Office of Water (4303)
               Washington, DC 20460
EPA-B21-B-01-001
January 2001
    Agency
EPA Environmental Assessment of
    Proposed Revisions to the
    National Pollutant Discharge
    Elimination System Regulation
    and the Effluent Guidelines for
    Concentrated Animal Feeding
    Operations

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   Environmental Assessment of Proposed Revisions to the
National Pollutant Discharge Elimination System Regulation
           and Effluent Limitations Guidelines for
          Concentrated Animal Feeding Operations
                          Carol M. Browner
                           Administrator

                           J. Charles Fox
                 Assistant Administrator, Office of Water

                           Sheila E. Frace
                Director, Engineering and Analysis Division

                         Donald F. Anderson
                      Chief, Commodities Branch

                          Patricia Harrigan
                        Environmental Assessor
                    Engineering and Analysis Division
                    Office of Science and Technology
                  U.S. Environmental Protection Agency
                       Washington, D.C.  20460
                            January 2001

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                 ACKNOWLEDGMENTS AND DISCLAIMER
This report has been reviewed and approved for publication by the Engineering and Analysis
Division, Office of Science and Technology, This report was prepared with the support of Abt
Associates Inc., under the direction and review of the Office of Science and Technology. Dr.
Gerald D. Stedge served as Abt Associates' Principal Investigator and Project Manager.  Dr.
Stedge was assisted by Mr. Peter Eglington, Ms. Amy Benson, Ms. Laura Kirk and Ms. Diane
Ferguson.

Neither the United States government nor any of its employees, contractors, subcontractors, or
other employees makes any warranty, expressed or implied, or assumes any legal liability or
responsibility for any third party's use of, or the results of such use of, any information,
apparatus, product, or process discussed in this report, or represents that its use by such a third
party would not infringe on privately owned rights.

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                               CONTENTS

EXECUTIVE SUMMARY	,	 ix

1.     INTRODUCTION	1-1
      1.1   BACKGROUND	1-1
      1.2   OVERVIEW OF ANIMAL FEEDING OPERATIONS 	1-3
      1.3   ORGANIZATION OF REPORT	1-6

2.     ANIMAL WASTE CHARACTERISTICS AND TRANSPORT TO SURFACE
      WATERS	2-1
      2.1   QUANTITY OF MANURE GENERATED	2-1
           2.1.1  Total Manure	2-1
           2.1.2  Recoverable Manure 	2-2
      2.2   POLLUTANTS OF CONCERN	2-7
           2.2.1  Nutrients	2-7
           2.2.2  Ammonia	2-10
           2.2.3  Pathogens	2-12
           2.2.4  Organic Matter	2-12
           2.2.5  Salts and Trace Elements	2-14
           2.2.6  Antibiotics	2-15
           2.2.7  Hormones	2-15
           2.2.8  Other Pollutants of Concern	2-15
      2.3   TRANSPORT OF MANURE POLLUTANTS TO SURFACE WATER .... 2-16
           2.3.1  Surface Discharges	2-16
           2.3.2  Other Discharges to Surface Waters 	2-18
           2.3.3  Pollutant-specific Transport	2-20

3.     POTENTIAL HAZARDS FROM AFO POLLUTANTS  	3-1
      3.1   PRIMARY NUTRIENTS 	3-2
           3.1.1  Ecology 	3-2
           3.1.2  Human Health	3-4
      3.2   AMMONIA	3-6
           3.2.1  Ecology 	3-6
           3.2.2  Human Health	 3-6
      3.3   PATHOGENS 	3-7
           3.3.1  Ecology	 3-7
           3.3.2  Human Health	3-7
      3.4   ORGANIC MATTER 	3-12
           3.4.1  Ecology	3-12
           3.4.2  Human Health 	3-13
      3.5   SALTS AND TRACE ELEMENTS 	3-13
           3.5.1  Ecology	3-13
           3.5.2  Human Health	3-14
      3.6   SOLIDS  	3-15
      3.7   ANTIBIOTICS AND ANTIBIOTIC RESISTANCE  	3-15

                                    iii

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      3,8   HORMONES AND ENDOCRINE DISRUPTION	 3-16
      3.9   OTHER POLLUTANTS OF CONCERN	3-16
           3.9.1  Gas Emissions 	3-16
           3.9.2  Particulates	3-17
           3.9.3  Pesticides	3-17

4.     NATIONAL AND LOCAL IMPACTS OF ANIMAL AGRICULTURE	4-1
      4.1   NATIONAL WATER QUALITY INVENTORY RESULTS  	4-1
      4.2   NATIONAL ANALYSES OF NUTRIENT CONTRIBUTIONS	4-3
           4.2.1  1994 USGS Study on Nitrogen Production from Various Sources .... 4-3
           4.2.2  1998 USDA Study of Nitrogen and Phosphorus Production Relative to
                 Crop Uptake Potential		4-6
           4.2.3  1997 USGS Modeling Study of Nitrogen and Phosphorus Loadings to
                 Surface Waters	4-12
      4.3   NATIONAL ANALYSIS OF SHELLFISH BED IMPAIRMENT	4-17
      4.4   LOCALMPACTS	4-17
           4.4.1  Lake Eucha	4-61
           4.4.2  The Chino Basin 	4-61
           4.4.3  Lake Waco and the Bosque River Watershed	4-62
      4.5   CASE STUDY SUMMARY	4-63

5.     EFFECTS OFTHE PROPOSED REGULATIONS  	5-1
      5.1   POTENTIAL BENEFITS FROM POLLUTANT REDUCTIONS  	5-1
      5.2   REPORTED BENEFITS OF ANIMAL WASTE MANAGEMENT AND
           RELATED NON-POINT SOURCE MEASURES IN SELECTED
           WATERSHEDS	5-5
           5.2.1  Benefits of Single Practices 	5-5
           5.2.2  Benefits of Multiple Practices 	5-6
                                    IV

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                                   EXHIBITS

EXHIBIT 1-1
      Industry Consolidation of Animal Feeding Operations, 1978 - 1992 	1-4
EXHIBIT 1-2
      Increase in the Average Number of Animal Units per Operation, 1978-1992	  1-4
EXHIBIT 1-3
      Farms, Number of Head, and Cropland, by Confined Animal Facility Size, 1992 ....  1-5
EXHIBIT 2-1
      Manure Production by Both Livestock and Humans	,	2-2
EXHIBIT 2-2
      Fraction of Recoverable Manure, by Animal and by State  	2-4
EXHIBIT 2-3
      Estimated Recoverable Manure and Manure Nutrients Generated by Sector	2-6
EXHIBIT 2-4
      Primary Nutrients in Both Livestock and Human Manures	2-8
EXHIBIT 2-5
      The Nitrogen Cycle 	2-9
EXHIBIT 2-6
      The Phosphorus Cycle	2-11
EXHIBIT 2-7
      Coliform Bacteria in Manure (colonies per cubic foot of manure, as excreted) 	2-12
EXHIBIT 2-8
      Reported BOD5 and COD Concentrations for Manures and Domestic Sewage	2-14
EXHIBIT 3-1
      Some Diseases and Parasites Transmittable to Humans from Animal Manure	3-8
EXHIBIT 3-2
      Etiology of Waterborne Disease Outbreaks Causing Gastroenteritis 1989-1996 -.... 3-10
EXHIBIT 4-1
      Five Leading Sources of Water Quality Impairment in the United States	4-1
EXHIBIT 4-2
      Summary of U.S. Water Quality Impairment Survey 	4-2
EXHIBIT 4-3
      Percent of Total Agricultural Impairment Contributed by Animal Agriculture  	4-2
EXHIBIT 4-4
      Five Leading Causes of Water Quality Impairment in the United States  	4-3
EXHIBIT 4-5
      Proportions of Nitrogen Sources in Selected Watersheds (1987 Base Year)  	4-5
EXHIBIT 4-6
      Estimated Manure Nitrogen Production from Confined Livestock	4-8
EXHIBIT 4-7
      Estimated Manure Phosphorus Production from Confined Livestock	4-9
EXHIBIT 4-8
      Potential for Nitrogen Available from Animal Manure to Meet or Exceed
      Uptake and Removal on Non-Legume, Harvested Cropland and Hayland	4-10

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EXHIBIT 4-9
      Potential for Phosphorus Available from Animal Manure to Meet or Exceed
      Uptake and Removal on Non-Legume, Harvested Cropland and Hayland	 4-11
EXHIBIT 4-10
      Predicted Local Nitrogen Yield in Hydrologic Cataloging Units  	4-13
EXHIBIT 4-11
      Predicted Local Total Phosphorus Yield in Hydrologic Cataloging Units 	4-14
EXHIBIT 4-12
      Predicted Percentage Contribution of Animal Waste to Local
      Total Nitrogen Export from Hydrologic Cataloging Units	4-15
EXHIBIT 4-13
      Predicted Percentage Contribution of Animal Waste to Local
      Total Phosphorus Export from Hydrologic Cataloging Units	4-16
EXHIBIT 4-14
      Shellfish Beds Impaired by Feedlots	4-17
EXHIBIT 4-15
      Description of Environmental Incidents and Impacts Tables ,	4-18
EXHIBIT 4-16
      Documented Discharges from Swine Operations to Surface Waters	4-19
EXHIBIT 4-17
      Documented Human Health Related Impacts from Swine Operations 	4-29
EXHIBIT 4-18
      Documented Ecological, Recreational, and Other Impacts from Swine Operations . . 4-30
EXHIBIT 4-19
      Documented Discharges from Poultry Operations to Surface Waters	4-37
EXHIBIT 4-20
      Documented Human Health Related Impacts from Poultry Operations 	4-39
EXHIBIT 4-21
      Documented Ecological, Recreational, and Other Impacts from Poultry Operations . 4-40
EXHIBIT 4-22
      Documented Discharges from Beef and Dairy Operations to Surface Waters 	4-41
EXHIBIT 4-23
      Documented Human Health Related Impacts from Beef and Dairy Operations	4-49
EXHIBIT 4-24
      Documented Ecological, Recreational, and Other Impacts from Beef and Dairy
      Operations  	4-50
EXHIBIT 4-25
      Documented Discharges to Surface Waters from Operations with Unspecified or Multiple
      Animal Types	4-51
EXHIBIT 4-26
      Documented Human Health-Related Impacts from Operations with Unspecified or
      Multiple Animal Types	4-57
                                         VI

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EXHIBIT 4-27
      Documented Ecological, Recreational, and Other Impacts from Operations with
      Unspecified or Multiple Animal Types	4-58
EXHIBIT 5-1
      Anticipated Benefits of the CAFO Proposed Regulations	5-2
                                         vn

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                               EXECUTIVE SUMMARY

States report that agriculture is the leading source of impairment in the nation's surveyed rivers
and lakes. In the states that categorized sources of impacts to rivers in 1998, intensive animal
operations accounted for over 15 percent of the total impairment due to agriculture. Manure and
other animal wastes from these animal feeding operations (AFOs) can result in human health and
potentially significant environmental impacts. Such impacts continue to cause concern despite
federal effluent limitation guidelines that address feedlots, which have been in place since 1974.
Since the EPA promulgated the original effluent guidelines, there have been persistent reports of
discharge and runoff of manure pollutants reaching surface and groundwater and resulting in fish
kills and other adverse impacts.

Animal production has undergone significant changes in the past several decades. Between 1987
and 1992, the total number of animal units increased by about 4.5 million (approximately 3
percent). At the same time, the number of facilities has decreased, indicating a consolidation
within the livestock industry.

Animal Waste Characteristics

Beef, dairy, swine, and poultry operations generated a total of 291 billion pounds of manure
(weight of dry-state or dried manure) in 1997. This figure represents  recoverable and non-
recoverable manure.  Recoverable manure is generally indicative of confined operations, because
it is waste that is contained within the production area. The U.S. Environmental Protection
Agency (EPA) estimates the amount of manure that is recoverable from each of the four animal
sectors addressed by the guidelines to be beef (16 percent), dairy (76 percent), swine (92
percent), and poultry (98 percent).

Animal waste contains a number of pollutants. The presence and concentration of these
pollutants may vary depending on the animal species and other factors, such as  animal size,
maturity, and health, as well as the composition (e.g., protein content) of animal feed.

Nitrogen, an essential nutrient required by all living organisms, exists in fresh manure in organic
and ammonium forms. Nitrogen can transform to nitrate, and it is then water soluble and highly
mobile in the environment. When farmers apply excess manure as fertilizer to crops, nitrates
may run off into surface water and may leach to groundwater. Like nitrogen, phosphorus also
exists in animal waste. As animal waste ages, the organic phosphorus mineralizes to inorganic
phosphate compounds and becomes available to plants.  Organic phosphorus compounds are
generally water soluble and may leach through soil  to groundwater and run off into surface
waters.  Inorganic phosphorus attaches to soil particles and may reach surface waters through
erosion.

The ammonia content of fresh manure varies among animal species and changes as the manure
ages. Ammonia content may increase as organic matter breaks down; it may decrease when
volatilization occurs or when nitrate oxidizes to nitrite under  aerobic  conditions. A major
method of transport of ammonia is through atmospheric deposition from airborne emissions.
                                           IX

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Livestock manure contains many pathogens, including protozoa, bacteria, and viruses. Multiple
species of pathogens may be transmitted directly from a host animal's manure and may increase
in number in a waterbody due to loadings of animal manure nutrients. Pathogen contamination
from AFOs includes discharges directly to surface waters and discharges from leaching lagoons,
and can reach surface waters and groundwater. Soil type, manure application rate, and soil pH
are dominating factors in the survivability of bacteria. Type of storage and length of storage also
affect bacterial survivability.

Organic compounds in animal manure can enter water directly from feedlots and land application
sites.  They then undergo decomposition by aquatic bacteria and other microorganisms. In the
process, the organisms consume dissolved oxygen, reducing the amount available for aquatic
animals. Measures that indicate presence of the organic compounds in manure are the
biochemical oxygen demand (BOD) and the chemical oxygen demand (COD). Even after
treatment, these measures are much higher for animal waste than for municipal treated waste.

Several other pollutants can reach surface water and groundwater. Dissolved mineral salts and
several trace elements (including arsenic, copper, selenium, and zinc) can reach surface waters
via discharges directly to the waterbody as well as runoff from land application sites and can
leach into groundwater. Although present in small amounts in manure, trace elements may
bioconcentrate in plants and animal tissues and persist in the environment.  The degradation of
animal wastes by microorganisms may produce gases with strong odors.  Particulate emissions,
pesticides, antibiotics, and hormones also exist in animal waste and may impact the environment.

Human Health Hazards Associated with Animal Wastes

Many constituents of animal waste, including primary nutrients, pathogens, salts, and gases, can
affect human health. Elevated nitrate levels in drinking water are a major health concern. In
particular, infants are at risk from nitrate poisoning (also referred to as methemoglobinemia or
"blue baby syndrome"), which results in oxygen starvation. Nitrate poisoning may increase the
risk of birth defects and miscarriages, and is potentially fatal.

Pathogens in animal waste cause many human diseases. These include salmonellosis,
cryptosporidiosis, giardiasis, cholera, typhoid fever, and polio. Humans may come into contact
with the pathogens via the  fecal-oral route, inhalation, or consumption of contaminated water.
The protozoan Cryptosporidium parvum is of particular concern because it is resistant to
conventional drinking water treatment. Cryptosporidium can produce gastrointestinal illness,
with symptoms such as severe diarrhea.

Salts  in animal waste are also a human health hazard. At low levels, salts can increase blood
pressure in salt-sensitive individuals, increasing the risk of stroke and heart attack. Trace metal
elements in manure can also impact human health For example, while zinc (a feed additive) is a
requirement for human physiology, it may induce toxicity at elevated concentrations.

The primary gases associated with aerobic decomposition include carbon dioxide and ammonia.
Gases associated with anaerobic conditions, which dominate in typical, unaerated animal waste

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lagoons, include methane, carbon dioxide, ammonia, hydrogen sulfide, and over 150 other
compounds. Many of the end products can produce negative impacts, including strong odors.

Ecological Effects Associated with Animal Wastes

Animal waste can also have an effect on the natural ecosystem. Perhaps the most documented
impact of nutrient pollution is the increased surface water eutrophication (nutrient enrichment)
and its effects on aquatic ecosystems. Eutrophication causes the enhanced growth and
subsequent decay of algae, which can lower dissolved oxygen content of a waterbody to levels
insufficient to support fish and invertebrates. In some cases, this situation can produce large
areas devoid of life because of a lack of sufficient dissolved oxygen. An example of this is the
"Dead Zone," a 10,000 km2 area in the Gulf of Mexico. Researchers believe the Dead Zone is
caused by excess chemical fertilizer; however, nutrients from animal waste have also contributed
to the problem. Eutrophication may increase the incidence of harmful algal blooms, which
release toxins as they die and can severely impact wildlife as well as humans.

Parasites, bacteria, and viruses in animal waste may be harmful to wildlife. Certain bacteria in
livestock waste cause avian botulism and avian cholera, which have killed thousands of
migratory waterfowl. Shellfish can concentrate a broad range of microorganisms in their tissues,
providing a pathway for pathogen transmission to predator organisms.

Ammonia is highly toxic to aquatic life and is a leading cause of fish kills. It is of environmental
concern because it exerts a direct oxygen demand on the receiving water as it breaks down.
Ammonia loadings can contribute to accelerated eutrophication of surface waters. Also, organic
matter in surface waters supports increased microbial population and activity, and as these
microorganisms degrade the organic matter, the amount of dissolved oxygen available to other
aquatic organisms decreases.

Salts from manure can impact the ecosystem. In fresh water, increasing the salinity can disrupt
the balance of the ecosystem. On land, salts can become toxic to plants and deteriorate soil
quality by reducing permeability and generally impacting physical condition. Trace elements in
manure can impact plants, aquatic organisms, and terrestrial organisms. For example, metals
such as zinc (a feed additive) can accumulate at high concentrations in soil and become toxic to
plants.

National and Local Impacts from Animal Agriculture

Several analyses have estimated nationwide impacts from animal operations.  First, in an analysis
of nitrogen sources (including manure, fertilizers, point sources, and atmospheric deposition) in
107  U.S. watersheds, the U.S. Geological Survey (USGS) found that proportions of nitrogen
originating from various sources differ according to climate, hydrologic conditions, land use,
population, and physical geography (Puckett, 1994). In several watersheds (particularly in the
South and Northeast), manure nitrogen accounts for a large portion of the total nitrogen added to
the watershed.
                                            XI

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In a second analysis, Lander et al. (1998) estimated the quantity of nutrients available from
confined livestock manure relative to crop growth requirements, by county, based on data from
the 1992 Census of Agriculture (USDC/Census Bureau, 1994). Recoverable manure nitrogen
exceeded crop system needs in 266 counties, and recoverable phosphorus exceeded crop system
needs in 485 counties.

A third analysis, by Smith et al. (1997), modeled transport of manure nutrients to surface water.
The authors found that animal waste is a significant source (relative to other local sources) of in-
strearn nutrient concentrations in many watershed outlets, particularly in the central and eastern
United States. They also conclude that livestock waste contributes more than commercial
fertilizer application to total phosphorus exported from local sources (independent of upstream
sources).

The EPA has also documented local impacts. In Oklahoma, Lake Eucha has very high nutrient
loads associated with poultry production operations.  In Florida, Lake Okeechobee has
experienced significant effects of phosphorus loadings from AFOs, In southeastern Delaware
and the Eastern Shore of Maryland, where poultry production is widespread, over 20 percent of
wells have nitrate levels exceeding the Maximum Contaminant Level (MCL) set by the EPA's
Office of Ground Water and Drinking Water. Furthermore, localities have reported various
ecological impacts associated with releases from AFOs, including eutrophication and fish kills.
Over a 10-year period, localities have also reported nearly 100  individual fish kill events
associated with spills and discharges from AFOs.

This Report

Unlike environmental assessments prepared to support other effluent guidelines, this report
focuses  on the qualitative impacts on human health and the environment associated with releases
of wastes to surface water from concentrated animal feeding operations  (CAFOs). The EPA is
not currently able to quantitatively evaluate all human health and ecosystem benefits associated
with water quality improvements  from reduced releases of CAFO wastes.  The EPA is even more
limited in its ability to assign monetary values to those benefits. The economic benefit analysis
is available in the benefit report, titled "Environmental and Economic Benefits of the
NPDES/ELG CAFO Rules" and located in section 9.5 of the public record.

To present a sense of the scope of the problem, this report relies on state and federal information,
as well as news articles and data collected by environmental advocacy groups. While data from
government agencies are more reliable, the resources are not available to thoroughly track
C AFO-related releases of pollutants to the environment and the resulting environmental and
human health impacts.  The intention of this more inclusive approach is to provide a sense of the
possible scope of the impacts until state and federal agencies can fully document them.
                                           XII

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1.      INTRODUCTION

1.1    BACKGROUND

Animal waste can have a negative impact on surface water, ground water, soil, and air. While
there are many sources of water pollution, states report that agriculture is the leading source of
impairment in the nation's surveyed rivers and lakes. Furthermore, nutrients and pathogens
account for a large percentage of contaminants found in the nation's impaired waters (USEPA,
2000a).

Animal feeding operations (AFOs or feedlots) can pose a number of risks to human health and
the environment, mainly because of the significant amount of animal manure they generate. In
1997, farm animals generated an estimated 291 billion pounds (132 million metric tons) of
manure (dry-state basis) (USDA/NRCS, 2000).' This figure far exceeds the estimated 49 billion
pounds (22 million metric tons) of human sanitary waste produced.  Since the calculations handle
human and animal wastes differently, this comparison does not provide an indication of relative
environmental impact; however, it does indicate the significance of animal waste as a potential
source of pollution.

AFOs contribute manure pollutants  to the environment via discharges directly into surface water,
surface runoff, leaching into soil and ground water, and volatilization/deposition. Sources of
these pollutants include animal confinement areas, pastures, treatment and storage lagoons,
manure stockpiles, and land application fields. Organic matter, ammonia, nutrients (particularly
nitrogen and phosphorus), solids, pathogens, and odorous compounds are the pollutants most
commonly associated with animal waste. Animal waste is also a source of salts and trace
elements, and to a lesser extent, pesticides, antibiotics, and hormones.

Manure can be a valuable fertilizer and soil conditioner, but in many cases it is  applied in excess
of crop nutrient requirements due to manure nutrient ratios that differ from crop needs, and/or
lack of available nearby land on which to spread the manure. This problem has been of
increasing concern as more concentrated feeding operations maintain greater numbers of animals.

In surface water, the waste's oxygen demand and ammonia content can directly result in fish
kills and reduced biodiversity.  Solids can increase turbidity and suffocate benthic organisms.
Nitrogen and phosphorus can contribute to eutrophication and associated algae blooms. These
blooms can produce negative aesthetic impacts and increase the costs of drinking water
treatment. Turbidity from the blooms can reduce penetration of sunlight in the water column and
thereby limit growth of seagrass beds and other submerged aquatic vegetation, which serve as
critical habitat for fish, crabs, and other aquatic organisms. Decay of algae blooms (as well as
nighttime algal respiration) can depress oxygen levels, leading to fish kills and reduced
biodiversity. Eutrophication is also a factor in blooms of toxic algae and other  toxic
microorganisms, such as Pfiesteria piscicida, which can affect human health as well as animal
health. Pathogens and nitrogen in animal waste can also affect human and animal health.
       'USDA's National Resources Conservation Service calculated animal waste figures using the 1997 Census
of Agriculture (USDA/NASS, 1999) and the procedures in Lander et al. (1998).

                                           1-1

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Nitrogen in manure is easily transformed into its nitrate form, which can be transported to
drinking water sources and result in potentially fatal health risks to infants. Trace elements in
manure may also present human health and ecological risks.  Salts can contribute to salinization
and disruption of ecosystems. Antibiotics, pesticides, and hormones may have low-level, long-
term human health and ecological effects.

Ground water sources of drinking water can have impacts from nitrates, pathogens, salts, and
other contaminants from manure. Ground water is typically more prone than surface water to
contamination by nitrates, in particular.  In fact, the EPA found that nitrate is the most
widespread agricultural contaminant in drinking water wells and estimates that 4.5 million
people are exposed to elevated nitrate levels from wells (USEPA, 1990).

In soils, salts and trace elements from land-applied manure can accumulate and become toxic to
plants.  Salts can deteriorate soil quality by leading to reduced permeability and poor tilth.  Crops
may provide a human and animal exposure pathway for trace elements and pathogens.

Air emissions from volatilization occurring at AFOs also produce environmental impacts.  Odors
from anaerobic waste decomposition are particularly offensive.  Odors can produce mood
disorders such as tension, depression, and fatigue (Schiffman et al,, 1995;  Thu, 1995). Many
odor-causing substances (e.g., ammonia, hydrogen sulfide, and organic dusts) can  also cause
physical effects. Furthermore, volatilized ammonia can be redeposited on the earth and
contribute to eutrophication of surface waters. Methane emissions from anaerobic waste lagoons
are a concern because they increase greenhouse gas concentrations.

Such impacts continue to cause concern despite federal effluent limitation guidelines (ELGs5
"effluent guidelines," or "guidelines") that have been in place for feedlots  since 1974.
Essentially, these guidelines apply to large operations and prohibit discharges to surface waters
except when chronic or catastrophic rainfall events cause an overflow from a containment
system. The current regulations do not specifically address discharges that may occur when
wastes are applied to soil.

To help address the various concerns outlined above, the EPA is currently revising the feedlots
effluent limitation guidelines. This report presents the environmental assessment  of the proposed
regulations for the pork, poultry, beef, and dairy sectors of concentrated animal feeding
operations (CAFOs),  Briefly, each animal sector is composed of:

       •  pork:      facilities that produce mature or immature swine;
       «  poultry:    facilities that produce laying hens, broilers, and turkeys;
       •  beef:      facilities that produce all cattle—this includes veal and replacement
                     heifers and excludes mature dairy cattle; and
       •  dairy:      facilities that produce mature dairy cattle, whether milked or dry.
                                           1-2

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1.2    OVERVIEW OF ANIMAL FEEDING OPERATIONS

Animal production industries have undergone significant changes in the past several decades.
Domestic and export market forces, technological changes, and industry adaptations have
promoted expansion in the number of confined production units. This includes:

       »   growth in both existing and new areas;
       •   integration and concentration of some industries;
       *   geographic separation of animal production and feed production operations; and
       •   the concentration of large quantities of manure and wastewater on farms and in some
          watersheds (USDA/USEPA, 1999),

In terms of production, the total number of animal units produced in the U.S. increased by about
4.5 million (approximately three percent) between 1987 and 1992.  During the same period,
however, the number of AFOs decreased, indicating a consolidation within the industry overall
and greater production from fewer, larger AFOs (USGAO, 1995b). These changes are not
uniform across animal type or across the country.

Exhibits 1-1 and 1-2 illustrate the consolidation of animal production between 1978 and 1992.
The number of operations decreased significantly for most major animal types during this period
(Exhibit 1-1). At the same time, the average number of animals per operation increased
significantly (Exhibit 1-2).
                                         1-3

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                                     EXHIBIT 1-1
                  Industry Consolidation of Animal Feeding Operations
                                      1978 -1992
Compiled from data in USGAO (1995b),

         400,000
         300,000
       g. 200,000
       o
         100,000
                  Cattle
Dairy
Hogs (top
   10
production
 states)
Broilers
Layers
Turkeys
                                     EXHIBIT 1-2
                           Increase in the Average Number of
                         Animal Units per Operation, 1978-1992
Animall^ype
Swine
Layers
Broilers
Turkeys
Beef Cattle
Dairy Cattle
Increase in
Animal Units/Operation
134%
176%
148%
129%
56%
93%
                       Derived from data in USGAO (1995b).
                                           1-4

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Confined AFOs range in size from small-scale operations with few animals to large, intensive
production facilities.  Letson and Gollehon (1996) analyzed 1992 Census of Agriculture data
(USDC/Census Bureau, 1994) to estimate the distribution of confined animals among various
farm sizes (Exhibit 1-3). Their analysis shows that for all animal types, small facilities accounted
for a large share of farms, but a small percentage of animals. Larger farms were less numerous,
but maintained a disproportionately greater percentage of animals.  The greatest proportion of
layers and beef cattle were raised on large farms, whereas medium-sized farms accounted for the
greatest proportion of swine, broilers, turkeys, and dairy cattle.

                                     EXHIBIT 1-3
      Farms, Number of Head, and Cropland, by Confined Animal Facility Size, 1992
Animal Type
Small
(< 50 AUs)
Number
Percent
Medium
(50 to 999 AUs)
Number
Percent
Large
(> 1,000 AUs)
Number
Percent
Swine
Number of farms
Total Head (1,000s)
Total Cropland (1,000 acres)
115,830
3,089
17,029
56%
5%
30%
88,042
38,984
37,121
43%
68%
66%
2,578
15,270
1,795
1%
27%
3%
Layers
Number of farms
Total Head (1,000s)
Cropland (1,000 acres)
81,903
4,033
8,848
93%
1%
90%
5,733
137,366
881
6%
39%
9%
599
209,911
149
1%
60%
2%
Broilers
Number of farms
Total Head (1,000s)
Total Cropland (1,000 acres)
17,65?
2,193
2,207
49%
<1%
58%
16,704
684,507
1,371
47%
73%
36%
1,398
246,667
211
4%
26%
6%
Turkeys
Number of farms
Total Head (1,000s)
Total Cropland (1,000 acres)
7,379
892
848
70%
1%
60%
2,911
64,019
535
28%
74%
38%
276
21,703
33
3%
25%
2%
Beef
Number of farms
Total Head (1,000s)
Total Cropland (1,000 acres)
134,847
995
34,199
92%
10%
75%
11,411
1,941
10,160
8%
19%
22%
943
7,098
1,117
1%
71%
2%
Dairy
Number of farms
Total Head (1,000s)
Total Cropland (1,000 acres)
43,700
238
6,097
28%
3%
16%
110,700
8,002
32,524
71%
84%
83%
939
1,252
515
1%
13%
1%
 Source: Letson and Gollehon (1996).
                                           1-5

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The Letson and Gollehon (1996) analysis also provides useful insight regarding the cropland held
by various sizes of AFOs. As shown in Exhibit 1-3, medium and large poultry operations
(particularly layer facilities and beef operations) account for a large percentage of animals, but a
small percentage of cropland on which to apply manure. Pork and dairy operations exhibit a
similar characteristic for large farms. The amount of cropland ultimately influences animal waste
disposal options.  Historically, farm enterprises integrated crop and animal production by using
the manure generated to fertilize crops, constituting a crucial element of manure management.
Such integrated pork and dairy operations are still common, particularly in the eastern Corn Belt.
However, the breeding and raising phases of livestock production increasingly occurs in large-
scale, specialized operations.  This trend toward high-volume commercial enterprises separates
the locations of manure generation and cropland available for its application (Letson and
Gollehon, 1996).

