Notice of Availability of an Environmental Assessment Worksheet (EAW) REG Albert Lea, LLC

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1 Notice of Availability of an Worksheet (EAW) Doc Type: Public Notice Public Comment Information EAW Public comment period begins: August 17, 2015 EAW Public comment period ends: 4:30 p.m. on September 16, 2015 Notice published in the EQB Monitor: August 17, 2015 Facility Specific Information Facility name and location: SW ¼ of Section 1, Township 101 North Range 21 West, Glenville/Freeman Township Freeborn County, MN Facility contact: Julie Ingoli 416 S Bell Avenue Ames, Iowa Phone: Fax: Julie.Ingoli@REGi.com MPCA Contact Information MPCA EAW contact person: Charles Peterson Resource Management and Assistance Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN Phone: Fax: charles.peterson@state.mn.us Admin staff phone: MPCA Permit contact person: Bonnie Nelson Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN Phone: Fax: bonnie.nelson@state.mn.us General Information The Minnesota Pollution Control Agency (MPCA) is distributing this Worksheet (EAW) for a 30-day review and comment period pursuant to the Environmental Quality Board (EQB) rules. The MPCA uses the EAW and any comments received to evaluate the potential for significant environmental effects from the project and decide on the need for an Environmental Impact Statement (EIS). An electronic version of the EAW is available on the MPCA Environmental Review webpage at If you would like a copy of the EAW or NPDES/SDS Permit or have any questions on the EAW or NPDES/SDS Permit, contact the appropriate person(s) listed above. p-ear2-80a TTY or Available in alternative formats i-admin /2/14 Page 1 of 2

2 Description of Proposed Project, ( Proposer ) operates a biodiesel production facility ( Facility ) in Glenville, Minnesota and is proposing to increase the maximum biodiesel production rate from 31.5 million gallons per year ( MGY ) to 38 MGY ( Project ). Biodiesel is an alternative fuel for use in diesel engines and produced from soybeans, used corn oil, and animal fats. A copy of the Worksheet will be posted on the Minnesota Pollution Control Agency website, at the following: Written comments on the EAW should be submitted to Charles Peterson. A copy of the EAW may also be obtained by contacting Beth Tegdesch at In addition to the Worksheet (EAW), the Minnesota Pollution Control Agency s draft Air Permit will also be available for public comment beginning shortly after EAW publication. The contact person for the Air Permit is Bonnie Nelson at To Submit Written Comments on the EAW and NPDES/SDS Permit Written comments on the EAW must be received by the MPCA EAW contact person within the comment period listed above. For information on how to comment on the (NPDES/SDS Permit, contact the MPCA Permit contact person listed above. NOTE: All comment letters are public documents and will be part of the official public record for this project. Need for an EIS (1) The MPCA Commissioner will make a final decision on the need for an EIS after the end of the comment period TTY or Available in alternative formats i-admin /2/14 Page 2 of 2

3 ENVIRONMENTAL ASSESSMENT WORKSHEET This Worksheet (EAW) form and EAW Guidelines are available at the Environmental Quality Board s website at: The EAW form provides information about a project that may have the potential for significant environmental effects. The EAW Guidelines provide additional detail and resources for completing the EAW form. Cumulative potential effects can either be addressed under each applicable EAW Item, or can be addresses collectively under EAW Item 19. Note to reviewers: Comments must be submitted to the RGU during the 30-day comment period following notice of the EAW in the EQB Monitor. Comments should address the accuracy and completeness of information, potential impacts that warrant further investigation and the need for an EIS. 1. Project title: 2. Proposer: 3. RGU: Minnesota Pollution Control Agency Contact person: Julie Ingoli Contact person: Charles Peterson Title: Mgr., Environmental Compliance and Services Title: Planner Principal Address: 416 S. Bell Avenue Address: 520 Lafayette Road North City, State, ZIP: Ames, Iowa City, State, ZIP: St. Paul, Minnesota Phone: (515) Phone: (651) Fax: (515) Fax: (651) Julie.Ingoli@REGi.com charles.peterson@state.mn.us 4. Reason for EAW Preparation: (check one) Required: Discretionary: - EIS Scoping - Citizen petition X Mandatory EAW - RGU discretion - Proposer initiated If EAW or EIS is mandatory give EQB rule category subpart number(s) and name(s): Minn. R , subp. 5A Fuel Conversion Facilities 5. Project Location: County: Freeborn City/Township: Glenville / Freeman Township PLS Location: SE ¼, SW ¼, Section 1, Township 101N, Range 21W Watershed (81 major watershed scale): Shell Rock River Watershed GPS Coordinates: , , N ', W ' Tax Parcel Number: R TDD (for hearing and speech impaired only): Printed on recycled paper containing 30% fibers from paper recycled by consumers

