78        10.8       1.35        0.01     0.01       1.34       <1        9.5       1009        7.2    0.70     56.91      13.10    43.81
 10/4/96    109        10.0       1.58       <0.01      0.05      1.58       <1        9.5        952         6.9   0.85     56.91      15.27    41.64
 4/23/97    131        16.8       3.71        0.13      0.01      3.58       <1        9.2       1012        7.2      *       NA         NA       43.2
 7/30/97    103        18.4       4.53        0.03     <0.01       4.5       <1       13.1       1016        7.11     *       NA         NA      42.99
 10/7/97    122        22.0       7.86        0.01     <0.01      7.85       <1       12.1       1109        7.24     *       NA         NA      40.80
  2/3/98    104        14.6       1.75        0.01     <0.01      1.74       <1        4.3       1015        6.87     *      56.91      17.45    39.46
 4/30/98    119        19.3       3.21        0.02     <0.08      3.19       <10      11.8       1040        7.20     *      56.91      12.70    44.21
 7/29/98     54        18.6       4.16       <0.01     <0.01      4.16       <1       12.5       1040        7.14     *      56.91      14.39    42.52
10/30/98     92        14.2       0.81          *      <0.08        *        <1        8.6       1057        6.93     *      56.91      16.40    40.51
 1/29/99     99        17.1       0.80          *      <0.08        *        <1        8.9        965        7.20     *      56.91      16.57    40.34
 4/29/99     92        15.6       2.46          *      <0.08        *        <1       10.5        982        6.83     *      56.91      14.90    42.01
 7/21/99     98        20.2       4.23          *      <0.01        *        <1       12.4        929        7.13     *      56.91      9.73     90.27
10/12/99     76        11.5       0.92          *      0.03         *        <1       10.7        910        6.93    *       56.91      15.42    41.49
  1/6/00    100        16.8       0.41          *      <0.01        *        <1        7.7        997        6.93     *      56.91      17.13    39.78
 4/27/00    107        16.7      <0.2           *       0.04        *        <1       10.2       1044        6.95     *      56.91      16.97    39.94
 7/21/00    102        20.3       1.61          *      <0.02        *        <10      10.0       1050        7.09     *      56.91      14.85    42.06
10/20/00    100        18.1       1.58          *      <0.02        *        <1       11.0        909        6.84     *      56.91      17.73    39.18
                                                                   Table 5 (continued)
                                                 Farm 2/NF – Water Quality Data, Monitoring Well #2
                                               Section 27, Norfolk Township, Renville County, Minnesota
Sampling     Sulfate   Chloride     Nitrate+    Nitrite   Ammonia      Nitrate      Fecal      Temp.       Temp.           pH     DO     Measuring     Depth       Ground
                                                                                                o
  Date       (ppm)      (ppm)       Nitrite     (ppm)     Nitrogen     (ppm)      Coliform        C       Corrected                        Point         To         Water
                                    (ppm)                  (ppm)                  (CFU/100               Conductivity                    Elevation     Ground      Elevation
                                                                                     ml)                 (umhos/cm)                                    Water
  7/6/94       84         43.5         3.6       0.03       <0.01        3.57        <1          11.0       1024           7.0    *         49.69       8.01         41.68
 7/25/94       97         42.7        15.8        0.09      <0.01        15.7        <1          12.5       1143           7.2   5.25       49.69       8.32         41.37
 8/16/94      102         32.3        17.5        0.06      <0.01        17.4         1          12.5       1012           7.2   5.00       49.69       6.99         42.70
Manure       Added         To       Lagoons        In       Sept.        1994
11/30/94      127         38.8        14.8        0.15       0.02        14.6        <1          10.5          996         7.3   3.15      49.69         9.25        40.44
 2/13/95      165         32.1        10.6        0.08       0.01        10.5         1           6.5         1083        7.3    0.75      49.69        11.27        38.42
  5/8/95      107         35.8        23.0       <0.01      <0.01        23.0        <1           5.0         1100         7.0   6.20      49.69         6.58        43.11
  7/7/95      131         36.9        19.4        0.02      <0.01        19.4        <1           9.5         1167         7.0   2.42      49.69         8.64        41.05
10/12/95      128         36.8        17.0       <0.01      <0.01        17.0        <1          13.0         1129         6.7   2.42      49.69        10.09        39.60
 1/11/96      114         37.4        22.7       <0.01      <0.01        22.7        <1           7.5         1097         7.4   2.40      49.69         8.34        41.35
 4/22/96       91         39.3        18.3       <0.01      <0.01        18.3        <1           6.0         1146         7.1   4.90      49.69         8.14        41.55
 7/15/96      105         39.5        18.4       <0.01      <0.01        18.4        <1          10.5         1189         7.6   4.70      49.69        37.83a       41.86
 10/4/96      107         35.9        15.6       <0.01       0.14        15.6        <1          11.0         1078         7.1   1.45      49.69         9.09        40.60
 4/23/97       91         39.8        13.2        0.11       0.01        16.1        <1           9.3         1109        7.3     *         NA           NA          44.26
 7/30/97       97         38.4        14.6       0.01       <0.01        14.6        <1          10.1         1673        7.33     *        NA           NA           41.9
 10/7/97      120         35.3        10.5       0.27       <0.01        10.2        <1          12.0         1036        7.35     *        NA           NA          40.50
  2/4/98      114         43.9        9.39       <0.01      <0.01        9.39        <1           6.4         1193        7.06     *       49.69        10.29        39.40
 4/30/98      103         59.0        7.45       0.01       <0.08        7.44        <4           7.4         1190        7.30    *        49.69         6.35        43.34
 7/29/98       99         58.3        7.51       <0.01      <0.01        7.51        <1          13.0         1240        7.02     *       49.69         8.50        41.19
10/30/98       95         79.8        4.46          *       <0.08         *          <1          10.5         1471        7.30     *       49.69         9.64        40.05
 1/29/99       97         127         2.82          *       <0.08         *          <1           7.7         1354        7.4     *        49.69        10.17        39.52
 4/29/99       69         167         1.16          *       <0.08         *          <1           7.9         1558        7.14    *        49.69         7.41        42.28
 7/21/99       66         149         1.45          *       <0.01         *          <1          11.8         1493        7.20     *       49.69b        8.97        40.72
10/12/99       62         145         1.15          *       0.01          *          <1          11.9         1490        7.04    *        49.69b        9.47        40.22
  1/6/00       62         197         0.62          *       <0.01         *          <1           7.8         2330        7.02    *        49.69b       10.70        38.99
 4/27/00       61         212         0.74          *       <0.02         *          <1           8.3         1915        7.04    *        49.69        10.25        39.44
 7/21/00       60         222         0.72          *       <0.02         *          <10         10.6         1950        7.28     *       49.69b        9.91        39.78
10/20/00       58         222         0.40          *       <0.02         *          <1          11.6         1815        6.98    *        49.69b       10.93        38.76
a
  This number is reported as it appears in ESC (1997b), however, it should be 7.83 ft. if the groundwater elevation number is correct.
b
  The measuring point elevation is actually reported as 46.69 feet for these dates, but this appears to be a typographic error; the groundwater elevations for these dates do not
appear as reported in the relevant reports, but rather are recalculated using the correct measuring point elevation and the reported depth to groundwater. This would give a
slightly more southeasterly component to groundwater flow than reported for those dates, but does not significantly alter the flow direction at the site.
                                                              Table 5 (continued)
                                                Farm 2/NF – Water Quality Data, Monitoring Well #3
                                                   Section 27, Norfolk Township, Renville County, Minnesota

Sampling     Sulfate   Chloride    Nitrate+    Nitrite   Ammonia       Nitrate     Fecal       Temp.       Temp.          pH     DO     Measuring     Depth       Ground
                                                                                                o
  Date       (ppm)      (ppm)      Nitrite     (ppm)     Nitrogen      (ppm)     Coliform         C       Corrected                       Point         To         Water
                                   (ppm)                  (ppm)                  (CFU/100                Conductivity                   Elevation     Ground      Elevation
                                                                                    ml)                  (umhos/cm)                                   Water
  7/6/94       81         44.0       5.03       0.06        <0.01       4.97        <1          11.5        1038          7.1     *        45.74       7.51         38.23
 7/25/94      100         43.8       9.00       0.10        <0.01       8.90        <1          13.0        1182          7.2    3.45      45.74       7.65         38.09
 8/16/94       82         33.7       9.26       0.04        <0.01       9.22        <1          13.0        1025          7.2    3.00      45.74       6.70         30.04
Manure       Added         To      Lagoons       In         Sept.       1994
11/30/94      397         16.6       0.22       <0.01        0.21       0.22         <1         10.0         1108         7.2    3.05      45.74         8.56       37.18
 2/13/95      518         16.6       0.05       <0.01        0.33       0.05          5          7.0         1390         7.2    0.90      45.74         9.58       36.16
  5/8/95       83         35.6       10.4       <0.01       <0.01       10.40        <1          5.5         1004         7.0    3.70      45.74         5.95       39.79
  7/7/95      161         30.9       7.68       0.02         0.01       7.66         <1         10.0         1136         7.0    2.02      45.74         7.51       38.23
10/12/95      452         12.9       0.75       0.01         0.49       0.74         <1         13.0         1453         6.6    1.00      45.74         8.38       37.36
 1/11/96      317         17.2       2.04       0.02         0.01       2.02         <1          7.5         1150         7.4    1.25      45.74         8.48       37.26
 4/22/96       88         30.9       12.3       <0.01       <0.01        12.3        <1          6.0         1146         7.1    5.30      45.74         6.72       39.02
 7/15/96       55         28.2       12.4       <0.01       <0.01        12.4        <1         10.5         1205         7.5    3.45      45.74         7.41       38.33
 10/4/96      405         15.3       1.48       <0.01        0.01       1.48         <1         11.0         1202         7.2    1.15      45.74         8.53       37.21
 4/23/97      105         32.3       12.9       0.05        <0.01       12.8         <1          8.8         1066         7.4     *         NA           NA         40.72
 7/30/97      379         18.5       0.53       0.03         0.23        0.5         <1         11.7         1801        7.35     *         NA           NA         38.24
 10/7/97      242         23.4       1.57       0.02        <0.01       1.55         <1         12.5         1217        7.46      *        NA           NA         37.23
  2/4/98      136         28.8       9.37       <0.01       <0.01        9.37        <1          6.7         1384        6.94      *       45.74         9.02       36.72
 4/30/98      153         34.1       7.82       0.02        <0.08        7.8         <10         8.1         1350        7.30      *       45.74         5.70       40.04
 7/29/98      182         30.7       2.46       0.01        <0.01       2.45         <1         12.5         1383        7.06      *       45.74         7.98       37.76
10/30/98      116          <3        7.56         *         <0.08         *          <1         10.3         1485        7.20      *       45.74         8.80       36.94
 1/29/99      159         62.5       3.69         *          0.92         *          <1          7.2         1364        7.40     *        45.74         8.76       36.98
 4/29/99       92         92.2       2.32         *         <0.08         *          <1          7.5         1412        7.05      *       45.74         6.41       39.33
 7/21/99       93         92.9       2.83         *          0.02         *          <1         12.2         1287        7.22      *       45.74a        7.90       37.84
10/12/99      112         79.0       2.25         *         0.01          *          <1         11.8         1293        7.04     *        45.74a        8.46       37.28
  1/6/00      121         91.3       2.17         *         0.02          *          <1          8.1         1410        7.04     *        45.74a        9.05       36.69
 4/27/00      126         119        1.14         *         <0.02         *          <1          8.3         1588        7.09     *        45.74         8.39       37.35
 7/21/00       91         167        0.96         *         <0.02         *          <10        11.3         1720        7.28     *        45.74         8.95       36.79
10/20/00      126         137        0.36         *         <0.02         *          <1         11.8         1427        7.01     *        45.74         9.55       36.19
a
 The measuring point elevation is actually reported as 45.94 feet for these dates, but this appears to be a typographic error; the groundwater elevations for these dates do not
appear as reported in the relevant reports, but rather are recalculated using the correct measuring point elevation and the reported depth to groundwater. This would have
negligible affect on the reported groundwater flow directions on these dates.
                                                                    Table 5 (continued)
                                                  Farm 2/NF – Water Quality Data, Monitoring Well #4
                                                Section 27, Norfolk Township, Renville County, Minnesota

Sampling    Sulfate   Chloride    Nitrate+   Nitrite   Ammonia     Nitrate     Fecal     Temp.      Temp.         pH     DO     Measuring   Depth    Ground
                                                                                          o
  Date      (ppm)      (ppm)      Nitrite    (ppm)     Nitrogen    (ppm)     Coliform       C      Corrected                      Point       To      Water
                                  (ppm)                 (ppm)                (CFU/100             Conductivity                  Elevation   Ground   Elevation
                                                                                ml)               (umhos/cm)                                Water
  7/6/94      85        46.1        9.61     <0.01       <0.01       9.60       <1        12.5       1038         7.1      *      44.86      7.28     37.58
 7/25/94      82        40.6        7.62     0.02        <0.01       7.60       <1        13.0       1128         7.3    2.40     44.86      7.46     37.40
 8/16/94      73        29.0        6.84     0.04        <0.01       6.80        1        13.5       1000         7.1    4.60     44.86      6.74     38.12
Manure      Added        To       Lagoons      In        Sept.       1994
11/30/94     273        33.5        1.79     0.02        0.12        1.77       <1        10.0        999         7.2    3.00     44.86      8.30     36.56
 2/13/95     403        28.3        0.72      0.09        0.14       0.63      <10         6.0        980         7.3    0.50     44.86      9.09     35.77
  5/8/95      85        26.6        5.40      0.01       <0.01       5.39       <1         4.5         838         7.0   6.30     44.86      5.63     39.23
  7/7/95      75        25.1        6.50      0.01        0.02       6.49       <1        10.5        913         7.1    7.95     44.86      7.14     37.72
10/12/95      77        29.3        6.09     <0.01       <0.01       6.09       <1        14.0         976         6.6   4.05     44.86      8.07     36.79
 1/11/96      99        31.5        6.50     <0.01       <0.01       6.50       <1         7.5         991         7.4   1.85     44.86      8.75     36.11
 4/22/96      65        17.2        2.16     <0.01       <0.01       2.16       <1         5.0         841         7.1   7.85     44.86      5.53     39.33
 7/15/96      37        14.4        1.23     <0.01       <0.01       1.23       <1        10.5         857         7.5   4.05     44.86      7.23     37.63
 10/4/96     322        22.7        0.72     <0.01        0.44       0.72       <1        11.5         851         7.2   1.05     44.86      8.62     36.24
 4/23/97      70        12.5        1.43      0.02        0.02       1.41       <1         9.4        881         7.3     *        NA        NA       39.86
 7/30/97      74        12.5        1.13     <0.01       <0.01       1.13       <1        12.3         417        7.43     *       NA        NA       37.84
 10/7/97      83        12.6        0.83     <0.01       <0.01       0.83       <1        12.1         829         7.3     *       NA        NA       36.25
  2/4/98     171        18.1         0.8     <0.01       <0.01        0.8       <1         6.8        1180         6.9     *      44.86      9.50     35.36
 4/30/98      95        14.1        1.57     0.01        <0.08       1.56      <100        8.5        870         7.5     *       44.86      5.66     39.20
 7/29/98     101        15.2        1.33     0.01        <0.01       1.32       <1        13.5        1008         7.9    *       44.86      7.85     37.01
10/30/98     120        17.2        1.13        *        <0.08         *        <1        10.4        1155         7.3    *       44.86      9.37     35.49
 1/29/99     126        21.3        2.03        *        <0.08         *        <1         6.7         964        7.60    *       44.86      9.40     35.46
 4/29/99     134        17.3        4.14        *        <0.08         *        <1         7.2         885        7.17    *       44.86      5.75     39.11
 7/21/99     112        14.0        0.48        *        0.07          *        <1        12.4        889         7.36    *       44.86      7.50     37.36
10/12/99     116        18.7        1.17        *        0.01          *        <1        12.2        926         7.18    *       44.86      8.50     36.36
  1/6/00     143        19.1        0.33        *        <0.01         *        <1         7.3        1320        7.14    *       44.86      9.36     35.50
 4/27/00     136        21.5        1.64        *        <0.02         *        <1         7.9        1071        7.40    *       44.86      8.44     36.42
 7/21/00     136        21.1        0.75        *        <0.02         *       <10        10.9        1030        7.47     *      44.86      8.46     36.40
10/20/00     139        21.1        0.46        *        0.02          *        <1        13.4        911         7.49    *       44.86      9.79     35.07