1.3    ORGANIZATION OF REPORT

This report presents a water-quality-based environmental impact assessment of the proposed
regulations for swine, poultry, beef, and dairy CAFOs.  Chapter 2 quantifies the amount of
manure and total solids generated by swine, poultry, beef, and dairy operations as well as by
other livestock and humans. Chapter 2 also provides information on animal manure  constituents.
Chapter 3 describes the potential human health and ecological hazards from manure pollutants.
Chapter 4 discusses studies that estimate the potential environmental impact of animal waste at
the national level and describes other reported impacts.  Finally, Chapter 5 describes potential
and reported benefits from the implementation of proposed management practices to control
wastes from animal feeding operations.

To present a seme of the scope of the problem, this report relies on state and federal information,
as well as news articles and data collected by environmental advocacy groups. While data from
government agencies are considered more reliable, the resources are not available to thoroughly
track CAFO-related releases of pollutants to the environment and the resulting environmental
and human health impacts. This more inclusive approach is intended to provide a sense of the
possible scope of the impacts until state and federal agencies can fully document them.
                                           1-6

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2.     ANIMAL WASTE CHARACTERISTICS AND TRANSPORT
      TO SURFACE WATERS

Animal feeding operations generate large volumes of waste of the following types:

      •   animal manure and urine;
      •   hair, feathers, and corpses;
      •   bedding and spilled feed;
      •   wash-flush water; and
      «   other processing wastes.

Many of these wastes are convertible to useful resources, such as fertilizer, soil conditioner, and
feed (Shih, 1993; Edwards and Daniel, 1992a; USDA, 1992). However, these wastes can be a
source of environmental degradation when improperly managed. In many cases, manure is
applied in excess of crop nutrient requirements, due to manure nutrient ratios that differ from
crop needs and/or lack of available nearby land. For example, the U.S. Fish and Wildlife Service
estimates that the amount of phosphorus currently excreted by livestock in Nebraska exceeds
what can currently be applied to farm fields at agronomic rates statewide (USFWS, 2000). This
problem has received increasing attention as livestock operations have become more
concentrated, with a trend toward more animals on fewer farms and less land. Incidents of
discharges from waste storage lagoons, excessive runoff, leaking lagoons, and offensive odors
have heightened public awareness and concerns about environmental impacts from AFOs.

Although many of the above-mentioned wastes can pose environmental risks, this chapter
focuses on the characteristics of manure, which is often cited as a significant contributor to water
quality degradation (USEPA, 1997a).  In general, pollutant production figures reported here are
based on 1997 data, the most readily available Census of Agriculture data (USDA/NRCS, 2000;
USDA/NASS, 1999). USDA's Natural Resources  Conservation Service (NRCS) estimated the
quantities of manure and primary nutrients generated by livestock. NRCS based its approach on
Lander et al.  (1998), which provides a more detailed description of the methods and data sources
used.

2.1   QUANTITY OF MANURE GENERATED

2.1.1  Total Manure

The large quantity of animal waste helps demonstrate why proper handling and disposal are
essential in limiting environmental risks from manure.  Animal manure is significantly more
abundant than human waste.  USDA's National Resources Conservation Service estimated that
291 billion pounds of manure measured on a wet basis (132 million metric tons when dried) was
generated in  1997 from swine, poultry, and beef and dairy cattle (USDA/NRCS 2000) (see
                                         2-1

-------
Exhibit 2-1).2 By comparison, the human sanitary waste production for that year was only 49
billion pounds (22 million metric tons total solids, dry-weight basis) (USDA/NRCS, 1996). This
comparison, however, cannot be used as a surrogate for the relative extent of environmental
impacts, since human and animal wastes are handled differently. For example, human sanitary
waste is typically treated at a wastewater treatment plant, with the liquid effluent being
discharged after treatment to surface water and the residual solids (sludge, or biosolids) being
land applied, landfilled, or incinerated. Animal waste is typically land applied in its entirety,
without an associated point source discharge (if properly applied). Nevertheless, the figures
provide a sense of the  significance of the total animal waste problem, especially in light of
industry trends toward increased concentration of animals on farms. The figures are also relevant
when considering that disposal of human waste is highly regulated, but disposal of animal waste
has been largely unregulated.

                                       EXHIBIT 2-1
                    Manure Production by Both  Livestock and Humans
Species
Swine
Layer
Broiler
Turkey
Beef
Dairy
Human
Average
Mass of Species
(pounds)
135
4,0
2,0
15
800
1,400
150
Pounds Per 1,000 Pounds Live Unit Weight Per Day
Wet-Weight Manure "
84
64
85
47
58
86
30
Dry-Weight Manure b
8.2
16
21
12
6.9
10
3.3
 Sources: Livestock data are "as excreted" and are from ASAE (1999); human waste data are "as excreted" and are
 from USDA/NRCS (1996).
 Values rounded to two significant figures,
 1 Includes feces and urine as voided.
 h Calculated using average solids content for each category, based on data from USDA/NRCS (1996).

2.1.2  Recoverable Manure

Although the above figures give a good indication of the magnitude of the total animal waste
problem, they are not the best indicators of the problem that the proposed regulations address,
because much of the total manure is generated by grazing or pastured animals, which are not the
subject of the proposed regulations. Instead, the regulations address the manure generated by
confined animal facilities, which is considered recoverable manure because waste is contained
within the production area.  Recoverable manure may include scraped manure, stored slurry
       2These quantities reflect the most recent estimates by USDA of manure generation from livestock
operations, using data from the 1997 Census of Agriculture (USDA/NASS, 1999) and an approach developed by
Lander et al. (1998).  USDA's estimates are calculated on a wet manure basis, but expressed on a "dry-state" basis
(to adjust for water content). Previous studies have reported a wide range of manure generation estimates for
livestock and poultry operations that vary depending on the approach used and on whether the load is estimated on a
wet or dry basis.
                                             2-2

-------
manure, lagoon effluent, and poultry litters, and may be applied later to croplands as fertilizer
(Westerman et al, 1985).

It is important to estimate the amount of recoverable manure produced, not only to provide a
good representation of the amount produced by confined animal operations, but also because
recoverable manure may be a usable resource.  For each state, Exhibit 2-2 lists the fraction of
manure produced by major animal sectors that is recoverable. Lander et al. (1998) prepared these
estimates using state survey responses from a study by Van Dyne and Gilbertson (1978).

As presented in Exhibit 2-2, nearly all manure  (90 to 100 percent) from layers and broilers in the
major producing states was  recoverable.  Turkey manure recovery ratios varied more widely in
the top producing states. For example, recovery ratios ranged from 70 to 100 percent in North
Carolina, South Carolina, Texas, Virginia, and Wisconsin, whereas they were only 20 to 45
percent in California, Michigan, and Minnesota. Approximately 90 percent of all swine manure
in North Carolina was recoverable. In other major pork producing states, manure recovery ratios
ranged from 65 to 85 percent. In top producing beef states, only five to ten percent of the manure
from grazing cattle was recoverable, whereas 60 to 90 percent of the manure from fattened cattle
was recoverable. Recovery ratios for milk cows in top producing states ranged from 75 to 90
percent.
                                           2-3

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                                         EXHIBIT 2-2
Fraction of Recoverable Manure, by Animal and by State (Top Ten Producing States Indicated by Bold
Font)
State
AL
AZ
AR
CA
CO
CT
DE
FL
GA
ID
IL
IN
IA
KS
KY
LA
ME
MD
MA
MI
MN
MS
MO
MT
NE
Beef
(Grazing)
0.10
0.05
0.10
0.05
O.OS
0.10
0.10
0.00
0.00
0.00
0.10
0.10
0.10
0.05
0.08
0.00
0,10
0.10
0.10
0.08
0.15
0.10
0.10
0.01
0.08
Beef
(Fattened)
0.70
0.85
0,50
0.85
0.8S
0.85
0.85
0.00
0.75
0.85
0.60
0.75
0.63
0.75
0.70
0.80
0.85
0.85
0.85
0.75
0.90
0.75
0,60
0.85
0.90
Milk
0.40
0.80
0.50
0.80
0.80
0.90
0.80
0.50
0.70
0.95
0.80
0.60
0.87
0.85
0.70
0.50
0.80
0.80
0.80
0.90
0.90
0.60
0.65
0.75
0.80
Swine
(Breeding)
0.75
0.85
0.50
0,85
0.85
0.80
0.80
0.40
0.50
0.70
0.70
0.80
0.80
0.80
0.60
0.80
0.80
0.80
0.80
0.66
0.85
0.65
0.6S
0.80
0.66
Swine
(Other)
0.75
0.85
0.50
0.85
0.85
0.80
0.80
0.40
0.50
0.70
0.70
0.80
0.80
0.80
0.60
0.80
0.80
0.80
0.80
0.66
0.85
0.65
0,65
0.80
0.66
Laying
Hen/Pullet
0.95
0.90
0.80
1.00
0.95
1.00
0.90
0.95
0.90
0.90
1.00
0.95
0.99
0.95
0.80
1,00
0.90
0.90
0.90
1.00
1.00
0.90
0.85
1.00
1.00
Pullets
(<3 mos.)
0.95
0.90
0.80
1.00
0.95
1.00
0.90
0.95
0.90
0.90
1.00
0.95
0.99
0.95
0.80
1.00
0.90
0.90
0,90
1.00
1.00
0.90
0.85
1.00
1.00
Broilers
0.98
0.90
0.95
1.00
0.95
0,95
0.95
0.95
0.95
0.90
1.00
0.95
0.99
0.95
0.80
1.00
0.95
0.95
0.95
1.00
1.00
0.95
0.90
1.00
1.00
Turkeys
(slaughter)
0.85
0.65
0.70
0.20
0.65
0.95
0.95
0.85
0.85
0.65
0.95
0.95
0.69
0.75
0.80
0.80
0.95
0.95
0.95
0.45
0.40
0.85
0.75
0.90
0.64
Turkeys
(breeding)
0.85
0.65
0.70
0.20
0.50
0.95
0.95
0.85
0.85
0.65
0.95
0.95
0.69
0.75
0.80
0.80
0.95
0.95
0.95
0,45
0.40
0.85
0.75
0.90
0.64

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                                                        EXHIBIT 2-2
        Fraction of Recoverable Manure, by Animal and by State (Top Ten Producing States Indicated by Bold
Font)
State
NV
NH
NJ
NM
NY
NC
ND
OH
OK
OR
PA
RI
SC
SD
TN
TX
UT
VT
VA
WA
WV
WI
WY
Beef
(Grazing)
0.05
0.10
0.10
0.00
0.10
0.00
0.00
0.10
0.10
0.05
0.05
0.10
0.00
0.10
0.10
o.os
0.05
0.20
0.10
0.05
0.00
0.08
0.05
Beef
(Fattened)
0.85
0.85
0.85
0.80
0.85
0.75
0.85
0.70
0.80
0.85
0.85
0.85
0,80
0.75
0.75
0.85
0.85
0.90
0.85
0.85
1.00
0.70
0.80
Milk
0.80
0.80
0.80
0.85
0.80
0.59
0.80
0.90
0.65
0.60
0.80
0.80
0.59
0.80
0.60
0.75
0.80
0.90
0.60
0.80
0.80
0.90
0.80
Swine
(Breeding)
0.85
0.80
0.80
0.85
0.80
0.90
0.50
0.75
0.75
0.85
0.80
0.80
0.49
0.70
0.65
1.00
0.85
0.80
0.80
0.85
0.75
0.66
0.75
Swine
(Other)
0.85
0.80
0.80
0.90
0.80
0.90
0.50
0.75
0,75
0.85
0.80
0.80
0.49
0.70
0.65
1.00
0.85
0.80
0.80
0.85
0.75
0.66
0.75
Laying
Hen/Pullet
0.90
1.00
0.90
0.90
0.90
1.00
1.00
1.00
1.00
0.90
0.95
0.90
1.00
0.95
0.90
1.00
0.90
0.90
1.00
0.80
1.00
1.00
0.95
Pullets
(<3 mos.)
0.90
1.00
0.90
0.90
0.90
1.00
1.00
1.00
1.00
0.90
0.95
0.90
1.00
0.95
0,90
1.00
0.90
0.90
1.00
0.80
1.00
1.00
0.95
Broilers
0.90
1.00
0.95
0.90
0.95
1.00
1.00
1.00
1.00
0.90
0.95
0.95
1.00
0.95
0.95
1.00
0,90
0.95
1.00
0.80
1.00
1.00
0.95
Turkeys
(slaughter)
0.65
0.95
0,95
0.65
0.95
0.99
0,85
0.70
0,80
0.65
0.95
0.95
0.85
0.80
0.85
1.00
0.65
0.95
1.00
0.65
1.00
0.70
0.75
Turkeys
(breeding)
0.65
0.95
0.95
0.65
0.95
0.99
0.85
0.70
0.80
0.65
0.95
0.95
0.85
0.80
0,85
0.80
0.65
0.95
1.00
0.65
1,00
0.70
0,75
Source: Recoverable fractions are from Lander et al. (1998). Top producing states were identified through the 1992 Census of A griculture
(USDC/Census Bureau, 1994).

-------
Exhibit 2-3 lists the amount of recoverable manure and recoverable nutrients (nitrogen and
phosphorus) generated by individual animal sectors (beef, dairy, swine, and poultry operations)
throughout the U.S. in 1997. Nationwide, approximately 16 percent of beef manure was
recoverable, accounting for 22 percent of total recoverable livestock manure (dry-state).
Approximately 76 percent of dairy manure was recoverable, translating to 37 percent of
recoverable livestock manure. About 92 percent of swine manure was recoverable, accounting
for 13 percent of total recoverable livestock manure. Nationwide, 98 percent of poultry manure
was recoverable, representing approximately 27 percent of recoverable livestock manure.  These
quantities reflect the most recent estimates by USDA of manure generation from livestock and
poultry operations, using an approach developed by Lander et al. (1998). The benefits analysis
contains additional information on manure production.

                                     EXHIBIT 2-3
       Estimated Recoverable Manure and Manure Nutrients Generated by Sector
Animal Group
Beef
Dairy
Swine
Poultry - Total
Layers
Broilers
Turkeys
1997 Manure Production
Recoverable
Manure
(million Ibs)
28,637
47,476
17,120
34,979
7,101
19,199
8,679
Total, all livestock II 128,212
Percent of Total
Manure Production
That Is Recoverable
16%
76%
92%
98%
98%
98%
98%
44%
Recoverable
Nitrogen
(1,000 Ibs)
484
672
274
1,153
231
616
306
2,583
Recoverable
Phosphorus
(1,000 Ibs)
340
266
277
554
123
255
175
1,437
  Calculated by USDA/NRCS based on 1997 Census of Agriculture (USDA/NASS, 1999) using procedures in
  Lander et al. 1998, Numbers are "dry state" (wet basis, adjusted for water content).
Recoverable Nitrogen

Poultry manure has the highest amount of recoverable nitrogen (58 percent), making up 45
percent of all recoverable nitrogen for the sectors under consideration.  Dairy manure has the
next highest amount of recoverable nitrogen (30 percent), accounting for 26 percent of all
recoverable nitrogen for the sectors under consideration. Manure from pork operations had the
third highest amount of recoverable nitrogen (23 percent), accounting for 11 percent of the total
for these sectors.  Beef manure had the lowest ratio of recoverable nitrogen (6 percent), but due
to volume this source accounted for 19 percent of the total for all sectors (Lander et al., 1998).

Recoverable Phosphorus

Poultry manure also had the highest amount of recoverable phosphorus (83 percent), making up
39 percent of all recoverable phosphorus. Swine manure had the second highest amount of
recoverable phosphorus (78 percent), accounting for 19 percent of the recoverable phosphorus
                                           2-6

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from the sectors considered.  Manure from dairy operations ranked third for recoverable
phosphorus (66 percent) and generated 19 percent of the recoverable phosphorus from all four
sectors. As with nitrogen, beef manure also had the lowest ratio of recoverable phosphorus (14
percent), but due to volume this source ranked second for all sectors with 24 percent (Lander et
al., 1998).

2.2    POLLUTANTS OF CONCERN

The primary pollutants associated with animal waste are nutrients (particularly nitrogen and
phosphorus), ammonia,3 pathogens, and organic matter. Animal waste is also a source of salts
and trace elements, and to a lesser extent, antibiotics, pesticides, and hormones.  The actual
composition of manure depends on the animal species, size, maturity, and health, as well as on
the composition (e.g., protein content) of animal feed (Phillips et al., 1992).  After waste has
been excreted, it may be altered further by the bedding and waste feed, and may be diluted with
water (Loehr, 1972; USDA,  1992).

The following sections describe the characteristics of each main group of AFO pollutants. The
estimates of manure pollutant production are based on average values reported in the scientific
literature and compiled by the American Society of Agricultural Engineers (ASAE, 1999),
USDA/NRCS (1996), and USDA/ARS (1998).

2.2.1   Nutrients

The three primary nutrients in manure are nitrogen, phosphorus, and potassium. Much of the
past research on animal manure has focused on these constituents, given their importance as
cropland fertilizers. The following discussions provide more detail on nitrogen and phosphorus
characteristics and concentrations in manure. Scientific literature and policy statements
commonly cite these two nutrients as key sources  of water quality impairments.  In the central
United States, a 1995 estimate notes that 37 percent of all nitrogen and 65 percent of all
phosphorus inputs  to watersheds  come from manure (USFWS, 2000). Actual or anticipated
levels of potassium in ground water and surface water are unlikely to pose hazards to human
health or aquatic life (Wetzel, 1983). Potassium does contribute to salinity, however, and
applications of high salinity manure  are likely to decrease the fertility of the  soil.

Exhibit 2-4 presents the amounts of total Kjeldahl nitrogen,4 total phosphorus, orthophosphorus,
and potassium generated per 1,000 pounds live animal weight per day (ASAE, 1999). For
comparison, Exhibit 2-4 presents similar information for humans.  The figures illustrate that per-
pound nutrient output varies among  animal types and is much higher for animals than humans.
       3Ammonia is also a nutrient but is listed separately here because it exhibits additional environmental
effects, such as aquatic toxieity and direct dissolved oxygen demand.

       4Total Kjeldahl nitrogen is the sum of organic nitrogen in the trinegative oxidation state and ammonia.

                                           2-7

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                                      EXHIBIT 2-4
                Primary Nutrients in Both Livestock and Human Manures
Nutrient
Mass of animal (Ibs.)
Animal Group
Swine
135
Layer
4.0
Broiler
2.0
Turkey
15
Beef
800
Dairy
1,400
Human
150
Pounds per 1,000 pounds live animal weight per day
Nitrogen
(Total Kjeldahl)
Phosphorus (Total)
Orthophosphorus
Potassium
0.52
0.18
0.12
0.29
0.84
0.30
0.09
0.30
1.1
0.30
n/a
0.40
0.62
0.23
n/a
0.24
0.34
0.092
0.03
0.21
0.45
0.094
0.061
0.29
0.20
0.02
n/a
0.07
 Sources: Livestock data are "as excreted" and are from ASAE (1999); human waste data are "as excreted" and are
 from USDA/NRCS (1996).
 Values rounded to two significant figures.
 n/a = not available

Nitrogen Compounds

Nitrogen (N) is an essential nutrient required by all living organisms.  Nitrogen occurs in the
environment in gaseous forms (elemental nitrogen, N2; nitrogen oxide compounds, N2O and NOX;
and ammonia, NH3); water soluble forms (ammonia, NH3; ammonium, NH4+; nitrite, NO2"; and
nitrate, NO3~); and as organic nitrogen, bound up in the proteins of living organisms and decaying
organic matter (Brady, 1990). The transformation of the different forms of nitrogen among land,
water, air, and living organisms is known as the nitrogen cycle (Exhibit 2-5).

Nitrogen in fresh manure exists primarily in the organic and ammonium forms (NCAES, 1982).
Sixty to 90 percent of total nitrogen in fresh manure is in the organic form.5 Organic nitrogen in
the solid content of animal feces is mostly in the form of complex molecules associated with
digested food, while organic nitrogen in urine is mostly in the form of urea ((NH2)2CO) (USDA,
1992).  In organic form, nitrogen is unavailable to plants. However, via microbial processes,
organic nitrogen is transformed to ammonium (NH4+) and nitrate (NO3") forms, which are
bioavailable and therefore have fertilizer value.

Under aerobic conditions, ammonia can oxidize to nitrites and nitrates.  Subsequent anaerobic
conditions can result in denitrification (transformation of nitrates/nitrites to gaseous nitrogen
forms). Overall, depending on the animal type and specific waste management practices,
between 30 and 90 percent of nitrogen excreted in manure can be lost before use as a fertilizer
(Vanderholm, 1975).
       5In an anaerobic lagoon, the organic fraction is about 20 to 30 percent of total nitrogen (USDA, 1992).

                                           2-8

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   EXHIBIT 2-5
The Nitrogen Cycle
          At mospher i c
            Nitrogen
                                 Leaching Loss
    Source: O'Leary et al, 1997.

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Phosphorus Compounds

Phosphorus exists in solid and dissolved phases, in both organic and inorganic forms. Like
nitrogen, the various forms of phosphorus are subject to transformation (Exhibit 2-6). Dissolved
phosphorus in the soil environment consists of orthophosphates (PO4"3, HPO4"2, or H2PCv),
inorganic polyphosphates, and organic phosphorus (Poultry Water Quality Consortium, 1998).
Solid phosphorus exists as organic phosphorus in dead and living materials; mineral phosphorus
in soil components; adsorbed phosphorus on soil particles; and precipitate phosphorus, which
forms upon reaction with soil cations such as iron,  aluminum, and calcium (Poultry Water
Quality Consortium, 1998). Orthophosphate species, both soluble and attached, are the
predominant forms of phosphorus in the natural environment (Bodek et al., 1988). Soluble
(available or dissolved) phosphorus  generally accounts for a small percentage of total soil
phosphorus. However, soils saturated with phosphorus can have significant occurrences of
phosphorus leaching. Soluble phosphorus is the form used by plants and is subject to leaching.
About 73 percent of the phosphorus in most types of fresh livestock waste is in the organic form
(USDA,  1992). As animal waste ages, the organic  phosphorus mineralizes to inorganic
phosphate compounds and becomes available to plants.

2.2.2  Ammonia

Ammonium (NH4+) is produced when microorganisms break down organic nitrogen products
(e.g., urea and proteins in manure).  This decomposition can occur in either aerobic or anaerobic
environments. In solution, ammonium enters into an equilibrium reaction with ammonia (NH3),
as shown in the following equation:

                                    NH4+ * NH3 + H4

Up to 50 percent or more of the nitrogen in fresh manure may be in the ammonia form or
converted to ammonia relatively quickly once manure is excreted (Vanderholm, 1975).
Ammonia is very volatile, and much of it is emitted as a gas, although it may also be absorbed by
or react with other substances.

Higher pH levels (lower H+ concentrations) favor the formation of ammonia, while lower pH
levels (higher H+ concentrations) favor the formation of ammonium.  The ammonia form is
subject to volatilization.

The ammonia content of fresh manure varies among animal species and changes as the manure
ages. Ammonia content may increase as organic matter breaks down; it may decrease when
volatilization occurs or when nitrate oxidizes to nitrite under aerobic conditions.
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                      EXHIBIT 2-6

                   The Phosphorus Cycle
Phosphate
             ,Removal by Crops —>*

                           Crop Residue
                            and Manure
                          Return Phosphate
                              to Soil
                                     Runoff to Water Body
   pnqspnaie     k                 ^^x^^c±^
Added in Fertilizer fMjptake of   . t.  "  ,. ^-^J
                               Mineralization of
                              0rqarijC phosphate
      Inorganic
      Available
     Phosphate *<
                         Fixed Phosphate
                  Source: Busman et al., 1997.

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2.2.3   Pathogens

Both manure and animal carcasses can be sources of pathogens (disease-causing organisms) in
the environment (Juranek, 1995). Livestock manure may contain bacteria, viruses, fungi,
helminths, protozoa, and parasites, many of which are pathogenic (USDA, 1998; Jackson et al.,
1987). For example, researchers have isolated pathogenic bacteria and viruses from feedlot
wastes (Derbyshire et al., 1966; Hrubant, 1973; Derbyshire and Brown,  1978). In addition,
USFWS (2000) has shown fields receiving animal waste applications to have elevated levels of
fecal coliforms and fecal streptococci. Specifically, bacteria such as Escherichia coli O157:H7,
Salmonella species, Campylobacter jejuni, Listeria monocytogenes, and Leptospira species are
often found in livestock manure and have also been associated with waterborne disease. A recent
study by the USDA revealed that about half the beef cattle presented for slaughter during July
and August 1999 carried Escherichia coli O157:H7 (Elder et al., 2000). Also, protozoa,
including Cryptosporidium parvum and Giardia species (such as Giardia lamblia), may occur in
animal waste.  Cryptosporidium parvum is associated with cows in particular; newborn dairy
calves are especially vulnerable to infection and excrete large numbers of the infectious oocysts
(USDA, 1998). Most pathogens are shed from host animals with active infections.

Presence of bacteria (and other pathogens) is often measured by the level of fecal coliforms,
Escherichia coli, or enterococci  in manure (Bouzaher et al., 1993). Use of indicator organisms
such as these has limitations; specifically, that there are no established relationships between
fecal coliform and pathogen contamination. However, indicators are still used because specific
pathogen testing protocols are too time consuming, expensive, and/or insensitive to be used for
monitoring purposes (Shelton, 2000). Exhibit 2-7 lists the number of total coliform bacteria,
fecal coliform bacteria, and fecal streptococcus bacteria per cubic foot of manure for swine,
poultry, beef, and dairy animals  (ASAE, 1999).

                                      EXHIBIT 2-7
       Coliform Bacteria  in Manure (colonies per cubic foot of manure, as excreted)
Animal Group
Swine
Poultry (layers)
Beef
Dairv
Total Coliform
Bacteria
1.6 x 10"
4.7 x 10"
3.2 x 10"
36 x 10"
Fecal Coliform
Bacteria
5.9 x 10'°
3,2 x 1010
14 x 10'°
5.2 x 10'°
Fecal Streptococcus
Bacteria
18x 10"
0.69 x 10"
1.5 x 10"
3.0 x 10"
  Source: ASAE (1999).
  Values rounded to two significant figures.

2.2.4  Organic Matter

Livestock manures contain many carbon-based, biodegradable compounds. These compounds
are of concern in surface water because dissolved oxygen is consumed as aquatic bacteria and
other microorganisms decompose these compounds. This process reduces the amount of oxygen
available for aquatic animals.
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The greater the manure's concentration of materials that can be readily decomposed, the greater
the manure's oxygen demand. Two measures are often used to estimate oxygen demand.
Biochemical oxygen demand (BOD) is an indirect measure of the concentration of biodegradable
substances present in an aqueous solution. The ultimate BOD is the amount of oxygen required
to completely degrade the waste biologically under aerobic conditions. BOD is often expressed
as BOD5. This measure refers to the amount of oxygen required by bacteria while decomposing
organic matter under aerobic conditions over a five-day period at 20°C in a laboratory test.
BOD5 is expressed as the number of milligrams of oxygen required to support oxidation of the
compounds in one liter of liquid waste. Alternatively, the chemical oxygen demand (COD) test
uses a chemical oxidant. This test provides an approximation of the ultimate BOD and can be
estimated more quickly than the five days required for the BOD5 test. If the waste contains only
readily available organic bacterial food and no toxic matter, the COD values correlate with BOD
values obtained from the same wastes (Dunne and Leopold,  1978).

Exhibit 2-8 lists BOD5 and COD estimates for manure generated by swine, poultry, beef, and
dairy animals and, for comparison, provides values for domestic sewage. Reported BOD5 values
for various untreated animal manures range from 24,000 mg/L to 33,000 mg/L. COD values
range from 25,000 mg/L to 260,000 mg/L. Dairy and beef cattle manure have BOD5 and COD
values of similar magnitude. By comparison, the BOD5 value for raw domestic sewage ranges
from 100 mg/L to 300 mg/L. Even after biological treatment in anaerobic lagoons, animal waste
BOD5 concentrations (200 mg/L to 3,800 mg/L) are much higher than those of municipal
wastewater treated to the secondary level (about 20 mg/L) (USDA, 1992).
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                                     EXHIBIT 2-8
       Reported BOD5 and COD Concentrations for Manures and Domestic Sewage
Waste
Swine manure
Untreated
Anaerobic lagoon influent
Anaerobic lagoon effluent
Poultry manure
Untreated (chicken)
Anaerobic lagoon influent (poultry)
Anaerobic lagoon effluent (poultry)
Dairy cattle manure
Untreated
Anaerobic lagoon influent
Anaerobic lagoon effluent
Beef cattle manure
Untreated
Anaerobic lagoon influent
Anaerobic lagoon effluent
Domestic sewage
Untreated
After secondary treatment
BOD5
(mg/L)

27,000 to 33,000
13,000
300 to 3,600
24,000
9,800
600 to 3, 800
26,000
6,000
200 to 1 ,200

28,000
6,700
200 to 2,500
100 to 300
20
COD
(ms/L)

25,000 to 180,000
n/a
n/a
100,000 to 260,000
n/a
n/a
68,000 to 170,000
n/a
n/a

73,000 to 260,000
n/a
n/a
400 to 600
n/a
 Sources: Untreated values, except for beef manure BOD5, are from NCAES (1982). The BOD5 value for beef manure
 is from ASAE (1997), Lagoon influent and effluent concentrations are from USDA/NRCS (1996).
 Values rounded to two significant figures.
 n/a = not available

2.2,5  Salts and Trace Elements

The salinity of animal manure is directly related to the presence of the nutrient potassium and
dissolved mineral salts that pass through the animal.  In particular, significant concentrations of
soluble salts containing the cations sodium and potassium remain from undigested feed that
passes unabsorbed through animals (NCAES, 1982), Other major cations contributing to salinity
are calcium and magnesium; the major anions are chloride, sulfate, bicarbonate, carbonate, and
nitrate (National Research Council, 1993). Salinity tends to increase as the volume of manure
decreases during decomposition and evaporation (Gresham et al, 1990).