4 At a minimum attach each of the following to the EAW: Attachment A - General location of the project. Attachment B - U.S. Geological Survey 7.5 minute, 1:24,000 scale map indicating project boundaries. Attachment C - Site plan. Attachment D Federally listed Threatened, Endangered, Proposed, and Candidate Species Attachment E Natural Heritage Review letter from Department of Natural Resources. Attachment F Minnesota Archaeological Inventory and Historic Structures Inventory search from State Historic Preservation Office. 6. Project Description: a. Provide the brief project summary to be published in the EQB Monitor, (approximately 50 words)., ( Proposer ) operates a biodiesel production facility ( Facility ) in Glenville, Minnesota and is proposing to increase the maximum biodiesel production rate from 31.5 million gallons per year ( MGY ) to 38 MGY ( Project ). Biodiesel is an alternative fuel for use in diesel engines and produced from soybeans, used corn oil, and animal fats. b. Give a complete description of the proposed project and related new construction, including infrastructure needs. If the project is an expansion include a description of the existing facility. Emphasize: 1) construction, operation methods and features that will cause physical manipulation of the environment or will produce wastes, 2) modifications to existing equipment or industrial processes, 3) significant demolition, removal or remodeling of existing structures, and 4) timing and duration of construction activities. History On July 7, 2011, the Proposer acquired the Glenville, Minnesota biodiesel plant from SoyMor Cooperative. On February 2, 2012, the necessary name change was applied to applicable air construction permits for the Facility. On March 4, 2013, the Minnesota Pollution Control Agency ( MPCA ) issued an amended air emission permit (Permit No ) in response to REG Albert Lea s request to modify the production Facility to process a lower quality feedstock. In addition, the permit established a maximum production capacity of 31,500,000 gallons of biodiesel per year. The Facility is a minor source of emissions for particulate matter ( PM ), particulate matter less than 10 microns ( PM 10 ), particulate matter less than 2.5 microns ( PM 2.5 ), nitrogen oxides ( NO x ), sulfur dioxide ( SO 2 ), volatile organic compounds ( VOC ), and carbon monoxide ( CO ). The Facility is a synthetic minor source for hazardous air pollutants ( HAPs ), specifically methanol. The Facility operates a flare to control VOC and methanol emissions. This flare has demonstrated a control efficiency of at least 98% per the requirements of Minn. R (Copy of Stack Test report attached in Appendix A of this EAW). Glenville Minnesota 2 Worksheet