* Sample not analyzed for this parameter             ppm = parts per million or milligrams per liter (mg/L)
NA = No data available                               DO = dissolved oxygen
NS = No sample collected on this date                Data sources: Baumgartner, 1998, 1999, 2000, 2001; and ESC, 1997b
                                                              Table 6
                                          Farm 2/NF – Water Quality Data, Perimeter Tile Line
                                            Section 27, Norfolk Township, Renville County, Minnesota
 Sampling     Sulfate    Chloride       Nitrate+   Nitrite   Ammonia     Nitrate       Fecal            Total        Temp.     Temp.        pH     DO
                                                                                                                      o
   Date       (ppm)       (ppm)         Nitrite    (ppm)     Nitrogen    (ppm)       Coliform       Phosphorous         C     Corrected
                                        (ppm)                 (ppm)                  (CFU/100          (ppm)                 Conductivity
                                                                                        ml)                                  (umhos/cm)
  Manure      Added         To          Lagoons      In        Sept.       1994
   5/8/95      144         37.3           23.4      0.08       <0.01       23.3         180              2.23         10.5      1010         7.8   9.40
   6/9/95       40         35.7           16.6      0.30        1.92       16.3         59               NA            8.0      903          6.8   9.10
   7/7/95       37         29.7           16.1      0.10        0.19       16.0          8              <0.08         11.0      956          7.5   10.20
  10/13/95     38          45.7           15.6      0.34        0.34       15.4          9              <0.08         12.5      945          7.3   7.20
   1/11/96     NS          NS             NS        NS          NS          NS          NS               NS           NS         NS         NS      NS
   4/22/96      38         43.9           10.4      2.73        4.31        7.7         44               0.1           6.0      1099        7.4    7.85
   7/15/96     54          31.9           16.8      0.27       <0.01       16.5          1              <0.1          10.5      1010         7.9   6.70
   10/4/96     43          38.4           19.0     0.05        <0.01       19.0          6              1.24          12.0      1024        7.7    6.50
   7/29/98     26          47.5           10.5     <0.01       <0.01       10.5          9               NA           15.0      1193        7.72    NA
   8/25/98     36          52.1           12.7     <0.01       <0.08       12.7         68               NA           NA         NA         NA      NA
   9/23/98     38          61.4           11.7      0.04       <0.01       11.7         18               NA           13.5      1294        7.59    NA
  10/30/98     36          53.5           13.8      NA         <0.08        NA          77              <0.1          11.8      1305        7.89    NA
   1/29/99     NS          NS             NS        NS          NS          NS          NS               NS           NS         NS         NS      NS
   4/29/99     33          52.1           8.73      NA         <0.08        NA          <1              <0.1           8.1      1115        7.85    NA
   7/21/99     32          45.3           10.7      NA                      NA          23              <0.1          12.9      1149        7.89    NA
  10/12/99     NS          NS             NS        NS          NS          NS          NS               NS           NS         NS         NS      NS
   1/6/00      NS          NS             NS        NS          NS          NS          NS               NS           NS         NS         NS      NS
   4/27/00     33          56.3           10.2      NA                      NA           1              <0.2           8.4      1292        8.01    NA
   7/24/00     33          56.8           11.5      NA         <0.02        NA          40              <0.2          12.8      1317        8.06    NA
  10/20/00     NS          NS             NS        NS          NS          NS          NS               NS           NS         NS         NS      NS

NA = No data available                              DO = dissolved oxygen
NS = No sample collected on this date               Data sources: ESC, 1997B (Table 2) and Baumgartner, 2000 (Table 5.0)
                                                            Table 7
                                    Farm 2/NF – Surface Water Quality Data, County Ditch 85A
                                           Section 27, Norfolk Township, Renville County, Minnesota
Sampling       Sampling    Sulfate      Chloride   Nitrate   Nitrite   Ammonia         Nitrate     Fecal        Total     Temp.     Temp.        pH    DO
                                                                                                                           o
Location         Date      (ppm)         (ppm)     +         (ppm)     Nitrogen        (ppm)     Coliform   Phosphorous      C     Corrected
                                                   Nitrite              (ppm)                    (CFU/100      (ppm)              Conductivity
                                                   (ppm)                                            ml)                           (umhos/cm)
  SW-1F         7/6/94        141         47.8       2.69      0.23       <0.01         2.46         60         NA        32.0       953         8.0   NA
                7/25/94       162         52.2       9.54      0.10       0.01          9.44        64          NA        30.5       896         8.7   13.2
                8/16/94       155         44.4       11.2      0.30       0.03          10.9        220         NA        26.5       914         8.6   15.8
               11/30/94       NS          NS         NS        NS          NS           NS          NS          NS        NS          NS         NS    NS
                5/8/95        144         37.3       23.4      0.08       <0.1          23.3        180        <0.08      10.5       1010        7.8   9.40
                7/7/95        161         36.9       26.0      0.08        0.03         25.9        250        0.09       18.0       1270        7.9   12.6
               10/13/95       196         31.8       16.2      0.04        0.02         16.2        100        0.21       12.5       1195        6.8   8.95

  SW-2F         7/6/94        149         38.6      3.14       0.29       0.02          2.85       <1           NA        32.5       1006        8.2   NA
                7/25/94       156         41.1      11.7       0.08       0.07          11.6       140          NA        27.0       877         8.7   17.0
                8/16/94       164         58.6      12.1       0.30       0.17          11.8       580          NA        25.0       1050        8.3   11.2
               11/30/94       NS          NS        NS         NS         NS            NS         NS           NS        NS          NS         NS    NS
                5/8/95        NA          40.1      24.6       NA         <0.1          NA         200         <0.08      10.5       1010        8.0   9.20
                7/7/95        135         36.8      25.8       0.09       0.03          25.7       290         0.10       18.0       1154        7.9   12.9
               10/13/95       160         34.6      19.2       0.12       0.03          19.1       <1          0.17       12.5       1182        7.4   12.9

  SW-3F         7/6/94        119         32.6      15.2       0.32       0.03          14.8       80           NA        36.5       886         8.1   NA
                7/25/94       130         36.4      10.1       0.07       <0.01         10.0       110          NA        32.0       864         8.5   12.4
                8/16/94       121         39.0      8.80       0.04       <0.01         8.76       230          NA        28.0       785         8.5   15.1
               11/30/94       NS          NS        NS         NS          NS           NS         NS           NS        NS          NS         NS    NS
                5/8/95        113         35.0      22.6       0.03       <0.1          22.6       110         <0.08      10.0       981         8.1   8.95
                7/7/95        104         31.7      25.8       0.05        0.02         25.8        84         0.08       18.0       1097        7.9   11.7
               10/13/95       141         35.8      19.8       0.02        0.02         19.8       130         0.13       13.0       1115        7.7   7.85

NA = No data available                             DO = dissolved oxygen
NS = No sample collected on this date              Data source: ESC, 1996b (Table 3)
                                                               Table 8
                                           Farm 3/BGF – Water Quality Data, Monitoring Well #1
                                                 Section 5, Flora Township, Renville County, Minnesota
Sampling       Sulfate   Chloride    Nitrate+    Nitrite   Ammonia      Nitrate      Fecal      Temp.       Temp.          pH    DO     Measuring   Depth    Ground
                                                                                                 o
  Date         (ppm)      (ppm)      Nitrite     (ppm)     Nitrogen     (ppm)      Coliform        C       Corrected                      Point       To      Water
                                     (ppm)                  (ppm)                  (CFU/100               Conductivity                  Elevation   Ground   Elevation
                                                                                      ml)                 (umhos/cm)                                Water
 1/18/95        1290        15.9       2.15        0.05        0.02       2.10        <1          8.5        2334          7.0   2.90    100.00      14.61    84.92
  2/1/95        1150        12.9       1.43       <0.01       <0.01       1.43        <1          8.5        2350          7.0   1.80    100.00      14.80    85.39
 2/16/95        1060         9.0       1.18       <0.01       <0.01       1.18         1          8.0        2221          6.8   4.02    100.00      15.05    85.20
Manure         Added         To      Lagoons        In        1995       (Date        Not         In         Files)
 5/24/95        1220        12.2       1.43       <0.01       <0.01       1.43        <1          7.0        2238          6.6   3.85    100.00       8.17    84.95
 7/26/95        1030        14.5       2.16       <0.01       <0.01       2.16        <1         10.0        2401          6.5   2.15    100.00       8.41    91.83
10/10/95        880         17.8       3.51       <0.01        0.01       3.51        <1         12.0        1937         6.4    2.49    100.00      11.51    91.59
 2/23/96        670         18.9       3.97       <0.01        0.03       3.97        <1          8.0        1910         7.0    1.96    100.00      12.11    88.49
 4/26/96        766         19.8       3.85       <0.01       <0.01       3.85        <1          6.4        1886         6.8    3.29    100.00      12.12    87.89
 7/26/96        1010        31.2       3.05       <0.01        0.04       3.05        <1         10.0        2110         6.9    1.95    100.00      9.62     87.88
 10/2/96        1370        19.2       3.88       <0.01       <0.01       3.88        <1         11.0        3392          6.8   3.30    100.00      12.03    87.97
 4/23/97        654         20.0       4.72       <0.01       <0.01       4.72        <1          8.5        3110         6.70     *      NA          NA      91.55
 7/31/97        822         18.4       3.95        0.03        0.04       3.92        <1          9.7        1659         6.88    *       NA          NA      89.86
 10/6/97        729         20.4       4.97       <0.01       <0.01       4.97        <1         11.5        3460         6.87     *      NA          NA      88.19
  2/4/98        656         21.6       4.87       <0.01       <0.01       4.87        <1          5.7        1943         6.91     *     100.00      12.96    87.04
  5/1/98        842         21.1       4.60       0.01        <0.08       4.59        <1          9.8        2240         7.00    *      100.00      7.87     92.13
 7/30/98        878         19.1       4.22       <0.01       <0.01       4.22        <1         13.0        2220         6.59     *     100.00      10.30    89.70
10/28/98        623         22.5       5.79          *         0.24        *           3         11.0        1993         6.60    *      100.00      13.79    86.21
 1/28/99        618         24.6       5.45          *        <0.08         *         <1          6.9        1835         7.20     *     100.00      13.11    86.89
 4/28/99        1560        24.2       5.82          *        <0.08         *         <1          8.8        1777         6.76     *     100.00      10.58    89.42
 7/19/99        622         22.8       5.97          *        <0.01         *         <1         12.2        1860         7.12     *     100.00       9.73    90.27
10/11/99        527         22.5       5.92          *        <0.01        *          <1         12.2        1671         7.01     *     100.00      13.33    86.67
  1/5/00        504         24.2       4.90       9.00a       <0.01         *         <1          8.3        2350         7.09     *     100.00      14.46    85.54
 4/26/00        788         21.3       5.19          *        <0.02         *         <1         10.4        2010         7.04     *     100.00      14.22    85.78
 7/24/00        691         20.8       4.77          *        <0.02         *         <10        10.3        1830         6.93     *     100.00      9.92     90.08
10/18/00        628         21.7       5.83          *        <0.02        *          <1         11.8        1823         6.79     *     100.00      14.24    85.76


a
    This result seems implausible, given that nitrate + nitrite only equaled 4.90 ppm. Mostly likely, this should be 0.90 ppm
                                                   Table 8 (continued)
                                    Farm 3/BGF – Water Quality Data, Monitoring Well #2
                                           Section 5, Flora Township, Renville County, Minnesota

Sampling   Sulfate   Chloride   Nitrate+   Nitrite   Ammonia    Nitrate     Fecal    Temp.      Temp.       pH    DO     Measuring   Depth    Ground
                                                                                      o
  Date     (ppm)      (ppm)     Nitrite    (ppm)     Nitrogen   (ppm)     Coliform      C     Corrected                    Point       To      Water
                                (ppm)                 (ppm)               (CFU/100           Conductivity                Elevation   Ground   Elevation
                                                                             ml)             (umhos/cm)                              Water
 1/18/95    73         15.9       5.78     0.08       0.04       5.70        <1       8.5         686       7.5   1.70     84.61      10.02    74.59
  2/1/95    72         19.8       8.57     0.01       0.07       8.56         5       8.5        715        7.5   2.00     84.61      10.22    74.39
 2/16/95    73         20.3       7.55     0.05       0.04       7.50        <1       7.5         713       7.3   3.20     84.61      10.40    74.21
Manure     Added        To      Lagoons     In        Early      1995       (Date     Not      Certain)
 5/24/95    63         16.8       5.31     <0.01      <0.01      5.31        <1       7.0         765       6.8   2.70     84.61      6.09     78.52
 7/26/95    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      6.30     78.31
10/10/95    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      7.75     76.86
 2/23/96    28         25.5       0.70     0.04       0.18       0.66        <1       5.0        1067       7.1   3.10     84.61      7.82     76.79
 4/26/96    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      7.71     76.90
 7/26/96    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      8.31     76.30
 10/2/96    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      9.40     75.21
 4/23/97    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS        NA         NA      78.09
 7/31/97    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS        NA         NA      77.68
 10/6/97    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS        NA         NA      75.81
  2/4/98    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      10.14    74.47
  5/1/98    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      7.70     76.91
 7/30/98    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      8.43     76.18
10/28/98    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      9.86     74.75
 1/28/99    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      9.58     75.03
 4/28/99    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      8.67     75.94
 7/19/99    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      7.69     76.92
10/11/99    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      9.46     75.15
  1/5/00    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      10.33    74.28
 4/26/00    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      10.31    74.30
 7/24/00    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      9.10     75.51
10/18/00    NS         NS         NS        NS         NS         NS         NS       NS          NS        NS    NS       84.61      10.71    73.90
                                                   Table 8 (continued)
                                    Farm 3/BGF – Water Quality Data, Monitoring Well #3
                                           Section 5, Flora Township, Renville County, Minnesota

