HomeMy WebLinkAbout20041958.tiff RESOLUTION
RE: ACTION OF BOARD CONCERNING VIOLATION OF SECTION 23-4-710, LIVESTOCK
FEEDING PERFORMANCE STANDARDS, OF THE WELD COUNTY CODE -
CONAGRA CATTLE FEEDING COMPANY, GILCREST FEEDLOT
WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to
Colorado statute and the Weld County Home Rule Charter, is vested with the authority of
administering the affairs of Weld County, Colorado, and
WHEREAS,the Board has been presented with a recommendation from the Weld County
Department of Public Health and Environment to authorize legal action by the County Attorney's
Office, followed by a subsequent request to continue the consideration of the request to proceed
with legal action against ConAgra Cattle Feeding Company - Gilcrest Feedlot, and
WHEREAS, a hearing before the Board was held on the 10th day of November, 2003, at
which time the Board deemed it advisable to continue said matter to June 30, 2004, to allow
ConAgra Cattle Feeding Company - Gilcrest Feedlot adequate time to comply with the following:
A. Incorporate and fulfill all aspects of the recently submitted Dust Control Plan,dated
November 6, 2003.
B. By January 1,2004,the facility shall provide to the Department of Public Health and
Environment, a detailed document describing the evaluation of cold weather month
dust control. By May 1,2004,the facility shall provide a report that describes all dust
control efforts implemented during cold weather months.
C. For the next 12 months, the facility provide monthly"self-evaluation" reports to the
Department of Public Health and Environment. The reports should describe
observed dust conditions, up and down-wind of the facility. Observations should be
made and recorded in the late-afternoon or early evening periods or during periods
when dust is most likely to be created from the facility.
WHEREAS,at said hearing on June 30, 2004, after hearing all of the testimony presented
and, having been fully informed, the Board of County Commissioners deemed it advisable to
dismiss the violation.
NOW,THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld
County,Colorado,that the violation of section 23-4-710, Livestock Feeding Performance Standards,
of the Weld County Code against ConAgra Cattle Feeding Company, Gilcrest Feedlot. be, and
hereby is, dismissed.
s-c-of ec, l4,L AL e4 ,44,1 2004-1958
RE: AUTHORIZATION FOR THE WELD COUNTY ATTORNEY TO PROCEED WITH LEGAL
ACTION AGAINST CONAGRA CATTLE FEEDING COMPANY - GILCREST FEEDLOT
PAGE 2
The above and foregoing Resolution was,on motion duly made and seconded, adopted by
the following vote on the 14th day of July, A.D., 2004.
BOARD OF COUNTY COMMISSIONERS
W D COU TY, �COLORADO
//��/� Web---
Robert D. asden, Chair
rc
snt lerk to the Board
isof . / '.7 7 William H. J e, Pro-Tem
u^a BY:::-, •
4; nAeput lerk to the Board i� Z1 v6Ld
- M. J. eile
APPRo AS TO .•
EXCUSED
David E. Long
unty Attor, ey S.,_,u
Qiiketec_______
Glenn Vaad
Date of signature: `e-- 6`7*/
2004-1958
H L0031
a
jot
CLERK TO THE BOARD
PHONE (970) 336-7215, Ext. 4225
FAX: (970) 352-0242
P. O. BOX 758
WI I D C• GREELEY, COLORADO 80632
COLORADO
June 21, 2004
Don Anderson, Senior Feedlot Manager
ConAgra Cattle Feeding Company
Gilcrest Feedlot
22777 Weld County Road 31
Gilcrest, Colorado 80645
RE: Consider Authorizing the Weld County Attorney to Proceed with Legal Action Against
ConAgra Cattle Feeding Company - Gilcrest Feedlot for Violation of Section 23-4-710,
Livestock Feeding Performance Standards, of the Weld County Code (Con't from
11/10/2003)
Dear Mr. Anderson:
This is to notify you that the Board of County Commissioner's meeting scheduled forJune 30,2004,
has been cancelled. Therefore,the matter referred to above has been rescheduled to July 14,2004,
at 9:00 a.m.
If you have questions or need additional information, please do not hesitate to contact me at(970)
356-4000, Extension 4217.
Very truly yours,
44,6,
Carol A. Harding,
Deputy Clerk to the Board
2004-1958
Page 1 of 1
Carol Harding
From: Carol Harding
Sent: Thursday, June 17, 2004 9:56 AM
To: 'TREVOR Jiricek'; Cindi Etcheverry
Cc: Bruce Barker
Subject: ConAgra Feedlot-Gilcrest
By Resolution #2003-3122 on 11/10/03, the Board continued the Probable Cause Hearing for the Gilcrest Feedlot
to June 30, 2004, at 9:00 a.m.; however, a quorum will not be present at the June 30th meeting, so it has been
cancelled. Therefore, we need to reschedule the Gilcrest Feedlot matter to another date. Since July 5th is a
holiday, there will be two meetings in a row cancelled. That will make the July 7th agenda very full, so the best
date for us would be either the 12th or 14th of July.
Please let me know which date you prefer, and I will notify the Feedlot of the schedule change. Of course, we will
need an updated memo from you prior to the scheduled date for the Board's consideration.
Thanks.
Carol
6/17/2004
•
Kik a
MEMORANDUM/, -:2
TO: BOARD OF CO MMISSIONERS L.