5 Biodiesel Production Biodiesel is an alternative fuel, derived from vegetable oils and fats, which has similar combustion properties to regular petroleum diesel fuel. Biodiesel is biodegradable, nontoxic, and has fewer emissions than petroleum based diesel when burned. The process utilized to produce biodiesel at this Facility is called trans-esterification. The Facility processes soybean oil, inedible corn oil, and low quality feedstock (such as used cooking oil and lower quality animal fats) into biodiesel. For low quality feedstock, the Proposer starts the production process with pre-treatment of the feedstock to remove metals, phospholipids, proteins, and other impurities using a filter of diatomaceous material and a centrifuge. The feedstock is then sent to a de-acidification column where the feedstock is heated up rapidly in order to separate out water and fatty acids from the triglycerides. From the de-acidification column, the feedstock is sent to a number of reactors and decanters which are collectively referred to as the trans-esterification process. Methanol is added to react with the feedstock, and sodium methylate is added as a catalyst. This chemical process, converts triglyceride and methanol into biodiesel and glycerin. After the trans-esterification reaction, hydrochloric acid is added to the biodiesel to neutralize the ph. The next step in the process is to recover the unreacted methanol. This is accomplished with a methanol rectification column, a feedstock absorber and a water absorber. The recovered methanol is recycled back and used again in the trans-esterification process. Once the methanol is removed from the biodiesel, the biodiesel is sent to the biodiesel distillation wipe-film evaporator ( WFE ) for final processing. From the distillation WFE the biodiesel is sent to storage and load out. Reason for EAW Request The original Worksheet ( EAW ) relative to the construction of the SoyMor Cooperative Biodiesel Facility was submitted on June 18, That EAW listed the maximum allowable production capacity for the Facility as 25 MGY. The March 4, 2013, permit amendment (mentioned in the History above), incorporated the installation of a free fatty acid ( FFA ) stripping system, a biodiesel distillation WFE system, and thermal heaters. The amendment also established a maximum allowable production capacity of 31.5 MGY. The threshold in Minn. R subp. 5(A) for requiring a mandatory EAW is an increase of 25,000 dry tons or more per year of input. The feedstock received by REG Albert Lea contains water, and the actual weight of the dry feedstock is not directly measured. Therefore, to stay below the threshold for a mandatory EAW, the Facility cannot increase its biodiesel production by more than 6.5 MGY. Using the density of biodiesel (7.35 pounds per gallon), the amount of feedstock needed to produce 6.5 million gallons of biodiesel is calculated as follows: Glenville Minnesota 3 Worksheet

6 6,500,000 gal biodiesel 7.35 lb 1 ton = 23,887.5 ton feedstock year gallon 2,000 lb year The March 4, 2013, requested increase from 25 million gallons to 31.5 million gallons did not trigger the requirements of a mandatory EAW. The equipment installed as part of the March 2013 permit amendment resulted in the following improvements: The FFA stripping system removes impurities from the feedstock prior to the biodiesel production process. The biodiesel distillation WFE system improves the separation of biodiesel from co-products. The thermal fluid heaters distribute thermal energy to the FFA stripper and the distillation system. This equipment, however, has resulted in production performances beyond expectation. Actual operations indicate that the current Facility is capable of increasing the rate of biodiesel production. Thus, the Facility is seeking to increase its maximum allowable production rate from 25 million gallons to 38 million gallons, which triggers the mandatory EAW category under Minn. R subp. 5(A), (an increase of 25,000 dry tons or more per year of input). c. Project magnitude: There will be no physical changes to the existing Facility associated with this requested production increase. Total Project Acreage 23 Linear project length Number and type of residential units Commercial building area (in square feet) Industrial building area (in square feet) 18,950 Institutional building area (in square feet) Other uses specify (in square feet) Structure height(s) 75 and d. Explain the project purpose; if the project will be carried out by a governmental unit, explain the need for the project and identify its beneficiaries. The purpose of this Project is to increase the maximum production capacity of the existing Facility. No physical changes will occur. The increase in the production rate will enable the company to continue to competitively respond to market demand. e. Are future stages of this development including development on any other property planned or likely to happen? Yes X No If yes, briefly describe future stages, relationship to present project, timeline and plans for environmental review. f. Is this project a subsequent stage of an earlier project? Yes X No If yes, briefly describe the past development, timeline and any past environmental review. Glenville Minnesota 4 Worksheet