Sampling   Sulfate   Chloride   Nitrate+   Nitrite   Ammonia    Nitrate     Fecal    Temp.     Temp.        pH     DO     Measuring   Depth    Ground
                                                                                      o
  Date     (ppm)      (ppm)     Nitrite    (ppm)     Nitrogen   (ppm)     Coliform      C     Corrected                     Point       To      Water
                                (ppm)                 (ppm)               (CFU/100           Conductivity                 Elevation   Ground   Elevation
                                                                             ml)             (umhos/cm)                               Water
 1/18/95    147        16.9       9.59      0.05      0.03       9.54        <1       7.5        901        7.3    5.20     84.43      9.38     75.05
  2/1/95    114        15.3       8.48      0.01      0.16       8.47        >50      7.5        976        7.4    3.60     84.43      9.40     75.03
 2/16/95    124        18.2       8.03      0.06      0.05       7.97        <1       6.5        928        7.3    3.50     84.43      9.88     74.55
Manure     Added        To      Lagoons      In       1995      (Date        Not      In        Files)
 5/24/95     92        13.5       10.4     <0.01      <0.01     10.40        <1       7.0        869         7.0   3.65     84.43      7.31     77.12
 7/26/95     66        16.1       17.3     <0.01       0.01     17.30        <1      14.0        886         6.8   8.85     84.43      7.53     76.90
10/10/95    115        17.1       9.66     <0.01       0.03      9.66        <1      14.5       1061        6.8    6.45     84.43      7.77     76.66
 2/23/96    NS         NS         NS        NS         NS        NS          NS      NS          NS         NS     NS        NM        NM        NM
 4/26/96     58         8.4       3.96     <0.01       0.01      3.96        <1       5.5        973        7.2    2.21     84.43      7.80     76.63
 7/26/96     62        11.8       10.7     <0.01       0.04      10.7        <1      13.5        846         7.6   4.05     84.43      7.84     76.59
 10/2/96    118        16.6       12.0     <0.01      <0.01      12.0        <1      13.5       2022         7.1   2.23     84.43      8.29     76.14
 4/23/97     88        10.8       9.59     <0.01       0.03      9.59        <1       9.2       1960        7.10    *        NA        NA       77.11
 7/31/97     45         <3        4.37     <0.01      <0.01      4.37        <1      10.4       2040        7.18     *       NA        NA       76.86
 10/6/97    115        17.4       9.25     0.02       <0.01      9.23        <1      11.0       1540        7.09     *       NA        NA       76.13
  2/4/98    200        29.8       7.01     <0.01      <0.01      7.01        <1       6.1       1284        6.87     *      84.43      8.38     76.05
  5/1/98    117        14.3       9.10     <0.01      <0.08      9.10        <1       8.5        965        7.40     *      84.43      7.25     77.18
 7/30/98     46         6.7       9.96     <0.01      <0.01      9.96        <1      15.0        807        7.08     *      84.43      7.80     76.63
10/28/98    232        35.0       7.43     <0.01       0.15       *          <1      12.5       1437        6.72     *      84.43      8.58     75.85
 1/28/99    190        30.5       6.55        *       <0.08        *         <1       4.6       1292        7.30     *      84.43      8.40     76.03
 4/28/99     45        10.3       3.49        *       <0.08        *         <1       7.6        671        7.00     *      84.43      7.40     77.03
 7/19/99    107        17.0       6.00        *       0.03        *          <1      13.2        924        7.18    *       84.43      7.38     77.05
10/11/99    164        31.5       10.6        *       <0.01        *         <1      13.0       1310        6.87     *      84.43      8.45     75.98
  1/5/00    178        49.8       2.88        *       0.02        *          <1       6.1       1321        6.89    *       84.43      8.80     75.63
 4/26/00    136        53.2       3.76        *       <0.02        *         <1       7.9       1205        7.19     *      84.43      8.26     76.17
 7/24/00    104        33.5       4.20        *       <0.02        *         <10     12.4       1005        6.97     *      84.43      7.55     76.88
10/18/00    167        79.3       2.68        *       <0.02       *          <1      13.0       1337        7.00     *      84.43      9.27     75.16
                                                   Table 8 (continued)
                                    Farm 3/BGF – Water Quality Data, Monitoring Well #4
                                           Section 5, Flora Township, Renville County, Minnesota
Sampling   Sulfate   Chloride   Nitrate+   Nitrite   Ammonia    Nitrate     Fecal    Temp.     Temp.        pH     DO     Measuring   Depth    Ground
                                                                                      o
  Date     (ppm)      (ppm)     Nitrite    (ppm)     Nitrogen   (ppm)     Coliform      C     Corrected                     Point       To      Water
                                (ppm)                 (ppm)               (CFU/100           Conductivity                 Elevation   Ground   Elevation
                                                                             ml)             (umhos/cm)                               Water
 1/18/95    219        27.3       11.2      0.04       0.02      11.2        <1       6.5       1144        7.0    3.75     85.25      7.32     77.93
  2/1/95    194        27.0       10.1      0.02       0.03      10.1        <1       6.5       1234        7.2    4.50     85.25      7.60     77.65
 2/16/95    173        27.4       9.26     0.04        0.12      9.22        <1       6.0       1177        7.2    3.80     85.25      7.86     77.39
Manure     Added        To      Lagoons      In       1995      (Date        Not      In        Files)
 5/24/95    196        24.9       7.79     0.01       <0.01      7.78        <1       7.5       1142         7.0   4.10     85.25      6.59     78.66
 7/26/95    NS         NS         NS        NS         NS        NS          NS      NS          NS         NS     NS       85.25      6.54     78.71
10/10/95    NS         NS         NS        NS         NS        NS          NS      NS          NS         NS     NS       85.25      6.66     78.59
 2/23/96    NS         NS         NS        NS         NS        NS          NS      NS          NS         NS     NS       85.25      6.81     78.44
 4/26/96    NS         NS         NS        NS         NS        NS          NS      NS          NS         NS     NS       85.25      6.55     78.70
 7/26/96    NS         NS         NS        NS         NS        NS          NS      NS          NS         NS     NS       85.25      6.58     78.67
 10/2/96    NS         NS         NS        NS         NS        NS          NS      NS          NS         NS     NS       85.25      6.74     78.51
 4/23/97    NS         NS         NS        NS         NS        NS          NS      NS          NS         NS     NS        NA        NA       78.63
 7/31/97    163         9.6       7.20     0.04       <0.01      7.16        <1      10.5       2500        7.07    *        NA        NA       78.63
 10/6/97    181        10.6       9.26     0.01       <0.01      9.25        <1      11.4       1410        7.34    *        NA        NA       78.55
  2/4/98    189        16.0       9.63     <0.01      <0.01      9.63        <1       6.5       1159        6.92    *       85.25      6.90     78.35
  5/1/98    154        13.7       14.2     0.04       <0.08      14.2        <1       9.0       1018        7.40    *       85.25      6.68     78.57
 7/30/98    198        11.1       15.5     <0.01      <0.01      15.5        <1      15.0       1157        6.95    *       85.25      6.71     78.54
10/28/98    196        33.0       8.03        *        0.27       *          <1      12.5       1312        6.83    *       85.25      6.68     78.57
 1/28/99    216        28.2       9.49        *       <0.08        *         <1       5.8       1202        7.40     *      85.25      6.76     78.49
 4/28/99    107        22.3       8.27        *       <0.08        *         <1       8.0        976        6.98    *       85.25      6.65     78.60
 7/19/99    159        18.1       16.0        *        0.02       *           2      12.7       1055        7.19    *       85.25      6.66     78.59
10/11/99    145        68.4       4.93        *       <0.01        *         <1      12.4       1372        6.85     *      85.25      6.66     78.59
  1/5/00    179        47.5       5.25        *       <0.01        *         <1       6.2       1380        6.99     *      85.25      6.85     78.40
 4/26/00    178        68.6       6.16        *       <0.02        *         <1       8.0       1511        7.20     *      85.25      6.75     78.50
 7/24/00    207        45.9       13.2        *       <0.02        *         <10     11.3       1390        6.99     *      85.25      6.75     78.50
10/18/00    228        81.4       7.68        *       <0.02        *         <1      12.7       1560        6.87     *      85.25      6.91     78.34
                                                         Table 8 (continued)
                                          Farm 3/BGF – Water Quality Data, Monitoring Well #5a
                                                  Section 5, Flora Township, Renville County, Minnesota
Sampling       Sulfate   Chloride    Nitrate+     Nitrite   Ammonia     Nitrate     Fecal      Temp.          Temp.        pH     DO     Measuring   Depth    Ground
                                                                                                o
  Date         (ppm)      (ppm)      Nitrite      (ppm)     Nitrogen    (ppm)     Coliform        C          Corrected                     Point       To      Water
                                     (ppm)                   (ppm)                (CFU/100                  Conductivity                 Elevation   Ground   Elevation
                                                                                     ml)                    (umhos/cm)                               Water
Manure         Added        To       Lagoons       In        1995        (Date       Not          In           Files)
 7/26/95        125        11.1        6.51       0.07       0.02         6.44       <1          11.5            888       7.0    7.50     81.95      6.29     75.66
10/10/95        145        11.5        6.12       0.13       <0.01        5.99       <1          13.5            849       7.1    5.49     81.95      6.60     75.35
 2/23/96        110        12.9        5.98       0.06       0.04         5.94       <1           7.0            884       7.0    2.35     81.95      6.86     75.09
 4/26/96        146        15.2        6.27       <0.01       0.01        6.27       <1           5.9            900       7.2    6.22     81.95      6.47     75.48
 7/26/96        178        15.0        5.63       <0.01       0.04        5.63       <1          10.5            927        7.6   3.30     81.95      7.20     74.75
 10/2/96        162        12.9        5.61       <0.01      <0.01        5.61       <1          12.0           1615        7.2   2.80     81.95       8.32    73.63
 4/23/97         90         8.0        5.67       <0.01       0.03        5.67       14           8.6          1760        7.10    *        NA         NA      76.05
 7/31/97         89         8.0        3.46       1.07       <0.01        2.39       170         11.1           1722       7.31    *        NA         NA      75.58
 10/6/97         94         9.0        5.29       0.07       <0.01        5.22       <1          10.9           1050       7.25     *       NA         NA      73.91
  2/4/98        271        4270        9.28       0.07       0.12         9.21       <1           7.0          10340       6.93    *       81.95      8.71     73.24
  5/1/98         98        1630        6.52       0.04       0.77         6.48       <1          10.0           6190       7.00    *       81.95      6.05     75.90
 7/30/98        140        689         5.26       0.03       0.06         5.23       <1          15.5           3120       6.76    *       81.95      7.01     74.94
10/28/98        135        511         4.33         *        0.61          *         <1          12.6           3370       6.60    *       81.95      9.10     72.85
 1/28/99        146        295         7.70         *        <0.08          *        <1           5.7           1877       7.30     *      81.95      8.20     73.75
 4/28/99         57        135         6.31         *        <0.08          *        <1           8.1           1122       7.07     *      81.95      6.15     75.80
 7/19/99         65        219         6.40         *        0.09          *         28          12.2          1533        7.17    *       81.95      6.45     75.50
10/11/99         38        89.0        8.51         *         0.01         *          7          13.3            984       7.07    *       81.95      8.30     73.65
  1/5/00         53        58.6        6.44         *        0.01          *         <1           6.3           1295       7.04    *       81.95      8.95     73.00
 4/26/00         66        75.2        7.62         *        <0.02          *        <1           8.7           1009       7.17     *      81.95      8.07     73.88
 7/24/00         67        58.8        3.25         *         0.04         *         <10         12.4            973       7.41     *      81.95      6.60     75.35
10/18/00         86        86.4        3.91         *         0.06         *         <1          14.4           1135       7.25     *      81.95      10.01    71.94
a
    Well #5 was installed later than the other wells, to provide a more downgradient monitoring location.

       * Sample not analyzed for this parameter                  ppm = parts per million or milligrams per liter (mg/L)
       NA = No data available                                    DO = dissolved oxygen
       NS = No sample collected on this date                     Data sources: Baumgartner, 1998, 1999, 2000, 2001; and ESC, 1997c
       NM = No measurement taken
                                                        Table 9
                                    Farm 4/BGF – Water Quality Data, Monitoring Well #1
                                           Section 31, Emmet Township, Renville County, Minnesota
Sampling   Sulfate   Chloride   Nitrate+    Nitrite   Ammonia    Nitrate     Fecal    Temp.     Temp.        pH     DO     Measuring   Depth    Ground
                                                                                       o
  Date     (ppm)      (ppm)     Nitrite     (ppm)     Nitrogen   (ppm)     Coliform      C     Corrected                     Point       To      Water
                                (ppm)                  (ppm)               (CFU/100           Conductivity                 Elevation   Ground   Elevation
                                                                              ml)             (umhos/cm)                               Water
 7/26/95    766        19.3       26.9      0.09        0.05      26.8        <1       9.5       2074        6.8    7.95    102.26      7.17      95.09
  8/9/95    620        15.5       25.5      0.02        0.04     25.25        <1      10.0       1710        6.8    7.15    102.26      8.09      94.17
Manure     Added        To      Lagoons       In       August    1995
 8/23/95    436        18.7       25.1      0.07        0.12      25.0       <1       11.0       2348        7.1    5.25    102.26       9.02    93.24
10/10/95    599        17.2       25.0      0.04        0.05     25.0        <1        9.5       1673        6.9    7.39    102.26      9.49     92.77
 1/17/96    1070       15.2       26.3       0.06       0.11      26.2       <1        7.5       1810         7.1   3.80    102.26      11.72    90.54
 4/26/96    816        17.9       29.0      0.05        <0.01     29.0       <1        7.7       1601        7.0    2.64    102.26      11.46    90.80
 7/26/96    660        33.1       24.1      0.05        0.08     24.0        <1       11.0       1583        7.2    4.05    102.26      10.06    92.20
 10/2/96    656        13.8       20.4      0.07        0.04     20.3        <1       9.0        3060        7.0    2.27    102.26      11.45    90.81
 4/23/97    245        10.5       20.0      <0.01       0.02      20.0       <1        9.0       2230        7.00     *
 7/31/97    211        15.5       27.0      0.04        <0.01     27.0       <1        9.4       1907        7.12    *
 10/6/97    146        15.6       27.8      0.01        <0.01     27.8       <1       12.3       2670        7.08    *
  2/4/98    356        29.0       23.1      0.03        <0.01     23.1       <1        5.7       1945        6.75    *
  5/1/98    280        16.4       18.9      0.02        <0.08     18.9       <1        8.9       1304        7.40    *
 7/30/98    328        15.9       21.4      0.03        <0.01     21.4       <1       12.0       1435        6.97     *
10/28/98    193        12.8       19.1         *        0.61       *         <1       12.4       1219        6.91     *
 1/28/99    104         8.9       17.3         *        <0.08      *         <1        7.8        968        7.40     *
 4/28/99    104        21.6       1.52         *        <0.08      *         <1       10.1        920        7.13    *
 7/19/99    133         6.5       11.1         *        <0.01      *         <1       12.9        848        7.36    *
10/11/99     75        3.8        5.64         *        <0.01      *         <1       11.8        810        7.20    *
  1/5/00    228         8.2       9.37         *        <0.01      *         <1        8.3       1127        6.95    *
 4/26/00    734         7.6       9.76         *        0.05       *         <1       10.4       1705        7.02     *
 7/24/00     69         <3        1.75         *        <0.02      *         <10      11.6        814        7.35     *
10/18/00    318         4.5       4.65         *        0.02       *         <1       10.8       1208        6.98     *
                                                   Table 9 (continued)
                                    Farm 4/BGF – Water Quality Data, Monitoring Well #2
                                           Section 31, Emmet Township, Renville County, Minnesota