Trace elements in manure that are of environmental concern include arsenic, copper, selenium,
zinc, cadmium, molybdenum, nickel, lead, iron, manganese, aluminum, and boron.  Arsenic,
copper, selenium, and zinc are often added to animal feed as growth stimulants or biocides
(Sims, 1995). Trace elements may also end up in manure through use of pesticides, which
farmers apply to livestock to suppress houseflies and other pests (USDA/ARS, 1998).

It is useful to compare trace element concentrations in manure to those in municipal sewage
sludge, which is regulated by the EPA's Standards for the Use or Disposal of Sewage Sludge
promulgated under the Clean Water Act and published in 40 CFR Part 503 (USEPA,  1993c).
Regulated trace elements in sewage sludge include arsenic, cadmium, chromium, copper, lead,
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mercury, molybdenum, nickel, selenium, and zinc.  Sims (1995) has reported total concentrations
of trace elements in animal manures as comparable to those in some municipal sludges, with
typical values well below the maximum concentrations allowed by Part 503 for land-applied
sewage sludge.

2.2.6   Antibiotics

A number of pharmacological agents, including antibiotics, are used in animal feeding operations
and can appear in animal wastes. Some of these agents are used only therapeutic ally (e.g., to
treat illness). Others are used both therapeutically and as feed additives to promote growth or to
improve feed conversion efficiency. In 1991, farmers used an estimated 19 million pounds of
antibiotics for disease prevention and growth promotion in animals. From 60 to 80 percent of
animals receive antibiotics during their productive life span (Tetra Tech, 2000a). Use as feed
additives accounts for most of the mass of antibiotics used in both the swine and poultry
industries and accounts for the presence of antibiotics in the resulting manure.  Although
antibiotic residues in beef and dairy manure are also a concern, the EPA could not locate any
literature on levels of antibiotics in  manure.  Estimated concentrations of the antibiotic
chlortetracycline in the lagoon systems of a pork producer in Nebraska range from 150 to 300
mg/L; that producer currently uses 16 different antibiotics as feed and drinking water additives
(USFWS, 2000).

2.2.7   Hormones

Hormones are the chemical messengers that carry instructions to target cells throughout the body
and are normally produced by the body's endocrine glands. The target cells read and follow the
hormones' instructions, sometimes  building a protein or releasing another hormone. These
actions lead to many bodily responses such as a faster heart beat or bone growth. Hormones
include steroids (estrogen, progesterone, testosterone), peptides (antidiuretic hormone),
polypeptides (insulin), amino acid derivatives (melatonin), and proteins (prolactin, growth
hormone).  Natural hormones are potent; only very small amounts are needed to cause an effect.

Specific hormones are administered to cattle to increase productivity in the beef and dairy
industries, and several studies have shown that hormones are present in animal manures (Mulla,
1999). For example, poultry manure has been shown to contain about 30 ng/g of estrogen, and
about the same levels of testosterone (Shore et al., 1995).  Also, estrogen was found in
concentrations up to 20 ng/L in runoff from fields fertilized with chicken manure (Shore et al.,
1995).

2.2.8   Other Pollutants of Concern

AFOs can also be a source of gas emissions, particulates, and pesticides.  A general overview of
each group of pollutants follows:

       «  Gas emissions. The degradation of animal wastes by microorganisms produces a
          variety of gases. Sources of odor include animal confinement buildings, waste
          lagoons, and land application sites. In addition to ammonia, which was discussed

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          earlier, three main gases generated from manure are carbon dioxide, methane, and
          hydrogen sulfide.  Aerobic conditions yield mainly carbon dioxide, while anaerobic
          conditions generate both methane and carbon dioxide. Anaerobic conditions, which
          dominate in typical, unaerated animal waste lagoons, also generate hydrogen sulfide
          and over 150 other odorous compounds, including volatile fatty acids, phenols,
          mercaptans, aromatics, sulfides, and various esters, carbonyls, and amines (O'Neill
          and Phillips, 1992; USDA, 1992; Bouzaher et al., 1993).

       •   Particulates.  Sources of particulate emissions from AFOs may include dried manure,
          feed, epithelial cells, hair, and feathers. The airborne particles make up an organic
          dust, which includes endotoxin (the toxic protoplasm liberated when a microorganism
          dies and disintegrates), adsorbed gases, and possibly steroids. At least 50 percent of
          dust emissions from swine operations may be respirable (Thu, 1995).

       •   Pesticides.  Pesticides are used in animal feeding operations and can appear in animal
          wastes. Farmers may use pesticides on crops grown for animal consumption or
          directly in animal housing areas to control parasites (among other reasons).  However,
          little information is available regarding the concentrations of pesticides in animal
          wastes or on their bioavailability in waste-amended soils.

2.3    TRANSPORT OF MANURE POLLUTANTS TO SURFACE WATER

Pollutants found in animal manures can reach surface water by several mechanisms.  These can
be categorized as either surface discharges or other discharges. Surface discharges can result
from runoff, erosion, spills, and dry-weather discharges,  hi surface discharges, the pollutant
travels overland or through drain tiles with surface inlets to a nearby stream, river, or lake.
Direct contact between confined animals and surface waters is another means of surface
discharge. For other types of discharges, the pollutant travels via another environmental medium
(ground water or air) to surface water.

2.3.1   Surface Discharges

Runoff

Feedlot runoff contains extremely large loads  of nutrients and oxygen-demanding substances,
which can severely degrade surface water quality (Mulla, 1999).  Water that falls on man-made
surfaces or soil and fails to be absorbed will flow across the surface. This process is called
runoff. Surface discharges of manure pollutants can originate from feedlots and from overland
runoff at land application sites. Runoff is especially likely at open-air feedlots, when rainfall
occurs soon  after application, and when farmers over-apply or misapply manure. For example,
experiments show that for all animal wastes, the application rate has a significant effect on the
runoff concentration (Daniel et al., 1995).  Other factors that promote runoff to surface waters are
steep  land slope, high rainfall, low soil porosity or permeability, and close proximity to surface
waters. In addition, manure applied to saturated or frozen soils is more likely to ran off the soil
surface (Mulla, 1999). Runoff of pollutants dissolved into rainwater is a significant transport
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mechanism for water soluble pollutants, including nitrate, nitrite, and organic forms of
phosphorus.

Runoff of manure pollutants has been identified as a factor in a number of documented impacts
from AFOs, For example, in 1994, an environmental advocacy group noted multiple runoff
problems for a swine operation in Minnesota (Clean Water Action Alliance, 1998), and in 1996,
the State of Ohio identified runoff from manure spread on land at several Ohio operations that
were feeding swine and chicken (Ohio Department of Natural Resources, 1997). More
discussion of runoff and its impacts on the environment and human health appears later in this
document.

Erosion

In addition to runoff, surface discharges can occur by erosion, in which the soil surface is worn
away by the action of water or wind.  Erosion is a significant transport mechanism for land-
applied pollutants, such as phosphorus, that are strongly sorbed to soils (Gerritse, 1977).

The USDA Natural Resources Conservation Service (NRCS) reviewed the manure production in
a watershed in South Carolina.  Agricultural activities in the project area are a major influence on
the streams and ponds in the watershed and  contribute to nutrient-related water quality problems
in the headwaters of Lake Murray. NRCS found that bacteria, nutrients, and sediment from soil
erosion  are the primary contaminants affecting the waters in this watershed. The NRCS has
calculated that soil erosion, occurring on over 13,000 acres of cropland in the watershed, ranges
from 9.6 to 41.5 tons per acre per year (USEPA, 1997b).

Spills and Dry-Weather Discharges

Surface discharges can occur through spills  or other discharges from lagoons. Catastrophic spills
from large manure storage facilities can occur primarily through overflow following large storms
or by intentional releases (Mulla et aL,  1999). Other causes of spills include pump failures,
malfunctions of manure irrigation guns, and breakage of pipes or retaining walls. Manure
entering tile drains has a direct route to surface water. (Tile drains are a network of pipes buried
in fields below the root zone of plants to remove subsurface drainage water from the root zone to
a stream, drainage ditch, or evaporation pond.)  In addition, spills can occur as a result of
washouts from floodwaters when lagoons are sited on floodplains. There are also indications
that discharges from siphoning lagoons occur deliberately as a means  to reduce the volume in
overfull lagoons (Clean Water Action Alliance, 1998). An independent review of Indiana
Department of Environmental Management records indicated that two common causes of waste
releases in that state were intentional discharges and accidental discharges resulting from lack of
operator knowledge (Hoosier Environmental Council, 1997).

Localities have identified numerous such discharges. The Ohio Department of Natural
Resources (ODNR) documented chicken manure traveling through tile drains into a nearby
stream in several instances occurring in 1994,1995, and 1996 (ODNR, 1997). In 1995, a
discharge of 25 million gallons of manure from swine farms in North Carolina was documented
(Meadows, 1995; NRDC, 1995; Warrick, 1995b). Subsequent discharges of hundreds of

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thousands of gallons of manure were documented from swine operations in Iowa (1996), Illinois
(1997), and Minnesota (1997) (IDNR, 1998; Illinois Stewardship Alliance, 1997; Macomb
Journal, 1999; Clean Water Action Alliance, 1998). Between 1994 and 1996, half a dozen
discharges from poultry operations in Ohio resulted when manure entered drain tiles (ODNR,
1997). In 1996, more than 40 animal waste spills occurred in Iowa, Minnesota, and Missouri
alone (U.S. Senate,  1997). In 1998, a dairy feedlot in Minnesota discharged 125,000 gallons of
manure (Clean Water Action Alliance, 1998).  Acute discharges of this kind frequently result in
dramatic fish kills.  For example, fish kills were reported as a result of the North Carolina, Iowa,
Minnesota, and Missouri discharges mentioned above.

Direct Contact between Confined Animals and Surface Water

Finally, surface discharges can occur as a result of direct contact between confined animals and
the rivers or ponds that are located within their reach.  Historically, people located their farms
near waterways for both water access by animals and discharge of wastes.  Certain animals,
particularly cattle, wade into the waterbody, linger to drink, and often urinate and defecate in the
water. This practice is now restricted for CAFOs; however, enforcement actions are the primary
means for reducing direct access, as described below (McFall, 2000).

In traditional farm production regions of the Midwest and Northeast, dairy barns and feedlots are
often in close proximity to streams or other water sources. This close proximity to streams was
formerly necessary in order to provide drinking water for the dairy cattle, to cool the animals in
hot weather via direct access, and to cool the milk prior to the widespread use of refrigeration.
For CAFO-size facilities, this practice is now replaced with more efficient means of providing
drinking  water for the dairy herd.  In addition, the use of freestall barns and modern milking
centers minimizes the exposure of dairy cattle to the environment. For example, in New York
direct access of animals to surface water is more of a problem for the smaller, traditional dairy
farms that use older methods of housing animals. However, at these smaller facilities, direct
access to surface water has relatively lower impact on surface water compared with impacts
associated with silage leachate and milkhouse waste (Dimura, 2000).

In the arid West, feedlots are typically located near waterbodies to allow for cheap and easy stock
watering. Many existing lots were configured to allow the animals direct access to the water.
The direct deposition of manure and urine contributes greatly to water quality problems.
Environmental problems associated with allowing farm animals access to waters that are adjacent
to the production area are well documented in the literature.  EPA Region X staff have
documented dramatically elevated levels of Escherichia coli in rivers downstream of AFOs with
direct access to surface water. Recent enforcement actions against direct access facilities have
resulted in the assessment of tens of thousands of dollars in civil penalties (McFall, 2000).

2.3.2  Other Discharges to Surface Waters

Leaching to Ground Water

Leaching of land-applied pollutants is a significant transport mechanism for water soluble
pollutants. In addition, leaking lagoons are a source of manure pollutants in ground water.

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Although manure solids purportedly "self-seal" lagoons to prevent ground water contamination,
some studies have shown otherwise. A study for the Iowa legislature published in 1999 indicates
that leaking is part of lagoon design standards and that all lagoons should be expected to leak
(Iowa State University, 1999). A survey of swine and poultry lagoons in the Carolinas found that
nearly two-thirds of the 36 lagoons sampled had leaked into the ground water (Meadows, 1995).
Even clay-lined lagoons have the potential to leak, since they can crack or break as they age, and
can be susceptible to burrowing worms. In a three-year study of clay-lined swine lagoons on the
Delmarva Peninsula, researchers found that leachate from lagoons located in well-drained loamy
sand had a severe impact on ground water quality (Ritter and Chirnside, 1990).

Pollutant transport to ground water is also greater in areas with high soil permeability and
shallow water tables. Percolating water can transport pollutants to ground water, as well as to
surface waters via interflow.  Contaminated ground water can deliver pollutants to surface waters
through hydrologic connections.  Nationally, about 40 percent of the average annual stream flow
is from ground water (USEPA, 1993b). In the Chesapeake Bay watershed, the USGS estimates
that about half of the nitrogen loads from all  sources to nontidal streams and rivers originate from
ground water (ASCE, 1998).

Understanding the connection between ground water and surface water is important when
developing surface water protection strategies, because ground water moves much more slowly
than surface water.  For example, ground water in the Chesapeake Bay region takes an average of
10 to 20 years to reach the Bay; thus, it may take several decades to realize the full effect of
pollutant additions or reductions (ASCE, 1998).

Discharge to the Air and Subsequent Deposition

Atmospheric deposition can be a significant  mechanism of transport to surface waters, as
nitrogen emissions to air can return to terrestrial or aquatic environments in dry form or dissolved
in precipitation (Agricultural Animal Waste Task Force, 1996). Discharges to air can occur as a
result of volatilization of pollutants already present in the manure, and of pollutants generated as
the manure decomposes. Ammonia is very volatile and can have significant impacts on water
quality through atmospheric deposition (Aneja et al., 1998). Ammonia losses from animal
feeding operations can be considerable, arising from manure piles, storage lagoons, and land
application fields. Other ways that manure pollutants can enter the air are from spray application
methods for land applying manure and from  particulates wind-borne in dust.

The degree of volatilization of manure pollutants is dependent on the manure management
system. For example, losses are greater when manure remains on the land surface rather than
being incorporated into the soil and are particularly high when farmers perform spray application.
Environmental conditions  such as soil acidity and moisture content also affect the extent of
volatilization.  Losses are reduced by the presence of growing plants (Follett, 1995).

Once airborne, pollutants can find their way  into nearby streams, rivers, and lakes. The  1998
National Water Quality Inventory indicates that atmospheric deposition is the third largest cause
of water quality impairment for estuaries and the fifth largest cause of water quality impairment
for lakes, ponds, and reservoirs (USEPA, 2000a).

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2.3.3   Pollutant-specific Transport

Nitrogen Compounds

Livestock waste can contribute up to 37 percent of total nitrogen loads to surface water (Mulla,
1999). Nitrogen compounds and nitrates in manure can reach surface water through several
pathways. As suggested by Follett (1995), agricultural nitrate contributions to surface water are
primarily from ground water connections and other subsurface flows. Although potentially less
significant, overland runoff can also carry nitrate to surface waters. A recent Iowa investigation
of chemical and microbial contamination near large-scale swine operations demonstrated the
presence of nitrate and nitrite not only in manure lagoons used to store swine waste before it is
land applied, but also  in drainage ditches, agricultural drainage wells, tile line inlets and outlets,
and an adjacent river (CDCP, 1998).

Studies of small geographical areas have revealed evidence of nitrate contamination in ground
water. As of 1988,40 percent of wells in the Chino Basin, California, had nitrate levels in excess
of the MCL; USEPA (1993b) identified dairy operations as the major source of contamination.
This presents potentially widespread impacts, since water from the Chino Basin is used to
recharge the primary source of drinking water for residents of heavily populated Orange County.
On the Delmarva peninsula, in Maryland, where poultry production is dominant, over 15 percent
of wells were found to have nitrate levels exceeding the MCL. Wells located close to chicken
houses contained the highest median nitrate concentrations (Ritter et al., 1989).  Measured nitrate
levels in ground water beneath Delaware poultry houses are as high as 100 mg/L (Ritter et al.,
1989).

Elevated nitrate levels can also exist in surface waters, although these impacts are typically less
severe than ground water impacts. In a historical assessment, USGS (1997) found that nitrate
levels in streams in agricultural areas were elevated compared to undeveloped areas.
Nevertheless, the in-stream nitrate concentrations were generally less than those for ground water
in similar locations, and the drinking water MCL was rarely exceeded.  The primary exception to
this pattern was in the Midwest, where poorly drained soils restrict water percolation and
artificial drainage provides a quick path for nutrient-rich runoff to reach streams (USGS, 1997).

When farmers apply manure to land as fertilizer, risk of nitrate pollution generally increases at
higher rates of nitrogen application.  Even when farmers land apply manure at agronomic rates,
nitrogen transport to surface water and ground water can still occur for the following reasons: (1)
nitrate is extremely mobile and may move below the plant root zone before being taken  up; (2)
ammonia may volatilize and be redeposited in surface water; (3) the waste may be unevenly
distributed, resulting in local "hot spots"; (4) it may be difficult to obtain a representative sample
of the waste to determine the amount of mineralized (plant-available) nitrogen; (5) there are
uncertainties about the estimated rate of nitrogen mineralization in the applied waste; (6)
transport is affected by the manure application method (e.g., drip irrigation, spray irrigation,
knifing, etc.); and (7)  transport is affected by uncontrollable environmental factors such as
rainfall and other local conditions (Follett, 1995).
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Phosphorus Compounds

Phosphorus can reach surface waters via discharges directly into surface water and runoff of
manure to surface water from feedlots, and via runoff and erosion from land application sites.
The organic phosphorus compounds in manure are generally water soluble and subject to
leaching and dissolution in runoff (Gerritse, 1977),  Once in receiving waters, these compounds
can undergo transformation and become available to aquatic plants.  Overall, land-applied
phosphorus is less mobile than nitrogen, since the mineralized (inorganic phosphate) form is
easily adsorbed to soil particles. A report by the Agricultural Research Service noted that
phosphorus bound to eroded sediment particles makes up 60 to 90 percent of phosphorus
transported in surface runoff from  cultivated land (USDA/ARS, 1999).  For this reason, most
agricultural phosphorus control measures have focused on soil erosion control to limit transport
of particulate phosphorus. However, soils do not have infinite phosphate adsorption capacity,
and dissolved inorganic phosphates can still enter waterways via runoff even if soil erosion is
controlled (National Research Council, 1993).

Livestock waste can contribute up  to 65 percent of total phosphorus loads in surface waters
(Mulla, 1999).  Animal wastes typically have lower N:P ratios than crop N:P requirements, such
that application of manure at a nitrogen-based agronomic rate can result in application of
phosphorus at several times the agronomic rate (Sims, 1995), Summaries of soil test data in the
United States confirm that many soils in areas dominated by animal-based agriculture have
excessive levels of phosphorus (Sims, 1995). Research also indicates that there is  a potential for
phosphorus to leach into ground water through sandy soils with already high phosphorus content
(Citizens Pfiesteria Action Commission, 1997).

Ammonia

Ammonia can reach surface waters in a number of ways, including discharge directly to surface
waters, leaching, dissolution in surface runoff, erosion, and atmospheric deposition. Leaching
and runoff are generally not significant transport  mechanisms for ammonia compounds in land-
applied manure, because ammonium can be sorbed to soils (particularly those with high cation
exchange capacity), incorporated (fixed) into clay or other soil complexes, or transformed into
organic form by soil microbes (Follett, 1995). However, in these forms, erosion can  transport
nitrogen to surface waters.  A recent Iowa investigation of chemical and microbial contamination
near large-scale swine operations demonstrated the presence of ammonia not only  in  manure
lagoons used to store swine waste  before it is land applied, but also in drainage ditches,
agricultural drainage wells, tile line inlets and outlets, and an adjacent river (CDCP, 1998).

Ammonia losses from animal feeding operations  to the air and subsequent deposition to surface
waters can be considerable, arising from sources  such as manure piles, storage lagoons, and land
application fields. For example, in North Carolina, animal agriculture is responsible  for over 90
percent of all ammonia emissions (Aneja et al., 1998). Ammonia composes more  than
40 percent of the total estimated nitrogen emissions from all sources  (Aneja et al.,  1998).
Furthermore, data from Sampson County, North Carolina, indicate that ammonia levels in rain
have increased with increases in the size of the pork industry. Levels more than doubled between
1985 and 1995  (Aneja et  al, 1998). Based on EPA estimates, swine operations in  eastern North

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Carolina were responsible for emissions of 135 million pounds of nitrogen per year as of 1995.
If deposited in a single basin, this would result in nitrogen loadings of almost 2.1 million pounds
of nitrogen per year (Nowlin et al., 1997),

Pathogens

Sources of pathogen contamination from AFOs include surface discharges and lagoon leachate.
Surface runoff from land application fields can be a source of pathogen contamination,
particularly if a rainfall event occurs soon after application or if the land is frozen or snow-
covered (Mulla, 1999). Researchers have reported concentrations of bacteria in runoff water
from fields treated with poultry litter at several orders of magnitude above contact standards
(Giddens and Barnett, 1980; Coyne and Blevins, 1995).

A recent Iowa investigation of chemical and microbial contamination near large-scale swine
operations demonstrated the presence of pathogens not only in manure lagoons used to store
swine waste before it is land applied, but also in drainage ditches, agricultural drainage wells, tile
line inlets and outlets, and an adjacent river (CDCP, 1998), Also, studies have reported that
lands receiving fresh manure application can be the source of up to 80 percent of the fecal
bacteria in surface waters (Mulla, 1999).  Similarly, both Cryptosporidium parvum and Giardia
species have also been found in over 80 percent of 66 surface water sites tested (LeChevallier et
al., 1991).  Since these protozoa do not multiply outside of the host, livestock animals are one
potential source of this contamination. The bacterium Erysipelothrix spp., primarily a swine
pathogen, has been isolated from many fish and avian species (USFWS, 2000).

High levels of indicator bacteria in surface water near CAFOs have been documented. For
instance, Zirbser (1998) documented a report of fecal coliform counts of 3,000/100 ml and fecal
streptococci counts over 30,000/100 ml downstream from a swine waste lagoon site. (No
sampling was performed upstream of the lagoon site.)  Fecal coliform pollution from treated and
partially treated sewage and storm water runoff is often cited in beach closures and shellfish
restrictions.

The natural filtering and adsorption action of soils typically causes a majority of the
microorganisms in land-applied manure to be stranded at the soil surface (Crane et al., 1980).
This phenomenon helps protect underlying ground water but increases the likelihood of runoff
losses  to surface waters. Pathogens discharged to the water column can subsequently adsorb to
sediments, presenting a long-term health hazard.  Benthic sediments harbor significantly higher
concentrations of bacteria than the overlying water column (Mulla, 1999). When the bottom
stream is disturbed, as when animals have direct access to a stream, the sediment releases
bacteria back into the water column (Sherer et al., 1988, 1992).

While surface waters are typically more prone to pathogen contamination than ground waters,
subsurface flows may also be a mechanism for pathogen transport depending on weather, site,
and operating conditions. Ground waters in areas of sandy soils, limestone formations,  or
sinkholes are particularly vulnerable. For example, the bacteria  Clostridium perfringens was
detected in the ground water below plots of land treated with swine manure, and fecal coliform
has been detected in ground water beneath soil amended with poultry manure (Mulla, 1999).  In

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1998, Campylobacter jejuni was isolated from ground water, and some of the strains were the
same type as those from a dairy farm in the same hydrologic area (Stanley et al., 1998).

There are other accounts of high levels of micoorganisms in ground water near feedlots. In cow
pasture areas of Door County, Wisconsin, where a thin topsoil layer is underlain by fractured
limestone bedrock, ground water wells have commonly been shut down due to high bacteria
levels (Behm,  1989), For example, a well at one rural household produced brown, manure-laden
water (Behm, 1989). Private wells are more prone to contamination than public wells, since they
tend to be shallower and therefore more susceptible to contaminants leaching from the surface.
In a survey of drinking water standard violations in six states over a four-year period, the U.S.
General Accounting Office (USGAO, 1997) found that bacterial standard violations occurred in
3 to 6 percent of community water systems each year.6 By contrast, USGAO reported that some
bacterial contamination occurred in 15 to 42 percent of private wells, according to statistically
representative assessments performed by others.7

Several factors affect the likelihood of disease transmission by pathogens in animal manure,
including pathogen  survivability in the environment.  For example, Salmonella can survive in the
environment for nine months or more,  providing for increased dissemination potential (USFWS,
2000); and Campylobacter can remain dormant, making water an important vehicle  for
campylobacteriosis  (Altekruse, 1998).  Recent studies are better characterizing the survivability
and transport of pathogens in manure once it has been land applied. Several researchers (Dazzo
et al., Himathongkham et al., 1999; Kudva et al., 1998; Maule, 1999; Van Donsel et al., 1967)
found that soil type, manure application rate, temperature, moisture level, aeration, soil pH, and
the amount of time that manure is  held before it is applied to pastureland are dominating factors
in bacteria survival.

Experiments on land-applied poultry manure (Crane et al., 1980) indicated  that the population of
fecal organisms decreases rapidly  as manure is heated, dried, and exposed to sunlight on the soil
surface.  However, regrowth of fecal organisms also occurred in these experiments.  More recent
research indicated that pathogens can survive in manure for 30 days or more (Himathongkham et
al., 1999; Kudva et  al., 1998; Maule, 1999). Kudva found that Escherichia coli survived for 47
days in aerated cattle manure piles that were exposed to outdoor weather; drying the manure
reduced the number of viable pathogens. Stehman (2000) also notes that Escherichia coli
O157:H7, Cryptosporidium parvum, and Giardia can survive and remain infectious in surface
waters for a month or more.

The continued application of waste on a particular area could lead to extended pathogen survival
and buildup (Dazzo et al., 1973).  Additionally, repeated applications and/or high application
rates increase the likelihood of runoff to surface water and transport to ground water.
       6GAO reviewed compliance data from 1993 through 1996, from more than 17,000 community water
systems, in California, Illinois, Nebraska, New Hampshire, North Carolina, and Wisconsin.

       7The 15 percent figure is from a 1996 study of Nebraska wells by the Nebraska Department of Health and
University of Nebraska; the 42 percent figure is from the EPA National Statistical Assessment of Rural Water
Conditions (1984).

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Organic Matter

Discharge and runoff of manure from feedlots cause large loadings of organic matter to surface
waters. There have been numerous incidents of discharges from AFOs nationwide directly to
surface waters (see Chapter 4), Discharges can also originate from land application sites when
farmers over-apply or misapply manure.  Even if farmers apply manure such that there is not a
concentrated discharge, organic matter will be present in runoff from land application sites. As
shown by Daniel et al. (1995), runoff of organic matter increases as application rate increases.8
For example, Daniel et al. (1995) reported that when the swine manure slurry application rate
increased from 193 Ib N/acre to 387 Ib N/acre,9 COD levels in runoff (generated from a rainfall
intensity of 2 inches/hour) increased from 282 mg/L to 504 mg/L. By comparison, runoff from a
control plot yielded 78 mg/L COD.

Salts and Trace Elements

Salts can reach surface waters via discharges from feedlots and runoff from land application
sites. Salts can also leach into ground water and subsequently reach surface water. Trace
elements can also be transported by these mechanisms.  A recent Iowa investigation showed that
trace elements were present not only in manure lagoons used to store swine waste before land
application, but also in drainage ditches, agricultural drainage wells, tile line inlets and outlets,
and an adjacent river (CDCP,  1998).  Selenium concentrations have been detected in swine
manure lagoons at up to 6 ug/L, copper has been detected in liquid swine manure prior to land
application at 15 mg/L, and zinc has been detected in soils that receive applications of cattle
manure at levels up to 9.5 rng/kg in the upper 60 centimeters of soil (USFWS,  2000).

Antibiotics

Little information is available regarding the fate and transport properties of antibiotics, or the
potential releases from animal waste compared to other sources such as municipal and industrial
wastewaters, septic tank leaehate, runoff from land-applied sewage sludge, crop runoff, and
urban runoff.  However, it is known that the primary mechanisms of eliminating antibiotics from
livestock are through urine and bile. Also, essentially all of an antibiotic administered to an
animal is eventually excreted, whether unchanged or in metabolite form (Tetra Tech, 2000a).

Although the presence of excreted antibiotics themselves may be of concern, the development of
antibiotic-resistant pathogens  due to exposure to environmental levels of antibiotics is generally
of greater concern. The risk for development of antibiotic-resistant pathogens  from this exposure
is unknown.
        In a series of experiments, Edwards and Daniel (1992b, 1993a,b, as reported by Daniel et al,, 1995)
measured runoff from fescue grass plots treated with poultry litter, poultry manure slurry, and swine manure slurry
to determine how runoff quality is impacted by application rate and rain intensity. They found that for all wastes,
the application rate had a significant effect on the runoff concentration and mass loss of COD (as well as other
constituents).

       9EPA assumes that 175 Ib N/acre is a typical requirement for a fescue crop in Arkansas, based on
information from U.S.  Department of Agriculture extension agents (Tetra Tech, 2000b).

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Hormones

Hormones can reach surface waters through the same routes as other manure pollutants,
including runoff and erosion as well as direct contact of animals with the water. Considering
specific hormones used, however, estrogen is more likely to be lost by runoff than leaching,
while testosterone is lost mainly through leaching (Shore et al., 1995).