FROM: Z'JL�
FROM: TREVOR JIRICEK CINDIETCHEVERRY
ISUBJECT:CONAGRA FEEDLOT-GILCREST,DUST EMISSIONS
DATE: 11/7/2003
C. CC: WELD COUNTY ATTORNEYS OFFICE
COLORADO DEPARTMENT OF PLANNING SERVICES
This hearing has been requested due to the observation of the ConAgra Cattle Feeding Company
(ConAgra)—Gilcrest Feedlot failing to comply with Section 23-4-710 of the Weld County Code (WCC),
pertaining to the control of dust emissions from the facility.
The Department of Public Health and Environment recommends that the Board of County Commissioners
(BOCC) continue this hearing concerning the ConAgra Cattle Feeding Company — Gilcrest Feedlot, until
July 1, 2003. However, we recommend that the BOCC require that the facility comply with the following
conditions:
• Incorporate and fulfill all aspects of the recently submitted dust control plan, dated November 6,
2003.
• By January 1, 2004, the facility provide to the Department of Public Health & Environment, a
detailed document describing the evaluation of cold weather month dust control. By May 1,
2004, the facility shall provide a report that describes all dust control efforts implemented during
cold weather months.
• For the next 12-months, the facility provide monthly "self-evaluation" reports to the Department
of Public Health & Environment. The reports should describe observed dust conditions, up and
down-wind of the facility. Observations should be made and recorded in the late-afternoon or
early evening periods or during periods when dust is most likely to be created from the facility.
This recommendation is based upon efforts by ConAgra to improve dust control at the facility including
meeting with County staff on November 6, 2003, and the submittal of an amended plan. The plan
(attached), dated November 6, 2003, outlines significant repairs and enhancements that have and are in
the process of being implemented. The plan also makes a commitment to evaluate and research
additional viable dust control options. Based upon our discussions and the plan, the enhancements
generally take a labor intensive system and make it more efficient. The amended plan, if diligently
implemented and assuming maintenance of the system occurs, appears to be sufficient to limit dust
emissions from the facility for warm weather months.
The Department of Public Health&Environment will contact ConAgra when complaints are received and
conduct random facility observations in the absence of complaints. Should County_staff observe
violations of Section 23-4-710 notification will be made 6t2 the facility. Should a cornplaini be received
and verified by County staff a hearing will be scheduled with the BOCC where a recommendation for the
County Attorney to proceed with legal action will be presented.
We have attached a detailed chronology which includes complaints, investigations, communications,
control plan submittals, etc. We have also attached a brief summary of the potential public health impacts
of feedlot dust and a summary of feedlot dust control techniques cited in literature.
2
ConAgra Cattle Feeding Company Gi'crest Feedlot
22777 WCR 31
Gilcrest, CO 80645
November 6, 2003
Mr. Trevor Jiricek, Director, Environmental Health Services
Weld County Department of Public Health and Environment
1555 N. 17th Ave
Greeley, CO 80631
Dear Mr. Jiricek,
RE: Outline of Existing Dust Abatement Process & Proposed System Enhancements
Gilcrest Feedlot—ConAgra Cattle Feeding Co.
OVERVIEW:
Since July '03 ConAgra Cattle Feeding Company has invested more than $260,000 in equipment,
personnel, and system upgrades for the water sprinkling capabilities at our Gilcrest Feedlot. One hundred
and fifty-four high-pressure Nelson guns have been installed and extensive retrofits have been made to the
existing supply lines and control valves. These enhancements will significantly increase the sprinkling
system's mechanical reliability, thereby allowing for timely and efficient dust abatement during the times
of the year when water sprinkling does not pose a detrimental effect to our livestock. The following
Standard Operating Procedures have been incorporated into our operating plans.
Warm Weather Operation:
- Sprinklers will be operated to reflect best management practices for dust abatement.
- Mobile water application equipment will be utilized as needed for control of dust in the small
percentage of pen areas not covered by the sprinkler system(estimated at approximately 10
percent of the total pen area dependent on wind conditions).
- Pen floors will be maintained in a manner designed to minimize dust generation.
Cool Weather Operation:
During periods when daytime temperatures begin to cool, water application to both the pen floor as well
as the cattle themselves must be managed to reduce any adverse impact to the cattle or pen conditions.
The professional community acknowledges that there is a range of ambient temperatures at which cattle
are comfortable and do not use energy to either heat or cool themselves. The 1984 & 1996 National
Research Council (NRC)Nutrient Requirements of Beef Cattle refer to this range of environmental
temperatures as the "Zone of Thermoneutrality". The NRC established the Lower Critical Temperature at
15 degrees C (59 degrees F), with a mean of the thermoneutral zone being established at 20 degrees C (68
degrees F). Precipitation, humidity, mud or wet contact surfaces all increase maintenance requirements
and in effect narrow the range of thermoneutrality, thus increasing energy maintenance requirements and
negatively affecting animal welfare.
It is recommended that pen floors be kept as dry as possible during the early winter months(October—
November). Due to the decrease in both daylight hours and day time temperatures, any natural pen floor
moisture evaporation and drying is minimized. Applying additional moisture by way of mechanical
sprinkling reduces our ability to maintain a comfortable environment for the cattle.
Best Practices Research for Cold-Weather Months:
ConAgra Cattle Feeding Co. is exploring all options to determine if there are viable alternatives to
contribute to our dust abatement program during cold-weather months. Our primary objective is to
implement effective dust control measures that will not have a potentially negative health effect on
livestock. To that end, we have initiated a cooperative effort with Colorado State University's
Department of Animal Science, as well as CSU's Weld County Extension Office, regarding current trial
data and future research as it applies to environmental enhancement of livestock feeding operations.
Communication also has been initiated with industry partners, both livestock associations and livestock
feeding companies regarding any innovations that can contribute t0 successful and practical dust
abatement applications.