Sampling   Sulfate   Chloride   Nitrate+    Nitrite   Ammonia    Nitrate     Fecal    Temp.     Temp.        pH     DO     Measuring   Depth    Ground
                                                                                       o
  Date     (ppm)      (ppm)     Nitrite     (ppm)     Nitrogen   (ppm)     Coliform      C     Corrected                     Point       To      Water
                                (ppm)                  (ppm)               (CFU/100           Conductivity                 Elevation   Ground   Elevation
                                                                              ml)             (umhos/cm)                               Water
 7/26/95    249        121        77.6      0.04        0.21      77.6        <1      10.5       1950        7.0    10.2     86.37      6.58     79.79
  8/9/95    294        119        71.0      0.04        0.24      71.0        <1      11.0       1894        7.2    6.40     86.37      7.02     79.35
Manure     Added        To      Lagoons       In       August     1995
 8/23/95    257        120        74.0       0.10       0.19      73.9       <1       13.0       1816        7.4    5.00     86.37      7.60      78.77
10/10/95    263        118        78.2       0.06      <0.01      78.1       <1       14.0       1886         6.9   4.92     86.37      5.99      80.38
 1/17/96    247        113        80.5       0.01      <0.01      80.5       <1        5.0       1769         7.0   2.80     86.37      6.51      79.86
 4/26/96    238        120        86.0       0.01      <0.01      86.0       <1        5.1       1910         7.1   2.40     86.37      6.15      80.22
 7/26/96    230        114        84.4       0.04      <0.01      84.4       <1       11.5       1843         7.3   0.90     86.37      7.03      79.34
 10/2/96    237        116        78.0      <0.01      <0.01      78.0       <1       11.5       3355        7.0    2.09     86.37      7.43      78.94
 4/23/97    194        112        71.2       0.23       0.09      71.0       14       8.7        3600        7.10    *
 7/31/97    235         94        55.1       0.07      <0.01      55.0       170      10.4       1770        6.97    *
 10/6/97    216        96.4       56.5       0.26      <0.01      56.2       <1       12.2       3110        7.10     *
  2/4/98    192        104        54.6       0.02      <0.01      54.6       <1        6.3       2110        6.87     *
  5/1/98     96        123        100       0.01       <0.08       100       <1        9.0       1961        7.50    *
 7/30/98    182         91        35.5       0.08      <0.01      35.4       <1       14.0       1662        7.90     *
10/28/98    195        95.9       38.0         *        0.18        *        <1       11.6       1711        6.83    *
 1/28/99    190        108        33.1         *        0.12        *        <1        5.9       1608        7.60    *
 4/28/99    149        104        26.7         *       <0.08        *        <1        8.1       1586        7.07    *
 7/19/99    134        103        23.6         *       <0.01        *        <1       12.7       1535        7.19    *
10/11/99    119        107        14.2         *       <0.01        *        <1       12.0       1473        6.97    *
  1/5/00    145        122        12.8         *       <0.01        *        <1        6.3       1554        6.96    *
 4/26/00    125        137        22.4         *       <0.02        *        <1        8.5       1623        7.25    *
 7/24/00    133        149        16.4         *       <0.02        *        <10      10.5       1640        7.05    *
10/18/00    128        163        15.5         *       <0.02        *        <1       11.8       1681        7.07    *
                                                   Table 9 (continued)
                                    Farm 4/BGF – Water Quality Data, Monitoring Well #3
                                           Section 31, Emmet Township, Renville County, Minnesota

Sampling   Sulfate   Chloride   Nitrate+    Nitrite   Ammonia    Nitrate     Fecal    Temp.     Temp.        pH     DO     Measuring   Depth    Ground
                                                                                       o
  Date     (ppm)      (ppm)     Nitrite     (ppm)     Nitrogen   (ppm)     Coliform      C     Corrected                     Point       To      Water
                                (ppm)                  (ppm)               (CFU/100           Conductivity                 Elevation   Ground   Elevation
                                                                              ml)             (umhos/cm)                               Water
 7/26/95    105        131        136        0.08       0.04      136         <1      10.0       2060        6.8    7.50     94.92      16.30     78.62
  8/9/95    113        133        127       <0.01       0.02       127        <1      10.0       2074        6.6    5.85     94.92      17.03     77.89
Manure     Added        To      Lagoons       In       August     1995
 8/23/95    115        134        124       0.03       <0.01       124       <1       11.5       1886        6.8    5.05     94.92     17.56     77.36
10/10/95    100        121        120       <0.01      <0.01       120       <1       12.0       1934        7.3    6.69     94.92     12.74     82.18
 1/17/96    120        116        114       <0.01       0.04       114       <1        6.5       1894        7.0    3.20     94.92     17.33     77.59
 4/26/96    111        147        143       0.01       <0.01       143       <1        6.7       2055        7.1    3.07     94.92     17.96     76.96
 7/26/96    109        135        131       0.01        0.03      131        <1       9.0        1940        7.5    3.10     94.92     17.50     77.42
 10/2/96     95        130        128       <0.01      <0.01       128       <1        8.5       3655        7.2    4.61     94.92     19.19     75.73
 4/23/97     85        133        127       <0.01      <0.01       127       <1        8.8       2940        7.30     *
 7/31/97     98        113        116       0.01       <0.01      116        <1       11.1       3110        7.19     *
 10/6/97    216        95.4        57        0.11      <0.01      56.9       <1       12.4       4200        7.23     *
  2/4/98     84        130        128        0.17       0.02      128        <1        6.7       1873        6.91     *
  5/1/98     99        116        96.5      <0.01       0.23      96.5       <1        9.8       1960        7.30     *
 7/30/98     93        97.0       98.2       0.03      <0.01      98.2       <1       13.0       1985        6.93     *
10/28/98     89        115        110          *        0.18        *        <1       10.9       2070        6.75     *
 1/28/99     99        113        106          *       <0.08        *        <1        6.0       1978        7.40     *
 4/28/99     94        83.5       71.2         *       <0.08        *        <1        9.0       1707        6.82     *
 7/19/99     95        59.5       63.2         *       <0.01        *        <1       11.3       1349        7.20     *
10/11/99     86        95.9       95.2         *       <0.01        *        <1       10.2       1787        6.82     *
  1/5/00    NA         NA         NA         NA         NA         NA        NA       NA          NA         NA     NA
 4/26/00    NA         NA         NA         NA         NA         NA        NA       NA          NA         NA     NA
 7/24/00    NA         NA         NA         NA         NA         NA        NA       NA          NA         NA     NA
10/18/00    NA         NA         NA         NA         NA         NA        NA       NA          NA         NA     NA
                                                    Table 9 (continued)
                                     Farm 4/BGF – Water Quality Data, Monitoring Well #4
                                           Section 31, Emmet Township, Renville County, Minnesota
Sampling   Sulfate   Chloride   Nitrate+      Nitrite   Ammonia    Nitrate     Fecal    Temp.      Temp.         pH    DO       Measuring   Depth    Ground
                                                                                         o
  Date     (ppm)      (ppm)     Nitrite       (ppm)     Nitrogen   (ppm)     Coliform      C      Corrected                       Point       To      Water
                                (ppm)                    (ppm)               (CFU/100            Conductivity                   Elevation   Ground   Elevation
                                                                                ml)              (umhos/cm)                                 Water
 7/26/95    108        135        140          0.03       0.04      140         <1       10.5       2047         6.9   11.6      102.70      9.97     92.73
  8/9/95    118        128        122          0.04       0.24      122         <1       10.5       1971         6.6   7.25      102.70      10.73    91.97
Manure     Added        To      Lagoons         In       August     1995
 8/23/95    137        132        124         0.09       <0.01       124       <1        12.0        1993        6.7   7.30      102.70     11.61     91.09
10/10/95    106        122        103         0.24        0.01      103        <1        11.0        1976       11.0   6.43      102.70     12.41     90.29
 1/17/96    102        116        112         <0.01       0.01      112        <1         7.5        1802        6.9   4.20      102.70     12.86     89.84
 4/26/96    416        118        109         <0.01       0.02      109        <1         6.8        1949        7.0   2.39      102.70     14.22     88.48
 7/26/96    108        133        126         0.01        0.04      126        <1         6.8        2000       7.4    5.95      102.70     11.17     91.53
 10/2/96    103        126        114         <0.01      <0.01       114        3         8.5        3435        7.0   7.00      102.70     14.23     88.47
 4/23/97     93        121        111         <0.01       0.02      111        <1         8.6        3160       7.10     *
 7/31/97    107        107        110         0.25       <0.01      110        <1        10.5        1886       7.20     *
 10/6/97     96        122        110         0.58       <0.01      109        <1        12.6        3480       7.14     *
  2/4/98     92        126        109          0.28       0.01      109        <1         6.5        2400       6.98     *
  5/1/98    177        94.3       48.6         0.03      <0.08      48.6       <1         8.4        1616       7.20     *
 7/30/98     95        121        107         <0.01      <0.01       107       <1        12.0        2000       6.80     *
10/28/98     96        121        109            *        0.03        *        <1        10.4        2060       6.62     *
 1/28/99    103        128        114            *       <0.08        *        <1         8.0        2000       7.50     *
 4/28/99     89        122        43.9           *       <0.08        *        <1         8.6        1988       6.81     *
 7/19/99     98        118        113            *       <0.01        *        <1        11.0        1914       7.07     *
10/11/99     96        113        112            *       <0.01        *        <1        10.6        1925       6.81     *
  1/5/00    104        127        91.7           *        0.01        *        <1         7.5        1940       6.81     *
 4/26/00     90        132        105            *       <0.02        *        <1         9.7        1942       7.06     *
 7/24/00     96        126        108            *        0.05        *        <10        9.5        1880       6.89     *
10/18/00     98        124        106            *       <0.02        *        <1        10.8        1756       6.86     *



   * Sample not analyzed for this parameter                 ppm = parts per million or milligrams per liter (mg/L)
   NA = No data available                                   DO = dissolved oxygen
   NS = No sample collected on this date                    Data sources: Baumgartner, 1998, 1999, 2000, 2001; and ESC, 1997d
                                                           Table 10
                                       Farm 4/BGF – Water Quality Data, Perimeter Tile Line
                                           Section 31, Emmet Township, Renville County, Minnesota
Sampling      Sampling    Sulfate    Chloride    Nitrate+     Nitrite    Ammonia       Nitrate      Fecal            Total     Temp.     Temp.        pH    DO
                                                                                                                                o
Location        Date      (ppm)       (ppm)      Nitrite      (ppm)      Nitrogen      (ppm)      Coliform       Phosphorous      C     Corrected
                                                 (ppm)                    (ppm)                   (CFU/100          (ppm)              Conductivity
                                                                                                     ml)                               (umhos/cm)
 Tile 1        10/10/95      147         93.9         59.0        0.02       <0.01         59.0      <1               <0.08    14.0         6a        7.2   10.1
                1/17/96      NA          NA            NA         NA          NA           NA        NA                NA      NA          NA         NA    NA
                4/26/96      156         116          85.1       <0.01        0.02         85.1      <1                0.58     6.6        905        7.2   11.4
                7/26/96      179         113          91.0       <0.01       <0.01         91.0      <1                0.64    10.0       1,766       7.5    5.4
                10/2/96      173         96.1         62.5       <0.01       <0.01         62.5      <1                0.15    10.0       1,544       8.0   10.8
                4/23/97      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                7/31/97      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                10/6/97      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                 2/5/98      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                 5/1/98      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                7/30/98      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                8/25/98      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                9/23/98      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
               10/28/98      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                1/28/99      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                4/28/99      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                7/19/99      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
               10/11/99      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                 1/5/00      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                4/26/00      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
                7/24/00      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
               10/18/00      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS    NS
a ESC report suggests this was a possible field recording error
NA = No data available                                 DO = dissolved oxygen
NS = No sample collected on this date                  Data sources: ESC, 1997d (Table 2) and Baumgartner, 2000 (Table 5.0)
                                                     Table 10 (continued)
                                       Farm 4/BGF – Water Quality Data, Perimeter Tile Line
                                           Section 31, Emmet Township, Renville County, Minnesota
Sampling      Sampling    Sulfate    Chloride    Nitrate+     Nitrite    Ammonia       Nitrate      Fecal            Total     Temp.     Temp.        pH     DO
                                                                                                                                o
Location        Date      (ppm)       (ppm)      Nitrite      (ppm)      Nitrogen      (ppm)      Coliform       Phosphorous      C     Corrected
                                                 (ppm)                    (ppm)                   (CFU/100          (ppm)              Conductivity
                                                                                                     ml)                               (umhos/cm)
 Tile 2        10/10/95      207         99.0         74.0       <0.01       <0.01         74.0      <1               <0.08    14.0         7a        7.1    9.67
                1/17/96      NA          NA            NA         NA          NA           NA        NA                NA      NA          NA         NA     NA
                4/26/96      241         86.5         30.8        0.02       <0.01         30.8      <1                <0.1     7.0        797         7.1   11.1
                7/26/96      224         93.7         31.5        0.09       <0.01         31.4      <1                <0.1    12.5       1616         7.0   3.20
                10/2/96      162         106          22.1        0.14        0.09         22.0      100               1.71    9.0        3036        7.5    9.80
                4/23/97      NA          NA            NA         NA          NA           NA        <1                NA      NA          NA         NA     NA
                7/31/97       43         34.8         22.6        0.04         0.1         22.6      10                NA      13.1       1775        7.72   NA
                10/6/97      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS     NS
                 2/5/98      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS     NS
                 5/1/98      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS     NS
                7/30/98      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS     NS
                8/25/98      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS     NS
                9/23/98      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS     NS
               10/28/98      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS     NS
                1/28/99      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS     NS
                4/28/99       39         37.1         13.9        NA         <0.08         NA         12               2.18     7.2       911         7.40   NA
                7/19/99       37         33.6         27.7        NA         <0.01         NA          3               0.14    15.4        908        7.59   NA
               10/11/99      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS     NS
                 1/5/00      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS     NS
                4/26/00       57         31.1         26.9        NA         <0.02         NA         1                <0.2    10.2       1108        7.92   NA
                7/24/00      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS     NS
               10/18/00      NS          NS            NS         NS          NS           NS        NS                NS      NS          NS         NS     NS
a ESC report suggests this was a possible field recording error
NA = No data available                                 DO = dissolved oxygen
NS = No sample collected on this date                  Data sources: ESC, 1997d (Table 2) and Baumgartner, 2000 (Table 5.0)
Appendix C – Citizen Complaints Regarding Feedlots




                       71
                                         Complaints

What complaints can tell us

If good records are being kept, and all complaints are being logged into one well-organized
system, complaint logs can be helpful. Complaint logs can indicate what the complainant called
about, the physical symptoms the caller is complaining about, and other circumstances that may
be contributing to the complaint (i.e. whether there was a spill associated with the complaint or
whether the complaint was generated because of odors, etc.). Complaint logs may also provide
dates of complaints and can provide information to look at trends over time.