Several sites have documented the presence of hormones in runoff and surface waters.  For
example, runoff from a field receiving poultry litter was found to contain estrogen. Also, an
irrigation pond and three streams in the Conestoga River watershed near the Chesapeake Bay had
both estrogen and testosterone. Each of these sites were affected by fields receiving poultry litter
(Shore et al., 1995). Runoff from fields with land-applied manure has been reported to contain
estrogens, estradiol, progesterone, and testosterone, as well as their synthetic counterparts.
Estrogens have also been found in runoff from heavily grazed land (Addis et al., 1999).

Other Pollutants

There has been almost no research on losses of pesticides in runoff from manured lands. A 1999
literature review by the University of Minnesota discussed a 1994 study showing that losses of
cyromazine (used to control flies in poultry litter) in runoff increased with the rate of poultry
manure application  and the intensity of rainfall.  The 1999 literature review also includes a 1995
study documenting that about 1 percent of all pesticides enter  surface water. However, the
magnitude of the  impacts of these losses on surface water are  unknown (Mulla, 1999).  hi
general, little information is available regarding the fate and transport of pesticides or their
bioavailability in  waste-amended soils.  Furthermore, there is  little information comparing
potential releases  of these compounds from animal waste to other sources such as municipal and
industrial wastewaters, septic  tank leachate, runoff from land-applied sewage sludge, crop runoff,
and urban runoff.
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3.     POTENTIAL HAZARDS FROM AFO POLLUTANTS

As described in Chapter 2, animal feeding operations are associated with a variety of pollutants,
including nutrients (specifically nitrogen and phosphorus), ammonia, pathogens, organic matter,
salts, trace elements, solids, antibiotics, hormones, gas and paniculate emissions, and pesticides.
These AFO pollutants can produce multimedia impacts, such as the following:

       •  Surface water. Impacts have been associated with surface discharges of waste, as
          well as leaching to ground water and subsurface flow to surface water. Generally,
          states with high concentrations of feedlots experience 20 to 30 serious water quality
          pollution problems per year involving manure lagoon spills and feedlot runoff (Mulla,
          1999). The waste's oxygen demand and ammonia content can result in fish kills and
          reduced biodiversity. Solids can increase turbidity and impact benthic organisms.
          Nutrients contribute to eutrophication and associated algae blooms.  Algal decay and
          nighttime respiration can depress dissolved oxygen levels, potentially leading to fish
          kills and reduced biodiversity. Eutrophication is also a factor in blooms  of toxic algae
          and other toxic microorganisms, such as Pfiesteria piscicida.  Human and animal
          health impacts are primarily associated with drinking contaminated water (pathogens
          and nitrates), coming into contact with contaminated water (pathogens such as toxic
          algae and Pfiesteria), and consuming contaminated shellfish (pathogens such as toxic
          algae).  Trace elements (e.g., arsenic, copper, selenium, and zinc) may also present
          human health and ecological risks.  Salts contribute to salinization and disruption of
          ecosystem balance, as well as degradation of drinking water supplies. Antibiotics,
          pesticides, and hormones  may have low-level, long-term ecosystem effects.

       »  Ground water. Impacts have been associated with pollutants leaching to ground
          water. Human and animal health impacts are associated with pathogens and nitrates
          in drinking water. Leaching salts can increase health risks to salt-sensitive
          individuals, and can make the water unpalatable. Trace elements, antibiotics,
          pesticides, and hormones  may also present human health and ecological risks through
          ground water pathways.

       «  Air.  Air impacts include human health effects from ammonia, hydrogen sulfide, other
          odor-causing compounds, particulates, and the contribution to global climate change
          due to methane emissions. In addition, volatilized ammonia can be redeposited on the
          earth and contribute to eutrophication.

       •  Soil.  Trace elements and salts in animal manure can accumulate in soil and become
          toxic to plants. Salts also deteriorate soil quality by leading to reduced permeability
          and overall poor physical condition. Crops may provide a human and animal
          exposure pathway for trace elements and pathogens.

This chapter describes in greater detail the known or potential adverse human health and
ecological effects of AFO pollutants.
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3.1    PRIMARY NUTRIENTS

This section reviews the hazards posed by primary nutrients in animal manure. It focuses on
nitrogen and phosphorus, which have received the greatest attention in the scientific literature.
Actual or anticipated levels of potassium in ground water and surface water are unlikely to pose
hazards to aquatic life or human health (Wetzel, 1983). Potassium does contribute to salinity,
however, and applications of high salinity manure are likely to decrease the fertility of the soil.

3.1.1  Ecology

Eutrophieation

Eutrophication is the process in which phosphorus and nitrogen over-enrich a waterbody and
disrupt the balance of life in that waterbody. Perhaps the most documented impact of nutrient
pollution is the increase in surface water eutrophication (nutrient enrichment) and its effects on
aquatic ecosystems (Vallentyne, 1974).  Although nutrients are essential for the growth of
phytoplankton (free-floating algae), periphyton (attached algae), and aquatic plants, which form
the base of the aquatic food web,  the overabundance of nutrients can lead to harmful algal
blooms and  other adverse effects, such as:

       «   Increased biomass of phytoplankton;
       •   Shifts in phytoplankton to bloom-forming species that may be toxic or inedible;
       •   Changes in macrophyte species composition and biornass;
       *   Death of coral reefs and loss of coral reef communities;
       «   Decreases in water transparency;
       •   Taste, odor, and water treatment problems;
       •   Oxygen depletion;
       «   Increased incidence of fish kills;
       •   Loss of desirable fish  species;
       •   Reductions in harvestable fish and shellfish; and
       »   Decreases in aesthetic value of the waterbody (Carpenter et al., 1998).

The type of  waterbody impacted may dictate which nutrient (nitrogen or phosphorus) will have
the most impact. In estuaries and coastal marine waters, nitrogen is typically the limiting nutrient
(i.e., in these waters, phosphorus  levels are sufficiently high compared to  nitrogen such that small
changes in nitrogen concentrations have a greater effect on plant growth). In fresh waters,
phosphorus  is typically the limiting nutrient (Wendt and Corey, 1980; Robinson and Sharpley,
1995). There can be exceptions to this generalization, however, especially in waterbodies with
heavy pollutant loads. For example, estuarine systems may become phosphorus-limited when
nitrogen concentrations are high.  In such cases, excess phosphorus will produce algal blooms
(North Carolina's Nicholas School of the Environment's Agricultural Animal Waste Task Force,
1994). Thus, both nitrogen and phosphorus loads can contribute to eutrophication in either water
type.
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Algae and Other Toxic Microorganisms

Eutrophication causes the enhanced growth and subsequent decay of algae, which can lower
dissolved oxygen content of a waterbody to levels insufficient to support fish and invertebrates.
In some cases, this situation can produce large areas devoid of life because of a lack of sufficient
dissolved oxygen. One extreme example is the "Dead Zone," an area of hypoxic water larger
than 10,000 km2 that spreads off the Louisiana coast in the Gulf of Mexico each summer.  The
Dead Zone is believed to be caused by excess chemical fertilizer; however, nutrients from animal
waste have also contributed to the problem. This condition has been attributed to excess
nutrients delivered primarily by the Mississippi and Atchafalaya river systems (Atwood et al,
1994). The problem in the Gulf demonstrates that pollutant discharges can have far-reaching
downstream impacts. In fact, the nutrient loadings to the Gulf originate from sources over a large
land area covering approximately 41 percent of the conterminous United States (Goolsby et al.,
1999).

Eutrophication can also affect phytoplankton and zooplankton population diversity, abundance,
and biomass, and increase the mortality rates of aquatic species. For example, floating algal mats
can prevent sunlight from reaching submerged aquatic vegetation, which serves as habitat for fish
spawning, juvenile fish, and fish prey (e.g., aquatic insects).  The resulting decrease in
submerged aquatic vegetation adversely affects both fish and shellfish populations (USEPA,
2000a).

Another effect of eutrophication is increased incidence of harmful algal blooms, which release
toxins as they die and can severely impact wildlife as well as humans. In marine ecosystems,
blooms known as red or brown tides have caused significant  mortality in marine mammals
(Carpenter et al., 1998). In fresh water, cyanobacterial toxins have caused many incidents of
poisoning of wild and domestic animals that have consumed  impacted waters (Health Canada
Environmental Health Program, 1998). Published reports of wildlife poisoning from these
blooms include amphibians, fish, snakes, waterfowl, raptors,  and deer (USFWS, 2000).

Eutrophication is also associated with blooms of other toxic organisms, such as the estuarine
dinoflagellate Pfiesteria piscicida. Pfiesteria has been implicated as the primary causative agent
of many major fish kills and fish disease events in North Carolina estuaries and coastal areas
(NCSU, 2000), as well as in Maryland and Virginia tributaries to the Chesapeake Bay (USEPA,
1997b). Pfiesteria often lives as a nontoxic predatory animal, becoming toxic in response to
human influences including excessive nutrient enrichment (NCSU, 2000). While nutrient-
enriched conditions  are not required for toxic outbreaks  to occur, excessive nutrient loadings are
a concern because they help create an environment rich in microbial prey and organic matter that
Pfiesteria uses as a food supply. By increasing the concentration of Pfiesteria, nutrient loads
increase the likelihood of a toxic outbreak when adequate numbers of fish are present (Citizens
Pfiesteria Action Commission, 1997). Researchers have documented stimulation of Pfiesteria
growth by human sewage and swine effluent spills and have  shown that the organism's growth
can be highly stimulated by both inorganic and organic nitrogen and phosphorus enrichments
(NCSU, 2000).
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Increased algal growth can also raise the pH of waterbodies, as algae consume dissolved carbon
dioxide to support photosynthesis. Many biological processes, including reproduction, cannot
function in water that is very acidic or alkaline (USEPA, 20QOa).

Nitrites

Nitrites can also pose a risk to aquatic life;  if sediments are enriched with nutrients, the
concentrations of nitrites in the overlying water may be raised enough to cause nitrite poisoning
or "brown blood disease"10 in fish (USDA,  1992). In addition, excess nitrogen can contribute to
water quality decline by increasing the acidity of surface waters,

3.1.2  Human Health

Nitrates/Nitrites

The main hazard to human health from primary nutrients is elevated nitrate levels in drinking
water. In particular, infants are at risk from nitrate poisoning (also referred to as
methemoglobinemia or "blue baby syndrome"), which can be fatal. This poisoning results in
oxygen starvation and is due to nitrite (a metabolite of nitrate), which is formed in the
environment, foods, and the human digestive system. Compared to adults and older children,
infants under six months experience elevated nitrite production because their digestive systems
have a higher concentration of nitrate-reducing bacteria. Nitrite oxidizes iron in the hemoglobin
of red blood cells to form methemoglobin, which cannot carry sufficient oxygen to the body's
cells and tissues.  Although methemoglobin is continually produced in humans, an enzyme in the
human body reduces methemoglobin back to hemoglobin.  In most individuals, this conversion
occurs rapidly.  Infants, however, have a low concentration of methemoglobin-reducing enzyme,
as do individuals  with an enzyme deficiency. In these people, methemoglobin is not converted to
hemoglobin as readily (Nebraska Cooperative Extension, 1995).

Because infants under six months have a higher concentration of digestive bacteria that reduce
nitrates, and a lower concentration of methemoglobin-reducing enzyme, they are at higher risk
for methemoglobinemia (Nebraska Cooperative Extension, 1995). To protect infant health, the
EPA set drinking water Maximum Contaminant Levels (MCLs) of 10 mg/L for nitrate-nitrogen
and 1 mg/L for nitrite-nitrogen.  MCLs are  the maximum permissible levels of pollutants allowed
in water delivered to public drinking water  systems. Once a water source is contaminated, the
costs of protecting consumers from nitrate exposure can be significant. Nitrate is not removed by
conventional drinking water treatment processes.  Its removal requires additional, relatively
expensive treatment units.

Although reported cases of methemoglobinemia are rare, the incidence of actual cases may be
greater than the number reported. Studies in South Dakota and Nebraska have indicated that
most cases of methemoglobinemia are not reported (Michel et al.,  1996; Meyer, 1994). For
example, in South Dakota between 1950 and 1980, only two cases were reported, while at least
       10 Brown blood disease is named for the color of the blood of dead or dying fish, indicating that the
hemoglobin has been converted to methemoglobin.

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80 were estimated to have occurred (Meyer, 1994). There are at least two reasons for this
underreporting. First, methemoglobinemia can be difficult to detect in infants because its
symptoms are similar to other conditions (Michel et al., 1996),  In addition, doctors are not
always required to report it (Michel et al.,  1996).

In addition to blue baby syndrome, low blood oxygen due to methemoglobinemia has also been
linked to birth defects, miscarriages, and general poor health in humans and animals. These
effects are exacerbated by concurrent exposure to many species of bacteria in water (IRIS, 2000).
Studies in Australia found an increased risk of congenital malformations with consumption of
high-nitrate ground water (Bruning-Fann and Kaneene, 1993).  Multi-generation animal studies
have found decreases in birth weight, post-natal growth, and organ weights among mammals
prenatally exposed to nitrite (IRIS, 2000).  Nitrate- and nitrite-containing compounds may also
cause hypotension or circulatory collapse (Bruning-Fann and Kaneene,  1993).

High nitrate levels in drinking water have  also been implicated in higher rates of stomach and
esophageal cancer, although a 1995 National Research Council report concludes that exposure to
nitrate and nitrite concentrations in drinking water are unlikely to contribute to human cancer
risks (National Research Council, 1995). However, nitrate metabolites  such as N-nitroso
compounds (especially nitrosamines) have been linked to severe human health effects such as
gastric cancer (Bruning-Fann and Kaneene, 1993).  The formation of N-nitroso compounds
occurs in the presence of catalytic bacteria (e.g., those found in the stomach) or thiocyanate.

Generally, people drawing water from domestic wells are at greater risk of nitrate poisoning than
those drawing from public wells (Nolan and Ruddy, 1996), since domestic wells are typically
shallower and not subject to wellhead protection or monitoring requirements.  Reported cases of
methemoglobinemia are most often associated with wells that were privately dug and that may
have been badly positioned in relation to the disposal of human and animal excreta (Addiscott et
al., 1991). Furthermore, people served by public systems are better protected even if the water
becomes contaminated, due to water quality monitoring and treatment requirements.

Phosphorus

Animal manure also contributes to increased phosphorus concentrations in water supplies.
Previous evaluations of phosphorus have not identified significant adverse human health effects,
but phosphate levels greater than 1.0 mg/L may interfere with coagulation in drinking water
treatment plants and thereby increase treatment costs (North Carolina's Nicholas School of the
Environment's Agricultural Animal Waste Task Force, 1994),

Eutrophication/Algal Blooms

To the extent that nitrogen and phosphorus contribute to algal blooms in surface water through
accelerated eutrophication as described in Section 3.1.1, these  nutrients can reduce the aesthetic
and recreational value of surface water resources.  Algae can affect drinking water by clogging
treatment plant intakes, producing objectionable tastes and odors. Algae can also increase
production of harmful chlorinated byproducts (e.g., trihalomethanes) by reacting with chlorine
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used to disinfect drinking water. These impacts result in increased costs of drinking water
treatment, reduced drinking water quality, and/or increased health risks.

Eutrophication can also affect human health by enhancing growth of harmful algal blooms that
release toxins as they die. In marine ecosystems, harmful algal blooms such as red tides can
result in human health impacts via shellfish poisoning and recreational contact (Thomann and
Mueller,  1987). In fresh water, blooms of cyanobacteria (blue-green algae) may pose a serious
health hazard to humans via water consumption. When cyanobacterial blooms die or are
ingested, they release water-soluble compounds that are toxic to the nervous system and liver
(Carpenter et al., 1998).

In addition, eutrophication is associated with blooms of a variety of other organisms that are
toxic to humans, such as the estuarine dinoflagellate Pfiesteria piscicida. While Pfiesteria is
primarily associated with fish kills and fish disease events, the organism has also been linked
with human health impacts through dermal or inhalation exposure. Researchers working with
dilute toxic cultures of Pfiesteria exhibited symptoms such as  skin sores, severe headaches,
blurred vision, nausea/vomiting, sustained difficulty breathing, kidney and liver dysfunction,
acute short-term memory loss, and severe cognitive impairment (NCSU, 2000). People with
heavy environmental exposure have exhibited symptoms as well.  In a 1998 study, such
environmental exposure was definitively linked with cognitive impairment and less consistently
linked with physical symptoms (Morris et al., 1998).

3.2    AMMONIA

3.2.1  Ecology

Ammonia exerts a direct biochemical oxygen demand (BOD)  on the receiving water. As
ammonia is oxidized, dissolved oxygen is consumed. Moderate depressions of dissolved oxygen
are associated with reduced species diversity, while more severe depressions can produce fish
kills. In fact, ammonia is a leading cause of fish kills (USDA, 1992).  Ammonia-induced fish
kills are a potential consequence of the discharge of animal wastes directly to  surface waters. For
example, in a May 1997 incident in Wabasha County, Minnesota, ammonia in a dairy cattle
manure discharge killed 16,500 minnows and white suckers (Clean Water Action Alliance,
1998). Additionally, ammonia loadings can contribute to accelerated eutrophication of surface
waters, which can significantly impact aquatic ecosystems in a number of ways, as noted above.

3.2.2  Human Health

Ammonia is a nutrient form of nitrogen that can have several impacts. First, volatilized
ammonia is of concern because of direct  localized impacts on  air quality. Ammonia produces an
objectionable odor and can cause nasal and respiratory irritation.

In addition, ammonia contributes to eutrophication of surface waters.  This phenomenon is
primarily a hazard to aquatic life but is also associated with human health impacts (see Section
3.1.2). As previously mentioned, eutrophication reduces the aesthetic and recreational value of
water bodies. Additionally, the associated algae blooms can affect drinking water by clogging

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treatment plant intakes, producing objectionable tastes and odors, and increasing production of
harmful chlorinated byproducts. These impacts result in increased drinking water treatment
costs, reduced drinking water quality, and/or increased health risks, Eutrophieation can also
impact human health by enhancing the growth of toxic algae and other toxic organisms.

3.3    PATHOGENS

3.3.1   Ecology

Animal wastes carry parasites, bacteria, and viruses, many of which have the potential to be
harmful to wildlife (USDA, 1992; Jackson et al., 1987). Some bacteria in livestock waste cause
avian botulism and avian cholera, which have killed thousands of migratory waterfowl in the past
(USEPA, 1993b). Avian botulism is a food poisoning caused by ingestion of a neurotoxin
produced by the bacterium Clostridium botulinum type C., and Salmonella spp, both of which
naturally occur in the intestinal tract of warm-blooded animals (USFWS, 2000).

Pathogens in surface water can adhere to the skin of fish or be taken up internally when present at
high enough concentrations, hi a controlled experiment, Fattal et al. (1992) detected significant
bacterial concentrations in fish exposed to Escherichia coli and other microorganisms for up to
48 hours. The data suggest that harmful pathogens could be taken up by fish-eating carnivores
feeding in contaminated surface waters.

Shellfish are filter feeders that pass large volumes of water over their gills. As a result, they can
concentrate a broad range of microorganisms in their tissues (Chai et al., 1994).  This provides a
pathway for pathogen transmission to higher trophic organisms. However, little information is
available to assess the health effects of contaminated shellfish on wildlife receptors.

3.3.2  Human Health

Pathogens may be transmitted to humans through contaminated surface water or ground water
used for drinking, or by direct contact with contaminated surface water through recreational uses.
By the year 2010, about 20 percent of the human population (especially infants, the elderly, and
those with compromised immune systems) will be classified as particularly vulnerable to the
health effects of pathogens (Mulla, 1999). Over 150 pathogens in livestock manure are
associated with risks to humans (CAST, 1992). Exhibit 3-1 presents a list of several of these
pathogens and their associated diseases, including salmonellosis, cryptosporidiosis, and
giardiasis. Other pathogens that have been associated with livestock waste include those that
cause cholera, typhoid fever, and polio (USEPA, 1993b).  Many of these pathogens are
transmitted to humans via the fecal-oral route. In the water environment, humans may be
exposed to pathogens through consumption of contaminated drinking water (although the EPA
assumes adequate drinking water treatment of public supplies), or by incidental ingestion during
recreational activities  in contaminated waters.
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                           EXHIBIT 3-1
Some Diseases and Parasites Transmittable to Humans from Animal Manure
Disease
Responsible Organism
Symptoms
Bacteria
Anthrax
Brucellosis
Colibaciliosis
Coliform mastitis-
metritis
Erysipelas
Leptospirosis
Listeriosis
Salmonellosis
Tetanus
Tuberculosis
Bacillus anthracis
Brucella abortus, Brucella
melitensis, Brucella suis
Escherichia coli (some serotypes)
Escherichia coli (some serotypes)
Erysipelothrix rhusiopathiae
Leptospira pomona
Listeria monocytogenes
Salmonella species
Clostridium tetani
Mycobacterium tuberculosis,
Mycobacterium avium
Skin sores, fever, chills, lethargy, headache,
nausea, vomiting, shortness of breath, cough,
nose/throat congestion, pneumonia, joint stiffness,
joint pain
Weakness, lethargy, fever, chills, sweating,
headache
Diarrhea, abdominal gas
Diarrhea, abdominal gas
Skin inflammation, rash, facial swelling, fever,
chills, sweating, joint stiffness, muscle aches,
headache, nausea, vomiting
Abdominal pain, muscle pain, vomiting, fever
Fever, fatigue, nausea, vomiting, diarrhea
Abdominal pain, diarrhea, nausea, chills, fever,
headache
Violent muscle spasms, "lockjaw" spasms of jaw
muscles, difficulty breathing
Cough, fatigue, fever, pain in chest, back, and/or
kidneys
Rickettsia
Q fever
Coxiella burneti
Fever, headache, muscle pains, joint pain, dry
cough, chest pain, abdominal pain, jaundice
Viruses
Foot and Mouth
Swine Cholera
New Castle
Psittacosis
virus
virus
virus
virus
Rash, sore throat, fever


Pneumonia
Fungi
Coccidioidomycosis
Histoplasmosis
Ringworm
Coccidioides immitus
Histoplasma capsulatum
Various microsporum and
trichophyton
Cough, chest pain, fever, chills, sweating,
headache, muscle stiffness, joint stiffness, rash,
wheezing
Fever, chills, muscle ache, muscle stiffness,
cough, rash, joint pain, joint stiffness
Itching, rash
Protozoa
Balantidiasis
Balatidium coli

                               3-8

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                                      EXHIBIT 3-1
      Some Diseases and Parasites Transmittable to Humans from Animal Manure
Disease
Coccidiosis
Cryptosporidiosis
Giardiasis
Toxoplasraosis
Responsible Organism
Eimeria species
Cryptosporidium parvum
Giardia lamblia
Toxoplasma species
Symptoms
Diarrhea, abdominal gas
Watery diarrhea, dehydration, weakness,
abdominal cramping
Diarrhea, abdominal pain, abdominal gas, nausea,
vomiting, headache, fever
Headache, lethargy, seizures, reduced cognitive
function
Par asites/M etazoa
Ascariasis
Sarcocystiasis
Ascaris lumbricoides
Sarcosystis species
Worms in stool or vomit, fever, cough, abdominal
pain, bloody sputum, wheezing, skin rash,
shortness of breath
Fever, diarrhea, abdominal pain
 Sources: Diseases and organisms were compiled from USDA/NRCS (1996) and USEPA (1998). Symptom
 descriptions were obtained from various medical and public health service Internet sites.
 " Pathogens in animal manure are a potential source of disease in humans and other animals. This list represents a
 sampling of diseases that may be transmittable to humans,

Although a wide range of organisms may cause disease in humans, relatively few microbial
agents are responsible for the majority of human disease outbreaks from water-based exposure
routes. This point is illustrated by Exhibit 3-2, which presents reports of waterborne disease
outbreaks and their causes (if known) in the United States for the period 1989-1996.  Intestinal
infections are the most common type of waterborne infection,  and affect the most people.

As presented in Exhibit 3-2, most reported outbreaks were associated with protozoa and bacteria.
As noted in Exhibit 3-1, Cryptosporidium parvum can produce gastrointestinal illness, with
symptoms such as severe diarrhea.  Relatively low doses of both Cryptosporidium parvum as
well as Giardia species are needed to cause infection (Stehman, 2000). Although healthy people
typically recover relatively quickly (within 2 to 10 days) from this type of illness, these diseases
can be fatal in people with weakened immune systems. These individuals typically include
children, the elderly, people with human immunovirus (HIV) infection, chemotherapy patients,
and those taking medications that suppress the immune system.
                                            3-9

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                                     EXHIBIT 3-2
      Etiology of Waterborne Disease Outbreaks Causing Gastroenteritis 1989-1996
Type of
Organism
Protozoa
Bacteria with
Potential for
Infecting
Multiple
Species
Bacterial
Infections
Associated
with Humans
Human
viruses
Acute
Gastroenteritis
Other
Etiologic Agent
Giardia spp.
Cryptosporidium parvum
Escherichia coli 0157:H7
Campylobacterjejuni
Salmonella typhimurium
Salmonella Java
Leptospira grippotyphosa
Shigella sonnei
Shigellaflexneri
Hepatitis A
Norwalk virus
Norwalk-like virus
Small round structured
virus
Unidentified etiology-
many consistent with viral
epidemiology
Cyanobacteria-like bodies
Total
Number of
Outbreaks
27
21
11
3
1
1
1
17
2
3
1
1
1
60
1
Outbreaks
Associated with
Drinking Water
Surface
12
4
-
3
-
-
-
-
-
-
-
.
1
8
1
Ground
6
4
3
-
1
-
-
7
1
-
1
-
-
44
-
Outbreaks
Associated with
Recreational Water
Natural
4
2
7
-
-
-
1
10
1
-
-
-
-
7
-
Pool/
Park
5
11
1
-
-
1
-
-
-
3
-
]
-
1
-
Source: Stehman, 2000.

Exhibit 3-2 shows that infections caused by Giardia species and Cryptosporidium parvum
(considered the two most important waterborne protozoa) were the leading causes of infectious
waterborne disease outbreaks in which an agent was identified, both for total cases and for
number of outbreaks (Mulla, 1999; Stehman, 2000). In 1993 in Milwaukee, Wisconsin,
Cryptosporidium parvum contamination of a public water supply caused more than 100 deaths
and an estimated 403,000 illnesses (Smith,  1994; Gasman, 1996). The outbreak cost an
estimated $37 million in lost wages and productivity (Smith, 1994).  The source of the oocysts
was not identified, but speculated sources include runoff from  cow manure application sites,
wastewater from a slaughterhouse and meat packing plant, and municipal wastewater treatment
                                         3-10

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plant effluent (Gasman, 1996).  Four documented cases of cryptosporidiosis occurring since 1984
have been linked to non-point source agricultural pollution (Mulla, 1999). Two outbreaks of
Cryptosporidium parvum were  also traced to contamination of drinking water by cow manure in
England (Stehman, 2000).

The mandated treatment of public water supplies helps reduce the risk of infection via drinking
water, but the first step in providing safe drinking water is source water protection, especially
because Cryptosporidium parvum is resistant to conventional treatment.

Escherichia coli is an important cause of bacterial waterborne infection in untreated and
recreational water (Stehman, 2000). Infection can be life-threatening, especially in the young and
in the elderly.  It can cause bloody diarrhea and, if not treated promptly, can result in kidney
failure and death (Shelton, 2000). In particular, Escherichia coli O157:H7 is emerging as the
second most important cause of bacterial waterborne disease after Shigella species, which is
associated with human feces. Escherichia coli O157:H7 was unknown until  1982, when it was
associated with a multistate outbreak of hemorrhagic colitis (Shelton, 2000).  In 1999, an
Escherichia coli outbreak occurred at the Washington County Fair in New York State. This
outbreak was possibly the largest waterborne outbreak of Escherichia coli O157:H7 in U.S.
history. It took the lives of two fair attendees and sent 71 others to the hospital. An investigation
identified 781  persons with confirmed or suspected illness related to this outbreak. The outbreak
is thought to have been caused  by contamination of the Fair's Well 6 by either a dormitory septic
system or manure runoff from the nearby Youth Cattle Barn (NYSDOH, 2000). More recently,
in May 2000, an outbreak of Escherichia coli O157:H7 in Walkerton, Ontario resulted in at least
seven deaths and 1,000 cases of intestinal problems; public health officials theorize that one
possible cause was floodwaters washing manure contaminated with Escherichia coli into  the
town's drinking water well; an  investigation is currently underway (Brooke, 2000). An outbreak
of Escherichia coli O157:H7 was reported in Canada from well water potentially  contaminated
by manure runoff (Stehman, 2000).

Cow manure has specifically been implicated as a causative factor in the high bacteria levels and
ensuing swimming restrictions  on Tainter Lake, Wisconsin (Behm, 1989).  Contact recreation
can result in infections of the skin, eye, ear, nose, and throat (Juranek, 1995; Stehman, 2000).
The EPA's recommended ambient water quality standard for human health protection in contact-
recreational fresh waters is either 120 Escherichia coli bacteria/100 ml, or 33 enterococcus
bacteria/100 ml. (This standard, finalized in 1986, replaces the previous standard of 200 fecal
coliform bacteria/100 ml.) About 8 percent of U.S. outbreaks of Escherichia coli O157:H7
between the years 1982 and 1996 occurred as a result of swimming (Griffin, 1998).  Certain
regions, in particular, may be adversely impacted.  For example, pathogen impairment of  surface
waters is a great problem in most rural  areas of southern Minnesota. This causes  many rivers and
lakes to be unsuitable for swimming (Mulla, 1999).

Most human infections caused  by bacteria such as Escherichia coli O157:H7, Salmonella
species, Campylobacter jejuni,  and Leptospira species are spread by foodborne or direct contact
(Stehman, 2000). Many pathogens might be transmitted through shellfish (Stelma and McCabe,

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1992), which are filter feeders prone to accumulating bacteria and viruses. Others may be
transmitted through inhalation. In particular, there is concern that pathogens may also be
introduced to the air directly from animal feeding houses or during spray application of wastes.
Flies and other vectors also present potential pathways for disease transmission.