Research will be evaluated and the merits analyzed as they pertain to the Gilcrest Feedlot site. ConAgra
Cattle Feeding Company will cooperate with land grant universities and industry associations to develop
processes by which dust generation can be minimized during cool weather periods while optimizing cattle
well being.
ConAgra Cattle Feeding Company is committed to addressing the issues raised by Weld County and our
neighbors. We are also committed to maintaining the quality of life for our employees, animals in our
care, and our community. To ensure open communication, we will provide copies of our strategic plan
for local community review. ConAgra Cattle Feeding Company and its representatives welcome the
opportunity for productive dialogue with all interested parties.
Sincerely,
Ce
Don E. Anderson
Senior Feedlot Manager
ConAgra Cattle Feeding Company
Cc: Don Willms—VP ConAgra Cattle Feeding Company
Richard Bishop—ConAgra Cattle Feeding Company
Stan Campbell—Manager, Gilcrest Feedlot
Tom Siegrist—Director of Environmental Affairs, Swift& Co.
Jim Herlihy —VP Public Relations, Swift & Co.
L-' :,,
MEMORANDUM it
TO: FILE L l'
FROM: CINDI ETCHEVERRY ETCHEVERRY, WCDPHE
Il ' SUBJECT: REVISED AND UPDATED CHRONOLOGY
O DATE: 10/30/2003
OM CONAGRA FEEDLOT AT GILCREST•COLORADO CC: TREVOR JIRICEK,DIRECTOR,WCDPHE
2002
July 29 Dust complaint received.
August 24 Dust concerns discussed with anonymous caller.
September 30 Dust complaint received. Complainant alleges dust from ConAgra settles in the
buffalo pastures every night, causing the buffalo to die from Pasturella
Pneumonia. Arborland Nursery has documentation from a veterinarian.
October 1 Cindi Etcheverry spoke with Frank Bendrick Jr. of ConAgra concerning alleged
dust issues.
October 2 Arborland Nursery called. Cindi Etcheverry spoke with Arborland Nursery and
requested veterinary report or any information they had to support allegation.
They have a call in to get veterinary information.
October 2 Frank Bendrick of ConAgra called to discuss with Cindi Etcheverry that the
pneumonia is a common illness. He said he acknowledged ConAgra does have a
dust problem and would get with the facility manager to discuss dust management
methods.
October 9 Dust complaint received.
October 10 Cindi Etcheverry received correspondence from Arborland Nursery. A faxed
copy of the mortality count, veterinary autopsy report and stated October 9, 2002
dust as very heavy.
October 14 Cindi Etcheverry had a conference call with Frank Bendrick and Tom Secrest of
ConAgra, to discuss dust issues.
October 15 Cindi Etcheverry wrote a memo to file, concerning conference call with Frank
Bendrick and Tom Secrest. Mr. Bendrick stated that their records show they
applied 34% more water to their pens this year than last year and that his records
indicate they water from 5:00 am until sundown, and that if they run sprinklers at
night it causes the cattle to run into the fences. He said next summer they would
be willing to apply water to pens 6 to 7 days per week. I asked him to summarize
in writing what the facility would do to prevent dust problems next summer. He
said he would get it to me within a few weeks.
October 17 Cindi Etcheverry observed facility. Dust observed leaving the facility along WCR
46.
October 21 Received call from Frank Bendrick requesting dates that dust was documented.
October 28 Cindi Etcheverry emailed Frank Bendrick, letting him know last dust complaint
was October 9, and on October 17, observed significant amount of dust leaving
the facility. Notified him that he would be getting a letter requesting a corrective
action and time line that it will take to control dust coming from facility.
ConAgra, Memo to file
October 13, 2003
Page 2
Complainant was particularly concerned about next summer, as this summer is
over.
November 20 Dust complaint received, also complaining about Miller feedlot. Cindi Etcheverry
informed complainant that we had requested a corrective action from ConAgra
facility and is waiting on that.
December 5 Dust complaint received, also complaining about Miller feedlot, every day dust
and odor cloud. Complainant called facility and plant manager and Mr. Miller,
and they thought it was a joke. Cindi Etcheverry could not go out to verify this
time.
December 6 Cindi Etcheverry conducted complaint investigation, went to complainants home
and discussed enforcement procedures and ConAgra and Miller dust and odor
observations.
December 11 Letter sent to ConAgra Notification that dust was not confined on property,
requesting a written plan of correction and maintenance to prevent fugitive dust.
Plan due within 30 days.
December 13 Cindi Etcheverry spoke with Frank Bendrick concerning letter.
2003
January 7 Dust complaint received. Informed complainant that the County was waiting for
written plan of correction from ConAgra.
January 8 Site investigation conducted. Cindi Etcheverry arrived at facility at 4:30 pm,
observed significant amount of dust throughout the valley. Because of the
amount of dust and lack of wind, could not confirm where dust was coming from.
January 9 Closed complaint.
January 10 Trevor Jiricek phone conversation with Frank Bendrick concerning dust control.
January 17 Letter from ConAgra to Trevor, requesting additional time to review and evaluate
dust control management options. Evaluating improvements to existing system.
Evaluating current technologies for feedlot dust control. Will have sufficient time
to implement improvements to address summer issues.
April 14 Letter to Trevor from ConAgra, discussing dust control methods that will be used
at facility. Sprinkler guns set up to allow for multiple pen coverage per day.
Sprinkler gun rotation, using additional labor can effectively control fugitive dust
emissions from the feedlot.
June 9 Letter to ConAgra approving proposed dust control methods.