Of the 17 Duty Officer Reports that MDH requested, six of those complaints were reported by
one individual, while 4 of the remaining complaints were filed by a second individual. The
remaining complaints were from a variety of entities or the complainant was unnamed in the
report.

According to Minnesota’s Generic Environmental Impact Statement (GEIS) for Animal
Agriculture, odor was the cause of most of the MPCA complaint records and odor complaints are
an excellent indicator of feedlot/land use conflicts (MN EQB, 2002).

Often the trigger to a complaint can be a phone number that has been newly published and the
perception that action will result from the complaint. Complaints in Minnesota may be handled
by different programs in local government, state government and/or the Minnesota Duty Officer.
Once a person has a phone number to call, they will tend to continue to use that number, so the
logs are not necessarily indicative of the magnitude of the problem. In addition, some
individuals may not want to complain because they are afraid that they will experience
retribution at a later date or that their complaint will do no good. Others may repeatedly
complain to enhance the record (increase the total number of complaints against a person or a
facility).

The complaints about odors emanating from swine feedlots do not provide the entire picture as to
the extent a facility may be affecting the quality of life for nearby residents. Eric VanDyken, an
environmental officer with Renville County, has provided his log of complaints to the MDH.
The 204 complaints about the ValAdCo facility recorded by Mr. VanDyken and his colleagues
include:

        Year                  Complaints                   Year                 Complaints
1995                     96                         1999                   15
1996                     25                         2000                   No record available
1997                     No record available        2001                   41
1998                     12                         2001                   15

Mr. VanDyken notes that most of the complaints were in regards to sections 27 and 29 of
Norfolk Township. No records were available in the year 2000 due to staff turnover. In 2001, it
was publicized that a new “odor hotline” was available at Renville County and Mr. VanDyken’s
personal extension provided to citizens to handle odor complaints. Mr. VanDyken relayed his
belief that complaints died out when citizens who called were not seeing “action” or “results”



                                               72
based on their complaints. In turn, Mr. VanDyken relayed complaints to the Minnesota
Pollution Control Agency (MPCA) staff located in the Willmar office. MPCA did not log the
complaints from the County. To log a complaint with the MPCA, the citizen needed to directly
contact MPCA.

In comparison, the Renville County Public Health Complaints Log has 34 swine or hog-related
calls in the past 10 years.

        Year                 Complaints                Year                 Complaints
1993                    1                      1998                    1
1994                    0                      1999                    1
1995                    0                      2000                    8
1996                    4                      2001                    0
1997                    18                     2002                    1

In addition to complaints about hog odor to Renville County Public Health, the complaints above
included private citizens detecting H2S with a monitor on their own property, manure spills and
high nitrates in drinking water after a manure spill, dead pigs and disposal issues, headaches,
nausea and other health effects.

MDH’s request to the MPCA for the official complaint log yielded only 6 incidents in Renville
County that were attributed to sites near ValAdCo in Renville County. Five complaints
specifically cited the ValAdCo facility (incident IDs 10579, 16959, 8122, 8120, and 8107). One
complaint came from a citizen complaining about ValAdCo and the Sugar Beet Cooperative.
This is in contrast to complaints in Renville County as noted in the GEIS: 167 of the total 912
complaints (18%) about odors from feedlot operations in Minnesota counties reported to the
MPCA between June 1996 and September 2000. Three counties (Renville, Nicollet and Carver)
accounted for nearly 46% percent of the total complaints.

Formal complaints to MPCA staff about ValAdCo:
     2000           4
     2001           1
     2002           1

It is important to note that between 9/25/96 and 6/18/98, various MPCA staff logged 35
complaints about ValAdCo owned facilities. These complaints were never added to the official
complaint log.

The Minnesota Duty Officer also keeps records of releases and spills into the environment. The
Minnesota Duty Officer reports the following complaints were received about the ValAdCo
facilities in 2000 and 2001.
Year Complaints
         2000           12
         2001            5




                                             73
Appendix D – Comments Received from Other Agencies




                     74
The original draft of the Public Health Assessment report was mailed in early April, 2003 to the
following agencies for review and comment: Minnesota Pollution Control Agency, Minnesota
Department of Natural Resources, Minnesota Department of Agriculture, Minnesota Attorney
General’s Office, Renville County Public Health. Comments were received only from the
MPCA. Those comments, and the MDH response, are included below.


Comments received from the Minnesota Pollution Control Agency:

1) On page 4 in the Executive Summary it states in the last sentence of the 3rd paragraph that
"The air emissions from the ValAdCo facilities represent a public health risk." Actually, there is
sufficient data to indicate that this is the case at F2/NF only.
Response: Accepted. The text has been amended to be consistent with the conclusion section,
which notes that a public health risk is present at F2/NF, and that the public health risk at the
other facilities is indeterminent at this time due to lack of information, but a public health risk
may be present at these other facilities.

2) On page 6 in the Background and History section a summary is provided on animal numbers
and manure storage capacity. We have different information from the report for a number of the
facilities. For F2/BGF we have 2316 gilts, 480 sows, and 130 boars, while for F3 we have 5760
nursery pigs, 480 sows, 2116 gilts, 130 boars, and for F4/BGF sows 480, 2116 gestating sows,
and 130 boars.
Response: Accepted. The text has been amended to reflect these numbers and to indicate the
source of information for animal numbers at the facilities. The discrepancy in numbers, in most
cases, was the result of ValAdCo documents not differentiating between gilts and sows. There
was also a typographic error in the original Health Assessment document (760 nursery pigs,
rather than 5,760 nursery pigs at F3).

3) On page 7 the 3rd sentence indicates "....lagoons will be converted to wetlands." This is not
accurate as the use of these lagoons have not been determined.
Response: Accepted. This language has been removed.

4) On page 9 in the 1st paragraph it indicates that violations have accrued despite efforts to
control air emissions covers and ozonation. It should also be acknowledged that as a result of
these violations it was determined that the ozone system was not working according to design
parameters.
Response: Accepted. A sentence was added to indicate that the system was not working
according to design parameters.

5) On page 9 in the first paragraph in the section on Waste Storage it should indicate that manure
basins were all covered by impermeable covers by ValAdCo at some point to address air quality
issues.
Response: Accepted. This has been added to the paragraph, but also with a note that no data has
been presented to indicate the effectiveness of the covers in addressing the air quality issues.

6) On page 61 in the Recommendations section in #4 it states that if MAAQS can not be met
then the number of animals should be reduced to achieve compliance. Please be advised that as



                                               75
regulator we are obligated to consider all proposals made to address noncompliance and not be
restricted to any one course of action, i.e., reducing animal numbers.
Response: Accepted. The recommendation has been divided into two parts. The first indicates
that the MPCA should ensure that the facilities comply with the MAAQS. The second indicates
that compliance with the MAAQS may be achieved by a variety of means, including reducing
the number of animals at the facility.




                                             76
Appendix E – Comments Received from the Public




                Public Comments




                   77
Background:

The public comment period opened on August 1, 2003 when the first copies of the report were
mailed to interested parties. The comment period was extended to October 3 at the request of
several commentors and because media coverage generated additional interest in the report.

MDH received comments from one environmental organization, one business, and 13 members
of the public (10 living near the ValAdCo facilities, and 3 from elsewhere in the state). In some
cases, the comments have been summarized and compiled to avoid duplication. Where possible,
the exact language of the comments was preserved and the identity of the commentor was
concealed. The comments are presented in italics and are organized into two categories: general
comments relating to larger issues raised by the report and specific comments regarding the
recommendations made in the report. Sources cited in the course of responding to the comments
are listed at the end of this appendix.


General Comments:

Commentor #1 – “[The commentor]generally supports the recommendations in the Public
Health Assessment (PHA). Staff seem to evaluate carefully and thoroughly the potential for air,
surface water and ground water contamination posed by the facilities. However, since many of
these impacts could not be quantified or clearly determined due to a lack of data and failure to
enforce proper management practices under the previous owners, [the commentor] is concerned
that the recommendations of the PHA may be meaningless without strict enforcement and
accountability by the Minnesota Pollution Control Agency when the new owner and management
takes over. For example, if the slipshod record-keeping of land application practices and total
non-compliance with manure BMPs continues, it is likely that health problems and risks will
continue.

[The commentor] substantially supports the recommendations of the PHA. We feel that given the
seriousness of the past violations, the paucity of good documentation, the inability to correctly
implement even basic BMPs and the record of previous ownership and management behaving as
“bad actors” the utmost care should be given to monitoring and enforcing these new
recommendations.

In the past, local residents have felt angry and betrayed by the owners and operators of this
facility as well as different government officials – partly because their concerns and evidence
about pollution and health impacts were disregarded or impugned and partly because once the
veracity of their concerns was established, the process of remedying the problem was slow and
viewed as unjustly favoring the business interests of the owners and operators of the facility. The
tensions over this battle were serious enough to cause hard feelings in local communities.

Care should be taken to seize the opportunity we have in both the PHA and the change in
ownership to reverse this situation and make a “clean start.” Quality data must be gathered,
records carefully kept, any violations quickly remedied and -- if that doesn’t happen – applicable
penalties should be enforced.”



                                               78
MDH Response: MDH agrees that careful monitoring of the facilities be conducted to ensure
that air emissions are reduced, air quality standards are met, and groundwater and surface water
are not harmed by activities at the facilities. Part of the on-going public health plan for the
facilities will be continued MDH review of air and water quality data to ensure that proper
monitoring is occurring and that applicable standards are being met.


2. Requests for Additional Assessments At Other Facilities:
Several commentors, from areas not located near the ValAdCo facilities, questioned why Public
Health Assessments are not being completed for other feedlots around the state. They reported
health concerns for themselves, family members, and neighbors that are consistent with the
symptoms of hydrogen sulfide poisoning, and requested that air quality monitoring be conducted
at hog confinement feeding facilities near Northfield and Young America.

MDH Response: The ValAdCo Public Health Assessment was completed in response to a citizen
petition to the Agency for Toxic Substances and Disease Registry (ATSDR). MDH does not
have resources to conduct similar scale investigations at all of the facilities where residents have
reported health concerns, and has no resources for gathering independent data (i.e. installing air
monitoring systems). Complaints, including those received in the public comments, are sent to
the Minnesota Pollution Control Agency, which has the responsibility and resources for
monitoring feedlot facilities and enforcing compliance with air and water quality standards.
MDH will recommend to the MPCA that they conduct ambient air monitoring for hydrogen
sulfide at the two feedlots identified by the commentors, and any others where complaints are
received. MDH will further recommend to MPCA that they consider monitoring for hydrogen
sulfide emissions at any new or expanding feedlots where a permit is required.


3. Request for a Health Study:
One commentor specifically requested that a study be done on the sickness and deaths around
the ValAdCo sites in Norfolk Township.

MDH Response: The commentor appears to be requesting a quantitative study of sickness and
deaths, in contrast to the more qualitative assessment performed for this report. Unfortunately,
to objectively study health impacts around any swine feeding operation, there must be a
sufficiently large population to produce statistically significant results. Where only a small
population is present, it would be impossible to distinguish types and rates of illnesses within the
local population from the expected background levels of disease and death. In addition, because
the exposures, and many of the symptoms, are transient, developing meaningful measurements is
difficult, if not impossible. No statistical analysis of illness related to feedlots has been
completed anywhere, to our knowledge. This doesn’t mean that exposures and health effects are
not real.

Because of these difficulties, MDH has taken the approach that it is more important to prevent
the exposures than to prove the exposure has caused a particular person’s illness or symptom.
Monitoring the H2S levels and ensuring that they do not exceed the MAAQS is a precautionary
approach to protecting public health. For that reason, MDH recommended that monitoring occur



                                                79
at all of the former ValAdCo facilities.


4. Health concerns:
Many residents living near the ValAdCo facilities cited health concerns they associate with their
proximity to the facilities:

   “…odor and gasses emitted from these hog sites causes medial symptoms such as with the
   respiratory system, headaches, nausea, etc….”

   “…I started to notice that when I had to work in the smell, it would give me a
   headache….Then I started getting sore throats…soon I was going to the doctor for coughs
   and what I thought was some form of bronchitis. At one time the doctor even had me on
   inhalers. The strange thing…is that whenever I got out of this area, away from these hog
   sites, I would get well…When I spent time in the ValAdCo environment, I got sick. When I
   got out of it, I got well. Not once or twice, but over and over again and again.”

   “The part that scared me was that our kids were also living in it…they also got sore throats
   and the tired, achy feeling that myself and my wife were experiencing.”

   “My dad who lives close by has dizzy spells. He never had them before this all came along.”

MDH Response: These symptoms are consistent with hydrogen sulfide exposure. If the
occurrences were isolated, it would be difficult to associate them with any particular cause or
source. But the fact that they were pervasive, and dependent upon being near the facilities,
strongly suggests a connection with the air emissions from the facilities. What has been difficult
to sort out is the actual mechanism by which exposure to emissions from swine operations makes
people ill. Wing and Wolf (1999) reported that unpleasant odors can affect well-being by
“…eliciting unpleasant sensations, triggering possible harmful reflexes, modifying olfactory
function and other physiological reactions.” They also reported that annoyance and depression
can result from exposure to unpleasant odors along with nausea, vomiting, headache, shallow
breathing, coughing, sleep disturbances, and loss of appetite, symptoms akin to those reported by
the U.S. Public Health Service (1964) upon an investigation in Terre Haute Indiana.


5. Loss of quality of life:
Many residents living near the ValAdCo facilities cited health concerns they associate with lost
quality of life associated with the facilities:

   “I often times feel like a prisoner in my own home…These hog sites definitely have interfered
   with the enjoyment of our life and property.”