A final concern is exposure to pathogens via consumption of raw foods improperly subjected to
manure application. Cieslak et al. (1993) suggest that a 1993 Escherichia coli outbreak in Maine
was the result of manure applications to a vegetable garden. Additionally, three Escherichia coli
outbreaks (Montana in 1995, Illinois in 1996, and Connecticut in 1996) were traced to organic
lettuce growers. It is suspected that the lettuces were contaminated by infected cattle manure
(Nelson,  1997). In another incident in Maine, a few hundred children were sickened by
Cryptosporidium parvum. The source was fresh-pressed apple cider made from apples gathered
from a cattle pasture (Millard et al., 1994).  Although this exposure route can cause health
problems, the proposed revisions to the EPA regulations do not attempt to address it directly.

3.4    ORGANIC MATTER

3.4.1   Ecology

Increased organic matter loading to surface waters supports increased microbial population and
activity; as these organisms aerobically degrade the organic matter, dissolved oxygen is
consumed, reducing the amount available for aquatic organisms. This impact is exacerbated in
warm waters compared to colder waters, because the dissolved oxygen saturation level is lower
and because the higher temperatures support increased microbial metabolism.

As a result of dissolved oxygen depletion, aquatic species may suffocate (USEPA, 1993a) or be
driven out of areas that lack sufficient oxygen. This phenomenon can occur rapidly, particularly
with loadings of high-strength waste such as those that may result from catastrophic  lagoon
breaches (Goldman and Home, 1983).  There are many examples nationwide of fish kills
resulting from manure discharges from animal feeding operations (see Chapter 4). In Nebraska
in 1995, 50 percent of all agriculture-related fish kills investigated were due to livestock waste.
In 1996, that percentage rose to 75 percent. In 1997 and 1998, 100 percent of agriculture-related
fish kills were traced to livestock waste (USFWS, 2000).

Oxygen-stressed aquatic systems may also experience decreases in species richness or
community structure as sensitive species are driven out or die off.  Organisms living in
borderline hypoxic (low oxygen) water are also likely to experience physiological stress, which
may increase the potential for diseases, decrease feeding rates, or increase predation. Livestock
has been widely reported to cause significant decreases in wildlife species and  numbers (Mulla et
al., 1999). For example, reduction in biodiversity due to AFOs has been documented in a study
of three Indiana stream systems (Hoosier Environmental Council,  1997).  That study shows that
waters downstream of animal feedlots (mainly swine and dairy operations) contained fewer fish
and a limited number of species of fish in comparison with reference sites.  Excessive algal
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growth; altered oxygen content; and increased levels of ammonia, turbidity, pH, and total
dissolved solids were also observed.

High oxygen depletion rates due to microbial activity have been reported in manure-amended
agricultural soils as well. In soils, elevated microbial populations can affect crop growth by
competing with plant roots for soil oxygen and nutrients (USDA, 1992),

3.4.2   Human Health

The release of organic matter to surface waters is a human health concern insofar as it can impact
drinking water sources and recreational waters. As aquatic bacteria and other microorganisms
degrade organic matter in manure, they consume dissolved oxygen. This can lead to foul odors
and ecological impacts, reducing the water's value as a source of drinking water and recreation.
Additionally, increased organic matter in drinking water sources can lead to excessive production
of harmful chlorinated byproducts, resulting in higher drinking water treatment costs and/or
higher health risks. Pathogen growth is another concern, as large inflows of nutrient-rich organic
matter, under the right environmental conditions, can cause rapid increases in microbial
populations.

3.5    SALTS AND TRACE ELEMENTS

3,5.1   Ecology

Salts in manure can impact the water and soil environment. In fresh waters, increasing salinity
can disrupt the balance of the ecosystem. Drinking water high in salt content was shown to
inhibit growth and cause slowed molting in mallard ducklings (DEC, 1993). On land, salts can
accumulate and become toxic to plants, and reduce crop yields. Salts can damage soil quality by
reducing permeability and deteriorating soil structure (Bloom, 1999).

Trace elements in manure can impact plants, aquatic organisms, and terrestrial organisms. While
many of the trace elements are essential nutrients at low concentrations, they can have significant
ecotoxicological effects at elevated concentrations. For example, metals such as zinc (a feed
additive) can accumulate in soil and become toxic to plants at high concentrations. Arsenic,
copper, and selenium are other feed additives that can produce aquatic and terrestrial toxicity at
elevated concentrations. Bottom feeding birds can be quite susceptible to metal toxicity because
they are attracted to shallow feedlot wastewater ponds  and waters adjacent to feedlots. Metals
can remain in aquatic ecosystems for long periods of time because of adsorption to suspended or
bed sediments or uptake by aquatic biota.

Several of the trace elements in manure are regulated in treated municipal sewage sludge (but not
manure) by the Clean Water Act's Part 503 Rule.  Total concentrations of trace elements in
animal manures have been reported as comparable to those in some municipal sludges, with
typical values well below the maximum concentrations allowed by Part 503 for land-applied
sewage sludge (Sims,  1995).  Based on this information, trace elements in agronomically applied

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manures should pose little risk to human health and the environment.  However, repeated
application of manures above agronomic rates could result in exceedances of the cumulative
metal loading rates established in Part 503, thereby potentially impacting human health and the
environment (USFWS, 1991).

In 1991, the U.S. Fish and Wildlife Service (USFWS) reported on suspected impacts from a large
number of cattle feedlots on Tierra Blanca Creek, upstream of the Buffalo Lake National
Wildlife Refuge in the Texas Panhandle.  USFWS found elevated concentrations of the feed
additives copper and zinc in the creek sediment (as well as elevated aqueous concentrations of
ammonia, chemical oxygen demand, chlorophyll a, coliform bacteria, chloride, conductivity,
total Kjeldahl nitrogen, and volatile suspended solids). The relative contribution of these
contaminants from various sources (e.g., runoff from facilities without containment lagoons,
lagoon discharges, and lagoon leachate) was not assessed (USFWS, 1991).

In 1998, USFWS found copper and zinc in wetlands fed by wastewater from a nearby swine
production operation in Nebraska.  Concentrations of copper exceeded both a proposed aquatic
life criterion of 43 ug/L and the current least-protective criterion of 121 ug/L.  Zinc
concentrations exceeded the concentrations recommended for the protection of aquatic life
(USFWS, 2000).

3.5.2  Human Health

Salts from manure can impact surface and ground water drinking water sources. Salt load into
the Chino Basin from local dairies is over 1,500 tons per year, and the cost to remove that salt by
the drinking water treatment system ranges from $320 to $690 for every ton (USEPA, 1993b).
At lower levels, salts can increase blood pressure in salt-sensitive individuals, increasing the risk
of stroke and heart attack.  Salts  can also make drinking water unpalatable and unsuitable for
human consumption.

Some of the trace elements in manure are essential nutrients required for human physiology;
however, they can induce toxicity at elevated concentrations.  These include zinc, arsenic,
copper, and selenium, which are feed additives (Sims, 1995).  Although these elements are
typically present in relatively low concentrations in manure, they are of concern because of their
ability to persist in the environment and to bioconcentrate in plant and animal tissues.  These
elements could pose a hazard if manure is overapplied to land, due to insufficient  acreage
available to accommodate manure from increasingly concentrated AFOs. Over-applied manure
increases the likelihood of pollutants reaching surface water and ultimately being  ingested.

Trace elements are associated with a variety of illnesses. For example, arsenic is carcinogenic to
humans, based on evidence from human studies; some of these studies have found increased skin
cancer and mortality from multiple internal organ cancers in populations who consumed drinking
water with high levels of inorganic arsenic. Arsenic is also linked with non-cancer effects,
including hyperpigmentation and possible vascular complications. Selenium is associated with
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liver dysfunction and loss of hair and nails, and zinc can result in changes in copper and iron
balances, particularly copper deficiency anemia (IRIS, 2000).

3.6    SOLIDS

Excessive silting and sedimentation are prime agents responsible for the long-term degradation
of rivers, streams, and lakes. Major sources of siltation include runoff from agricultural, urban,
and forest lands and other non-point sources (USEPA, 1992b).

Solids entering surface water can degrade aquatic ecosystems to the point of non-viability.
Suspended particles can reduce the depth to which sunlight can reach, decreasing photosynthetic
activity (and the resulting oxygen production) by plants and phytoplankton. The increased
turbidity also limits the growth of desirable aquatic plants that serve as critical habitat for fish,
crabs, and other aquatic organisms.  In addition, suspended particles can clog fish gills, degrade
feeding areas, and reduce visibility for sight feeders (Abt Associates, 1993), and can disrupt
migration by interfering with fish's ability to detect chemical communication signals in water
(Goldman and Home, 1983). Sediment can smother eggs, interrupt the reproductive process, and
alter or destroy habitat for fish and benthic organisms.

Solids can also degrade drinking water sources, thereby increasing treatment costs.  Furthermore,
solids provide a medium for the accumulation, transport, and storage of other pollutants,
including nutrients, pathogens, and trace elements.  Sediment-bound pollutants often have a long
history of interaction with the water column through cycles of deposition, resuspension, and
redeposition.

3.7    ANTIBIOTICS AND ANTIBIOTIC RESISTANCE

Antibiotic-resistant strains of bacteria develop as a result of continual exposure to antibiotics.
Use of antibiotics in raising animals, especially broad spectrum antibiotics, is increasing.  As a
result, more strains of antibiotic-resistant pathogens are emerging, along with strains that  are
increasingly resistant (Mulla, 1999).  Antibiotic-resistant forms of Salmonella, Campylobacter,
Escherichia coli, and Listeria are known or suspected to exist.  An antibiotic-resistant strain  of
the bacterium Clostridium perfringens was detected in the ground water below plots of land
treated with swine manure, while it was nearly absent beneath unmanured plots.

Antibiotic resistance poses a significant health threat,  hi April 2000 the New England Journal of
Medicine published an article that discussed the case of a 12-year-old boy infected with a strain
of Salmonella that was resistant to no fewer than 13 antimicrobial agents (Fey et al., 2000). The
cause of the child's illness is believed to be exposure to the cattle on his family's Nebraska
ranch.

The Centers for Disease Control and Prevention, the Food and Drug Administration, and  the
National Institutes of Health issued a draft action plan in June 2000 to address the increase in
antibiotic resistant diseases (CDCP, 2000). The plan is intended to combat antimicrobial

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resistance through surveys, prevention and control activities, research, and product development.
One of the action items involves conducting pilot studies to assess the impact of environmental
contamination by antimicrobial drug residues and drug-resistant organisms that enter the soil or
water from human and animal waste.

3.8    HORMONES AND ENDOCRINE DISRUPTION

The presence of estrogen and estrogen-like compounds in surface water has caused much
concern.  Their ultimate fate in the environment is unknown, although early studies indicate that
no common soil or fecal bacteria can metabolize estrogen (Shore et al., 1995). When present in
high concentrations, hormones in the environment are linked to reduced fertility, mutations, and
the death of fish, and there is evidence that fish in some streams are experiencing endocrine
disruption (Shore et al.,  1995; Mulla, 1999).

Estradiol, an estrogen hormone, was found in runoff from a field receiving poultry litter at
concentrations up to 3.5 ug/L. Fish exposed to 0.25 ug/L of estradiol often have gender changes;
exposures at levels above 10 ug/L can be fatal (Mulla, 1999). Estrogen levels of 10 ug/L have
been shown to affect trout (Shore et al.,  1995).

Endocrine disrupters have also been the subject of increasing concern because they alter hormone
pathways that regulate reproductive processes in both human and animal populations. Estrogen
hormones have been implicated in the drastic reduction in sperm counts among European and
North American men (Sharpe and Skakkebaek,  1993) and widespread reproductive disorders in a
variety of wildlife (Colburn et al., 1993). A number of agricultural chemicals have also been
demonstrated to cause endocrine disruption as well, including pesticides (Shore et al., 1995).
The effects of these chemicals on the environment and their impacts on human health through
environmental exposures are not completely understood.  They are currently being studied for
neurobiological, developmental, reproductive, and carcinogenic effects (Tetra Tech, 2000a). The
EPA is not aware of any studies done on the human health impact of hormones from watersheds
that have impairment from animal manure.

3.9    OTHER POLLUTANTS OF CONCERN

3.9.1  Gas Emissions

Odor sources include animal confinement buildings, waste lagoons, and land application sites.
As animal waste decomposes, various gases are produced. The primary gases associated with
aerobic decomposition include carbon dioxide and ammonia. Gases associated with anaerobic
conditions, which dominate  in typical, unaerated animal waste lagoons, include methane, carbon
dioxide,  ammonia, hydrogen sulfide, and over 150 other odorous compounds (USDA, 1992;
Bouzaher et al., 1993; O'Neill and Phillips, 1992). These include volatile fatty acids, phenols,
mercaptans, aromatics, sulfides, and various esters, carbonyls,  and amines. The decomposition
process is desirable because it reduces the biochemical oxygen demand and pathogen content of
the waste. However, many of the end products can produce negative impacts, including strong

                                         3-16

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odors.  Heavy odors are the most common complaint from neighbors of swine operations in
particular (Agricultural Animal Waste Task Force, 1996).

Odor is itself a significant concern because of its documented effect on moods, such as increased
tension, depression, and fatigue (Schiffman et al., 1995). Odor also has the potential for vector
attraction and affects property values. Additionally, many of the odor-causing compounds can
cause physical health impacts. For example, hydrogen sulfide is toxic, and ammonia gas is a
nasal and respiratory irritant.

In 1996, the Minnesota Department of Health found levels of hydrogen sulfide gas at residences
near AFOs that were high enough to cause symptoms such as headaches, nausea, vomiting, eye
irritation, respiratory problems (including shallow breathing and coughing), achy joints,
dizziness, fatigue, sore throats, swollen glands, tightness in the chest, irritability, insomnia, and
blackouts (Addis et al., 1999). In an Iowa study, neighbors within two miles of a 4,000-sow
swine facility reported more physical and mental health symptoms than a control group (Thu,
1998). These symptoms included chronic bronchitis, hyperactive airways, mucus membrane
irritation, headache, nausea, tension, anger, fatigue, and confusion.

Methane and carbon dioxide are greenhouse gases that contribute to global warming. Methane
also contributes to the formation of tropospheric ozone (a component of photochemical smog).
Based on various EPA estimates (USEPA, 1989 and USEPA, 1992a), methane emissions from
U.S. animal wastes are a very small contributor to the global warming effect.

3.9.2  Participates

Sources of particulate  emissions from AFOs may include dried manure, feed, skin, hair, and
possibly bedding. The airborne particles make up an organic dust, which includes endotoxin (the
toxic protoplasm liberated when a microorganism dies and disintegrates), adsorbed gases, and
possibly steroids (Thu, 1995). At least 50 percent of dust emissions from swine production
facilities are believed to be respirable. The main impact downwind appears to be respiratory
irritation due to the inhalation of organic dusts. Studies indicate that the associated microbes
generally are not infectious, but may induce inflammation (Thu, 1995).

3.9.3  Pesticides

Pesticides may pose risks to the environment, such as chronic aquatic toxicity, and human health
effects, such as systemic toxicity. In a few studies, common herbicides have been shown to
cause endocrine disruption. There is some evidence that fish in some streams are experiencing
endocrine disruption and that contaminants including pesticides may be the cause (Mulla, 1999).
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4.
NATIONAL AND LOCAL IMPACTS OF ANIMAL AGRICULTURE
4.1    NATIONAL WATER QUALITY INVENTORY RESULTS

Agricultural operations, including AFOs, are a significant source of water pollution in the United
States. The recently released National Water Quality Inventory: 1998 Report to Congress
(USEPA, 2QOOa) was prepared under Section 305(b) of the Clean Water Act.11  Under this
section of the Act, states and tribes report their impaired water bodies to the EPA, including the
suspected sources of those impairments.  The most recent report indicates that agriculture (which
includes crop production, pasture and range grazing, concentrated and other confined animal
feeding operations, and aquaculture) is the leading contributor to identified water quality
impairments in the nation's rivers and lakes, and the fifth leading contributor to identified water
quality impairments in the nation's estuaries (Exhibit 4-1).

                                      EXHIBIT 4-1
         Five Leading Sources of Water Quality Impairment in the United States
Rank
1
2
3
4
5
Rivers | Lakes
Agriculture (59%)
Hydromodification (20%)
Urban Runoff/Storm Sewers
(11%)
Municipal Point Sources
(10%)
Resource Extraction (9%)
Agriculture (31%)
Hydromodification (15%)
Urban Runoff/Storm Sewers (12%)
Municipal Point Sources (11%)
Atmospheric Deposition (8%)
Estuaries
Municipal Point Sources (28%)
Urban Runoff/Storm Sewers (28%)
Atmospheric Deposition (23%)
Industrial Discharges (15%)
Agriculture (15%)
 Source: USEPA (2000a).
 Fraction of impairment attributed to each source is shown in parentheses. For example, agriculture is listed as a
 source of impairment in 59 percent of impaired river miles. The portion of "agricultural" impairment attributable to
 animal waste (as compared to crop production, pasture grazing, range grazing, and aquaculture) is not specified.
 Figure totals exceed 100 percent because water bodies may be impaired by more than one source.

Exhibit 4-2 presents additional summary statistics from the 1998 National Water Quality
Inventory. These figures indicate that agriculture contributes to the impairment of at least
170,000 river miles, 2.4 million lake acres, and almost 2,000 estuarine square miles.  The total
portion of impairment attributable to animal agriculture nationwide is unknown, because only a
portion of all states  and tribes identified specific agricultural sources. Some conclusions,
however, can be made based on the reporting states, as indicated  in Exhibit 4-3.
       "This report can be found on the Internet at http://www.epa.gov/305b/98report.

                                           4-1

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                                      EXHIBIT 4-2
                   Summary of U.S. Water Quality Impairment Survey
Total Quantity in U.S.
Rivers
3,662,255 miles
Lakes, Ponds, and Reservoirs
41,6 million acres
Estuaries
90,465 square miles
Waters Assessed
23% of total
840,402 miles
42% of total
17.4 million acres
32% of total
28,687 square miles
Quantity Impaired by
All Sources
35% of assessed
291,263 miles
45% of assessed
7,9 million acres
44% of assessed
12,482 square miles
Quantity Impaired by
Agriculture *
59% of impaired
170,750 miles
31% of impaired
2,417,801 acres
15% of impaired
1,827 square miles
 Source: USEPA (2000a).
 " AFOs are a subset of the agriculture category. Summaries of impairment by non-agricultural sources are not
 presented here.

                                      EXHIBIT 4-3
       Percent of Total Agricultural Impairment Contributed by Animal Agriculture
Type of Animal Agriculture
AFOs (Feedlots, Holding Areas, Other)
Range and Pasture Grazing
Rivers, Streams"
16
17
Lakes, Ponds,
Reservoirs'1
4
39
"Based on reports from 28 states.
b Based on reports from 16 states.
Note: Impairment due to land application of manure was not reported.

Exhibit 4-4 lists the leading pollutants impairing surface water quality in the United States.
AFOs are a potential source of all listed pollutants, but are most commonly associated with
nutrients, pathogens, oxygen-depleting substances, and solids (siltation). AFOs can also
contribute to the growth of noxious aquatic plants due to the discharge of excess nutrients.
Further, AFOs may contribute loadings of priority toxic organic chemicals and oil and grease, but
probably to a lesser extent than the other leading pollutants.

Pollutants associated with AFOs can also originate from a variety of other sources, such as
cropland, municipal and industrial wastewater discharges, urban runoff, and septic systems. The
national analyses described in the following section are useful in assessing the significance of
animal waste as a potential or actual contributor to water quality degradation across the United
States.
                                            4-2

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                                      EXHIBIT 4-4
          Five Leading Causes of Water Quality Impairment in the United States
Rank
1
2
3
4
5
Rivers
Siltation (38%)
Pathogens (36%)
Nutrients (29%)
Oxygen-Depleting Substances
(23%)
Metals (21%)
Lakes
Nutrients (44 %)
Metals (27%)
Siltation (15%)
Oxygen-Depleting Substances
(14%)
Suspended Solids (10%)
Estuaries
Pathogens (47%)
Oxygen-Depleting Substances
(42%)
Metals (27%)
Nutrients (23%)
Thermal Modifications (18%)
 Source: USEPA (2000a),
 Note: Percent impairment attributed to each pollutant is shown in parentheses. For example, siltation is listed as a
 cause of impairment in 38 percent of impaired river miles. Items in bold print are those commonly associated with
 animal feeding operations, although they are also associated with other sources. Figure totals exceed 100 percent
 because water bodies may be impaired by more than one source.

4.2    NATIONAL ANALYSES OF NUTRIENT CONTRIBUTIONS

The national contribution and importance of nitrogen and phosphorus from animal operations has
been estimated in several analyses. The first two analyses (Sections 4.2.1 and 4.2.2) focus on the
production of nitrogen/phosphorus (and therefore, the potential for animal waste to contribute to
nutrient loadings in water), whereas the last analysis (Section 4.2.3) uses sophisticated modeling
techniques to estimate the amount of nutrients that reach surface water due to disposal and use of
animal manure.

4.2.1   1994 USGS Study on Nitrogen Production from Various Sources

USGS analyzed  nitrogen sources (manure, fertilizers, point sources, and atmospheric
deposition)12 in 107 U.S. watersheds, and found that the proportion of nitrogen originating from
each source differs according to climate, hydrologic conditions, land use, population, and
physical geography (Puckett, 1994).

Exhibit 4-5 displays results of the analysis for selected watersheds using information from 1987.
As shown, the production of manure nitrogen relative to other sources varies by watershed. The
"manure" source estimates include waste from both confined and unconfined animals.  Puckett
(1994) does not  address whether the proportion of waste from confined facilities is larger or
smaller than the  fraction from unconfined animals. In some cases, manure nitrogen is a large
       l2The analysis does not include other potentially significant sources of nitrogen, such as urban runoff,
sewer overflows, septic systems, and contaminated ground water.
                                            4-3

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portion of the total nitrogen added to the watershed. In the following watersheds, more than 25
percent of nitrogen originates from manure:

       •       Trinity River, Texas
       *       White River, Arkansas
       •       Apalachicola River, Florida
       •       Altamaha River, Georgia
       •       Potomac River, District of Columbia
       •       Susquehanna River, Pennsylvania
       «       Platte River, Nebraska
       »       Snake River, Idaho
       »       San Joaquin River, California

As indicated by the wide distribution of these geographic areas, significant contributions of
nitrogen from animal manure occur throughout the U.S.
                                           4-4

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      Palouse
      River,
      WA
   Willamette River,
   OR
    Snake River,
    ID
   San Joaquin
   Rivi
                                                         EXHIBIT 4-5
                           Proportions of Nitrogen Sources in Selected Watersheds (1987 Base Year)
Platte
River,
NE
Red River of
the North,
MN.ND
                                         White
                                         River,
                                         IN
Susquehanna
River, PA
 LEGEND
    Nitrogen Source
  I   I  Point Sources

        Fertilizer

  HI  Atmosphere

  HI  Manure

Source:  Puckett (1994).
 South Platte
 River, CO
                                    Apalachioola
                                    River, FL
               Trinity River, TX      White River, AR

Note: CAFO point sources are included in the "manure" category.
Connecticut
River, CT
                                                                                     Potomac
                                                                                     River, DC
                                                                                   Tar River, NC
                                                                                 Altamaha River, GA

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4.2.2  1998 USDA Study of Nitrogen and Phosphorus Production Relative to Crop Uptake
       Potential

Because of its nutrient content, animal manure is a valuable crop fertilizer. However, if nutrients
are applied in excess of amounts that can be used by plants, there may be a greater potential for
releases to the environment.  Based on data from the 1992 Census of Agriculture (USDC/Census
Bureau, 1994), USDA evaluated the quantity of nutrients available from recoverable livestock
manure relative to crop  growth requirements, by county (Lander et al., 1998).13 The analyses are
intended to reflect the amount of manure that can be recovered and utilized; the analyses
therefore do not consider manure from unconfined animals.

Exhibits 4-6 and 4-7 show the estimated useable manure nitrogen and phosphorus production
from confined livestock, including swine, chickens, turkeys, and cattle. The figures account for
the inability to completely recover manure, as well as typical nutrient losses during storage and
treatment.  These losses can be significant, particularly for nitrogen, due to the high volatilization
potential of ammonia.14 Considering typical management systems, average manure nitrogen
losses range from 31 to 50 percent for poultry, 60 to 70 percent for cattle (beef, dairy, and other
categories), and 75 percent for swine. By contrast, the typical phosphorus loss is 15 percent
(Lander et al., 1998).

Exhibits 4-8 and 4-9 illustrate the potential for available manure nitrogen and phosphorus to
meet or exceed plant uptake and removal in each of the 3,141 mainland counties, considering
harvested non-legume15 cropland and hayland. (See Lander et al.  [1998] for results of additional
analyses which also consider legume cropland and pastureland.)  Based on this analysis, available
manure nitrogen exceeds crop system needs in 266 counties, and available manure  phosphorus
exceeds crop needs in 485 counties. The relative excess of phosphorus compared to nitrogen is
not surprising, since manure is typically nitrogen-deficient relative to crop needs. Therefore,
when manure is applied to meet a crop's nitrogen requirement, phosphorus is typically applied in
excess of its crop requirement (Sims,  1995).

Several points underscore the magnitude of the problem.  First, in several of the counties where
animal manure nutrients exceeded crop capacities, excesses would occur even if manure were
applied to all suitable land in those counties. In addition, county-wide nutrient balances likely
       13County level data are not yet available for the 1997 Census. However, in Chapter 2, Exhibit 2-4 presents
the national production of recoverable manure and nutrients generated by animal sector based on the 1997 Census
data (USDA/NRCS, 2000; USDA/NASS, 1999).

       l4As noted earlier, volatilized ammonia can have significant impacts on air quality and water quality (via
atmospheric deposition).

       15Legumes (e.g., alfalfa, clovers, peas, and beans), through symbiotic biological nitrogen fixation, can "fix"
atmospheric nitrogen gas  into plant-available ammonia (Follett, 1995). Thus, legumes do not require nitrogen
application.

                                            4-6

-------
understate occurrences of local nutrient excesses, because most manure remains on the farm
where it was generated, and confined animal production farms often do not have enough land to
accommodate the manure (Letson and Gollehon, 1998).  Specifically, large, specialized animal
production farms typically have a relatively high animal/acre ratio when compared to smaller,
integrated farms, as indicated by information on consolidation trends presented in Chapter 2.
Information is not available on the number of AFOs that lease land for manure application or
distribute the manure to others.

In a more recent evaluation of manure nutrients relative to the capacity of cropland to assimilate
nutrients, USDA estimated that 1.5 billion pounds of farm-level excess manure nitrogen and 0.9
billion pounds of farm-level excess phosphorus were produced in 1997, representing about 60
percent of the recoverable manure nitrogen and 65 percent of the recoverable manure
phosphorus. Excess farm level nutrients increased by more than 60 percent for both phosphorus
and nitrogen between 1982 and 1997, and most were associated with large farms by 1997. For
example, AFOs accounted for 64 percent of the excess nitrogen and 67 percent of the excess
phosphorus in 1997 (Kellogg et al., 2000).

These USDA analyses are not intended to reflect actual manure  management practices, but rather
the potential for manure nutrient usage, without consideration of economic conditions, land
ownership limitations, and other nutrient sources (e.g., commercial  fertilizers). Additionally, the
analyses do not account for environmental transport of applied manure nutrients. Therefore, an
excess of nutrients does not necessarily indicate that a water quality problem exists; likewise, a
lack of excess nutrients does not imply the absence of water quality problems. Nevertheless, the
analyses are useful as a general indicator of excess nutrients on a broad-scale basis.16
       '6See Lander et al. (1998) for a complete list of assumptions and limitations.

                                           4-7

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                                      EXHIBIT 4-6
           Estimated Manure Nitrogen Production from Confined Livestock
                                                                       Pounds per County
                                                                       h Thousands
                                                                          LKJ unit ICO
                                                                          100 to KK>
                                                                          SDO t« i .000
                                                                          1, 000 1» 2,000
                                                                          ZOOO erpiair
                          Source: Lander et al, 1998

Nrte: Manure nitrogen prediction includes recoverable manure nitrogen, after treatment/storage losses.

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                                     EXHIBIT 4-7
        Estimated Manure Phosphorus Production from Confined Livestock
                                                                        Pounds per County
                                                                        in Thousands
                                                                        P reduction
                                                                           HLsthzn [00
                                                                           100W5QC
                                                                        BJi 500 tn 1,000
                                                                        RBI 1.DDO to 2,OOO
                                                                        |[H ZOO3
                           Source: Lander etal., 1898

Note: Manure phosfrfiorus proAidion includes recoverable manure phosphorus, after treatment/storage losses.

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                           EXHIBIT 4-8
Potential for Nitrogen Available from Animal Manure to Meet or Exceed
Uptake and Removal on Non-Legume, Harvested Cropland and Hayland
                    Scurce. 6.andcrcial ,

       avaliailf &aiiti« nmiwv silUc^ttj,

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                          EXHIBIT 4-9
Potential for Phosphorus Available from Animal Manure to Meet or Exceed
 Uptake and Removal on Non-Legume, Harvested Cropland and Hayland
                                                              mt>

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4.2.3   1997 USGS Modeling Study of Nitrogen and Phosphorus Loadings
       to Surface Waters

The analyses described in Sections 4.2.1 and 4.2.2 are land-based and are not intended to
represent in-stream water quality conditions. Delivery of nutrients to surface water is affected by
many watershed characteristics, such as soil permeability, stream density, temperature, slope, and
precipitation. Other watershed attributes, such as stream depth, stream velocity, and reservoir
retention, further affect nutrient delivery along stream networks. USGS's SPARROW (SPAtially
Referenced Regressions On Watershed attributes) water quality model accounts for these
characteristics.  SPARROW is a statistical method that relates measured water quality data to
spatially referenced pollutant sources and watershed attributes. The model's regression equations
express in-stream nutrient loads as a function of stream and land-surface characteristics. The
equations incorporate point and non-point pollutant sources, as well as factors associated with
material transport through the watershed (e.g., soil permeability and stream velocity). The model
is used to describe spatial and temporal patterns in water quality and to identify factors and
processes that influence those conditions (Smith et al., 1997).