July 1 Dust complaint received.
July 1 Site investigation conducted by Cindi Etcheverry, 7:30 dust starting to stir up, by
8:26 dust everywhere. Documented by many photos.
July 7 Arborland Nursery complaint received. Allegedly lost 12 buffalo last year.
Allegedly lost 3 babies because of the dust.
July 8 Trevor Jiricek emailed Frank Bendrick concerning July 1 photos attached to
email, and scheduled meeting on July 9.
July 9 Trevor met with Fran Bendrick, Don Anderson, and Stan Campbell from
ConAgra at 8:30 pm to discuss dust issues. Observed fugitive dust, documented
with photo.
C:\Documents and Settings\cetcheverry\Local Settings\Temp\031021 chronology from 2002 to present.doc
ConAgra, Memo to file
October 13, 2003
Page 3
July 10 Memo from Trevor to file. Memo summarized meeting of July 9 where ConAgra
agreed to implement additional controls that would be provide in writing on July
10, 2003. We will observed facility to see effectiveness of additional controls.
July 10 Letter faxed to Trevor, from Don Anderson, purchased additional sprinkler guns
to enhance speed of sprinkler rotation, and increased number of employees
assigned to sprinklers, leased 5,000-gallon water tanker with high-pressure gun.
Should improve overall dust control and limit amount of dust emitted from
facility.
July 14 Dust complaint received, complaint alleges dust is causing animals to die.
Notified complainant that facility is working on getting dust controls done.
July 15 Arborland Nursery complaint, alleges dust was really bad through the 4m of July
weekend, and yesterday bad. Wants state to do ambient air samples at property.
July 17 Dust complaint received.
July 17 Dust investigation, Cindi Etcheverry observed sprinklers were running at
approximately 1:30 pm. Saw some dust generating from corrals, but did not
appear to be leaving site. See July 22, 2003 email to Trevor.
July 19 Cindi Etcheverry visited Arborland Nursery, the husband said dust has been much
better.
July 23 Cindi Etcheverry conducted site investigation, observed sprinklers running, slight
dust, but not leaving site.
July 31 Cindi Etcheverry sent letter to ConAgra, approving dust abatement methods.
August 15 Dust complaint alleging dusty conditions.
August 15 Cindi Etcheverry called Don Anderson, he said they had been shipping loads of
cattle out - dirt roads, 2 water trucks broke down. Usually run water trucks during
shipping.
August 18 Don Anderson says they are watering 24 hours a day this weekend. He indicated
that the facility did have some dust on the previous Saturday morning, but got
right on it.
October First week of October Cindi Etcheverry observed significant dust while going
home during evenings.
October 7 Observed dust on way home.
October 8 Dust complaint received. Complaint alleges dust has been real bad for the last
week. Complainant indicated that for the last month you can tell they quit
watering pens.
October 8 Cindi Etcheverry conducted a site investigation. Dust observed and documented
with photographs.
October 8 Dust complaint received during dust investigation, Miller feedlot dust also
creating significant dust.
October 9 Cindi Etcheverry conducted site investigation. Dust observed and photographed.
Photos difficult to take during the dusk.
October 10 Cindi Etcheverry conducted site investigation. Dust observed. Attempted to
obtained photographs.
October 11 Site investigation. Dust observed and photographed.
October 15 Cindi Etcheverry observed facility. Video tape of dust coming off of facility
obtained.
C'.\Documents and Settings\cetcheverry\Local Settings\Temp\031021 chronology from 2002 to present doc
ConAgra, Memo to file
October 13, 2003
Page 4
October 16 Cindi Etcheverry met with Stan Campbell of ConAgra concerning other issue.
Verbally informed Mr. Campbell of complaints, investigations, and that the
facility may be scheduled for a public hearing.
October 16 Cindi Etcheverry observed dust coming off facility at around 6:30pm.
October 21 Certified letter sent to ConAgra Concerning Hearing date scheduled for violation
of WCC.
October 23 Cindi Etcheverry observed dust coming off facility at 6:28pm.
October 29 Call from complainant, saying that it was dusty October 28, and last Tuesday also
(October 21, 2003).
C'.\Documents and Settings\cetcheverry\Local Settings\Temp\031021 chronology from 2002 to present doc
Literature Review:
Public Health Impacts from Feedlot Dust
By Cindi Etcheverry
October 29, 2003
The major source of dust in the feedlot comes from the pens. However, dust can also come from
roads, service areas, and feed processing. Generally, the peak time for dust to occur is around
sunset, when the temperature starts to cool and cattle become more active (2).
Some studies have shown dust and odors do have an effect on rural and urban resident health.
However, factors such as concentration, frequency, duration, character, and perceived
offensiveness determines whether odor or emissions from feedlots are considered a nuisance or a
health problem (1).
The studies discussed in this paper focus on the characteristics of dust particulate matter. With
increasing concern for human health effects believed to be caused by fine particulate matter, the
United States Environmental Protection Agency (USEPA) has set National Ambient Air Quality
Standards. These standards include standards for particulate matter less than 2.5 micrometers
(µm) in diameter(PM2.5) and 10 µm in diameter(PM,0).
According to the US EPA, particulates less than PM,() pose a health concern because they can be
inhaled into and accumulate in the respiratory system. Particulates less than PMZ_5 are referred to
as "fine" particles and are believed to pose the largest health risk. Because of their small size,
fine particles can lodge deeply into the lungs. Health studies have shown a significant
association between exposure to fine particles and premature mortality. Other important effects
include aggravation of respiratory and cardiovascular disease (as indicated by increased hospital
admissions, emergency room visits, absences from school or work, and restricted activity days),
lung disease, decreased lung function, asthma attacks, and certain cardiovascular problems such
as heart attacks and cardiac arrhythmia (6).