   “When we planned for our children’s graduations, we always had to have an alternate
   location to go to if the air was offensive here at our home.”

   “We couldn’t count the number of times we have awakened in the middle of the night by the
   stench coming from the lagoon, often times causing headaches, but always the loss of a good




                                              80
   night’s rest. We have learned to keep the windows closed. The lagoon has controlled our
   life; when we can open windows, when we can enjoy the yard, when we can get outdoor
   exercise. Cookouts just don’t happen here. It is a type of prison…”

MDH Response: It is not within the scope of the authority of MDH to address quality of life
issues. However, there are studies that show that the stress associated with these issues may
augment experienced health symptoms. Susan S. Schiffman and her colleagues (Schiffman, et.
al., 1995) at Duke University Medical Center conclude that odors from swine operations have a
significant negative impact on mood of nearby residents. Persons living near the intensive swine
operations who experienced the odors reported significantly more tension, more depression,
more anger, less vigor, more fatigue, and more confusion than control subjects as measured by
the Profile of Mood States questionnaire.

6. Impacts to livelihoods:
Two residents raised concerns about the impact of the odors on their businesses:

   “I’ve had a mechanic leave my farm because the smell got so bad, only to come back at
   10:30 p.m. and work on my tractor till 2 a.m. because the wind had shifted. I’ve had field
   workers get sick and were O.K. after I took them to a different field out of the smell.”

   Another commentor, in a follow-up telephone conversation, related that they had closed their
   business near the facilities and moved away, because customers did not want to come to the
   shop due to the odors.

MDH Response: It is not in the scope of the authority of MDH to address these issues.
However, we felt it was important to include them as part of the record of residents’ concerns.


7. Loss of property value:
Several commentors described the affect they believe the facilities have had on their property
value.

   “This hog setup has taken a lot of the value of our farm site away. Who would want to live
   here?”

MDH Response: It is not in the scope of the authority of MDH to address these issues.
However, we felt it was important to include them as part of the record of residents’ concerns.


8. Frustration with state agencies:
Nearly every resident expressed extreme frustration with the length of time for the issues at the
facilities to be addressed:

   “The law for hydrogen sulfide was broken over and over but they continued to operate till
   they sold their business. Why do we pay taxes to organizations like MPCA. They didn’t do
   their job.”




                                               81
   “We’ve asked for help for the past 9-10 years. Everything we told you for years is now in
   your booklet in black and white.”

   “We just want clean water, fresh air, and a healthy place to live. You have all the proof you
   need in your publication. Don’t make us have to go through more of the same for years to
   come.”

   “…we hope for it to improve – but 11 years to this point – and we get a report. When will
   the action come???…Our question is – how are you going to insure that this situation will
   improve with the new owners. We certainly hope that you have more authority than to spend
   another 11 years making yet another assessment.”

   “It is bad enough to live there but to have the “do nothings” for ten years just cash their
   govt [sic] checks and also be part of the problem…it is too much to smell or swallow!”

MDH Response: On February 2, 1996, the MDH issued an assessment that hydrogen sulfide
emissions at the Norfolk facilities were above regulatory standards and at levels of concern;
MDH urged the MPCA to address the problems. MPCA staff worked with ValAdCo to
implement a variety of fixes, but as the air monitoring data demonstrate, these were not effective
in reducing hydrogen sulfide emissions to acceptable levels. MDH continued to urge that
actions be taken to address the problems. When we were asked by ATSDR to conduct the site
investigations following their acceptance of a citizen petition, we did so as quickly as possible.
The Minnesota Attorney General’s office also worked to enforce ValAdCo’s compliance with air
quality standards. While no documentation is yet available, we understand from several
residents, that the changes in waste storage that occurred this year under new ownership by
Christensen Family, LLC has resulted in improved air quality, at least in terms of odor levels.

Does this mean that the problems were addressed as quickly as they should have been? No.
Failure to meet the air quality standards should have been dealt with more quickly and
effectively.

In some cases, state agencies were unable to impose penalties sufficient to achieve compliance
because of lack of clear legal authority to do so. For example, the worst odor (and likely
hydrogen sulfide) events often occurred during times when state law “suspends” the enforcement
of the standards for feedlots (land application and draining of lagoons).

A lot of lessons were learned at the ValAdCo facilities, that should be applied both under the
new ownership and statewide, but that must be small comfort to those families who lived near
the facilities during the worst periods of operation.


9. Skepticism regarding change:
Several of the commentors expressed doubts that change will occur at the facilities:

   “The information you sent us tells it all. It proves we were right with our concerns from the
   start, but the Tisdell site will still have a lagoon with the new owners, and there are as many
   hogs in those barns as there were when ValAdCo had it. So, how long until we really see



                                               82
   someone step in and take control?”

   “Having read the ValAdCo Public Health Assessment…which to me was a reiteration of the
   complaints of the last 10 years I wonder what, if anything, is going to be done other than a
   sequel.”

MDH Response: This skepticism is understandable. However, several residents have indicated
that they have noted improvements in the air quality, or at least odor, near the facilities now that
they are under new ownership. Monitoring wells have been required by the MPCA at Crooks
Township, section 29 facility. MDH will continue to review air and water quality data from the
facilities to ensure that the changes in waste storage and management have resulted in promised
improvements, and that the facilities are in compliance with state and federal laws.


10. General ground water concerns: Several commentors rejected the report’s assessment that
the ground water has not been seriously impacted. Commentor #5 stated: “We do not use any
water from our well for cooking or drinking.” Commentor #10 stated: “Drink the water south of
the sites at the neighbor or their neighbor. I know a neighbor [there who will not take] a bath.
The ground water is a hazard; but not according to the report.” Commentor #12 stated: “My
groundwater level is low since ValAdCo built by me. Also polluted my well water. Had very
good water before.” Commentor #8 stated: “You’ve already said they’re [the lagoons] are
leaking, so close the lagoons at all sites and be done with it, once the water is contaminated its
too late.”

MDH Response: In part, these concerns may be addressed by the waste storage upgrades being
implemented by Christensen Family, LLC. The primary lagoons have been replaced with
concrete lined lagoons that should limit any leakage. The proof of this, however, remains to be
seen from groundwater monitoring data, which MDH intends to continue to review as part of
their public health action plan for the facilities.

The groundwater monitoring did show elevated levels of some inorganic compounds, most
notably chloride, downgradient of the lagoons. This indicates that some leakage from the
lagoons is occurring. However, it is important to reiterate that elevated levels of contaminants
which might cause health concerns, such as ammonia, nitrate, and bacteria, were not detected in
any of the monitoring wells. At the facilities where monitoring wells were present, the
monitoring wells appear to be located appropriately to detect the presence of such contaminants.
In addition, the shallow groundwater (less than 30 feet) is not used in this area as a drinking
water source and the ground water, generally discharges to drainage ditches and creeks.

To be sure private wells near the Norfolk facility were not being contaminated, the wells were
sampled by MDH for bacteria, including the wells of some of the commentors. Some wells were
found to contain coliform bacteria, which are ubiquitous in the environment, but none were
found to contain fecal coliform bacteria, which would indicate contamination by a human or
animal waste source.

There is no evidence to indicate that neighboring wells have been contaminated by the facilities.
However, the presence of the rising chloride concentrations in the groundwater downgradient of



                                                83
the lagoons does warrant continued monitoring to ensure that contaminants that could cause
health effects are not being discharged to the environment.

We do not have any information regarding the possibility that water withdrawal by the facilities
may have affected water levels in nearby wells, and therefore cannot comment on this
possibility. Such concerns should be reported to the Department of Natural Resources, Waters
Division, which has the permitting authority for water withdrawals. They can be contacted at:
651-296-4800.


11. Air quality improvements: Commentor #12 noted that air quality appears to have improved
this year, since Christensen Farms took over ownership of the facilities.

MDH Response: Informal conversations with other residents have indicated similar experiences
that the odor levels are not as severe as before. Continued air quality monitoring should help to
verify whether the actual hydrogen sulfide concentrations have been reduced.


12. General comments regarding Flora Township: Commentor #13 noted that the smell is “not
very bad” and smells it “about twice a year”, but “…when I drive around the section, depending
on wind, the H2S can be much worse than at my residence.” This commentor also raised
concerns about aquifer levels and about the potential for a spill from the lagoons at the Flora 5
and Flora 7 facilities to reach Sacred Heart Creek before anything could be done to contain the
release.

MDH Response: MDH shares the concern regarding the proximity of the Flora township
facilities lagoons to Ditch 45 (which drains into Sacred Heart Creek), particularly the
Commercial Nursery facility in section 7 where the site slopes directly to the ditch.


13. Objections to the hydrogen sulfide standards: Commentor #14 (who does not live in the
Renville area) raised numerous objections to the report, related mainly to the hydrogen sulfide
standards. These objections included:

a. MDH’s use of the MAAQS for hydrogen sulfide, rather than federal OSHA standards which
   allow concentrations up to 10,000 ppb in the workplace. The commentor claims that there is
   no scientific basis for the MAAQS and that development of the standard allowed for too
   large an uncertainty factor. The commentor refers to, but does not cite, a study in which no
   ill effects were noted in healthy people at 10,000 ppb.

MDH Response: Worker safety standards differ from the safety standards for the general public
because worker standards protect healthy working individuals from the intermittent exposures
normally found in the workplace. Further, workplace standards are generally at or near health
effects levels with no margin of safety. More sensitive segments of the population such as the
young and the old, who are not typically found in the workforce, and individuals with a pre-
existing health condition or disease, are not protected by workplace standards. In addition,
typical occupational exposures occur on an eight to ten hours per day, five days a week schedule.



                                               84
These intermittent exposures allow time for elimination of chemicals from the body. Because
the exposure of the general population to chemicals in ambient air may be continuous, there are
no recovery periods for the exposed individual. For these reasons, MDH developed Health Risk
Values (HRVs), which protect the general population, including sensitive sub-populations. For
workers covered under OSHA, the MN OSHA workplace standards apply.

Minnesota’s HRV for hydrogen sulfide is based on an Environmental Protection Agency (EPA)
Integrated Risk Information System (IRIS) value for hydrogen sulfide. The chronic IRIS value
for hydrogen sulfide is from a published peer reviewed study by the Chemical Industry Institute
of Toxicology (CIIT, 1983). This is toxicologically derived data demonstrating inflammation of
the nasal mucosa as the critical endpoint. Odors are not considered to be a critical endpoint for
the HRV process.

For HRV rule-making, a technical advisory group was assembled with representation from
industry, consulting, environmental advocacy groups, public health organizations, academia,
state agencies and local governments. MDH followed all procedures necessary and required by
the State of Minnesota for adopting the HRVs. MDH did so under statutory authority to adopt
rules, set forth in Minnesota Statutes, section 144.12, subd. 1, item 14. The standards adopted
are similar to those used by California, Missouri, Montana, Nevada, New Mexico, and New
York. They are also similar to the interim level 1 Acute Exposure Guideline Levels for
hydrogen sulfide developed by the EPA.

The commentor is correct that an uncertainty factor was used in developing the HRV, but does
not support his claim that it amounts to “10,000 percent”. Uncertainty factors are intended to
provide a margin of safety and account for: variations in the sensitivity of individuals within the
human population; extrapolation of animal data to estimated human health effects; extrapolation
from data obtained in a study that is of less than lifetime exposure; incomplete data, particularly
with regard to reproductive and developmental toxicity; and using the lowest observable adverse
effect level (LOAEL) data rather than the no observed adverse effect level data (NOAEL). The
MDH uses the same process of assigning uncertainty factors to a chemical profile as does the
EPA.

The commentor does not specify the source of his information regarding human health effects to
hydrogen sulfide, but it is not supported by recent studies that indicate workplace exposures
result in physiological responses at concentrations less than the OSHA regulatory standards
(Ammann, 1986; Bhambahani et. al., 1991, 1994, 1996a, and 1996b; Zang, 1999).

b. Concern that the MDH hydrogen sulfide emission limits “…were specifically not created for
   the purpose of being used as MPCA’s H2S limit for law enforcement purposes.”

MDH Response: The MAAQS are enforceable limits in MPCA rules and were used
appropriately, in conjunction with other evidence, to demonstrate that a problem existed at the
facility that needed to be addressed. MPCA staff worked with ValAdCo to address the
problems, but without any real success for a long time. It is hoped the new waste storage
systems will reduce the odor and H2S problems. As noted in responses to comments regarding
air monitoring, MDH continues to recommend that this be verified by air monitoring. MDH
HRVs are also in rule; they are not enforceable, but are used to give advice to other agencies.



                                               85
c. Lack of scientific data to make a connection between hydrogen sulfide emissions and public
   health problems. The commentor alleges that MDH’s assessment of health problems related
   to hydrogen sulfide exposures near the facilities are “…based primarily on emotional
   complaints from farm neighbors who have no scientific education, training or expertise” and
   who “…allege that they have a poor quality of life when their neighboring farms smell like
   farms.”

MDH Response: While data are limited on the health effects of exposure to low concentrations
of hydrogen sulfide, there is a growing body of evidence that links exposure to emissions from
swine feedlots to health effects. As cited in the report, studies by Thu, et. al. (1997) and Wing
and Wolf (2000) determined that rates of reported illnesses among rural residents living near
swine confined feeding are higher than in control groups not located near such facilities. Given
that nearly every resident who registered health complaints regarding the ValAdCo facilities are
themselves farmers, MDH does not agree with the argument that these complaints were
generated by people who have a problem with a farm smelling like a farm. (See response to
Commentor #1, item 4 “Health Concerns”)

d. Concern that MDH was attempting to regulate odors and quality of life issues, rather than
   actual exposures and health effects.

MDH Response: MDH’s assessment of the impacts at the former ValAdCo sites was based on
air quality monitoring and violation of the MAAQS. MAAQS are enforceable standards in
MPCA rules and protect against odors and health effects. HRVs are not intended to directly
address odors. Odors can affect quality of life, but need not be directly related to adverse health
effects. However, continual odor emissions can play a role in producing adverse physical
symptoms. A study by Dr. Susan Schiffman et al., 1995 found that:

   Persons living near the intensive swine operations who experienced the odors reported significantly more
   tension, more depression, more anger, less vigor, more fatigue, and more confusion than control subjects.




e. The focus on hydrogen sulfide, without consideration of the 200+ other gases emitted from
   feedlots. The commentor alleges MPCA and MDH chose to do this because only hydrogen
   sulfide has an enforceable standard.

MDH Response: The MPCA required monitoring for hydrogen sulfide not only because it has
enforceable standards, which ValAdCo was required by law to meet, but also because it can be
monitored relatively easily, it has known human health effects, and it can be used as a marker
compound for the other gases. Monitoring for 200+ gases is not only impractical (as specific
monitors for each gas are generally not available), it would be cost prohibitive and the health
effects of most of those gases are not as well understood. However, it is possible, and even
likely, that the presence of those other gases add to the adverse physical effects experienced by
the nearby residents.

f. The MPCA and MDH have used “…enormous law enforcement powers, to punish citizens



                                                      86
   when the government does not have a valid reason for doing so.”

