# FUGITIVE DUST CONTROL PLAN

SIMPLOT FEEDERS LIMITED PARTNERSHIP

December l, 2003

### INTRODUCTION Simplot Feeders Limited Partnership developed this Fugitive Dust Control Plan ("Plan") to implement Best Management Practices ("BMP") at our cattle feedlot operation. This Plan has been developed in orderto implement reasonable precautions to minimize emissions of fugitive dust from the feedlot. The following BMP's were developed incorporating site specific characteristics ofouroperations. 

### SITE DESCRIPTION SimplotFeeders is a Confined Animal Feeding Operations (CAFO) located in Walla Walla County, approximately 3.5 miles north ofWallula, Washington. The feedlot was constructed in 1970 and has been in operation since that time. Simplot Feeders purchased theoperation in October, 1992. The feedlot and ancillary facilities are found principally on 705 acres within theE**~of**Section 34 and all ofSection 35, less a portion oftheSE 

### Y4 thereof, within Township 8N., Range 31 E.W. M
.. The facility is composed ofopen air fenced pens which are constructed on dirt and covered with manure to maintain moisture while providing abase for animals. Total pen area is approximately 294 acres or-145 square feet peranimal. Roadways are constructed with pit run gravel. Traffic roadways around the feed mixing milL repair shops and office are covered with crushedrock. Feedlot conditionsare affected bymany variables including, butnot limited to weather and operations.


### METEOROLOGICAL DATA Average precipitation from September 15 through April 15 is 6.97 inches, and April 16 to September 14 is 2.82 inches. Thetotal yearlyprecipitation is 9.79 inches. (US Weather Service Station Data located at Ice Harbor Dam). Estimated annual average class "A"pan evaporation rate is approximately 44 inches peryear.

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### DESCRIPTION OF BEST MANAGEMENT PRACTICES

PEN MAINTENANCE Through out the year, Simplot Feeders performs pen floor maintenance. During the winter months, excess manure is removed from the pen. The rest ofthe year, Simplot Feeders use tractors with box scrapers for shaping and grooming the mounds and pen floor. As needed, excess manure is removed to maintain minimal loose manure. At times, cattle carve out wallows in the pen floor. When these occur, they are filled with a compacted claytype soil and covered with manure. SPRINKLERSYSTEM Simplot Feeders' Plan includes a computercontrolled sprinkler system which is operational Aprillst through October 15th. The system includes full and part circle sprinklers and allows individual sprinklerrun times to be adjusted to maximize water application to minimize dust emissions. Run time for each sprinkleris based on several factors including but not limited to: visual pen floor condition, past and current weather conditions including rainfall, temperature, evapotranspiration. Ifnecessary, the systemmay be operated 24.hoursperday during hot, dry weather situations. SPRINKLER SYSTEM DATA • Approximately 3 hours per cycle (iffull circles operate 4 minutes, halfcircles operate 2 minutes). • Approximately250,000 gallons applied percycle. WATERRIGHTS Simplot Feeders has a waterright issued bythe state ofWashington that provides amaximum diversion ofI,500 gallons perminute and a volume restriction of525 million gallons per year. This is the waterright that provides the water for the implementation ofthe BMP'scontained in ourplan. WATERTRUCKS SimplotFeeders' Plan includes the utilization ofwatertrucks to control roadwaydust. The roadway is constructed with pit run gravel providing an effective road base. Feed trucks traveling less than IS miles an hourwill make approximately 8 round trips perday. A water truck traveling less than IS miles per hourwill apply water to roadwaysusing a rear-mounted splash plate to distribute the water. The water truck has a capacity of3000 gallons and averages a load every 25 minutes. Roadways are watered according to conditions and usage. Water trucks will be operated in a reasonable manner to control fugitive dust and emissions caused by feedlot weather, site and operational conditions. Generally, they start approximately one hourbefore othertraffic usage occurs on the roads.

