FUGITIVE DUST CONTROL PLAN 

SIMP LOT 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 order to implement reasonable precautions to minimize emissions of 

fugitive dust from the feedlot. The following BMP's were developed incorporating site 

specific characteristics of our operations. 

SITE DESCRIPTION 

Simplot Feeders is a Confined Animal Feeding Operations (CAFO) located in Walla Walla 

County, approximately 3.5 miles north of Wallula, Washington. The feedlot was constructed 

in 1970 and has been in operation since that time. Simp lot Feeders purchased the operation in 

October, 1992. The feedlot and ancillary facilities are found principally on 705 acres within 

theE ~of Section 34 and all of Section 35, less a portion of theSE Y4 thereof, within 

Township 8N., Range 31 E.W. M .. 

The facility is composed of open air fenced pens which are constructed on dirt and covered 

with manure to maintain moisture while providing a base for animals. Total pen area is 

approximately 294 acres or -145 square feet per animal. Roadways are constructed with pit 

run gravel. Traffic roadways around the feed mixing milL repair shops and office are covered 

with crushed rock. Feedlot conditions are affected by many variables including, but not 

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. The total yearly precipitation 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 per year. 

2 

. I 

\ 

) 

) 
\ 

! 

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 of the 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 clay type soil 

and covered with manure. 

SPRINKLER SYSTEM 

Simplot Feeders' Plan includes a computer controlled sprinkler system which is operational 

Aprillst through October 15th. The system includes full and part circle sprinklers and allows 

individual sprinkler run times to be adjusted to maximize water application to minimize dust 

emissions. Run time for each sprinkler is based on several factors including but not limited 

to: visual pen floor condition, past and current weather conditions including rainfall, 

temperature, evapotranspiration. If necessary, the system may be operated 24.hours per day 

during hot, dry weather situations. 

SPRINKLER SYSTEM DATA 

• Approximately 3 hours per cycle (if full circles operate 4 minutes, half circles operate 2 

minutes). 

• Approximately 250,000 gallons applied per cycle. 

WATER RIGHTS 

Simp lot Feeders has a water right issued by the state of Washington that provides a maximum 

diversion of I ,500 gallons per minute and a volume restriction of 525 million gallons per year. 

This is the water right that provides the water for the implementation of the BMP's contained 

in our plan. 

WATER TRUCKS 

Simplot Feeders' Plan includes the utilization of water trucks to control roadway dust. The 

roadway is constructed with pit run gravel providing an effective road base. Feed trucks 

traveling less than IS miles an hour will make approximately 8 round trips per day. A water 

truck traveling less than IS miles per hour will apply water to roadways using a rear-mounted 

splash plate to distribute the water. The water truck has a capacity of 3000 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 hour before other traffic usage occurs on the roads. 

3 
WATER TRUCK DATA 

• 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 or affect the implementation ofBMP's at 

our cattle feedlot operation: 

• Simplot Feeders balances water application in relationship to animal health, which is 

affected by moisture and ambient air temperature. Low ambient temperatures can create 

health and/or respiratory problems for the cattle. 

• Water application requires balancing effective dust control with control of odors 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 by wind 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 livestock performance while minimizing emissions. 

• Water application needs to be managed in conjunction with maintaining appropriate 

mound conditions for cattle. 

• Water quality concerns created by runoff must be taken into consideration when using 

water for emission control. 

• The sprinkler systems water distribution is affected by operational limitations. These 

include but are not limited to water pressure and system capacity. 

• Feedlot terrain complicates the operation of some BMP'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 the uneven pen surface, it is difficult to 

maintain minimal depth of loose manure. 

RECORD KEEPING AND REPORTING DATA 

Simplot Feeders will maintain the sprinkler system to assure reasonable performance and 

operation as designed. This includes: 

4 

• t 

) 

/ 
Record Keeping And Reporting Data Cont'. 

• Maintain, for one year, work orders documenting outside labor performed on the 

system and replacement parts used on the system. 

• Will maintain a computer log of system operation and will mail a copy of the logs each 

month to Department of Ecology. 

• Will maintain a daily log of water truck operation, (hours of operation, loads hauled) 

and will mail a copy of the logs each month to Department of Ecology. 

• Will notify Department of Ecology Air Quality Program, within 5 working days, of 

operational concerns and non-typical conditions that may affect the ability to control 

the formation of fugitive dust. 

GENERAL FACTORS 

Cattle are fed a high moisture-content ration which produces above normal moisture-content 

in feces and increased amount of urine. Feces and urine will add additional .03 inches 

moisture each day at pen capacity. Normal cattle operations have cattle moving during 

morning hours, however, cattle will be moved at various times as required by feedlot 

operations, including doctoring or shipping. 

OPERATIONAL CRITERIA 

GENERAL OPERATIONAL PLAN 

Simp lot Feeders Fugitive Dust Control Plan includes a computer-controlled sprinkler system. 

The system is started approximately April 1, prior to conditions that create the formation of 

fugitive dust, and continues until October 15, assuming a normal weather year. The sprinkler 

system operational plan may utilize historical weather data from the LEGROW (USBR) 

REMOTE STATION "LEGROW" as a water application guide. The water application 

capacity of the sprinkler system provides Simplot Feeders' with the flexibility to apply 

sufficient water to mitigate impacts and to maintain adequate soil moisture in relationship to 

evapotranspiration. 

Operation parameters will be affected by the following conditions: 

o Daily weather conditions including ambient temperature factors associated with cool 

nights and warm days; 

o Past weather data including evapotranspiration; 

o Weather forecasts including but not limited to temperature, precipitation, and wind; 

o Proper mound condition to maintain and promote animal health; 

o Pen floor moisture and general condition of pens determined by physical checking of 

the site; 

o Cattle inventory in relationship to moisture added by the number of cattle in pens; 

o Extent of manure cover over the areas receiving water; and 

o Odor and fly management. 

5 
General Operational Plan, Cont'. 

• The Plan will be implemented to control formation of fugitive dust. 

• The Plan will be implemented if fugitive dust is generated. 

• Annual startup evaluation of the system and correct and/or repair performance 

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 of day and frequency of water application will vary depending on weather, soil and 

feedlot conditions, including but not limited to pen conditions, recent and forecasted 

weather and cattle inventory. 

• Simp lot Feeders, within the limitations of the 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. Simp lot Feeders will notifY Ecology of changes to the Plan 

• The Department will notifY Simplot Feeders if they have any concerns. issues and/or 

modifications regarding our Plan . ) 

CONTACT PERSON 

Keith Pearce 

Feedlot Manager 

Simp lot Feeders Limited Partnership 

PO Box 1306 

IBP/Dodd Road 

Pasco, Washington 99301 

Phone- 509154 7-8864 

Fax- 509/547-8866 

BMP Plan Submittal for Simplot Feeders 

Ron Parks 

Environmental Manager 

/2-1 -0.3 

(Date) 

) 

6