MDH Response: As documented in the report, ValAdCo violated air quality standards hundreds
of times. MPCA worked with the company to try to address the causes of the violations, as it
was obligated to do under state law. After the state’s 1999 settlement with ValAdCo, the
company continued to violate the MAAQS for hydrogen sulfide. Only then, and as a result of
the continued violations, did the MPCA, in conjunction with the Minnesota Attorney General’s
Office, file a consent decree with the District Court. The court supported the actions of the
MPCA, resulting in a negotiated settlement.


g. Objecting to enforcement of air quality standards at property lines, rather than where people
   actually live.

MDH Response: All ambient air quality rules (state and federal) apply to air that is outside the
facility’s property boundary, and any areas within the property boundary where the general
public has access. This policy is based on the presumption that the public should breathe safe
air, even when they are not on their own property. It follows logically that if the air is safe at the
property boundary of the source facility, it will be safe further away.


14. Timeliness of the information – Commentor #15 notes that “…the bulk of the data referred
to, and upon which the assessment is based, were derived from meetings, visits, sampling and
inspections that for the most part occurred over two years ago. As a consequence, the report
does not necessarily reflect the current status and condition of the properties which are the
subject thereof. Most importantly, the report makes only a brief reference (page 7) to the
acquisition of the former ValAdCo properties by CFL [Christensen Family, LLC], and does not
detail the extensive work – remedial and otherwise – conducted on a collaborative basis by CFL,
the [MPCA], Renville County, and Minnesota’s Office of the Attorney General.”

MDH Response: The commentor is correct. However, at the time the investigation occurred and
the report was written (December 2002), the transfer of ownership had not yet occurred. That
made it impossible to do anything more than acknowledge that the transfer was planned and that
upgrades to the facilities were proposed. The MPCA reviewed the report in April 2003, but did
not recommend significant alterations to the report (see Appendix D) beyond including mention
of the modifications to the storage systems, which MDH incorporated into the report. We have
added additional information regarding the change in ownership in the Executive Summary
(pages 4-5). MDH has not been provided with any additional data regarding the facilities, so we
cannot comment on whether the changes mentioned by the commentor have resulted in actual
improvements. However, several residents have indicated that the odors from the lagoons were
not as offensive this year as in previous years.



Specific comments on the recommendations of the Public Health Assessment for ValAdCo

Recommendation 1: Containment of animal waste



                                                 87
Commentor #1 - “The upgrades of the waste storage planned by the new owners sound good, but
no data are included in the report to show the efficacy of this new storage in other CAFOs in
reducing air and water contamination problems. Thus, we have no way to assess whether or not
the new system will fix the problem. We can assume that complete enclosure of the waste will
reduce hydrogen sulfide emissions, but if in practice these systems need frequent venting or leak
or are in some other way problematic then we have gained no ground. This is particularly
troubling given the assurances made by ValAdCo in the past when trying other odor and air
emission control technologies which ultimately failed.”

Commentor #15 – “This recommendation has been satisfied on account of CFL’s acquisition of
the former ValAdCo facilities. Included in waste containment and air emissions control are
replacement of existing primary basin with small concrete manure storage structures to hold the
volatile solids – the size of which permits effective waste and air quality control; covers have
been retained on secondary lagoons to further control air emissions; and the existing primary
basin at one of the sites (Norfolk 27) will be closed by December 31…defective covers have been
repaired at a number of the sites; and covers have been placed on the new concrete primary
tanks at the site for which special concern was mentioned.”

MDH Response: No data was provided regarding the performance of the new storage systems
because they were not built at the time the report was written. MDH recommended continued air
and ground water quality monitoring at the facilities in order to verify the efficacy of these new
systems, and will continue to review such data. As noted above, several residents have indicated
that odors did appear to be reduced this year with the changes in waste storage and management.
Monitoring will help to verify whether the new waste management system has reduced H2S
emissions.



Recommendation 2: Emission reduction strategies

Commentor #1 – “The recommendations [regarding specific emission reduction strategies] are
not included in this report, nor are they even summarized. It is difficult to evaluate them,
especially for laymen and the public, without any information.”

MDH Response: The purpose of the recommendation was not to prescribe specific technologies,
but rather to insist that air quality standards be met by whatever combination of strategies are
available, and failing that, to reduce the number of animals at the violating facility until the
standards can be met (recommendation #5). The report cited (Iowa State University, 2002)
evaluates a variety of emission reducing strategies, from which any given operated may select
one or more options to create an integrated approach to reducing emissions from their facility.
The emission reduction strategies with the highest documented reduction rates (shown in
parentheses) suggested by the report were:

Housing Units: frequent pressure washing of feeding floor (65-70%); urine separation and
scraping of waste to sealed under-floor storage (50-65%); and avoiding air exchange between
under-floor storage and housing area (80%).



                                              88
Barn Ventilation: Dust and gas suppression using biofilters (85-90%); only dust suppression
using biofilters (50-60%); and dust suppression using oil sprayed on internal surfaces (50-60%)

Storage Units: Impermeable man-made covers (80-95%); anaerobic digestion of manure (80-
85%, but deemed financially unfeasible); chopped straw covers (75%); natural crusting of
manure surface (75%); and floating permeable man-made covers (60-75%)

Land Application Areas: Injection with full soil coverage (85-90%); surface applied,
incorporated immediately by plowing (50%); surface applied, incorporated within 3-6 hrs (0-
10%); surface applied, incorporated within 12-24 hrs (0-5%).



Commentor #7 – “What about the toxic gases – there shouldn’t be any emissions that cross onto
our property, period!! NONE”

MDH Response: A basic assumption of public health, and the standards that protect it, is that
the level of exposure is the determining factor in whether it is a health concern. Air quality
standards regulate concentrations at the source facility’s property line. Concentrations of gases
beyond the property boundary would be at levels below concentrations found at the fence line.
When standards are met at the property line, then air beyond the property line will meet the
standards.

Commentor #15 – “This recommendation has been satisfied…All facilities are utilizing a
combination of emissions-reducing strategies, including but not limited to: Manure in concrete
tanks and storage basins is agitated only during the land application period; All livestock are
fed to meet their nutritional needs on a phase feeding basis. The feed also contains added fat
which reduces dust released into the air; Scheduled daily housekeeping of the facilities includes
sweeping, scraping, and power washing…; Farrowing rooms are power washed from top to
bottom every 24-28 days…; Sows are washed and shampooed every 4 months reducing dry skin
and hair shedding; Gestation and breeding barns are washed every 4 months as animals rotate
through…”

MDH Response: The combination of strategies described should help to reduce odors and
emissions. This should be confirmed by air quality monitoring.


Recommendation 3: Odor management BMPs
Commentor #1 – “How will these be enforced?”

MDH Response: It is the responsibility of the MPCA to ensure that the BMPs are implemented.

Commentor #15 – “This recommendation has been satisfied…An MPCA-approved “Air
Emissions Plan”, including best management practices, is a requirement of each facility’s
NPDES permit. Extensive record-keeping is required…”




                                               89
MDH Response: No response required.


Recommendation 4: hydrogen sulfide MAAQS and air monitoring
Commentor #1 – “The simple recommendation of air monitoring is problematic on its own. As
detailed in the report, at least three different entities performed air monitoring on the facilities,
each obtaining vastly different data. The variables in air monitoring protocols (how many
monitors, mobile or stationary, down wind or upwind, in the plume or out, in summer or winter)
are so significant that they mean that the results can be ‘rigged’ for any result desired.

For example, a stationary monitor that is upwind of the plant -- though proximal— may never
record significant amounts of H2S emissions, though these exist and are causing health problems
downwind a few hundred yards away. Since the penalties for violating air quality standards are
serious, the location of monitors and other details of monitoring protocols should be carefully
evaluated to fairly represent the real emissions, and the potential to cause health concerns.”

MDH Response: Even given the constraints on air quality monitoring raised both by the report
and by the commentor, air quality monitoring at the ValAdCo facilities documented numerous
violations. It is possible that monitoring devices could be placed in inappropriate locations, but
because wind direction is measured along with the hydrogen sulfide levels, it would not take
long to determine if the monitor were improperly located. The MPCA has general monitoring
protocols that include measuring wind direction and speed, which is critical in evaluating the
appropriateness of the monitor location.

Commentor #15 – “This recommendation has been satisfied…The Stipulation Agreement (Part
9.B.5.a-g) details air monitoring requirements to be undertaken by CFL with compliance
overseen by the MPCA; specific to CFL site NF-002 (Norfolk 27), per the Stipulation Agreement
(Part9.D.1.a and d), CFL has submitted an air quality management plan for the ozone treatment
system and a continuous air monitoring plan for monitoring hydrogen sulfide emissions from
April 2003 to December 2004.”

MDH Response: The Stipulation Agreement, according to staff in the Minnesota Attorney
General’s office, requires air monitoring only at the Norfolk 27 facility. The recommendation
was intended to apply to all of the facilities and has been revised to clarify this (page 61).


Recommendation 5: MAAQS violations
Commentor #1 – “These enforcement measures seem reasonable.”

Commentor #8 – “What are the plans if and when the air quality is worse??”

Commentor #15 – “[The commentor] believes that the air quality control measures which are
described in these comments and as otherwise contained within the extensive permit
requirements….established appropriate and sufficient air quality control processes.
Nonetheless, Minnesota state law and the permits issued to CFL contain the appropriate and
legally mandated protocol for insuring that alleged violations of air quality are not only
monitored, but dealt with in an appropriate manner. The Air Emission Plan…includes a



                                                90
description of measures to be used to mitigate air eimissions in the event the MPCA determines
the facility has the ‘potential to exceed’ the [MAAQS].”

MDH Response: As noted earlier, the recommendations were written before the referenced plans
were available. Implementation of the Air Emission Plan ought to address the concerns.
However, given the potential harm to public health that may result from long-term exceedence of
the MAAQS, MDH continues to assert that reduction in animal numbers should not be
automatically ruled out as a strategy for achieving compliance with the standards.


Recommendation 6: Monitoring wells at F1/NF
Commentor #1 – “These measures seem reasonable.”

Commentor #15 – “A Ground Water Monitoring Plan has been approved by the MPCA and
groundwater monitoring wells have been installed at the CFL site NF-001 (Crooks 29) per the
requirements of NPDES/SDS Permit MN 0066737 (Section IV.B)”

MDH Response: The actions taken appear to have addressed this recommendation. No response
necessary.


Recommendation 7: Monitoring of Renville city wells #5 and #6
Commentor #1 – “These measures seem reasonable.”

Commentor #15 – “[The commentor] is unaware of any human health issues with respect to
Renville city wells No. 5 and No. 6 – nor do we understand the draft Public Health Assessment to
have identified any. Nonetheless, monitoring of Renville City Wells is a matter that should be
referred to the City of Renville. To the extent that the City of Renville makes outreach to CFL, a
collaborative dialogue will be undertaken to address any possible concerns.”

MDH Response: Not all of the recommendations in this report are directed to CFL. Copies of
the report were sent to the city of Renville. The responsibility for monitoring the city wells falls
to the City of Renville and the MDH. It was not intended that CFL monitor the city wells. The
recommendation has been amended to clarify this (page 61). The commentor is correct that no
health issues were identified with respect to wells #5 and #6, but has missed the point of the
recommendation. These two wells, which are located very near the lagoons of the Crooks 29
(F1/NF) facility, are not tested individually. The city water supply is tested in the aggregate,
which could mask any evolving problem in wells #5 and/or #6, should a release from the lagoons
occur. The purpose of the recommendation is to establish a sampling protocol that could identify
any problem in the early stages, when corrective actions are most likely to be effective.


Recommendation 8: Monitoring wells at F1/BGF facility
Commentor #1 – “These measures seem reasonable.”

Commentor #15 – “CFL site C-041 (Crooks 34) has been issued [an] NPDES Permit…[which]
does not require the installation of groundwater monitoring wells. In addition, a communication



                                               91
from the the Minnesota Department of Health’s Environmental Health Division, Source Water
Protection Unit – Mankato to Brian Foster of Christensen Family Farms dated February 10,
2003 states: ‘Site 3 in Section 34 of Crooks Township…is not yet enrolled in the state Wellhead
Protection Program and therefore does not have a wellhead protection area (WHPA) nor a
drinking water source management area (DWSMA) delineated at this time.’ Finally, while [the
commentor] understands the comment that has been made, [the commentor] is unable to find in
the report documentation of any environmental effects resulting in a human health concern or
impact.”

MDH Response: The absence of a WHPA and a DWSMA has no bearing on whether the
groundwater in this area is sensitive to potential contamination. Such designations are only
made in areas where public water supply wells are located, not in areas with private wells, as is
the case for this particular facility. Moreover, the absence of information regarding
environmental effects that may or may not affect human health is precisely the reason why the
recommendation was made. The geologic setting of this facility is quite similar to that of the
Crooks 29 facility, where a WHPA has been established. The same buried stream channel
located near the Crooks 29 facility (which is the reason why groundwater in that area is
vulnerable to contamination) is present near the Crooks 34 facility. Permits for this facility may
not require monitoring wells; nevertheless, MDH stands by the recommendation. Without
monitoring wells at this facility the groundwater used by several private wells in the area
(including the water supply wells for the Crooks 34 facility) may be at risk. The only way to
know is to actually install the wells.


Recommendation 9: Monitoring of ditches near lagoons and land application sites
Commentor #1 – “These measures seem reasonable. [The commentor] would also recommend
sites be evaluated for suitability beyond mere soil testing. Criteria including the degree of slope,
location of drainage tiles and the presence or absence of riparian areas bordering fields should
be included in choosing sites for land application. Though these are “common sense” measures,
they should be included since land application has been such a trouble spot for these facilities in
the past.”

MDH Response: Other criteria, including degree of slope and set-backs from surface water, are
part of the evaluation used by MPCA to determine the suitability of land application areas.
MDH staff observed land application activities at the ValAdCo facilities on several occasions
and did not observe violations of surface water set-back distances. Nor did any of the fields used
for land application have significant slope, such as to warrant a concern regarding run-off.
Avoiding areas with drainage tiles become problematic because of the ubiquity of tiling in most
of the agricultural areas of Minnesota. The presence of this vast network of drain tiles is all the
more reason for the volume of land applied waste to be carefully controlled to meet the specific
soil and crop requirements in the land application area, to avoid excess nutrients infiltrating to
the drain tiles and, ultimately, to surface waters of the state (recommendations 11 and 12).