According to Wilson's et al. studies, particles that are 7µm in diameter can enter the nose, but
are mostly nonrespirable. Particles that are 1.1 to 6.0 in diameter can enter the terminal bronchi
and are respirable. Particles that are 0.65 to 1.1 µm in diameter are also respirable and can enter
the lung alveoli (7). Respirable particulates can be inhaled deeply into the lungs and cause lasting
damage (1).
John M. Sweeten et al. measured particle size distribution of ambient feedlot dust emissions
located in the Southern Great Plains. The number of cattle in the feedlots used in the study
ranged from 17,000 to 40,000 head. Sweeten's measurements showed the average diameter of
feedlot dust emissions to be from 6.9 to 9.5 µm (4, 5), with the concentration of total suspended
particles to be from 54 to 35,536 µg/m3 (4, 3). Peak daily total suspended particulate
concentrations were observed at or just after sundown for 2 hours and ranged from 1946 to
35,536 µg/m3, averaging 14,200 µg/m3 (4). One half of these particles were measured to be
smaller than PM,o, and 5 to 10 percent of the total suspended particulates measured at or less
than PM25 (5, 3).
- 1 -
Microbial Flora studies indicate dust particulates from feedlots can be bacteriologically active.
Dust has shown to be a mechanism for transport of organisms (7, 3). Bacteria in the size range
from 0.65 to 7.0 µm can become airborne on dust particles. The presence of bacterial endotoxins
(heat-stable biological compounds located in the cell envelopes of gram-negative organisms)
may be a significant issue with regard to animal health. In humans, endotoxins affect humoral
and cell-mediated immunity and have the potential to affect lung function. Endotoxin is stable,
and its toxic effects are known to persist for long periods of time in dust. High endotoxin levels
have been found in cattle feedlot dust samples (7).
Studies have also shown there is a connection between dust and odor. Dust particles also adsorb
odorous compounds. As the dust particles are carried by the wind, so is odor. Odorous dust can
carry many times more molecules of odor compounds than the same volume of particulate free
air. Dust, in other words, concentrates odorous compounds (1).
In conclusion, evidence that fugitive dust emissions can cause adverse health effects in humans
is not disputed. However, it is difficult to ascertain the extent of adverse health effects due to the
variability of feedlot site conditions, climatic conditions, and neighboring property and resident
conditions.
References:
1. Control of Odor Emissions from Animal Operations, A report from the Board of Governors
of the University of North Carolina, September 1998.
http://www.cals.ncsu.edu:8050/waste mgt/newodor.html
2. Davis, J.G.; Stanton, T.L.; Haren, T. Feedlot Manure Management, Colorado State
University Cooperative Extension, Fact Sheet no. 1.220
Http://www.ext.colostate.edu/pubs/livestk/01220.html
3. Hasselback, Paul. Exposure Issues Associated with Feedlot Emissions,
http://www.casahome.org/S CISYM/ProceedingsPDF/Session%202/Hasselba.pdf
4. Sweeten, John M. Particle Size Distribution of Cattle Feedlot Dust Emissions, American
Society of Agricultural Engineers, Paper No. 98-4076.
Http://baen.tamu.edu/users/rel/agair/sweeten/particle.pdf
5. Sweeten, John M.; Erickson, Larry; Woodford, Phyllis, et al. Air Quality Research and
Technology Transfer White Paper and Recommendations for Concentrated Animal Feeding
Operations, Confined Livestock Air Quality Committee of the USDA Agricultural Air
Quality Task Force. http://www.nhq.nres.usda.gove/faca/Policies/CAFO.htm
6. U.S. Environmental Protection Agency, Technology Transfer Network National Ambient Air
Quality Standards. http://www.epa.gov/ttn/naafis/pm/pm25 index.html
7. Wilson, S.C.; Morrow-Tesch, J.; Straus, D.C.; et al. Airborne Microbial Flora in a Cattle
Feedlot, Applied and Environmental Microbiology, July 2002, p. 3238-3242, Vol.68, No. 7.
Http://aem.asm.org/cgi/content/full/68/7/3238
- 2 -
Literature Review:
Feedlot Dust Control Techniques
October 30, 2003
Agriculture,Food and Rural Revitalization,Health in the Feedlot,
http://www.agr.gov.sk.ca/DOCS/livestock/b eet%feedlots/healthfeedlot
Summary:
Dust control may be necessary in dry weather by removing excess surface manure and treating laneways with
gravel or other dust-inhibiting agents. Dust can be controlled in pens by spraying water at a rate of two liters
per square meter(approx. 1 inch)per day. Initial applications may take twice this amount.
Davis,J.G.; Stanton, T.L.; Haren T. Feedlot Manure Management,Colorado State University
Cooperative Extension. Fact sheet no. 1.220. http://www.ext.colostate.edu/pubs/livestk/01220.html
Summary:
Aim for pen moisture of 25 to 35 percent.
Design pens with a minimum of 3 percent slope to manage excess moisture and runoff collection.
Proper pen design and maintenance of surface moisture levels.
Routine cleaning of pen surfaces.
Keep loose manure layer less than 1 inch deep.
Windbreaks also may be used to control or capture fugitive dust.
Trees planted along perimeter of Feedyard will provide shelter from wind and may largely contain any fugitive
dust.
Surface moisture can be manipulated through stocking rate changes. Typical pen stocking densities in Colorado
are between 150 ft'and 300 ftz per animal.