3WATER TRUCKDATA • 3000 gallon capacity • Coverage per load: 10' x 4000', 0.12' water applied • Truck operates as necessary to minimize fugitive emissions up to 20 hours per day, average a load every 25 minutes. • 20 hours operation 48 loads or 129,000 gallons



### SITE-SPECIFIC FEATURES AND/OR CHARACTERISTICS The following are several factors which complicate oraffect the implementation ofBMP's at ourcattle feedlot operation:

• Simplot Feeders balances waterapplication in relationship to animal health, which is affected bymoisture and ambient airtemperature. Low ambient temperatures cancreate health and/orrespiratoryproblems for the cattle. • Water application requires balancing effective dust control with control ofodors and fly management program. • Water application must be managed in conjunction with maintaining appropriate floor conditions for cattle. • Water application at the Simplot Feeders site is complicated bywind conditions, pen size, and the necessity to ensure that the feed bunk area is protected from excessive moisture applications. • Pens are sized to provide optimum livestockperformancewhile minimizing emissions. • Water application needs to be managed in conjunctionwith maintaining appropriate mound conditions for cattle. • Water quality concerns created byrunoffmust be taken into consideration when using water for emission control. • The sprinkler systems waterdistribution is affected by operational limitations. These include but are not limited to waterpressure and system capacity. • Feedlot terrain complicates the operation ofsomeBMP's. The feedlot is located in and area where the landscape is rough and uneven. These physical factors affect water application rates and distribution uniformity. With theuneven pen surface, it is difficult to maintain minimal depth ofloose manure. 

### RECORD KEEPING AND REPORTING DATA Simplot Feeders will maintain the sprinkler system to assure reasonable performance and operation as designed. This includes:

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### Record Keeping And Reporting Data Cont'.

• Maintain, for one year, work orders documenting outside laborperformed on the system and replacement parts used on the system. • Will maintain a computer log ofsystem operation and will mail a copy ofthe logs each month to Department ofEcology. • Will maintain a daily log ofwater truck operation, (hours ofoperation, loads hauled) and will mail a copyofthe logs each month to Department ofEcology. • Will notifyDepartment ofEcologyAir QualityProgram, within 

### 5 working days, of operational concerns and non-typical conditions that may affect the ability to control the formation offugitive dust.


### GENERAL FACTORS Cattle are fed a high moisture-content ration which produces above normal moisture-content in feces and increased amount ofurine. Feces and urine will add additional .03 inches moisture each day at pen capacity. Normal cattle operations have cattle moving during morninghours, however, cattle will bemoved at various times as required byfeedlot operations, including doctoring orshipping.


### OPERATIONAL CRITERIA GENERAL OPERATIONAL PLAN Simplot Feeders Fugitive Dust Control Plan includes a computer-controlled sprinkler system. The system is started approximatelyApril 1, priorto conditions that create the formation of fugitive dust, and continues until October 15, assuming a normal weather year. The sprinkler system operational planmayutilize historical weatherdata from the LEGROW (USBR) REMOTE STATION "LEGROW" as a water application guide. The water application capacity ofthe sprinkler system provides Simplot Feeders' with the flexibility to apply sufficient waterto mitigate impacts and to maintain adequate soil moisture in relationship to evapotranspiration. Operation parameters will be affected bythe following conditions: o Daily weatherconditions including ambient temperature factors associated with cool nights and warm days; o Past weatherdata including evapotranspiration; o Weather forecasts includingbut not limited to temperature, precipitation, and wind; o Proper mound condition to maintain andpromote animal health; o Pen floor moisture and general condition ofpens determinedbyphysical checking of the site; o Cattle inventory in relationship to moisture added by the number ofcattle in pens; o Extent ofmanure coveroverthe areas receiving water; and o Odor and fly management.
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### General Operational Plan, Cont'.

• The Plan will be implemented to control formation offugitive dust. • The Plan will be implemented iffugitive dust is generated. • Annual startup evaluation ofthe system and correct and/or repairperformance deficiencies. • Throughout the season, maintain and repair the system within a reasonable time to ensure proper sprinkler system performance and that the system is operating at the maximum designed pressure. • Throughout the season, as necessary, use tractors with box scrapers for shaping and grooming the mounds and pen floor and as needed, excess manure is removed to maintain minimal loose manure. • Time ofday and frequency ofwater application will vary depending on weather, soil and feedlot conditions, including but not limited to pen conditions, recent and forecasted weather and cattle inventory. • Simplot Feeders, within the limitations ofthe sprinkler system, has the capacity to maintain adequate soil moisture in relationship to evapotranspiration and rainfall factors • Simplot Feeders may make modifications to the Plan as long as the effectiveness ofthe Plan is not compromised. Simplot Feeders will notifY Ecology ofchanges to the Plan • The Department will notifY Simplot Feeders ifthey have any concerns. issues and/or modifications regarding our Plan
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## CONTACT PERSON Keith Pearce Feedlot Manager Simplot Feeders Limited Partnership PO Box 1306 IBP/Dodd Road Pasco, Washington 99301 Phone- 509154

### 7-8864 Fax- 509/547-8866

BMP Plan Submittal for SimplotFeeders



### Ron Parks Environmental Manager 

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