As  described by Smith et al. (1997), USGS scientists applied the SPARROW model nationally to
the 2,056 hydrologic cataloging units (watersheds) in the contiguous United  States to estimate
total nitrogen (TN) and total phosphorus (TP) export from various point and non-point sources
(including commercial fertilizers, livestock waste, atmospheric nitrogen deposition, and non-
agricultural land).  Annual average livestock waste from both confined and unconfined animals
was estimated for 1987, using data from the 1987 Census of Agriculture.17

Exhibits 4-10 and 4-11 present the predicted total local nitrogen and phosphorus yields (mass
exported per unit of watershed area), from local (not upstream) sources.  Exhibits 4-12 and 4-13
present the predicted percent contribution from animal waste to those local yields.  The latter
exhibits show that animal waste is a significant source (relative to other local sources) of in-
stream nutrient concentrations in many watershed outlets, particularly in the  central and eastern
United States.

Smith et al. (1997) found that in general, commercial fertilizer contributes significantly more
than livestock waste to local TN yield.  By contrast, the analysis shows that livestock waste
contributes more than commercial fertilizer to local TP yield.  This may be due to the typically
low N:P ratio in manure relative to crop N:P needs, which results in over-application of
phosphorus when manure is applied to meet crop nitrogen requirements (Sims, 1995).
       "Although CAFOs are designated as point sources in the Clean Water Act, they are included in the
"livestock waste" category in this analysis. Point source data used in the analysis were obtained from a  1977 -1981
inventory (Smith et al., 1997).

                                           4-12

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                                           EXHIBIT 4-10
               Predicted Local Nitrogen Yield in Hydrologic Cataloging Units
Basfd on information from 'Regional Interpretation of Water Quality Data* (Smith et al.. 1697), describing SPARROW
model results for 198? base year, 'Local" refers to the viithin-HUC source contributions, independent of inflcws from
upstream watersheds. Other sources evaluated include point sources, commercial fertilizer, and noriagriciiitjrai land.

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                                          EXHIBIT 4-11
         Predicted Local Total Phosphorus Yield in Hydrologic Cataloging Units
Based on information from 'Regional Interpretation of Water Quality Data" (Smith el al, 1897), describing SPARROW
mode! results for 198? base year. 'Local" refers to (tie wOiin-HUC source contributions, independent of inflows from
upstream watersheds. Other sources evaluated include point sources, commercial fertilizer, and nonagricultural tend.

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                                       EXHIBIT 4-12
              Predicted Percentage Contribution of Animal Waste to Local
                Total Nitrogen Export from Hydrologic Cataloging Units
Based on information from "Regional interpretation of Water Quality Data" (Smith et ai., 1987), describing SPARROW
mode! results for 1i8? base year, 'Local' refers to the wtrtin-HUC source contributions. Independent of inflows from
upstream watersheds, Other sources evaluated include point sources, commercial fertiizer atmospheric deposition.

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                                     EXHIBIT 4-13
           Predicted Percentage Contribution of Animal Waste to Local
            Total Phosphorus Export from Hydrologic Cataloging Units
       information frwn »Rsotonal InterpretaBon of Water Quality Data* (Smith *t at.. 1M7>. descflNng SPARROW
model results tor 1987 has* year, "Local" refers to ttie •wWiin-HUC sowc» contriteittwts, Instependtm of inflows from
upstream watersheds. Other sources evaluated include point sources, commercial fertilizer, and nonagricultural land.

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4.3    NATIONAL ANALYSIS OF SHELLFISH BED IMPAIRMENT

In The 1995 National Shellfish Register of Classified Growing Waters, the National Oceanic and
Atmospheric Association (NOAA) characterizes the status of 4,230 shellfish-growing water areas
in 21 coastal states, reflecting an assessment of nearly 25 million acres of estuarine and non-
estuarine waters. These waters support a significant amount of shellfish produced in the United
States. Specifically, over 77 million pounds were harvested  from these waters in 1995, with a
commercial value of $200 million (NOAA, 1997).

Results of this analysis are presented in Exhibit 4-14, which  lists the number of shellfish beds
impaired by feedlots, according to impairment classifications and estimated level of contribution.
NOAA found that 3,404 shellfish areas had some level of impairment (i.e.,  a classification other
than "approved" or "unclassified").  Of these, 110 (3 percent) were impaired to varying degrees
by feedlots, and 280 (8 percent) were impaired by "other agriculture" (which could include land
where manure is applied).

                                    EXHIBIT 4-14
                          Shellfish Beds Impaired by Feedlots
Estimated Level of
Contribution from Feedlots
Actual Contributor (High)
Actual Contributor (Medium)
Actual Contributor (Low)
Potential Contributor
TOTAL
Level of Impairment (Harvest Classification)
Conditionally
Approved
6
3
2
1
12
Conditionally
Restricted
0
1
1
0
2
Restricted
12
16
2
8
Prohibited
22
23
9
4
38 _[ 58
Total
Impaired by
Feedlots
40
43
14
13
110
 Source:  NOAA (1997),

4.4    LOCAL IMPACTS

This section presents documented local-level environmental incidents and impacts from animal
feeding operations. The exhibits are organized by animal type and present information in three
areas: (1) a listing of discharges directly to surface water revealing violations of the "no
discharge" requirement; (2) human health related impacts; and (3) ecological, recreational, and
other impacts.  Exhibit 4-15 shows the organization of this information in the subsequent
exhibits. Because this compilation resulted from a non-exhaustive literature search, it cannot be
considered comprehensive. However, these exhibits show that a large number of events have
been reported over time.
                                         4-17

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                                     EXHIBIT 4-15
               Description of Environmental Incidents and Impacts Tables
Topic/Animal
Category
Listing of
Discharges to
Surface Water
Human Health
Related Impacts
Ecological,
Recreational,
Other Impacts
Swine
Exhibit 4- 16
110 items
Exhibit 4- 17
6 items
Exhibit 4- 18
50* items
Poultry
Exhibit 4- 19
18 items
Exhibit 4-20
2 items
Exhibit 4-21
9* items
Beef and Dairy
Exhibit 4-22
57 items
Exhibit 4-23
2 items
Exhibit 4-24
9* items
Unspecified or
Multiple
Exhibit 4-25
53 items
Exhibit 4-26
3 items
Exhibit 4-27
28* items
 *Includes items from exhibits of discharge to surface water that indicated fish kills resulting from the discharge.

The relatively high number of reported surface discharges compared to fewer documented
impacts probably reflects the higher visibility of the discharge events. Documenting
environmental impacts from animal waste can be difficult, because as noted above, several
manure constituents can also originate from other sources, and extensive investigations are
sometimes required to estimate the relative contribution of each source. The events reported here
are confined to impacts where AFOs were reported as a significant causative factor. Other
contributing factors are identified to the extent that they were included in the literature.
Examples of areas affected by animal waste are described in the following subsections.

Following Exhibits 4-16 through 4-27 are three examples that are discussed in more detail.
                                          4-18

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                      EXHIBIT 4-16
Documented Discharges from Swine Operations to Surface Waters
Date
7/1/97
10/17/97
10/9/97
9/18/97
8/27/97
7/26/97
9/4/96
8/26/96
8/19/96
Location
IL
Clear Creek, IA
Brooke Creek, IA
Prairie Creek, IA
South Fork of Iowa River, IA
Crane Creek, IA
North Buffalo Creek, IA
Rock Creek, IA
Cedar County, IA
Source
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
3,200 head swine
operation
Swine operation
Swine operation
Swine operation
Description of Event
800,000 gallons discharged
28, 134 fish killed
4 194 fish killed
93,403 fish killed
3,232 fish killed
109, 172 fish killed
More than 100,000 gallons
pumped into Creek;
586,753 fish killed
871 fish killed
3,676 fish killed
Comments
Contaminated drinking water
of at least 5 homes with
Escherichia coli; Illinois EPA
levies fines totaling $9,600 or
more, which will partially
fund creek restoration
$4,000 direct cost
+ $2,000 fine
£267.50 direct cost
+ $2,500 fine
516,140.84 direct cost;
fine was pending
5264,23 direct cost;
fine was pending
Blocked pipe resulted in
discharge.
$33,882.73 direct cost;
fine was pending
$30,000 direct cost
+ $3,000 fine
$237 direct cost
$408 .76 direct cost
Reference
Illinois Stewardship
Alliance (1997)
Macomb Journal (1999)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)

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                      EXHIBIT 4-16
Documented Discharges from Swine Operations to Surface Waters
Date
8/19/96
11/15/95
9/25/95
7/23/95
7/20/95
7/16/95
7/1/95
3/28/95
9/94
9/94
8/94
Location
Tipton Creek, IA
Indian Creek, LA
Williams Creek, IA
Elk Creek tributary, IA
Little Volga River, IA
South Fork of Iowa River, LA.
Hamilton, LA
South English River tributary,
IA
Kossuth County, IA
Williams Creek, IA
Otter Creek, IA
Source
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
700 head swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Description of Event
46,3 15 fish Wiled
4,928 fish Wiled
60,650 fish Wiled
16,280 fish killed
23,4 16 fish Wiled
8,861 fish killed
1 .5 million gallons discharged;
8,800 fish Wiled
Fish kill
408 fish killed
Fish kill
1,882 fish Wiled
Comments
$3,908 direct cost
+ $3,000 fine
$4 1 8 direct cost
+ $3,000 fine
J2 1,436 direct cost;
fine was pending
!> 1,4 10 direct cost
+ $2,500 fine
$8,1 55 direct cost
+ $1,500 fine
56,000 direct cost
+ $2,000 fine
$8,000 fine
$4,000 fine
$73 direct cost
+ $2,250 fine
$2,000 fine
$968 direct cost
Reference
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Clean Water Action
Alliance (1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)

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                      EXHIBIT 4-16
Documented Discharges from Swine Operations to Surface Waters
Date
5/94
5/94
3/94
12/93
11/93
10/93
9/93
7/93
6/93
5/93
4/93
Location
Church Creek, IA
Hickory Creek tributary, IA
Eagle Creek, IA
Boone River, IA
Union County, 1A
Middle Avery Creek, IA
South English River tributary,
IA
Iowa River tributary
Keokuk County, IA
Brush Creek, IA
Brookside Creek tributary, IA
Source
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Description of Event
5,750 fish killed
8,397 fish killed
Fish kill
Fish kill
Fish kill
Fish kill
Fish kill
Fish kill
Fish kill
265,000 fish killed
Fish kill
Comments
$2,1 18 direct cost
[>722 direct cost
+ $300 fine
$3,000 fine
$5,000 fine
$1,000 fine
£9,700 fine split between
operation and waste
management design company
$1,650 fine
$3,000 fine
$4,500 fine
$10,000 direct cost
+ $2,500 fine
52,000 fine
Reference
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)

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                      EXHIBIT 4-16
Documented Discharges from Swine Operations to Surface Waters
Date
4/93
8/92
8/92
7/92
7/92
7/92
3/92
2/92
6/19/97
8/96
4/96
4/96
Location
Iowa River tributary, IA
East Nishnabotna River, IA
Tipton Creek, IA
Skunk River, IA
South River, IA
Wright County, IA
Cedar River, IA
Beaverdam Creek, IA
Renville County, MN
Meeker County, MN
Blue Earth County, MN
Blue Earth County, MN
Source
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
9,000 swine
200 head swine operation
500 head swine operation
200 head swine operation
Description of Event
Fish kill
Fish kill
34,994 fish killed

6,264 fish killed
Fish kill


100,000 gallons discharged;
690,000 fish killed
Dverflowing lagoon
Siphoned basin into a stream and
had an un-permitted basin
Siphoned pit/
un-permitted basin
Comments
$300 fine
$1,000 fine
$200 fine
$100 fine
From land application of
lagoon contents; effects lasted
for 2 months.
$3,448 direct cost
+ $19,500 fine
$400 fine
Retention basin overflow.
$250 fine
Below-building pit overflow.
$300 fine
Lagoon overflow caused by
timer malfunction.
Fined for failure to notify.



Reference
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Iowa Department of
Natural Resources
(1998)
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)

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                      EXHIBIT 4-16
Documented Discharges from Swine Operations to Surface Waters
Date
4/96
4/96
2/96 - 4/96
10/95
9/95
8/1/95
5/95
4/94 - 8/94
4/94
9/1/95
8/1/95
8/96
6/95
3/95
Location
Nobles County, MN
Watonwan County, MN
Osborne Township, MN
Traverse County, MN
Lincoln County, MN
Lincoln, MN
Renville County, MN
Lone Tree Township, MN
Meeker County, MN
Gentry, MO
Greencastle MO
Four-Mile Creek, NE
Scholz Pond, NE
Swan Creek, NE
Source
Swine operation
700 head swine operation
Swine operation
2,500 head swine
operation
2,500 head swine
operation
Swine operation
700 head swine operation
Swine operation
1,500 head swine
operation
Swine operation
30,000 head swine
operation
Swine operation
Swine operation
Swine operation
Description of Event
Overflowing basin
Overflowing basin
Overflow from pit onto ground
and into Rock River, at rate up to
12gpm
Overflowing pits
Pumped manure basin into a river
5,000- 10,000 fish killed
Manure and contaminated
wastewater flowed into a surface
tile inlet in a county ditch
3umped about 5,000 gallons of
wastewater containing manure
into a ditch every two weeks
Multiple runoff problems
Unknown
Over 20,000 gallons discharged;
173,000 fish killed
300-500 bullhead, 100 carp, 100
cyprinids killed
96 fish killed
Fish kill
Comments











Lagoon discharge
Land application and pipeline
break,
$13. 25 direct cost
+ $1,000 fine
$97 1.66 direct cost
+ $10,000 fine
Reference
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
NRDC (1995)
NRDC(1995)
Nebraska Department ol
Environmental Quality
(1996)
Nebraska Department ol
Environmental Quality
(1995b)
Nebraska Department ol
Environmental Quality
(1995a)

-------
                      EXHIBIT 4-16
Documented Discharges from Swine Operations to Surface Waters
Date
2/1/97
8/1/95
8/1/95
7/1/95
6/1-21/95
6/1/95
5/1/91
12/10/96
10/10/96
09/03/96
35280
08/03/96
07/09/96
05/17/96
Location
Pamlico, NC
Brunswick County, NC
Onslow, NC
Bladen, NC
New River, Onslow County,
NC
Sampson County, NC
Duplin County, NC
West Branch Tontagony
Creek, OH
Tributary to Beaver Creek,
OH
West Branch Wolf
Creek/Aldrich Run, OH
Tributary to Beaver Creek,
OH
Tributary to Auglaize River
(RM 87.75), OH
Little Tymochtee Creek, OH
Painter Creek, OH
Source
4,000 swine
6,400 head swine
operation
Swine operation
Swine operation
10,000 head swine
operation
Swine operation
Swine operation
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Description of Event
1 ,000 gallon discharge
2 million gallons discharged
Under 1 million gallons
discharged
1 million gallons discharged over
2 days
25 million gallons discharged;
3,000-4,000 fish killed
1 million gallons discharged
'Tons of water" discharged
Manure leaked into barn and into
creek

Manure ran off into ditch and into
creek

Liquid manure applied too
heavily; runoff into tile
Jroken pipe on truck allowed
manure to enter creek
Junoff from manure spreading
Comments
No noticeable fish kill
6th major livestock discharge
in 2 weeks


$1 10,000 fine, including
$6,200 for fish kill and
$92,000 in civil penalties









Reference
Leaven worth (1997)
Warrick(1995a)
Warrick(1995a)
NRDC (1995)
Meadows (1995);
NRDC (1995);
Warrick (1995b)
NRDC (1995)
Stith and Warrick (1995
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)

-------
                      EXHIBIT 4-16
Documented Discharges from Swine Operations to Surface Waters
Date
02/27/96
12/06/95
12/02/95
1 1/26/95
10/25/95
10/20/95
08/27/95
34917
07/03/95
10/01/94
09/24/94
09/21/94
Location
Tributary to Pipe Creek, OH
Tributary to Still water River,
OH
Little Tymochtee Creek, OH
Leatherwood Creek, OH
Tributary to Spring Creek
(RM 1,25), OH
Wolf Creek, OH
Indian Creek, OH
Indian Run, OH
Oak Run, OH
Second Creek, OH
Tributary to Lake Fork
Mohican River, OH
East Branch Salt Creek, OH
Source
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Description of Event
Manure spread on fields, followed
by snow melt and rain
2,000,000 gallons pumped onto 54
acres
Liquid manure pumped onto fields
into tiles into creek

Manure pumped onto fields, ran
into tiles and to stream
Unknown amount leaked from
storage pit into stream
Lagoon pumped onto small field;
drained into creek

Accidental release from drain pipe
during application

Liquid manure entered field tile
and creek
Swine fenced to stream, defecated
on land - runoff to stream
Comments







Heavy rain after manure
application to fields




Reference
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)

-------
                      EXHIBIT 4-16
Documented Discharges from Swine Operations to Surface Waters
Date
09/20/94
09/1 1/94
05/31/94
07/15/93
04/08/93
11/18/92
33841
08/12/92
09/18/91
08/24/90
08/08/90
06/25/90
Location
North Branch Salt Creek, OH
Carter Creek, OH
Grog Run, OH
Barcer Run, OH
Tributary to Wabash River,
OH
Tributary to Lick Creek, OH
Little Sugar Creek, OH
Tributary to Auglaize River,
OH
Salt Creek, OH
Thompson Creek, OH
Bear Creek, OH
Cloverlick Creek, OH
Source
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Description of Event
Swine fenced to stream, defecated
on land - runoff to stream
800,000 gallons of manure applied
to 8 acre field; discharged into tile
into creek
La goon drained via hose to field
at edge of creek
Spray-irrigated manure ran off
into stream

Accidental discharge due to
clogged pump

Irrigated manure runoff into tile
into creek
Manure washed into stream



Comments | Reference












Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)

-------
                      EXHIBIT 4-16
Documented Discharges from Swine Operations to Surface Waters
Date
06/13/90
05/01/90
09/27/89
05/31/89
04/28/89
32579
11/15/87
09/02/87
08/04/87
08/03/87
06/27/87
05/21/87
Location
Lees Creek, OH
Tributary to Caesar Creek,
OH
Jennings Creek, OH
Grassy Fork, OH
Kale Creek, OH
Wolf Creek, OH
Jennings Creek, OH
Mill Creek, OH
Painter Creek, OH
Camp Creek, OH
Buck Run, OH
Camp Creek, OH
Source
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Swine manure
Description of Event












Comments 1 Reference












Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)

-------
                      EXHIBIT 4-16
Documented Discharges from Swine Operations to Surface Waters
Date
05/05/87
01/17/87
Location | Source
Chapman Creek, OH
Unnamed creek, OH
Swine manure
Swine manure
Description of Event


Comments


Reference
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)

-------
                      EXHIBIT 4-17
Documented Human Health Related Impacts from Swine Operations
Date
1990
4/98
12/1/95
10/1/95
10/1/95
4/1/95
Location
Delmarva Peninsula
(DE, MD, VA)
Duplin County, NC
Four Oaks, NC
Shannon, NC
NC
Browntown, NC
Source
Swine operation
Swine operation
Swine operations
1 ,200 head swine
operation
Swine operation
Swine operations
Environmental Impact
Ammonium-nitrogen concentrations of
1 ,000 mg/L in shallow monitoring
wells around swine waste lagoons
Ground water contamination
13 private wells contaminated
Family complains of overpowering
stench and mist of manure when
farmer sprays his fields
4 private wells were found to have
nitrate levels 10 times the health
standard equal to the MCL of 10 mg/L
Residents fighting with swine farmers
over odor
Comments
Scientific study
Nitrate levels five
times state standards


Linked conclusively
to the swine
operations

Reference
Ritter and Chirnside
(1990)
The Associated Press
(1998)
Warrick(1995e)
Warrick (1995d)
Warrick(1995c; 1995d)
Stith and Warrick (1995)

-------
                            EXHIBIT 4-18
Documented Ecological, Recreational, and Other Impacts from Swine Operations
Date
1997
1985-1995
9/1/95
9/1/95
6/13/95
1995

10/17/97
10/9/97
9/18/97
Location
NC rivers
Sampson County, NC
NC
Neuse River, NC
Neuse River, NC
Coastal wetlands of NC
NC
Clear Creek, IA
Brooke Creek, IA
Prairie Creek, IA
Source
Swine operations
Mainly swine (Livestock
responsible for 93% of ammonia
emissions across NC. Swine
account for 78% of ammonia
emissions from livestock
operations in the southern coastal
plain of NC, where Sampson
County is located.)
Swine
Swine
Swine
Swine operations
Swine
Swine operation
Swine operation
Swine operation
Environmental Impact
450,000 fish killed
100% increase in amount of ammonia
in rainwater corresponds with growth
of pork industry
Zinc and copper in manure building to
potentially harmful levels on fields
500,000 fish killed
1 billion fish killed
Closed shellfish beds
Low dissolved oxygen, fish kills, loss
of submerged vegetation
28, 134 fish killed
4194 fish killed
93,403 fish killed
Comments
Pfisteria piscicida
outbreak
Contributes to
eutrophication via
atmospheric deposition
Zinc and copper added to
feed
Toxic dinoflagellate
outbreak
Toxic dinoflagellate
outbreak

Total Maximum Daily
Load (TMDL) case study
$4,000 direct cost
+ $2,000 fine
$267.50 direct cost
+ $2,500 fine
$16, 140.84 direct cost;
fine was pending
Reference
U.S. Senate
(1997)
Aneja et al.
(1998)
Warrick and
Stith(I995)
Leaven worth
(1995c)
Leaven worth
(1995 a)
U.S. Senate
(1997)
USEPA(1999)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)

-------
                            EXHIBIT 4-18
Documented Ecological, Recreational, and Other Impacts from Swine Operations
Date
8/27/97


7/26/97
9/4/96

8/26/96


8/19/96


8/19/96


11/15/95


Location
South Fork of Iowa
River, IA


Crane Creek, IA
North Buffalo Creek, IA

Rock Creek, IA


Cedar County, LA


Tipton Creek, IA


Indian Creek, LA


Source
Swine operation


3,200 head swine operation
Swine operation

Swine operation


Swine operation


Swine operation


Swine operation


Environmental Impact
3,232 fish killed


109, 172 fish killed
More than 100,000 gallons pumped
into Creek;
586,753 fish killed

871 fish killed


3,676 fish killed


46,3 15 fish killed


4,928 fish killed


Comments
$264.23 direct cost;
fine was pending


Blocked pipe resulted in
discharge.
$33,882.73 direct cost;
fine was pending
$30,000 direct cost
+ $3,000 fine

$237 direct cost


$408.76 direct cost


$3,908 direct cost
+ $3,000 fine


$4 18 direct cost
+ $3,000 fine


Reference
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)

-------
                            EXHIBIT 4-18
Documented Ecological, Recreational, and Other Impacts from Swine Operations
Date
9/25/95
7/23/95
7/20/95
7/16/95
7/1/95
3/28/95
9/94
9/94
Location
Williams Creek, IA
Elk Creek tributary, IA
Little Volga River, IA
South Fork of Iowa
River, IA
Hamilton, IA
South English River
tributary, IA
Kossuth County, IA
Williams Creek, IA
Source
Swine operation
Swine operation
Swine operation
Swine operation
700 head swine operation
Swine operation
Swine operation
Swine operation
Environmental Impact
60,650 fish killed
16,280 fish killed
23,4 16 fish killed
8,861 fish killed
1.5 million gallons discharged;
8,800 fish killed
Fish kill
408 fish killed
Fish kill
Comments
$2 1,436 direct cost;
fine was pending
$1,4 10 direct cost
+ $2,500 fine
$8, 155 direct cost
+ $1,500 fine
$6,000 direct cost
+ $2,000 fine
$8,000 fine
$4,000 fine
$73 direct cost
+ $2,250 fine
$2,000 fine
Reference
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Clean Water
Action Alliance
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)

-------
                            EXHIBIT 4-18
Documented Ecological, Recreational, and Other Impacts from Swine Operations
Date
8/94
5/94
5/94
3/94
12/93
11/93
10/93
Location
Otter Creek, JA
Church Creek, IA
Hickory Creek tributary,
IA
Eagle Creek, IA
Boone River, LA
Union County, IA
Middle Avery Creek, LA
Source
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Environmental Impact
1,882 fish killed
5,750 fish killed
8,397 fish killed
Fish kill
Fish kill
Fish kill
Fish kill
Comments
$968 direct cost
$2,118 direct cost
$722 direct cost
+ $300 fine
$3,000 fine
$5,000 fine
$1,000 fine
$9,700 fine split between
operation and waste
management design
company
Reference
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)

-------
                            EXHIBIT 4-18
Documented Ecological, Recreational, and Other Impacts from Swine Operations
Date ] Location
9/93
7/93
6/93
5/93
4/93
4/93
8/92
South English River
tributary, IA
Iowa River tributary
Keokuk County, IA
Brush Creek, IA
Brookside Creek
tributary, IA
Iowa River tributary, IA
East Nishnabotna River,
IA
Source | Environmental Impact
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Swine operation
Fish kill
Fish kill
Fish kill
265,000 fish killed
Fish kill
Fish kill
Fish kill
Comments
$1,650 fine
$3,000 fine
$4,500 fine
$10,000 direct cost
+ $2,500 fine
$2,000 fine
$300 fine
$1,000 fine
Reference
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)

-------
                            EXHIBIT 4-18
Documented Ecological, Recreational, and Other Impacts from Swine Operations
Date
8/92
7/92
7/92
6/19/97
8/1/95
8/1/95
8/96
6/95
3/95
Location
Tipton Creek, IA
South River, IA
Wright County, 1A
Renville County, MN
Lincoln, MN
Greencastle MO
Four-Mile Creek, NE
Scholz Pond, NE
Swan Creek, NE
Source
Swine operation
Swine operation
Swine operation
9,000 swine
Swine operation
30,000 head swine operation
Swine operation
Swine operation
Swine operation
Environmental Impact
34,994 fish killed
6,264 fish killed
Fish kill
100,000 gallons discharged;
690,000 fish killed
5,000- 10,000 fish killed
Over 20,000 gallons discharged;
173,000 fish killed
300-500 bullhead, 100 carp, 100
cyprinids killed
96 fish killed
Fish kill
Comments
$200 fine
From land application of
lagoon contents; effects
lasted for 2 months.
$3,448 direct cost
+ $19,500 fine
$400 fine
Lagoon overflow caused
by timer malfunction.
Fined for failure to
notify.