Start prior to the time dust is a serious problem.
Sweeten,John M.; Erickson,Larry; Woodford,Phyllis; et al.Air Quality Research and Technology
Transfer White Paper and Recommendations for Concentrated Animal Feeding Operations, Confined
Livestock Air Quality Committee of the USDA Agricultural Air Quality Task Force,Washington D.C,
July 19,2000. http://www.nhq.nres.usda.gove/faca/policies/CAFO.htm
Summary:
Stocking density adjustment.
Frequent manure collection.
Water application or sprinkler irrigation. Typical guideline is 2.5 to 6.0 mm/day (0.1-0.25in/day).
Sullivan,James; Boesel, Greg; Criswell, Robert; et al. Feedlot Air Quality Summary: Data Collection.
Enforcement and Program Development,Minnesota Pollution Control Agency.March 1999.
http://www.pca.state.mn.us/hot/pubs/feedlot-an.pdf
Summary:
Vegetable oil sprinkling.
Dusty Feedlot Conditions Reduced Using Good Management,Alberta Cattle Feeders Association.
Intensive Livestock Working Group of Alberta,Nov. 22, 1999.
http://c attlefeeder.ab.ca/manu re/env991128.shtml
Summary:
Computer controlled pen sprinklers.
Keep feed lanes and roadways wet by using a water truck..
Cleaning pens at the proper time.
Cleaning the pen floor right down to the gleyed layer(black impermeable skin on top of the clay base).
Increase number of cattle in pens.
Planting windbreak trees or fences.
- 1 -
Brink, Philip. A Dusting Problem, Controlling Feedyard Dust and Odor Can Improve Cattle
Performance and Your Image with the Neighbors. 50 Drovers, October 2003.
Http://www.brinkinc.biz/pdf/dust.pdf
Summary:
Pen watering.
Regular Manure removal.
Increased pen stocking rates.
Adding bedding material to pens. Crop residues such as straw,waste hay, cotton gin trash, woodchips, sawdust,
keeping moisture in upper layer of the manure pack.
Synthetic and plant based oil blends.
Hygroscopic agents like calcium chloride and magnesium chloride. These are generally, used to control dust on
road bed or alley by either binding fines together or continuously absorbing moisture from the atmosphere.
Emulsified asphalt,a highway sealant.
Sprinkling systems.
Parker, D.; Perino, L.; Galyean,M; et. al. Beef Cattle Research Group, Soil-Cement Feedlot Surfacing.
Cooperative Research, Education and Extension Triangle, Texas A&M Research and Extension Center.
http://amarillo2.tamu.edu/amaweb/creet.htm
Summary:
Soil-Cement Feedlot Surfacing.
Melgares,Pat. Kansas,U.S. Researchers Studying Cattle Odor,Dust.July 29,2003.
Http://www.oznet.ksu.edu/news/sty/2003/cattle odor072903.htm
Summary:
Water curtain—40 foot structure built along edge of feedlot that sprays water periodically Adding 5% canola oil
to water will capture smallest dust particles.
Building pens with less room to minimize movement of cattle.
Shultz, Tom; Collar, Carol. Dairying and Air Emissions,University of California Cooperative Extension
Dairy Manure Management Series. UCCE-DMMS-4 10/93
http://animalscience.ucdavis.edu/extension/wm/ucce-dmms-4.pdf
Summary:
Animal size and spacing to moisture on the feedlot surface. 25%moisture is considered optimum.
Queensland Government,Department of Primary Industries. Feedlot Waste Management Dust Control,
File no:IL0050, September 2003. http://www.dpi.gld.gov.au/environment/5243.html
Summary:
Removal of excess manure.
Increase stocking density.
Water application.
Chemical application.
Properly sprinkled feedlots.
Treat large areas simultaneously.
Apply water exactly when required.
McInnis,Doug.Living with Your Neighbors,PRIMEDIA Magazines & Media Inc.,August 1, 1998.
http://beef-mag.com/ar/beef living neighbors/
Summary:
Elevated sprinklers, mists pens,but not enough to create mud.
- 2 -
f-
m
Qi
CIO
Ciao
sommig
ICS
paisse
Cie
awe
I
CCM
shawm
Feedlot Location
Section 9, Township 4 North , Range 66
West of the 6th P . M . , Weld County,
Colorado , including other adjacent
properties in the immediate vicinity that
may be included into a contemplated
general feed lot operation .
� zrt.' '-''''''''''n'"'. t', �'Ys le "�:�. P'.:7-7'''.."- -"),7".;4,-;:.'.'1':::41.§eliijY'' �ryt k
WINDS Y {} d 1D `i.si flP
�n .srt� 1; t 4 - _ {v fie
.. rKom'"..
{ ai
V5a, -.gamg ,.x r g"� S"-+`ii . §J„' "- s ,: E C` # C a t ,
r ¢
.�. � tea' .,.---.-'1:..
.S x �q+c
P , w —' 1� •
4'•'-W
,- �^ ..Frill t'
�J�I�NST e Wtag F• ,;
MIL`LIKEN "
.aEEE• �# 1
4 *`�>s ,.x wr C' - a .:1 alt ... titc•-'''‘'‘ r,, ' ;r— Cs �23 rt
'9£'441444
{ h P FL# • 9+,Y'�da $ ]` �yT 'Ch2v' '#'"iS".:.