Commentor #15 – “CFL…has agreed to implement an extensive and detailed Manure
Management Plan and protocol for the proper field application of the manure resource from
each site. That protocol includes sampling of material in basins before application, testing of
soils, observance of proper setbacks, incorporation of manure, and ongoing record



                                                92
retention,…to ensure adherence to best management practices and nutrient application at
agronomic rates to ensure that the manure resource is used for crop nutrient needs and does not
become runoff to county ditches. Because of the extensive testing and grid sampling of soil
resources in the area of the county ditches, the sampling as suggested is not necessary and
…would be duplicative…”

MDH Response: The commentor does not detail what they mean by “extensive testing and grid
sampling”. The soil sampling outlined in the NPDES permits only requires sampling only every
four years for phosphorous, and for nitrate only “as recommended by the University of
Minnesota Extension Service”. As noted in the response to commentor #1, the network of drain
tiles that underlies the land application sites creates a pathway for nutrients to migrate rapidly to
surface waters in this area of the state. Given the large volume of nutrients generated by
confined livestock operations, it seems prudent to ensure by direct measurement that the
procedures that “ought” to prevent contamination of the surface waters actually do so.


Recommendation 10: Dead animal storage
Commentor #1 - These measures seem reasonable, though past accounts of problems in this area
by residents were never able to be verified because staff could not reach the areas in a timely
manner to document the claims. Is it possible for some plan to include a “first responder” from
local government to respond to local resident’s observations of problems in this area? Since the
PHA said such reports were rare, this may not be an onerous commitment for a township or
county official.

Commentor #7 – “We believe the new owners will control these problems better.”

Commentor #15 – “Dead animal storage structures have been replaced or upgraded to be fully
enclosed to prevent access by animals and the loss of plastic bags or other garbage materials.”

MDH Response: The actions taken appear to have addressed this recommendation. No response
necessary.


Recommendation 11: Collect more samples from waste prior to land application
Commentor #1 – “These measures seem reasonable.”

Commentor #15 – “Prior to the initiation of land application activities, manure column samples
from the entire cross-section of manure were pulled from the primary manure storage basins at
sites NF-001, NF-002, C-042 and C-044. In addition, as manure agitation, pumping and land
application occurs, manure samples are regularly drawn for laboratory analysis per the
requirements of the…manure management plan.”

MDH Response: Sampling the cross-section of the waste prior to land application, and the other
sampling described, should address the concerns raised by this recommendation.


Recommendation 12: Sample soils at the land application sites prior to spreading waste



                                                93
Commentor #1 – “These measures seem reasonable.”

Commentor #15 – “Land application of manure from all sites is per MPCA-approved Manure
Management Plans (MMPs) that are part of the NPDES permits. Per the Stipulation Agreement
[Part 9.D.1.b (NF-002 site) and Part 9.D.2.a (all other sites], CFL has submitted Interim
Manure/Nutrient Management Plans for the existing manure storage structures that govern
manure/nutrient management from January 2003 through December 2004. Final MMP’s for all
sites will be in place by January 1, 2005 in conformance with Minnesota rule 7020.2225, ‘Land
Application of Manure’.”

MDH Response: Soil sampling at land application sites was also required by the permits for
ValAdCo, yet their records indicate that the required samples were never collected. The
recommendation has been revised to clarify that the intent is for permit requirements be adhered
to (page 62).


Recommendation 13: Monitoring lagoon waste levels
Commentor #1 – “These measures seem reasonable.”

Commentor #15 – “As per the requirements of each facility’s Manure Storage Area Operations
& Maintenance Plan that is part of the NPDES permit, records are maintained of waste/water
levels in all manure storage structures on a regular basis, including before and after land
application of manure.”

MDH Response: Monitoring waste/water levels in the lagoons was also required by the permits
for ValAdCo, yet records were not kept. The recommendation has been revised to clarify that
the intent is for permit requirements be adhered to (page 62).


Recommendation 14: Aerial photo review prior to land application
Commentor #1 – “These measures seem reasonable. See comments for # 9.”

Commentor #15 – “Land application of manure will follow nutrient rate standards and
application setbacks outline in Minnesota Rule 7020.2225. CFL standard operating procedure
is to digitally map every field in the MMP…, identifying on the field maps all field tile intakes,
wells, sinkholes and Special Protection Areas. Every effort will be made to work closely with
landowners where land application of manure is taking place to identify and properly seal
abandoned wells. In addition, while CFL has an obligation to respect the legal rights of all
independent land owners who utilize the manure resource, CFL does require its custom manure
applicators to at all times observe applicable laws with respect to field application and works
with landowners to ensure that the manure resource is properly applied.”

MDH Response: Visual observation for unsealed wells is not sufficient. Four unsealed well
locations near the Norfolk Township facilities were identified using aerial photographs, but there
were no surface indicators of the presence of the wells. Those wells had been cut off at 18
inches below grade, only 6 inches below the depth at which waste is knifed into the soil, creating
potential conduits directly to the drinking water aquifers used by nearby residents. No matter



                                               94
how diligent CFL and their manure applicators may be in observing the fields in which their
waste is applied, they may easily encounter similar circumstances. A review of historic aerial
photographs for a proposed land application area takes less than an hour and is not an onerous
recommendation, given the potential harm to public health that may result should waste enter a
drinking water aquifer.


Recommendation 15: Sampling facility water supply wells
Commentor #1 – “These measures seem reasonable. [The commentor] again raises the question
of what enforcement or remediation actions should take place in case of contamination.”

Commentor #15 – “CFL…is committed to worker health and safety. CFL relies upon its
workers to follow all permit and other regulatory requirements to which CFL may be
obligated…. With respect to worker safety, CFL will continue to comply with all permit
requirements and other obligations that may be imposed by law.”

MDH Response: The facilities do not fall under any regulatory framework, as they do not meet
the criteria to be classified as a “non-community public water supply”. Thus, simply complying
“with all permit requirements and other obligations that may be imposed by law” does not mean
that this potential problem has been addressed. Unless the owner takes it upon him/herself to
sample the water supply wells, the testing will not occur. That was the purpose of the
recommendation. If the wells fell under the regulatory framework, there would have been no
need to recommend that they be tested.

Regarding the actions that would take place in case of contamination of the water supply wells
for the facilities, because these are legally considered to be “private” wells, the MDH does not
have any enforcement authority regarding the wells. If notified of a detection of any level of
bacteria or nitrate concentrations exceeding health standards, MDH would recommend steps that
may be taken to disinfect the wells, but cannot order their closure. MDH would also report the
detection(s) to the MPCA, because the facility permits contain response action plans in case of
leakage from the lagoons.


Recommendation 16: Install an additional monitoring well at F2/BGF
Commentor #1 – “These measures seem reasonable. Again, CWAA raises the question of what
enforcement or remediation actions should take place in case of contamination.” (this was in
response to recommendations 16 and 17, which all related to monitoring well installation)

Commentor #7 – “You’ve already said they’re [the lagoons] are leaking, so close the lagoons at
all sites and be done with it, once the water is contaminated its too late.” (this was a general
comment, but related directly to the recommendations regarding additional monitoring wells)

Commentor #8 – “What are the plans if or when something happens to water quality in the
nearby wells?” (this was a general comment, but related directly to the recommendations
regarding additional monitoring wells)

Commentor #15 – “[The] NPDES Permit…outlines all perimeter tile…and groundwater



                                              95
monitoring well…sampling protocols. The Permit does not call for additional monitoring wells
to be installed. While the recommendation is noted, nowhere in the study does it suggest a water
quality issue with a demonstrable human health effect.”

MDH Response: The recommendation addresses an inadequacy in the monitoring well network
at this facility. Monitoring well networks are not installed because there is a demonstrable
human health effect, they are installed to determine if a problem is occurring. That can only be
done effectively if the monitoring wells are installed properly, both in terms of their location and
construction. MW-3, the well in the best downgradient location at this facility, was not screened
across the sand layer immediately below the base of the lagoons. This is the best screening
horizon for detecting any leakage from the lagoon, and should have been where the well was
completed.

Regarding the questions of what would happen should contamination be detected in the
monitoring wells: the permits for facilities with monitoring well networks require reporting of
the monitoring results to the MPCA on an annual basis. If unacceptable bacteria or nitrate
concentrations are detected in the monitoring wells, the facility operator is required to do
additional testing to confirm the detections and then must investigate the source of the
contamination and implement any repairs needed to stop the release. In only one case (F3/BGF)
were high levels of bacteria detected in one monitoring well. The well was re-sampled and the
detection confirmed. It was disinfected, and several years of subsequent testing did not detect
bacteria. This suggests that, rather than a widespread groundwater contamination problem, the
bacteria had been introduced directly into the well, possibly during a sampling event.

Regarding the request that the lagoons be closed, the primary lagoons at six of the seven
facilities have been replaced with concrete lined storage containers, which should provide better
protection for the groundwater resources near those facilities. This will be confirmed by
monitoring well networks at five of the facilities. There is no legal basis for closing the lagoons.

If contaminants that do represent a potential public health risk are found (i.e. bacteria or nitrate),
the facility will have to determine the source of the contamination and take whatever actions are
necessary to address that source. The goal is to detect any contamination before it affects nearby
wells, in time to take whatever actions are needed to prevent contamination of private drinking
water wells.


Recommendation 17: Install an additional monitoring well at F4/BGF
Commentors #1, #7, #8 – see comments and response under recommendation 16

Commentor #15 - “[The] NPDES Permit…outlines all perimeter tile…and groundwater
monitoring well…sampling protocols. The Permit does not call for additional monitoring wells
to be installed. Again, while the recommendation is noted, nowhere in the study does it suggest
a water quality issue with a demonstrable human health effect.”

MDH Response: As with the previous recommendation, the additional monitoring well
recommended for this facility would fill a gap in the monitoring network. Again, monitoring
networks are not installed because a demonstrable human health effect exists, but to ensure that



                                                96
one does not develop. To be effective, the network should provide adequate monitoring points
downgradient of the most likely source areas.


Recommendation 18: Recommence sampling monitoring well MW-2 at F3/BGF
Commentor #15 – “This recommendation has been satisfied…[the] NPDES permit…for CFL
site C-043 (Flora 5)…requires routine sampling from monitoring well MW-2.”

MDH Response: The actions taken appear to have addressed this recommendation. No response
necessary.


Recommendation 19: Private well testing
Commentor #1 – “These measures seem reasonable. However, the way the testing will be
carried out raises many questions: should ValAdCo be required to pay for it? Should the county
or other local government entity conduct the tests? Should the actual landowners be required to
test, and then how and to whom do they report? Is it fair to expect them to pay for these tests?”

Commentor #15 – “CFL Obviously has no legal right to require residents in the area to sample
from their wells annually. The recommendation seems to go to what every person ought to do as
a manner of management of their household as opposed to what should be required of CFL.”

MDH Response – As noted above, the recommendations in this report are not specifically
directed at CFL. This recommendation, as it is stated, is for residents to sample their own wells.
The recommendation regarding private well testing is advice that the MDH gives to every
private well owner in the state, but is particularly important for well owners in agricultural areas
where shallow ground water is more likely to be contaminated with nitrate and bacteria.

MDH believes it is fair to expect residents to pay for these tests, because all well owners ought
to test their water routinely. To put this into context, residents whose water comes from a
municipal system pay for such testing as part of their water bill. Residents are not obligated to
report any of the test results, but if they have concerns regarding the results, they may report
them either to the Renville County Department of Public Health or the Minnesota Department of
Health.

Testing kits are available from the Renville County Department of Public Health for a nominal
cost (currently $9.60 for the nitrate test and $11.60 for the bacteria test). Call 320-523-2570 for
more information.


Citations in responses to comments:

Ammann, H.M. (1986) A new look at physiologic respiratory response to H2S poisoning. J.
Hazard. Mater. 1986; 13:369-374.

ATSDR (1997) Toxicological Profile for Benzene (Update), prepared by the Agency for Toxic
Substances and Disease Registry, Atlanta, GA, pp. 423.



                                                97
Bhambani, Y., Burnham, R., Snydmiller, G., Maclean, I., Martin, T. (1994) Comparative
physiological responses of exercising men and women to 5 ppm hydrogen sulfide exposure.
American Industrial Hygiene Association Journal, 55:1030-1035.

Bhambani, Y., Burnham, R., Snydmiller, G., Maclean, I., Lovlin, R. (1996a) Effects of 10 ppm
hydrogen sulfide inhalation on pulmonary function in healthy men and women. Journal of
Occupational and Environmental Medicine. 38:10-12-1017.

Bhambani, Y., Burnham, R., Snydmiller, G., Maclean, I., Martin, T. (1996b) Effects of 5 ppm
hydrogen sulfide inhalation on biochemical properties of skeletal muscle in exercising men and
women. Amer. Ind. Hygiene Assoc. Jour. 57: 464-468.

Bhambani, Y. and Singh, M. (1991) Physiological effects of hydrogen sulfide inhalation during
exercise in healthy men. The Amer. Physiol. Soc. 1872-1877.

Schiffman, S.S., Sattely Miller, E.A., Suggs, M.S., and Graham, B.G. (1995) The Effect of
Environmental Odors Emanating From Commercial Swine Operations on the Mood of Nearby
Residents. Brain Research Bulletin. 37: 369-375.

U.S. Department of Health, Education, and Welfare (1964) The Air Pollution Situation in Terre
Haute, Indiana with Special Reference to the Hydrogen Sulfide Incident of May-June, 1964. A
joint report to the City of Terre Haute by the U.S. Public Health Service, Division of Air
Pollution and the Indiana Air Pollution Control Board, Division of Sanitary Engineering. U.S.
Department of Health, Education, and Welfare, Public Health Service, June 19, 1964.

Wing, S. and Wolf, S. (1999) Intensive Livestock Operations, Health and Quality of Life
Among Eastern North Carolina Residents. A report prepared for the North Carolina Department
of Health and Human Services, Division of Public Health. Department of Epidemiology,
University of NC at Chapel Hill. May 6, 1999.

Zang, Y., Tanaka, A., Dosman, J.A., Senthilselvan, A., Barber, E.M., Kirychuck, S.P., Holfield,
L.E., Hurst, T.S. (1998) Acute respiratory responses of human subjects to air quality in a swine
building. Jour. Agric. Eng. Res. 70: 367-373.




PREPARERS OF REPORT

Kathleen Norlien                                    Ginny Yingling
Research Scientist                                  Hydrologist
Health Risk Assessment Unit                         Site Assessment and Consultation Unit
Minnesota Department of Health                      Minnesota Department of Health
tel: (651) 215-0876                                 tel: (651) 215-0917



                                              98
Alan Yarbrough
Technical Project Officer
Division of Health and Consultation
State Program Section
Agency for Toxic Substances and Disease Registry




                                    CERTIFICATION

This Health Assessment was prepared by the Minnesota Department of Health under a
cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It
is in accordance with approved methodology and procedures existing at the time the health
consultation was begun.




                                      Alan Yarbrough
                   Technical Project Officer, SPS, SSAB, DHAC, ATSDR



The Division of Health Assessment and Consultation, ATSDR, has reviewed this public health
consultation and concurs with the findings.




                                       Richard Gillig
                       Chief, State Program Section, DHAC, ATSDR




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