Lagoon discharge
Land application and
pipeline break;
$13.25 direct cost
+ $1,000 fine
$97 1,66 direct cost
+ 510,000 fine
Reference
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Iowa
Department of
Natural
Resources
(1998)
Clean Water
Action Alliance
(1998)
Clean Water
Action Alliance
(1998)
Clean Water
Action Alliance
(1998)
Nebraska
Department of
Environmental
Quality (1996)
Nebraska
Department of
Environmental
Quality (1995b)
Nebraska
Department of
Environmental
Quality (1995a)

-------
                            EXHIBIT 4-18
Documented Ecological, Recreational, and Other Impacts from Swine Operations
Date
6/21/95
6/1/95
Location
New River, NC
Onslow County, NC
Source
Swine operation
10,000 head swine operation
Environmental Impact
25 million gallons discharged;
3,000-4,000 fish killed
25 million gallons discharged;
3,000-4,000 fish killed
Comments
$6,200 direct cost
+ $92,000 fine
$110,000 fine, including
$6,200 for fish kill and
$92,000 in civil penalties
Reference
Meadows
(1995);Warrick
(1995b)
NRDC(1995);
Warrick
(1995b)

-------
                       EXHIBIT 4-19
Documented Discharges from Poultry Operations to Surface Waters
Date
9/5/95
10/1/91
3/97
7/1/95
02/04/97
10/22/96
10/10/96
07/15/96
07/10/96
06/24/96
03/20/95
12/03/94
Location | Source
East Branch Beaverdam Creek,
IA
Deep Run, MD
Grant County, MN
Duplin, NC
Tributary to Town Run, OH
Dahlinghaus Ditch, OH
Dahlinghaus Ditch, OH
Tributary to Beaver Creek, OH
Dahlinghaus Ditch, OH
Little Chippewa Creek and
Tributary, OH
Little Chippewa Creek
Kraut Creek, OH
Poultry operation
Poultry operation
2,000 chicken poultry
operation
75 ,000 chicken
operation
Poultry manure
Chicken manure
Chicken manure
Chicken manure
Chicken manure
Chicken manure
Chicken manure
Chicken manure
Description of Event
9,002 fish killed
10,000 fish killed
Pumped waste into wetland
8.6 million gallons discharged;
fish kill resulted
Manure spread on frozen fields,
followed by rainfall
Manure entered field tiles and into
stream
Manure entered field tiles and into
stream
Manure entering stream from field
tile
Runoff from field application of
manure
Manure runoff into ditch from farm
(retention pond overflow)
Chicken manure possibly dumped
into field tile
Manure entered field tile
Comments I Reference
$839 direct cost
+ $500 fine










Accidental removal of
plank allowed manure to
enter tile
Iowa Department of
Natural Resources
(1998)
Maryland
Department of the
Environment (1987)
Clean Water Action
Alliance (1998)
NRDC (1995)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)

-------
                       EXHIBIT 4-19
Documented Discharges from Poultry Operations to Surface Waters
Date
9/13/94
05/09/93
08/14/92
11/03/91
09/13/90
11/02/87
Location
Stillwater River, OH
Henry Ditch, OH
Mississinewa River, OH
Sugar Creek, OH
Tributary to Blanchard River,
OH
Powderlick Run, OH
Source
Chicken manure
Chicken manure
Chicken manure
Chicken manure
Chicken manure
Chicken manure
Description of Event
Vlanure entered tile, then stream



Runoff from fields into creek

Comments

Approximately 4 miles
affected in Indiana




Reference
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)
Ohio Department of
Natural Resources
(1997)

-------
                       EXHIBIT 4-20
Documented Human Health Related Impacts from Poultry Operations
Date
1982

Location
Sussex County, DE
FL
Source
Poultry operations
Poultry operations
Environmental Impact
Nitrate levels greater than 10 mg/L in
32 percent of wells
Nitrate levels greater than 10 mg/L in
one-third of wells
Comments


Reference
Chapman
(1996)
Chapman
(1996)

-------
                             EXHIBIT 4-21
Documented Ecological, Recreational, and Other Impacts from Poultry Operations
Date
1997

8/97
6/20/95
6/19/95

1998
9/5/95
10/1/91
Location
Chesapeake Bay
DE
Pokomoke River, MD
Kings Creek, MD
MD
Double Pipe Creek, MD
Tulsa, OK
East Branch Beaverdam Creek,
IA
Deep Run, MD
Source
Poultry operations
Poultry industry
Poultry operations
Poultry operations
Poultry
Poultry (700,000 chickens)
Poultry (82.5 million
chickens in the watershed)
Poultry operation
Poultry operation
Environmental Impact
30,000 fish killed
Eutrophication, fish kills and red
tide
20,000-30,000 fish killed
Fish kill
Extensive fish kill in the
Chesapeake Bay
High fecal coliform counts
Excessive algal growth in Lake
Eucha; impacts on drinking water
taste and odor
9,002 fish killed
10,000 fish killed
Comments
Pfiesteria piscicida
outbreak
Not clear how much to
attribute to poultry waste
Pfiesteria piscicida
outbreak; 13 humans also
affected
Pfiesteria piscicida
outbreak
Pfiesteria piscicida
outbreak
Threatens water supply as
well as aquatic life and
recreation
Tulsa spends $100,000 per
year to address taste and
odor problems in the
drinking water
$839 direct cost
+ $500 fine

Reference
U.S. Senate
(1997)
Delaware's
Center for the
Inland Bays
(1995)
Shields (1997)
Shields and
Meyer (1997)
New York
Times (1997)
Gale et al.
(1993)
Lassek(1998);
Lassek(1997)
Iowa
Department of
Natural
Resources
(1998)
Maryland
Department of
the
Environment
(1987)

-------
                          EXHIBIT 4-22
Documented Discharges from Beef and Dairy Operations to Surface Waters
Date
3/1/98
7/97
5/97
4/97
3/97
3/97
8/96
6/96
4/96
Location
Olmsted, MN
Lyon County, MN
Wabasha County, MN
Lyon County, MN
LeSueur County, MN
Lyon County, MN
Nicollet County, MN
Clay County, MN
Crow Wing, MN
Source
Dairy feedlot
250 head cattle operation
Dairy operation
800 head cattle operation
1 ,960 head cattle operation
1 ,000 head cattle operation
1 ,400 head cattle operation
500 head cattle operation
100 head dairy operation
Description of Event
125,000 gallons discharged
runoff
16,500 minnows and white
suckers killed
Open lot runoff
Overapplication and runoff
Open lot runoff
Dverapplication and runoff
Multiple runoff culverts to river
Stockpile runoff
Comments | Reference
Contaminated local wells

Fish kill caused by ammonia.






Clean Watei
Action
Alliance
(1998)
Clean Water
Action
Alliance
(1998)
Clean Water
Action
Alliance
(1998)
Clean Water
Action
Alliance
(1998)
Clean Watei
Action
Alliance
(1998)
Clean Watei
Action
Alliance
(1998)
Clean Watei
Action
Alliance
(1998)
Clean Water
Action
Alliance
(1998)
Clean Watei
Action
Alliance
(1998)

-------
                          EXHIBIT 4-22
Documented Discharges from Beef and Dairy Operations to Surface Waters
Date
4/96
11/95
11/95
5/95
3/95
3/95
4/94
4/94
1985 - 1994
Location
Houston County, MM
Morrison County, MN
Olmsted County, MN
Slayton Township, MN
Lyon County, MN
Lyon County, MN
LeSueur County, MN
Redwood County, MN
Tyrone Township, MN
Source
1 ,500 head cattle operation
100 head cattle operation
10,000 head cattle operation
Steer operation
400 head cattle operation
2,000 head cattle operation
1 ,000 head cattle operation
750 head cattle operation
950 steer cattle operation
Description of Event
Overflowing basin
Runoff to river
Vlultiple runoff concerns
Runoff into a tributary of Beaver
Creek
File inlet in feedlot
Runoff and unpermitted
construction
Vlultiple runoff concerns
Unpermitted basin and discharge
Various problems, including
massive runoff
Comments j Reference









Clean Watei
Action
Alliance
(1998)
Clean Watei
Action
Alliance
(1998)
Clean Watei
Action
Alliance
(1998)
Clean Watei
Action
Alliance
(1998)
Clean Watei
Action
Alliance
(1998)
Clean Water
Action
Alliance
(1998)
Clean Watei
Action
Alliance
(1998)
Clean Water
Action
Alliance
(1998)
Clean Water
Action
Alliance
(1998)

-------
                          EXHIBIT 4-22
Documented Discharges from Beef and Dairy Operations to Surface Waters
Date
1/92
5/19/97


3/25/97


2/4/97


11/13/96



10/27/96


9/30/96


Location
Green Isle Township, MN
Tributary to Chickasaw Creek,
OH


Prairie Outlet, OH


Tributary to Little Scioto River
(RM 23.66), OH


Scherman Ditch, OH



Little Tymochtee Creek, OH


Tributary to Coldwater Creek,
OH


Source
Dairy operation
Cattle manure


Cattle manure


Cattle manure


Cattle manure



Cattle manure


Cattle manure


Description of Event
225,000 gallons of manure
pumped onto a field in 5 hours,
flowed through a drainage tile
into Curran Lake
Manure from cattle yard
discharged to stream via tile


Vianure leached from holding
ponds into creek


Manure spray gun malfunctioned
and flooded field






Vlanure leaking from pit at dairy
operation


Manure spread on fields ran into
creek


Comments | Reference




















Clean Watei
Action
Alliance
(1998)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)

-------
                          EXHIBIT 4-22
Documented Discharges from Beef and Dairy Operations to Surface Waters
Date
9/25/96


8/13/96


7/15/96


6/20/96


5/23/96


5/22/96


5/16/96


Location
Tributary to Chickasaw Creek,
OH


Blacklick Creek, OH


Tributary to Beaver Creek, OH


Threemile Creek, OH


Tributary to Pymatining Creek
(RM 23.95), OH


Little Bear Creek, OH


Tributary to Red Run, OH


Source
Cattle manure


Cattle manure


Cattle manure


Cattle manure


Cattle manure


Cattle manure


Cattle manure


Description of Event
Runoff from cattle feedlot into
field tile into creek


Manure sprayed on field ran into
tile drain





Runoff from field application of
manure


Runoff after spreading manure


300,000 gallons of manure spread
on fields, washed into creek


Manure spread directly into
several ditches


Comments [Reference





















Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)

-------
                          EXHIBIT 4-22
Documented Discharges from Beef and Dairy Operations to Surface Waters
Date
3/29/96


2/21/96


1/9/96


9/1/95


8/20/95


8/19/95


7/10/95


Location
Tributary to Little Short Creek,
OH


East Branch Sugar Creek, OH


Tributary to East Fork White
Eyes Creek, OH


Indian Creek, OH


Montezuma Creek, OH


Tributary to Anderson Fork,
OH


East Fork White Eyes Creek,
OH


Source
Cattle manure


Cattle manure


Cattle manure


Cattle manure


battle manure


Cattle manure


Cattle manure


Description of Event
Manure pumped into ravine and
into stream








600,000 - 800,000 gallons
pumped onto 40 acres


sprinkling system to cool animals
created excess runoff


Tractor got stuck; manure tank
emptied; rain washed manure into
creek





Comments | Reference



*4o fish kill; unsure if pollutants
entered stream


No fish kill; unsure if pollutants
entered stream














Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)

-------
                          EXHIBIT 4-22
Documented Discharges from Beef and Dairy Operations to Surface Waters
Date
5/3/95


5/3/95


12/5/94


6/16/94


12/15/93


8/20/93


8/11/93


Location
Tributary to Killbuck Creek,
OH


Sugar Creek, OH


Big Run, OH


Harmon Brook, OH


Tributary to Grand Lake St.
Mary's, OH


Stony Creek, OH


Middle Fork Sugar Creek, OH


Source
Cattle manure


Cattle manure


Cattle manure


Cattle manure


Cattle manure


Cattle manure


Cattle manure


Description of Event
Periodic discharges of manure to
stream


Broken pipe at pit, manure flow
into tile and then creek


Runoff from pasture and feedlots


Crack in lagoon led to manure
leak


Manure in ditch and tile leading
to stream


Runoff from feedlot entered
creek





Comments | Reference





















Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)

-------
                          EXHIBIT 4-22
Documented Discharges from Beef and Dairy Operations to Surface Waters
Date
7/12/92


4/18/91


2/20/91



8/20/90


8/18/90


8/16/90


6/16/90



Location
Tributary to Black Fork
Mohican River, OH


Tributary to Little Scioto River,
OH


Mohican River, OH



Olentangy River, OH


Tributary to Cowan Creek, OH


Schenck Creek, OH


Clear Creek, OH



Source
Cattle manure


Cattle manure


Cattle manure



Cattle manure


Cattle manure


Cattle manure


Cattle manure



Description of Event
Drainage from manure pit
through field tile to creek


Manure liquids ran off farm into
ditch












Manure pit overflowed into ditch






Comments | Reference























Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)

-------
                          EXHIBIT 4-22
Documented Discharges from Beef and Dairy Operations to Surface Waters
Date
8/12/89



6/29/89



8/2/88


5/2/87


Location
North Fork of Deer Creek, OH



Painter Run, OH



Tributary to Red Run, OH


Big Run, OH


Source
Cattle manure



Cattle manure



Cattle manure


Cattle manure


Description of Event














Comments | Reference














Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)
Ohio
Department
of Natural
Resources
(1997)

-------
                          EXHIBIT 4-23
Documented Human Health Related Impacts from Beef and Dairy Operations
Date


Location
Wl
Door County, Wl
Source
Dairy operation
Dairy operations
Environmental Impact
Contamination of surface waters;
ear and skin infections, as well as
intestinal illnesses common to
swimmers in manure-
contaminated waterways
Well contamination
Comments

State will spend $3 million
to protect Door County
ground water.
Families have had to drill
new wells.
Reference
Behm (1989)
Behm (1989)

-------
                                EXHIBIT 4-24
Documented Ecological, Recreational, and Other Impacts from Beef and Dairy Operations
Date


6/18/95
6/16/95
1991



5/97
Location
Taylor Creek, FL
Tillamook Bay, OR
Waco, TX
Erath, TX
Tierra Blanca Creek, TX
Eau Claire, Wl
Osh Kosh, Wl
Black Earth Creek Watershed,
Wl
Wabasha County, MN
Source
Dairy and beef operations
Dairy operations
Dairy operations, as well as
urban runoff and crop
fertilization
Dairy operations
Tattle operations
Dairy operations
Dairy operations, as well as
development
Dairy operations
Z>airy operation
Environmental Impact
Eutrophication of Lake
Okeechobee
High fecal coliform levels in the
waters of the Bay
An algal bloom of Anabaena,
which caused a foul-smelling and
-tasting chemical in water
supplies
Total N and P above screening
levels in Upper North Bosque
River
ilevated sediment concentrations
of copper and zinc; elevated
aqueous concentrations of
ammonia, chemical oxygen
demand, chlorophyll a, coliform
bacteria, chloride, conductivity,
total Kjeldahl nitrogen, and
volatile suspended solids
Swimming and water skiing are
prohibited in Tainter Lake
because of bacterial
contamination
Algal blooms in Lake Winnebago
Eutrophication
16,500 minnows and white
suckers killed
Comments

Affecting tourism and
oyster industries. May be
causing health hazards as
well.


Relative contribution from
various sources (e.g.,
runoff, lagoon discharges,
leachate) was not assessed
Sedimentation from
development and crop
runoff also causing
problems
Lake Winnebago
represents 17% of the
state's water surface. City
of Osh Kosh spends
$30,000 a year to kill
algae.

Fish kill caused by
ammonia.
Reference
Gale et al.
(1993)
Gale et al.
(1993)
Wallace (1997)
Pratt et al.
(1997)
USFWS (1991)
Behm (1989)
Behtn (1989)
USGAO
(1995a)
USGAO
(1995a)

-------
                                     EXHIBIT 4-25
Documented Discharges to Surface Waters from Operations with Unspecified or Multiple Animal Types
Date
7/1/95
7/1/95
3/92
7/1 1/95
7/26/94
6/22/90
9/24/87
3/30/87
7/30/86
7/15/86
9/30/85
Location
Fayette, IA
Howard, IA
Hamilton County, IA
Tuscarora Creek, MD
Toms Run, MD
Wagram Creek, MD
Farm Pond, MD
Morgan Creek, MD
Liitle Pipe Creek, MD
Cabbage Run, MD
Deep Run, MD
Source


Swine, turkey, and dairy
operation
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (ani mal
type unknown)
Description of Event
16,000 gallons discharged;
584 smallmouth bass, 22,01 1
minnows/ shiners killed
1 10 black bullheads, 16,000
minnows killed
Fish kill
1,000 fish killed
1,500 fish killed
19,000 fish killed
1,000 fish killed
2,500 fish killed
150 fish killed
175 fish killed
Hundreds of fish killed
Comments


$1,000 fine








Reference
NRDC (1995)
NRDC (1995)
Iowa Department ol
Natural Resources
(1998)
Maryland
Department of the
Environment (1987;
Maryland
Department of the
Environment (1987
Maryland
Department of the
Environment (1987;
Maryland
Department of the
Environment (1987;
Maryland
Department of the
Environment (1987;
Maryland
Department of the
Environment (1987^
Maryland
Department of the
Environment (1987]
Maryland
Department of the
Environment (1987'

-------
                                       EXHIBIT 4-25
Documented Discharges to Surface Waters from Operations with Unspecified or Multiple Animal Types
Date
9/29/85
8/10/85
1994
1994
1994
1993
1993
2/98
1/98
9/97
Location
Jennings Run, MD
Deer Creek, MD
Belle River, MI
Macon Creek, MI
Salt River, MI
Crockery Creek, MI
Deer Creek tributary, MI
Lake Wagon ga, MN
Mokasippi, MN
Blue Earth River, MN
Source
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
vlanure (animal
type unknown)
Manure (animal
type unknown)
Vlanure (animal
type unknown)
Description of Event
3,900 fish killed
100,000 fish killed
Fish kill
Fish kill
Fish kill


Manure-contaminated runoff
discharged to lake
Manure-contaminated runoff
(from feedlot and stockpile)
discharged to river
Fish kill of 6,626 catfish,
small-mouth bass, rock bass,
white bass, and minnows
Comments


Overflow and misapplication of
manure.
$5, 150 direct cost
+ $5,000 fine
Euipment failure caused manure
discharge.
$ 1 ,330 direct cost
+ $5,000 fine
Over-application of manure to field,
causing runoff,
$20,000 direct cost
+ $2,500 fine
$1,650 enforcement costs
+$2,500 fine
$4,000 enforcement costs
+ $20,000 fine

Failed to notify authorities, made
no attempt to abate or recover
discharge

Reference
Maryland
Department of the
Environment (1987
Maryland
Department of the
Environment (1987
Michigan
Department of
Environmental
Quality
Michigan
Department of
Environmental
Quality
Michigan
Department of
Environmental
Quality
Michigan
Department of
Environmental
Quality
Michigan
Department of
Environmental
Quality
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)

-------
                                       EXHIBIT 4-25
Documented Discharges to Surface Waters from Operations with Unspecified or Multiple Animal
Types
Date
8/97
8/97
6/97
1996
8/95 - 9/95
7/95 - 8/95
1994
6/96
10/28/96
09/18/96
07/31/96
Location
Hay Creek, MN
Speltz Creek, MN
Roseau County, MN
Mankato, MN
Larkin Township, MN
Drammen Township, MN
Nicollet County, MN
Lost Creek, NE
Apple Ditch, OH
Tributary to Beaver Creek, OH
Montezuma Creek, OH
Source
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Various animals
Manure (animal type
unknown)
Manure (animal type
unknown)
Jnclear if swine or cattle
Manure
Manure
Zattle and swine manure
Description of Event
Fish kill of 6,000 brown trout
and white suckers.
300 gallons discharged;
130 minnows killed
Manure discharge
Drained manure into
Watonwan and Blue Earth
Rivers
3 weeks worth of overflow
from lagoon through trench
and into Kanaranzi Creek
Overflow of pits which drained
into a ditch;
19,641 fish killed in Medary
Creek
Constant diversion of manure
into streams from unknown
facilities
2, 120 fish killed
"Manure coming from field tile

Manure entered stream from
field die
Comments


Discharge from un-permitted tank,
caused by improper construction
and pump failure.




& 1,079.50 direct cost;
fine was pending



Reference
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
Clean Water Action
Alliance (1998)
Clean Water Actior
Alliance (1998)
Clean Water Actior
Alliance (1998)
Clean Water Actior
Alliance (1998)
Clean Water Actior
Alliance (1998)
Nebraska
Department of
Environmental
Quality (1996)
Ohio Department 01
Natural Resources
(1997)
Ohio Department o:
Natural Resources
(1997)
Ohio Department 01
Natural Resources
(1997)

-------
                                       EXHIBIT 4-25
Documented Discharges to Surface Waters from Operations with Unspecified or Multiple Animal Types
Date
7/7/96
07/05/96
07/04/96
06/17/96
10/26/95
09/03/95
08/24/95
07/05/95
04/22/95
03/27/95
10/16/94
08/29/94
Location
Cedar Fork, OH
Wabash River, OH
Wabash River, OH
East Fork Vermilion River, OH
Tributary to Mile Creek (RM
4, 15), OH
Tributary to Poplar Creek, OH
Martins Creek, OH
Rock Creek, OH
Mewman Creek, OH
Kiber Run, OH
'rairie Creek, OH
Tributary to Beaver Creek, OH
Source
Manure
Manure
Cattle and swine manure
Manure
Manure
Vlanure
Manure and milk products
Manure
Vlanure
Cattle and swine manure
Manure
Cattle and swine manure
Description of Event
Hose sprung leak and manure
spread onto ground and into
tile
Manure runoff from milkhouse
into field tile
Runoff from field application
of manure

Liquid manure applied too
heavily
Accidental manure spill
Vlanure and milk washed into
drains into creek


lunoff from spraying fields
ran into field tiles
rrigated manure entered tile
into creek
Crack in holding pit into tile
Comments












Reference
Ohio Department o
Natural Resources
(1997)
Ohio Department o
Natural Resources
(1997)
Ohio Department o
Natural Resources
(1997)
Ohio Department o
Natural Resources
(1997)
Ohio Department o
Natural Resources
(1997)
Ohio Department o
Natural Resources
(1997)
Ohio Department o
Natural Resources
(1997)
Ohio Department o
Natural Resources
(1997)
Ohio Department o:
Natural Resources
(1997)
Ohio Department ol
Natural Resources
(1997)
Ohio Department o:
Natural Resources
(1997)
Ohio Department 01
Natural Resources
(1997)

-------
                                       EXHIBIT 4-25
Documented Discharges to Surface Waters from Operations with Unspecified or Multiple Animal Types
Date
7/17/94
09/08/93
09/09/92
08/18/92
07/08/92
04/29/91
03/02/91
07/30/90
1 1/09/89
08/19/89
08/07/89
10/20/88
Location
Black Run, OH
Little Beaver Creek, OH
Subtributary to Pawpaw Creek,
OH
Tributary to Coldwater Creek,
OH
Little Miami River, OH
Tributary to Bear Creek, OH
Middle Fork Little Beaver
Creek, OH
Sycamore Creek, OH
Tributary to Beaver Creek, OH
Tributary to Jerome Fork, OH
Elkhorn Creek, OH
Indian Creek, OH
Source
Manure
Milkhouse wastewater and
manure
Cattle and swine manure
Manure
Manure
Manure
Manure
Vtanure and household
wastes
Vlanure
Vlanure
Manure
Vlanure
Description of Event


Possible runoff from feedlots
Manure applied to field entered
creek
Runoff and leachate into
stream
Vlanure entered field tile and
into stream






Comments












Reference
Ohio Department o
Natural Resources
(1997)
Ohio Department o
Natural Resources
(1997)
Ohio Department o
Natural Resources
(1997)
Ohio Department o
Natural Resources
(1997)
Ohio Department o
Natural Resources
(1997)
Ohio Department o:
Natural Resources
(1997)
Ohio Department o:
Natural Resources
(1997)
Ohio Department o:
Natural Resources
(1997)
Ohio Department oi
Natural Resources
(1997)
Ohio Department oi
Natural Resources
(1997)
Ohio Department oj
Natural Resources
(1997)
Ohio Department ol
Natural Resources
(1997)

-------
                                      EXHIBIT 4-25
Documented Discharges to Surface Waters from Operations with Unspecified or Multiple Animal Types
Date
9/27/87
09/18/87
Location
Big Run, OH
Spring Creek, OH
Source
Manure
Manure
Description of Event


Comments


Reference
Ohio Department ol
Natural Resources
(1997)
Ohio Department ol
Natural Resources
(1997)

-------
                                      EXHIBIT 4-26
Documented Human Health-Related Impacts from Operations with Unspecified or Multiple Animal Types
Date
3/1/91
6/15/95

Location j
Des Moines, 1A
Wichita, KS
WI
Source
Animal waste, as well as
fertilizers
Nutrients from farm runoff,
including animal manure
Varied (including AFOs)
Environmental Impact
Contamination of drinking water
with nitrate
Contamination of drinking water
supply
Wl DNR estimates that 10% of
the state's 700,000 wells exceed
health standards
Comments
Waterworks will spend
$5 million on a nitrate
removal system
Some algal strains growing
in the reservoir are thought
to produce a liver toxin
linked to stomach flu.
Wichita is installing a
special filtering mechanism
which will cost $ 1 million
per year to operate
Major pollutant sources
include CAFOs,
development, crop farms,
and ski slopes.
Reference
Hubert (1 991)
Hays (1993)
Behm(1989)

-------
                                             EXHIBIT 4-27
Documented Ecological, Recreational, and Other Impacts from Operations with Unspecified or Multiple Animal Types
Date


6/15/95
1995



7/1/95
7/1/95
3/92
7/11/95
Location
Appoquinimink River, DE
GA, AL, FL
KS
NC
Tar-Pamlico River Basin, NC
Nansemond-Chuckatuck
watershed, VA
WI
Fayette, LA
Howard, LA
Hamilton County, LA
Tuscarora Creek, MD
Source
Poultry, dairy, and beef
Animal waste
Feedlots, as well as farms
Livestock waste

448,000 chickens 24,000
swine, 2724 beef cows, 125
dairy cows
Excessive nutrients


Swine, turkey, and dairy
operation
Vlanure (animal
type unknown)
Environmental Impact
Eutrophication
Excess nutrients in the
Apalachieola-Chattahoochee-
Flint watershed
Eutrophication in Arkansas River
8-fold increase in ammonia
emissions
Eutrophication resulting in die-
off of benthic life and toxic
dinoflagellate growth
Eutrophication and
contamination with fecal
coliform
90% decline in bass population
in one year
16,000 gallons discharged;
584 smallmouth bass, 22,01 1
minnows/ shiners killed
1 10 black bullheads, 16,000
minnows killed
Fish kill
1,000 fish killed
Comments
?ish kills and hindered
boating

37 species of fish are in
danger
Contributes to
eutrophication via
atmospheric deposition.
Winter algal blooms
occur regularly. Shellfish
beds have been closed
because of fecal coliform.
Major source is runoff
from agricultural areas.
Shellfish areas have been
closed.



$1,000 fine

Reference
Gale etal. (1993)
USGS(1996)
Hays (1993)
Leaven worth
(1995b)
North Carolina
Division of
Environmental
Management
(1995); USGAO
(1995a)
Gale etal. (1993)
Behm (1989)
NRDC (1995)
NRDC (1995)
Iowa Department of
Natural Resources
(1998)
Maryland
Department of the
Environment (1987)

-------
                                             EXHIBIT 4-27
Documented Ecological, Recreational, and Other Impacts from Operations with Unspecified or Multiple Animal Types
Date
7/26/94
6/22/90
9/24/87
3/30/87
7/30/86
7/15/86
9/30/85
9/29/85
8/10/85
1994
1994
Location | Source
Toms Run, MD
Wagram Creek, MD
Farm Pond, MD
Morgan Creek, MD
Liitle Pipe Creek, MD
Cabbage Run, MD
Deep Run, MD
Jennings Run, MD
Deer Creek, MD
Belle River, MI
VI aeon Creek, MI
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
:ype unknown)
Manure (animal
ype unknown)
Manure (animal
type unknown)
Vlanure (animal
ype unknown)
Environmental Impact
1,500 fish killed
19,000 fish Wiled
1,000 fish killed
2,500 fish killed
150 fish killed
175 fish killed
Hundreds of fish killed
3,900 fish killed
100,000 fish killed
Fish kill
Fish kill
Comments









Overflow and
misapplication of manure.
$5, 150 direct cost
+ $5,000 fine
Equipment failure caused
manure discharge,
$1,330 direct cost
+ $5,000 fine
Reference
Maryland
Department of the
Environment (1987)
Maryland
Department of the
Environment (1987)
Maryland
Department of the
Environment (1987^
Maryland
Department of the
Environment (1987)
Maryland
Department of the
Environment (1987)
Maryland
Department of the
Environment (1987)
Maryland
Department of the
Environment (1987)
Maryland
Department of the
Environment (1987)
Maryland
Department of the
Environment (1987)
Michigan
Department of
Environmental
Quality
Michigan
Department of
Environmental
Quality

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                                             EXHIBIT 4-27
Documented Ecological, Recreational, and Other Impacts from Operations with Unspecified or Multiple Animal Types
Date
1994
9/97
8/97
8/97
7/95 - 8/95
6/96
Location
Salt River, MI
Blue Earth River, MN
Hay Creek, MN
Speltz Creek, MN
Drammen Township, MN
Lost Creek, NE
Source
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal
type unknown)
Manure (animal type
unknown)
Unclear if swine or cattle
Environmental Impact
Fish kill
Fish kill of 6,626 catfish, small-
mouth bass, rock bass, white
bass, and minnows
Fish kill of 6,000 brown trout
and white suckers.
300 gallons discharged;
130 minnows killed
Overflow of pits which drained
into a ditch;
19,641 fish killed in Medary
Creek
1,1 20 fish killed
Comments
Over-application of
manure to field, causing
runoff.
$20,000 direct cost
+ $2,500 fine




n, 079.50 direct cost;
fine was pending
Reference
Michigan
Department of
Environmental
Quality
Michigan
Department of
Environmental
Quality
Michigan
Department of
Environmental
Quality
Michigan
Department of
Environmental
Quality
Michigan
Department of
Environmental
Quality
Nebraska
Department of
Environmental
Quality (1996)

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4.4.1   Lake Eucha

Lake Eucha is located in the Lower Neosho Watershed in northeast Oklahoma. It is a major
drinking water source for the city of Tulsa. Lake Eucha was included on the Oklahoma List of
Impaired Waters for 1998 as a result of nutrients. Recently, there have been taste and odor
problems in Tulsa's drinking water due to accelerated eutrophication (Lassek, 1998a; Front,
2000; Keyworth et al., 2000).

Officials estimate that approximately 750 chicken houses are located within the lake's watershed,
each containing about 110,000 birds (Lassek, 1998b). In the Lake Eucha basin, a popular method
of fertilizing permanent pasture is the surface application of poultry litter.  Litter  is highly
effective, due to its high content of nutrients (nitrogen, phosphorus, and potassium) and organic
matter.  However, if not properly managed, these nutrients could reach surface water and cause
eutrophication and consequently, algae blooms (Neal and Storm, 1999).

Detailed monitoring of Lake Eucha in 1997 showed that the algae  balance was typical of
eutrophic lakes.  In addition, although the lake was free of harmful bacteria (an indicator of
possible impacts from animal waste), excessive bacteria were found in the tributaries. This
study, by the Oklahoma Conservation Commission, linked phosphorus from poultry waste runoff
to excessive algae growth in the lake (Wagner and Woodruff, 1997; Lassek, 1998a). The algae
causes taste and odor problems in the water, costing Tulsa thousands of dollars for treatment
(Lassek, 1998a; Front, 2000).

The Oklahoma legislature has announced that drinking water contamination due  to CAFOs is a
priority issue to be addressed. Studies are being conducted at Oklahoma State University and
Texas A&M University to determine limiting nutrients in Lake Eucha tributaries. These studies
will be used in combination with other ongoing research to develop a total maximum daily load
(TMDL) for Lake Eucha (Keyworth et al.,  2000). In addition, the  city of Tulsa is working to
design a land conservation plan to  address  the problem (Front, 2000). Tulsa has  also begun to
buy land around Lake Eucha in an  effort to create a buffer zone for the city's drinking water
supply (Lassek, 1998b).

4.4.2  The Chino Basin

The Santa Ana River watershed has the highest density of dairy cows in the nation, averaging 25-
30 cows per acre. Currently, 270 dairies operate on 25,000 acres within the Chino Basin portion
of the watershed, with over 336,000 animals. Although the number of dairies continues to
decrease, the number of animals is increasing, and the resulting impact on water  quality is
enormous.  The  1998 California 303(d) List and Total Maximum Daily Load (TMDL) Priority
Schedule issued by the EPA for the Chino  Basin area cites agriculture and the dairies as the
source of significant impairment to surface waterbodies due to nutrients, pathogens, suspended
solids, salinity, total dissolved solids (TDS), and chlorides (OCWD, 2000).