> f .a x �gy ✓ e
S -:max r # .S -:,..-tai..-,..', 1 r .. - s: .,33 a raq
iYo E r G4 X E • Yn� 2 TFrvMP a., F . ..z x v•r F # &y+{^• 'i i :v f„Pi -✓ {a ,<utikAA,,,
l £ {y"� •_ .,F1aaR 4y, �
m yt
Weld Cou nty.Cobrado -- .. per."g? ~' ; 'LOOOft ^ .
'EVAN S
GILCREST
Weld.Couniy.Cobradoa f'', ,.�'t.I+�—== 5LUDD.ft,.... `. 1
O
O
a , r
I R4
4 M....
! O
„w.. ywnu..a.d.i.awYroM:' . . - n ' ux d»am>
tit
.. ilmRy _____- 1 . ...,..... Irv,
It
4
0
Y
y o
u
mire
• Between January 2002 and
October 2003, the Health
Department received 15 Hrri
complaints of dust coming from
the ConAgra feedlot in Gilcrest. tit
• During this same time, Health i
Department staff conducted 11 - 9
site visits and observed dust
coming from the property.
• In December of 2002, the health
department requested a written
plan of correction and
maintenance to prevent current
and future fugitive dust conditions.
On WCR 31, looking N., October 10, 2003
n 0
• After requesting and receiving
additional time, ConAgra
submitted a proposed dust control
plan in April of 2003. The plan
called for using the existing
sprinkler system, but hiring
= additional staff so that the
sprinkler guns could be moved
more frequently to cover each
On WCR 31, looking N., July 1, 2003 pen.
• In June of 2003, ConAgra was
notified that the proposed dust
j = control measures were approved.
• During July of 2003 more
complaints were received and site
investigations verified that dust
was leaving the property.
Southwest region of facility, July 1, 2003
0
• Health Department staff met with -
representatives of ConAgra on r m_
July 9, 2003. During this visit, �
staff observed dust leaving the
property.
• On July 10, 2003, a letter was
sent from ConAgra indicating
additional controls that would be
implemented, including purchase
of additional sprinkler guns to
enhance speed of sprinkler
rotation, increase number of
employees assigned to sprinklers,
and the lease of a 5,000 gallon
water tanker with high-pressure
gun.
Looking N. on WCR 31, 8:30pm, July 9, 2003
c: iircnoIogy
• Through mid-July to mid-August,
2003 no complaints were
received, and a site visit with a
complainant indicated that there
had been less dust present.
• The Health Department began to
receive complaints again around
Looking S on WCR 27% (77th Ave.), 6:13pm, October 11, 2003
mid-August, 2003. A call to
ConAgra indicated that they were
shipping cattle out and two of their
water trucks were broke down.
• During the past month (October
2003) our staff has observed dust
coming from the feedlot daily. The -
Health Department also began i . I
receiving complaints again.
Looking N. on WCR 46, 6:20pm, October 11, 2003
Potential
• According to the U.S. Environmental Protection Agency, dust
particles less than PM10 (10 micrometers in diameter) pose a health
concern because they can be inhaled into and accumulate in the
respiratory system. Particles less than PM2.5 (2.5 micrometers in
diameter) are referred to as "fine" particulate and pose the largest
health risk.
• Studies have shown a significant association between exposure to
fine particles and premature mortality. Other effects include
aggravation of respiratory and cardiovascular disease, lung disease,
decreased lung function, asthma attacks, and certain cardiovascular
problems such as heart attacks and cardiac arrhythmia.
U.S. Environmental Protection Agency, Technology Transfer Network National Ambient Air Quality Standards.
is e
• A study done by John M. Sweeten et al. measured particle size
distribution of ambient feedlot dust emissions in feedlots ranging
from 17,000 to 40,000 head of cattle. His findings showed the
average diameter of feedlot dust emissions to be between 6.9 and
9.5 micrometers. Peak daily total suspended particulate
concentrations, observed at or just after sundown for two hours,
averaged 14,200 micrometers per cubic meter. One half of these
particles were smaller than PM10 and 5 to 10 percent were less than
PM 2.5.
Hasselback, Paul. Exposure Issues Associated with Feedlot Emissions.
Sweeten, John M. Particle Size Distribution of Cattle Feedlot Dust Emissions, American Society of Agricultural
Engineers, Paper No. 98-4076.
Sweeten, John M.; Erickson, Larry; Woodford, Phyllis, et al. Air Quality Research and Technology Transfer White
Paper and Recommendations for Concentrated Animal Feeding Operations, Confined Livestock Air Quality
Committee of the USDA Agricultural Air Quality Task Force, Washington D.C., July 19, 2000.
o en la Health
• Microbial Flora studies indicate that dust particles from feedlots can
also be bacteriologically active. Bacteria ranging in size from 0.65 to
7 micrometers can become airborne on dust particles. The
presence of bacterial endotoxins may be a significant issue.
Endotoxins are very stable and their effects are known to persist for
long periods of time in dust. High endotoxin levels have been found
in cattle feedlot dust samples. In humans, endotoxins affect
humoral and cell-mediated immunity and have the potential to affect
lung function.
Wilson, S.C.; Morrow-Tesch, J.; Straus, D.C., et al. Airborne Microbial Flora in Cattle Feedlot, Applied and
Environmental Microbiology, July 2002, p. 3238-3242, Vol. 68, No. 7.
o st C
Control Techniques
• Dust control in pens by spraying water at a rate of two liters per square
meter (approx. 1 inch) per day (aiming for a pen moisture of 25 to 35
percent).
• Computer controlled pen sprinklers.
• Water curtain.
• Elevated sprinklers.
• Vegetable oil sprinkling.
• Removing excess surface manure.
• Adding bedding material to pens.
• Soil-cement feedlot surfacing.