Accumulation of salts and nitrates  in the Chino Basin is occurring as a result of stockpiling
manure and runoff from dairy waste. The Santa Ana River and the ground water basin it
recharges supply over 2 million residents with approximately 75 percent of their  water.  The
impact of large-scale dairies on recharge water quality is a critical issue in protecting Orange

                                          4-61

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County's primary drinking water supply.  The Orange County Water District (OCWD), along
with other concerned water agencies, has dedicated considerable resources to remove salts and
nitrates from the Orange County ground water basin in order to improve the quality of water.
Projects completed or in the construction phase that are directed at the removal of salts and
nitrates include:

       •   Santa Ana River Interceptor (SARI) - $100 million
       »   SARI Extension to Lake Elsinore - $25 million
       «   Arlington Desalter (Riverside) - $13.5 million
       •   Water Factory 21 (Fountain Valley) - $20 million
       •   Chino Desalter - $39 million
       •   7th Street Desalter (Tustin) - $7 million
       •   Prospect Desalter (Tustin) - $3 million
       •   Garden Grove Nitrate Reduction - $2 million

Efforts are currently underway at OCWD on two additional projects aimed at reduction of salts
and nitrates. The proposed Ground Water Replenishment System (GWRS) is a $350 million
proposed project that will utilize microfiltration and reverse osmosis to desalt treated wastewater,
which will be transported to ground water recharge basins to significantly lower the basin's salt
levels. The Irvine Desalter is a $30 million project to extract and remove salts from ground
water for use in the Irvine area (OCWD, 2000).

4.4.3  Lake Waco and the Bosque River Watershed

Lake Waco is located in the Bosque River watershed in Texas. It is the public water supply for
the city of Waco and several adjoining communities.  In 1996, 23  river or lake segments caused
concern or possible concern for six different criteria, including over 40 percent (19 instances)
caused by nutrients (Texas Office of Water Resource Management, 1997). In 2000, water quality
testing showed high levels of nutrients in the North Bosque River (Segment 1226) and in the
Upper North Bosque River (Segment 1255). These high levels have contributed to excessive
growths of algae and other aquatic plants, which can cause taste and odor problems in drinking
water and result in fish kills under certain circumstances. High levels were also found  for
chloride, sulfate, total dissolved solids, and occasionally, bacteria (TNRCC, 2000a).  The
elevated level of bacteria was found to correlate with dairy waste application fields and herd
density (TIAER, 1998).

The Upper North Bosque River (Segment 1255) is located in Erath County. Erath County is
home to a large dairy industry, which has become increasingly concentrated over the last few
decades. These dairy operations produce over 1.5 million tons of waste per year (PEER, 2000).
A judge in upstream Erath County requested a waste management study for the county's dairy
industry, which generates over 1 million cubic yards of dry-state dairy manure per year. The
application of dairy waste to fields resulted in non-point nutrient runoff into the Bosque River
during storm events, resulting in degraded water quality (Brazos River Authority, 1998). The
state of Texas has a TMDL goal of reducing annual average soluble phosphorus loading by about
50 percent.  The draft TMDL for the North Bosque River is due to be published this fall
(TNRCC, 2000a).
                                          4-62

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In public comment on the 2000 Texas Clean Water Act Section 303(d) List, a representative of
the National Wildlife Federation contended that there were taste and odor problems in Lake
Waco and that these are due to algae. The Texas Natural Resource Conservation Commission
(TNRCC) response to the comment notes that the TMDL currently being developed for the North
Bosque River is expected to significantly reduce nutrient loading to Lake Waco. This may
address the periodic taste and odor problem in Lake Waco if it is caused by algae (TNRCC,
2000b).

4.5    CASE STUDY SUMMARY

Over 100 case studies were compiled and presented in a summary report titled "Case Study
Summary: Manure Application" (USEPA, 2000b). This report is included in the public record.
                                        4-63

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5.     EFFECTS OF THE PROPOSED REGULATIONS

5.1    POTENTIAL BENEFITS FROM POLLUTANT REDUCTIONS

The main sources of pollution from CAFOs include:

«      waste, runoff, and leachate from confinement facilities and manure storage piles;
•      runoff and leachate from land application sites;
•      discharges and leachate from storage lagoons; and
•      airborne emissions from confinement facilities, land application sites, and storage.

The practical impacts of implementing the proposed regulations are a function of the following:
(1) the location and characteristics of affected facilities; (2) current waste and runoff
management practices; and (3) the contribution of pollutants from other sources.

In general, increased treatment and management practices can reduce environmental impacts and
subsequent human health effects from animal waste.  They can also maximize the use of animal
waste as a fertilizer. Exhibit 5-1 presents the main environmental benefits that could arise from
the treatment and management of animal waste.

The EPA is not currently able to quantitatively evaluate all human health and ecosystem benefits
associated with water quality improvements from reduced releases of CAFO wastes. The EPA is
even more limited in its ability to assign monetary values to those benefits.  The economic
benefit analysis can be found in the benefit report, titled "Environmental and Economic Benefits
of the NPDES/ELG CAFO Rules" and located in section 9.5 of the public record.

In some cases, animal waste releases to the environment result in direct monetary costs. Many of
these costs are associated with additional requirements for drinking water treatment. For
example, in California's Chino Basin, it could cost over $1 million per year to remove the
nitrates from drinking water due to loadings from local dairies (USEPA, 1993b).  In Iowa, Des
Moines Water Works planned to spend approximately $5 million to install a treatment system to
remove nitrates from their main sources of drinking water, the Raccoon and Des Moines Rivers
(Hubert, 1991).  Agriculture was cited as a major source of the nitrate contamination, although
the portion attributable to animal waste is unknown.  In Wisconsin, the city  of Oshkosh has spent
an extra $30,000 per year on copper sulfate to kill the algae in the water it draws from Lake
Winnebago (Behm, 1989).  The thick mats of algae in the lake have been attributed to excess
nutrients from manure, commercial fertilizers, and soil.
                                          5-1

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                                                                  EXHIBIT 5-1
                                        Anticipated Benefits  of the CAFO Proposed Regulations
 Category
          Benefit
  Origin of Impact
   Population/Resources Affected
                   Notes
Human
Health
Reduced risk of
methemoglobinemia ("blue
baby syndrome")
Nitrates in drinking
water in excess of
the MCL (Maximum
Contaminant Level)
of lOmg/L
Primarily infants drinking water not
treated by public treatment facilities
(private rural wells; ground water is
more susceptible than surface water)
Nitrate is extremely mobile in the environment,
and nitrate contamination of ground water is a
well-recognized historical problem in the
agricultural community.  According to the EPA's
National Survey of Pesticides in Drinking Water
Wells (1990), nitrate is the most widespread
agricultural contaminant in drinking water wells.
The EPA estimates that 4.5 million people are
exposed to nitrate levels in excess of the MCL.
Human
Health
Avoided illness from
pathogenic organisms (e.g.,
gastrointestinal illness;
infections of the skin, eye,
ear, nose, or throat)
Pathogens in
drinking and
recreational waters
People drinking or swimming in
contaminated water. Surface waters,
and ground waters in sandy or
fractured soils, are most susceptible to
contamination.
Over 150 pathogens in manure are linked to
human risk (e.g., Salmonella, Cryptosporidium
parvum, Giardia lamblia, Escherichia coli).

A U.S. General Accounting Office study (1997)
of bacterial contamination of ground water over
a four-year period found contamination in 3 to 6
percent of community water systems each year,
and 15 to 42 percent of private wells.

Drinking water disinfection does not eliminate
the need for source water protection; source
water protection is an integral part of the
multiple barrier approach to drinking water
treatment. Drinking water disinfection  also does
not address recreational risks.
Human
Health
Avoided illness from toxic
aquatic organisms (e.g., red
tides. Pfiesteria piscicida)
Toxic organisms
whose growth is
enhanced by
eutrophication
(nutrient enrichment)
People with significant dermal or
inhalation exposure to affected
estuarine/marine waters; people
consuming affected shellfish
(pathways vary by organism)

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                                                                  EXHIBIT 5-1
                                         Anticipated Benefits of the CAFO Proposed Regulations
Category
          Benefit
 Origin of Impact
  Population/Resources Affected
                   Notes
Ecological,
Recreational
Avoided fish kills and other
environmental damage (e.g.,
fish and wildlife disease,
clogged fish gills, benthic
habitat destruction,
eutrophication) due to
discharges of waste directly
to surface water
BOD, ammonia,
pathogens, solids,
nutrients
Surface waters, aquatic organisms,
waterfowl, people using the water for
recreation
States have documented hundreds of cases of
discharges from CAFOs, resulting in the death of
millions of fish, over the past decade.

Discharges directly to surface water are
prohibited by the existing effluent guidelines
except in the event of the 25-year, 24-hour
storm, but implementation of the guidelines has
been problematic. The proposed regulations are
likely to call attention to the problem of such
discharges and result in improved
implementation.  The proposed regulations also
expand the scope of regulatory coverage and
establish operation and maintenance
requirements for storage lagoons to reduce the
likelihood of discharge.
Ecological,
Recreational
Reduced contribution to
eutrophication effects
(harmful algae blooms,
decreased dissolved oxygen,
fish kills, reduced
biodiversity, reduced
abundance of desirable
aquatic plants) due to runoff
from land application sites
Nutrients
Surface waters, aquatic organisms,
people using the water for recreation
The EPA's National Water Quality Inventory
(1997) indicates that nutrients are the leading
cause of impairment of U.S. lakes and rivers and
are the fifth leading cause of impairment of U.S.
estuaries.
Ecological,
Recreational
Reduced contribution to
environmental damage due
to runoff of other (non-
nutrient) pollutants from land
application sites
BOD, pathogens,
solids, salts, metals
Surface waters, aquatic organisms,
waterfowl, people using the water for
recreation
The proposed regulations' CNMP requirement
focuses on nutrients but would also incidentally
address other pollutants.

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                                                                 EXHIBIT 5-1
                                        Anticipated Benefits of the CAFO Proposed Regulations
Category
          Benefit
  Origin of Impact
   Population/Resources Affected
                   Notes
Commercial
Reduced damage to
commercial fishing and
shellfish industries
Nutrients, BOD,
pathogens, solids
Commercial fishing and shellfish
industries
The National Oceanic and Atmospheric
Administration (1995) reported that feedlots
were a potential or actual contributor to the
impairment of 110 shellfish beds (3 percent of all
impaired shellfish areas).

Outbreaks of Pfiesteria  have directly impacted
menhaden (a commercially harvested fish), and
indirectly impacted the  commercial fishing
industry as a whole. Nutrient enrichment is one
of several factors that affect growth of  Pfiesteria.
                                                                                                       Reduction in submerged aquatic vegetation
                                                                                                       (SAV) due to excessive algae and suspended
                                                                                                       solids is a significant impact because SAV
                                                                                                       serves as critical habitat for juvenile fish and
                                                                                                       crabs.

                                                                                                       The proposed regulations' CNMP requirement
                                                                                                       focuses on nutrients but would also incidentally
                                                                                                       address other pollutants.
Other
Avoided costs associated
with treatment or
replacement of nitrate-
contaminated ground water
Nitrates in drinking
water in excess of
the MCL of 10 mg/L
Public and private drinking water
sources (ground water is generally
more susceptible than surface water)
By implementing the proposed regulations, the
following treatments may be avoided: private
well owners needing to drill deeper wells to
reach uncontaminated ground water or purchase
bottled water, and public water suppliers needing
to obtain an uncontaminated source or treat the
water to meet the MCL.
Other
Avoided costs associated
with treatment to remove
algae, odors, and disinfection
byproducts from drinking
Algae growth
stimulated by
nutrients
Drinking water sources (surface
water)
              water
Implementing the proposed regulations may
decrease the amount of disinfection byproducts
(e.g., trihalomethanes) in drinking water that
exceed the MCL. Disinfection byproducts are
caused by chlorination of organic matter. The
guidelines would also decrease additional or
alternative treatment required to avoid or remove
excess byproducts.	

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5.2    REPORTED BENEFITS OF ANIMAL WASTE MANAGEMENT AND RELATED
       NON-POINT SOURCE MEASURES IN SELECTED WATERSHEDS

Several states have successfully implemented non-point source pollution programs under
Section 319 of the Clean Water Act. Following are descriptions of the reported benefits derived
from some of these programs and summaries of other research on specific land application
practices. The examples provide anecdotal evidence of the effectiveness of animal waste
management measures that might be implemented as a result of the proposed regulations.
Several of the examples demonstrate the impact of a single management practice (e.g., dry litter
waste management), while others address comprehensive plans that may include several
practices.

5.2.1   Benefits of Single Practices

The effects of riparian forest restoration, dry litter waste management, dead bird composting, and
land application practices are discussed below. All examples except the land application
practices are described in Section 319 Success Stories Volume II: Highlights of State and Tribal
Nonpoint Source Programs (USEPA, 1997b). Land application practices were investigated by
Daniel et al. (1995).  Studying the effects of separate practices individually leads to a better
understanding of the impact associated with each of these practices and whether each would be a
useful component of comprehensive management plans.

Riparian Forest Restoration

In the Suwanee River basin near Tifton, Georgia, in the Southeastern Coastal Plain, a riparian
forest (trees, shrubs, and native grasses) was reestablished to ameliorate the water quality impacts
of liquid manure application to cropland. Project workers evaluated the effects of the riparian
restoration by measuring changes in the surface and subsurface water quality indicators in the
field where manure was applied and again after the runoff had moved through the restored
riparian area toward the stream. The monitoring results demonstrated that the restored riparian
area effectively removed nitrogen, phosphorus, and sediment in the first two years of the project.
Furthermore, nitrate levels leaving the area in shallow ground water not exposed to the riparian
forest were higher than in mature riparian forest sites.

Dry Litter Waste Management

At a swine farm in Hawaii, a modified dry litter waste management system was implemented to
lessen water quality impacts. In the dry system, swine are housed in sloping pens.  Dry litter or
bedding is used to help push the waste down the slope into a composting or storage pit, rather
than using water to transport the waste.

The Hawaiian farm improved the dry system by incorporating pen sizes with slopes ranging from
15:1 to 20:1.  Wood chips and grass cuttings were found to be excellent bedding materials, but
the farm achieved best results with macadamia nut husks. The swine crush the bedding materials
and the manure with their hooves; the mix dries and begins to decompose, and eventually moves
down slope into a composting pit. The composted product is a good medium for organic
farming, and can be used to generate income for the swine farmer. The product can be sold in

                                          5-5

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Hawaii for about $30 per cubic yard. A typical pen can convert about 30 cubic yards of green
waste into 20 cubic yards of compost annually.

In addition to helping protect water quality by eliminating lagoons, the dry litter waste
management system also produces very little odor. Hydrogen sulfide (H2S) levels recorded
throughout the production and storage areas were considerably less than the conventional wash
down system.  H2S measurements at the dry litter facility were 10.7 parts per billion (ppb) in the
production area and 5.0 ppb in the storage area. By comparison, H2S levels at the control or
conventional wash down facility were 54.3 ppb in the production area and 104.5 ppb at the entry
to the waste lagoon.

Dead Bird Composting

In 1993, 62 growers in a six-county area in south central Mississippi handled 7 million birds. By
1997,150 growers reported a census of 16.2 million birds. Because of this expansion, the state
was concerned about potential threats to surface and ground water resources from dead birds,
which traditionally were disposed in burial pits or incinerated. Arkansas recently prohibited the
use of pits for dead bird disposal, because the carcasses often decay only partially and the
leachate from the pits poses a danger to surface water and ground water.

The project promotes composting as a preferred method of dead bird disposal.  Approximately
194,400 birds per year will be disposed of by composting in a manner that reduces the chance of
ground water contamination. In addition, area farmers are saving up to $25 per ton by using the
composted material as a substitute for commercial fertilizer.  (When composting is combined
with other practices such as soil testing and nutrient management planning, it reduces the risk of
nutrient enrichment to nearby surface waters.)

Land Application Practices

Daniel et al. (1995) applied animal manure to constructed plots with established grass and
measured the resulting impacts on the quality of runoff and subsurface water. The study
investigated the effect of differing application rates and other factors on the runoff of the
following animal waste constituents: total Kjeldahl nitrogen, ammonia-nitrogen, nitrate-
nitrogen, total phosphorus, orthophosphorus, total suspended solids, and chemical oxygen
demand.

The results of the study indicate that lower application rates resulted in lower runoff for all
constituents from poultry litter, and lower runoff of all constituents except nitrate-nitrogen from
both poultry and swine manure. Lower application rates were also associated with less nitrate
leaching into subsurface water.

5.2.2  Benefits of Multiple Practices

The following examples demonstrate the effect of multiple practices available to farmers. These
examples are all taken from USEPA (1997b).
                                           5-6

-------
Cadron Creek, Arkansas

The Cadron Creek Watershed in Arkansas has a high concentration of poultry and dairy farms.
Cadron Creek is widely used for recreation, canoeing, and fishing; Brewer Lake provides
drinking water to the cities of Morrilton and Conway. Other land uses in the project area include
forestry (41 percent), grasslands (52 percent), and croplands (6 percent).

All waters within the watershed are threatened by bacteria and nutrients from confined animal
operations. At least 20 stream miles do not meet their designated uses, and it is likely that most
small streams in the watershed do not meet the standard for contact recreation.

To restore the watershed, the Van Buren County Conservation District implemented a portable
land application system for liquid animal waste, which collects and redistributes liquid waste
from 30 to 40 dairies to return nutrients to pastures and fields in the watershed and reduce
pollution in surface waters and ground water. Other key elements of the project include
monitoring on two creeks and establishing on-farm waste management systems. Farmers are
applying the following best management practices (BMPs):

       •   dead poultry composting;
       •   nutrient management planning;
       •   pasture management;
       •   proper grazing use;
       •   waste management systems; and
       •   waste management ponds.

Water quality monitoring indicates that these systems successfully reduced nutrient and bacteria
loading to Ward Creek in this watershed. For example, fecal coliform bacteria levels in the
stream decreased by a factor of 10 (from 100,000 to 10,000 colonies per 100 ml).  The count is
still far higher than the 200 colonies per 100 ml standard for recreational contact; however, with
continued efforts, the project is anticipated to restore swimming as a beneficial use of this
stream.

Benthic macroinvertebrate communities (aquatic insects) are another indicator of watershed
health and in-stream conditions.  Species diversity, a standard indicator of benthic community
strength, is measured on the Family Biotic Index (FBI): the lower the FBI, the more diverse the
community.  The FBI in the monitored stream improved from 5.48 (which indicates the
probability of substantial organic pollution) to 4.27 (which indicates the probability of slight
organic pollution).

Moore's Creek and Beatty Branch Subwatershed, Arkansas

The Moore's Creek and Beatty Branch subwatershed is part of the Muddy Fork Hydrologic Unit
Area in northwestern Arkansas. The Muddy Fork Hydrologic Unit Area encompasses 47,122
acres, the tributaries of the Illinois River and Lakes Lincoln, Budd Kidd, and Prairie1 Grove.
These tributaries form Lincoln Lake, a drinking water reservoir serving the city of Lincoln.
                                           5-7

-------
The project implemented under Section 319 began with a monitoring project in these waters to
help establish the usefulness of nutrient BMPs,  Land uses, primarily poultry production and
pasture management, are major sources of nutrients and chronic high turbidity. According to the
state's 7996 Water Quality Inventory Report, water in the area only partially supports aquatic
life.  Pathogen indicators sampled in the Muddy Fork Hydrologic Unit Area also exceed
acceptable limits for primary contact recreation. This problem, reported in the 1994 water
quality inventory, was traced to extensive poultry, swine, and dairy operations in the Moore's
Creek basin. Essentially, all parts of the subwatershed are affected by these activities.

Nitrogen and phosphorus management practices were applied throughout the basin to help
control the flow of nutrients from CAFOs.  Specifically, BMPs were used on approximately one
half of the pasture land along Moore's Creek and two-thirds of the pasture land along Beatty
Creek. Five monitoring sites were established on Moore's Creek and Beatty Branch to
demonstrate the integrated impact of the nutrient BMPs on water quality. Random samples were
collected at all five sites, and storm-event samples were also collected at two sites.

Monitoring during the first three years of the project (1991 to 1994) showed decreasing levels of
total Kjeldahl nitrogen, nitrate, chemical oxygen demand, total phosphorus, ammonia, and total
suspended solids. Nitrate-nitrogen levels declined by 55 to 66 percent per year, total Kjeldahl
nitrogen levels declined by 54 to 67 percent per year, and chemical oxygen demand levels
declined by 44 to 67 percent per year.

Lake Shaokatan, Minnesota

Lake  Shaokatan is a shallow prairie lake located in western Minnesota on the South Dakota
border.  The lake's water quality severely deteriorated in the 1980s as a result of excessive
nutrient loading associated with watershed land-use practices. Harmful algal blooms dominated
the open water season and occasionally produced algal toxins alleged to have resulted in the
death of dogs and cattle.  Sampling revealed extremely high levels of total phosphorus (average
summer value of 270 ug/L). Chlorophyll a concentrations were episodic with concentrations
noted to exceed 100 ug/L (with summer means  of 20 to 30 ug/L). The major source of the
phosphorus was attributed to swine and dairy feedlots and drain tile operations.

A complete watershed restoration project was implemented. The goal was to achieve total
phosphorus levels of 90 ug/L or less. Since late 1991, the restoration program has included the
following practices relevant to animal operations, as well as a variety of other practices (such as
repairing septic systems):

       •  diverting a stream from a swine operation; and
       *  upgrading a dairy feedlot operation.

The combination of the full range of practices in the watershed reduced phosphorus loading rates
by 58 to 90 percent. These practices cost about $3 to $11 per kilogram of reduced phosphorus.
The watershed's response to these corrective actions  was immediate and significant, as both
nutrient and sediment losses were reduced. Average summer total phosphorus concentrations
dropped from 270 to 89 ug/L by 1994. Furthermore, the intensity and duration of seasonal algal
blooms have been curtailed with all values now less than 20 ug/L.

                                           5-8

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Tangipahoa River, Mississippi

Animal waste from confined dairy, swine, and poultry waste lagoons is a contributing factor to
the high level of nitrogen, phosphorus, and fecal coliform found in some Mississippi streams.

Waste management plans were implemented in southwestern Mississippi to help remedy water
quality problems in the Tangipahoa River, which flows southeast across the Mississippi and
Louisiana state lines to Lake Pontchartrain, Louisiana. The project then expanded to other
districts. The plans included pumping solids from improperly functioning animal waste lagoons
and applying them to the land with a traveling gun irrigation system, in accordance with waste
management plans at various sites. Approved waste management plans may have also included
nutrient management plans. During the project time period, 12 lagoon systems (10 dairy, one
swine, and one poultry) were pumped out.  The total amount of land used for the applications
included 192 acres of cropland and 206 acres of pastureland. In total, the lagoon effluent
irrigated onto these acres contained 72,402 pounds of nitrogen, 34,911 pounds of phosphorus,
and 82,715 pounds of potassium.

The landowners who participated in the demonstration project were pleased with the outcome
and saved money on fertilizer costs. They noted that the demonstration resulted in the following
benefits:

       »  The irrigation system helps alleviate lagoon overflow problems.
       •  Expensive and time-consuming equipment is not necessary for the adoption of this
          lagoon management practice. Tank trucks and tractors, which cause soil erosion and
          compaction, can be eliminated.
       «  Production costs are significantly lower when nutrients are recycled to crop and
          pasture systems. The alternative practice, commercial fertilizers, is more expensive.

Crooked, Otter, and North Fork Tributaries, Missouri

This project covered an area of approximately 630 square miles in northeast Missouri, including
all of the drainage area of the Crooked, Otter, and North Fork tributaries that empty into Mark
Twain Lake.  Agricultural land composes 55 percent of the  project area's land use. The land is
intensively cropped and is also a major pork producing region.  Two counties within the drainage
area have over 300 swine facilities and an additional 100 dairy and beef operations.

This project expedited the adoption of innovative BMPs through technical assistance to
producers. The project is designed to help farmers;

       •  develop, implement, and evaluate total resource management (TRM) systems or
          whole-farm plans that emphasize nutrient and pesticide strategies;
       «  plan, design, and install animal waste systems; and
       «  provide assistance to field personnel in the formulation and implementation of TRM
          systems training.

The TRM plans include such practices as manure and nutrient management, intensive rotational
grazing systems, alternative water supplies for livestock, waste production storage and treatment

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programs, erosion control, dead animal composting, soil and water testing, prairie restoration,
woodland and wildlife management, precision farming, crop rotation, farm dump cleanups and
alternatives to illegal dumping, insect scouting, weed mapping, pesticide container recycling, and
nitrogen-fixing legumes for reduced fertilizer applications.

As a result of TRM plan implementation, the farms and communities reaped benefits, including
improved water quality, less field and streambank erosion, more plentiful wildlife and beneficial
pests, fewer chemicals and nutrients in runoff, and increased yields and income.

Godfrey Creek, Montana

Several dairy cattle, swine, and beef cattle operations are located immediately adjacent to
Godfrey Creek in Montana and are the major sources of impairment to the creek. Improper
grazing management, riparian area degradation, and crop farming also contribute to the problem.

A project was initiated in 1989 with two primary objectives: (1) to demonstrate  agricultural
BMPs that will reduce suspended solids, fecal coliform, and nitrates in runoff from dairy
operations, grazing, and farming practices; and (2) to develop an education program for
producers in the watershed. Over 80 percent of landowners in the area participated in major
efforts such as fencing riparian areas, adopting improved grazing systems, removing livestock
from riparian areas, establishing buffer zones, improving manure-handling systems, and
improving irrigation water management.

Post-project data, from samples taken in 1995 and 1996, suggest that water in Godfrey Creek
watershed improved as a result of project activity. Estimated reductions in mean annual
concentrations were 58 percent for total phosphorus and 64 percent for total dissolved solids
compared with pre-project conditions.  A dramatic decline (82 percent) in fecal coliform also
occurred. However, nitrate-plus-nitrite data show an average increase of 24 percent.  Although
the project has not yet reached its goal of 80 percent reduction in these key indicators (except for
fecal coliform), it is successfully helping landowners gain control of factors that  influence
surface and bank erosion and nutrient runoff. Agricultural practices that help control nitrate
include a combination of irrigation and manure disposal methods. Future project activities may
need to emphasize these practices to ensure the full realization of Godfrey Creek's potential.

Bush River-Camping Creek Watershed, South Carolina

The  Bush River-Camping Creek watershed in Newberry County, South Carolina, drains directly
to Lake Murray. This 51,000-acre impoundment is used to generate power, provide a municipal
water supply serving approximately 330,000 people, and provide a major recreational resource.
More than 175 miles of streams run through the project area, and more than 800  ponds  are
located along these streams.  The ponds are used for livestock watering, irrigation, and
recreation.

Although land uses vary, the potential for non-point source pollution is primarily agricultural.
The  watershed's nearly 130,000 acres support the following uses: about 29,500 acres of cropland,
60,700 acres of forest, 22,900 acres of pasture, and 16,600 acres of development (urban,
industrial, and commercial).  Over 200 farmsteads are  maintained in the watershed, with an

                                          5-10

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average size of 165 acres. The farm industry is quite diversified, although the most prevalent
enterprises are confined animal operations, small grain production, and row crop farming.  Over
60 confined animal operations have been inventoried in the watershed. The USD A Natural
Resources Conservation Service (NRCS) estimates that the watershed produces about 75,000
tons of animal waste annually.

Agricultural activities in the project area are a major influence on the streams and ponds in the
watershed, and contribute to nutrient-related water quality problems in the headwaters of Lake
Murray. In fact, bacteria, nutrients, and sediment from soil erosion are the primary contaminants
affecting these resources.  The NRCS has calculated that soil erosion, occurring on over 13,000
acres of cropland in the watershed, ranges from 9.6 to 41.5 tons per acre per year.  At times,
excessive amounts of nutrients, especially nitrates, are found in the water, primarily as a result of
land applying too much manure, sometimes with or in addition to commercial fertilizers. Based
on these conditions, the Bush River-Camping Creek watershed was identified in the South
Carolina Non-point Source Management Plan as a high priority watershed.

A coordinated multiple agency effort to control these non-point sources began in 1990. Phase
one of the project demonstrated agricultural BMPs, provided technical assistance to agricultural
landowners implementing non-point source pollution controls, financial assistance to qualifying
landowners for BMP installations, and a water quality monitoring program. Simultaneously, the
state inventoried and inspected all confined animal facilities in the watershed. Technical
assistance was then provided to owners who were not in compliance with regulations. Potential
violations include illegal discharge pipes, overflow discharges, high vegetation around lagoons,
runoff from animal housing, improper dead animal disposal, and absence of permits.  Phase two
of the project concentrates on confined animal operations in the watershed. Components include
demonstration of innovative BMPs, such as lagoon pump-out/irrigation practices and dead bird
composting. Farmers in the project area have access to a mobile nutrient testing service, which
helps them calculate the right amount of manure to apply to their fields and pastures, and
additional computerized information to help them make prudent decisions about pesticide
selection and management.  Educational activities include newsletters, workshops, field days,
and one-on-one technical assistance to farmers.

Several improvements have been noted since the implementation of this project:

       •  Ambient water quality samples gathered between May and October 1992  from the
          headwaters of Lake Murray, which receives water from the Bush River-Camping
          Creek watershed, indicated statistically significant reductions in nutrients  (nitrate-
          nitrite and total phosphorus) since the start of the project.  These decreases might be
          associated with reduced numbers of nutrients reaching the waterbody from non-point
          sources.  Similar data gathered between 1992 and 1996 indicate continued reductions
          in nitrate-nitrite.
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Of 48 AFOs that were out of compliance with regulations at the beginning of the
project, 26 of these operations were in compliance in 1993.  Twenty-two others were
working on gaining compliance through coordination with state and local entities.

Approximately 94,000 tons of soil in the watershed were saved through the use of
BMPs.  Also, 75,000 tons of animal waste are being properly used annually according
to South Carolina guidelines (i.e., application rates, slopes, and time of year).
                                5-12
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