• Stocking density adjustments.
• Treating laneways with gravel or other dust-inhibiting agents (e.g., calcium
chloride or magnesium chloride).
• Windbreaks used to control or capture fugitive dust.
- ee o ius on
Resource List
Agriculture, Food, and Rural Revitalization, Health in the Feedlot.
Davis, J.G.; Stanton, T.L.; Haren T. Feedlot Manure Management, Colorado State University
Cooperative Extension. Fact Sheet No. 1 .220.
Sweeten, John M.; Erickson, Larry; Woodford, Phyllis, et al. Air Quality Research and Technology
Transfer White Paper and Recommendations for Concentrated Animal Feeding Operations,
Confined Livestock Air Quality Committee of the USDA Agricultural Air Quality Task Force,
Washington D.C., July 19, 2000.
Sullivan, James; Boesel, Greg; Criswell, Robert; et al. Feedlot Air Quality Summary: Data Collection,
Enforcement and Program Development, Minnesota Pollution Control Agency, March 1999.
Dusty Feedlot Conditions Reduced Using good Management, Alberta Cattle Feeders Association.
Intensive Livestock Working Group of Alberta, Nov. 22, 1999.
Resource List
Brink, Philip. A Dusting Problem, Controlling Feedyard Dust and Odor Can Improve Cattle
Performance and Your Image with the Neighbors. 50 Drovers, October 2003.
Parker, D.; Perino, L.; Galyean, M.; et.al. Beef Cattle Research Group, Soil-Cement Feedlot
Surfacing. Cooperative Research, Education, and Extension Triangle, Texas A&M Research and
Extension Center.
Melgares, Pat. Kansas, U.S. Researchers Studying Cattle Odor, Dust, July 29, 2003.
Shultz, Tom; Collar, Carol. Dairying and Air Emissions, University of California Cooperative Extension
Dairy Manure Management Series, UCCE-DMMS-4, October, 1993.
Queensland Government, Department of Primary Industries. Feedlot Waste Management Dust
Control, File No: IL0050, September, 2003.
McInnis, Doug. Living With Your Neighbors, PRIMEDIA Magazines & Media, Inc., August 1 , 1998.
Kik a
MEMORANDUM. ;,, 2 c
TO: BOARD OF COUNTY COMMISSIONER .,, :y7 rY
FROM: TREVOR JIRICEK AND CINDI ETCHEVERRY i
ip SUBJECT:CONAGRA FEEDLOT-GILCREST, DUST EMISSIONS
C. DATE: 7/13/2004
CC: WELD COUNTY ATTORNEYS OFFICE
COLORADO DEPARTMENT OF PLANNING SERVICES
The Department of Public Health and Environment recommends that the ConAgra Cattle Feeding
Company hearing be closed. Our recommendation is based upon the progress made by the facility owner
towards complying with the resolution dated December 19, 2003.
The items required by the resolution were:
A. Incorporate and fulfill all aspects of the recently submitted Dust Control Plan, dated November 6,
2003.
B. By January 1, 2004, the facility shall provide to the Department of Public Health& Environment,
a detailed document describing the evaluation of cold weather month dust control. By May 1,
2004, the facility shall provide a report that describes all dust control efforts implemented during
cold weather months.
C. For the next 12 months, the facility provide monthly "self-evaluation" reports to the Department
of Public Health and Environment. The reports should describe observed dust conditions, up and
down-wind of the facility. Observations should be made and recorded in the late-afternoon or
early evening periods or during periods when dust is most likely to be created from the facility.
The facility has complied with all items required by the resolution. Additionally, our Department has not
verified any instances where dust has been observed to leave the facility. Below you will find a
chronology of all activities that have taken place since the November 10, 2003 hearing before the Board
of County Commissioners.
November 30, 2003 Letter from ConAgra, November self evaluation report.
December 29,2003 Letter from ConAgra, Evaluation of cold weather dust control.
December 30, 2003 Letter from ConAgra,December self evaluation report.
January 5, 2004 Letter from Weld County, Comments concerning monthly self evaluation report.
January 19, 2004 Letter from ConAgra, Response to our comments concerning self evaluation report.
January 30, 2004 Letter from ConAgra,January self evaluation report.
February 28, 2004 Letter from ConAgra, February self evaluation report.
March 17, 2004 Dust complaint. Cindi Etcheverry spoke with Stan Campbell on March 18, 2004.
He said they were nearly finished replacing the sprinkler heads and are working on
a well. He said they should be done by today or the next. Fugitive dust was not
confirmed.
March 18, 2004 Dust complaint. Cindi Etcheverry spoke with Stan Campbell. He said the wells
were nearly ready. Fugitive dust was not confirmed.
March 23, 2004 Dust complaint. Cindi Etcheverry spoke with Stan Campbell. He said they started
sprinkling the day before. Fugitive dust was not confirmed.
March 30, 2004 Letter from ConAgra, Monthly self evaluation report.
May 1, 2004 Letter from ConAgra, Cold weather dust control summary.
May 2, 2004 Letter from ConAgra,Aprils Monthly self evaluation report.
May 19, 2004 Stockpiling manure complaint. Troy Swain investigated complaint and determined
manure was being stockpiled in designated area.
May 30, 2004 Letter from ConAgra,Monthly self evaluation report.
June 7, 2004 Dust complaint. Troy Swain spoke with ConAgra. Pens were being watered the
on June 8, 2004. Fugitive dust was not confirmed.
July 10, 2004 Dust complaint. Fugitive dust was not confirmed.
Please do not hesitate to ask any questions that you may have.
2
Hello