7 7. Cover types: Estimate the acreage of the site with each of the following cover types before and after development: The current Project will not physically alter the current Facility footprint. Before After Before After Wetlands Lawn/landscaping Deep Impervious water/streams surface Wooded/forest Stormwater Pond Brush/Grassland Other (describe) 3 3 Cropland TOTAL Permits and approvals required: List all known local, state and federal permits, approvals, certifications and financial assistance for the project. Include modifications of any existing permits, governmental review of plans and all direct and indirect forms of public financial assistance including bond guarantees, Tax Increment Financing and infrastructure. All of these final decisions are prohibited until all appropriate environmental review has been completed. See Minnesota Rules, Chapter Unit of government Type of application Status MPCA Modification of Existing Air Emission Permit (No ) Pending - Application Submitted 2/13/2015 MPCA AST Major Facility Permit (No. AST # Modified 2/13/2015 Albert Lea Industrial Wastewater Discharge Permit to City of Received 4/15/2013 Albert Lea WWTF (No R) MPCA No exposure ISW exclusion (No. MNRNE37C7) Received - 2/3/2012 DNR Water Appropriation Permit (Permit No ) Received - 5/14/2013 Cumulative potential effects may be considered and addressed in response to individual EAW Item Nos. 9-18, or the RGU can address all cumulative potential effects in response to EAW Item No. 19. If addressing cumulative effect under individual items, make sure to include information requested in EAW Item No Land use: a. Describe: i. Existing land use of the site as well as areas adjacent to and near the site, including parks, trails, prime or unique farmlands. The existing land use is a currently operating biodiesel production facility located on land west of the city of Glenville, in the Glenville Industrial Park. Glenville Minnesota 5 Worksheet

8 ii. Plans. Describe planned land use as identified in comprehensive plan (if available) and any other applicable plan for land use, water, or resources management by a local, regional, state, or federal agency. Lands surrounding the Facility include an ethanol plant, railroad tracks, Highway 65, and agricultural lands to the north; railroad track, Highway 65, and commercial buildings to the east; agricultural lands, farmsteads and Highway 13 to the south; and agricultural lands and farmsteads to the west. iii. Zoning, including special districts or overlays such as shoreland, floodplain, wild and scenic rivers, critical area, agricultural preserves, etc. The Facility is located in an industrial zoned area. b. Discuss the project s compatibility with nearby land uses, zoning, and plans listed in Item 9a above, concentrating on implications for environmental effects. There is no evidence that the project would adversely affect any environmental conditions related to the property, or the surrounding areas at this time. The Project is compatible with nearby land use. c. Identify measures incorporated into the proposed project to mitigate any potential incompatibility as discussed in Item 9b above. N/A 10. Geology, soils and topography/land forms: a. Geology - Describe the geology underlying the project area and identify and map any susceptible geologic features such as sinkholes, shallow limestone formations, unconfined/shallow aquifers, or karst conditions. Discuss any limitations of these features for the project and any effects the project could have on these features. Identify any project designs or mitigation measures to address effects to geologic features. As indicated above, this Project will not involve any physical changes to the existing facility. The geology underlying the Facility is as follows: According to Hydrologic Investigations Atlas HA-552 (Farrell, Broussard, et. al. 1975), the geologic setting for that portion of Freeborn County where the Facility is located, is characterized by Wisconsin Drift glacial till deposits of 100 to 200 feet. The Wisconsin Drift till is an unsorted and unstratified mixture of clay, silt, sand, and gravel, with localized and intermittent sand and gravel deposits buried within the till. However, the Atlas indicates that most groundwater supplies (including those associated with Glenville and Albert Lea) utilize the bedrock aquifers for groundwater supplies. No karst conditions are located in the vicinity of the Facility. Well borings obtained by the Proposer in 2013 indicate top soil clay from zero to two feet; yellow clay from 2 to 18 feet; a yellow sand/clay mixture from 18 to 88 feet; blue shale form 88 Glenville Minnesota 6 Worksheet

9 to 91 feet; gray limestone from 91 to 220 feet; blue limestone from 220 to 285 feet; and tan limestone form 285 feet to 320 feet. b. Soils and topography - Describe the soils on the site, giving NRCS (SCS) classifications and descriptions, including limitations of soils. Describe topography, any special site conditions relating to erosion potential, soil stability or other soils limitations, such as steep slopes, highly permeable soils. Provide estimated volume and acreage of soil excavation and/or grading. Discuss impacts from project activities (distinguish between construction and operational activities) related to soils and topography. Identify measures during and after project construction to address soil limitations including stabilization, soil corrections or other measures. Erosion/sedimentation control related to storm water runoff should be addressed in response to Item 11.b.ii. According to the Natural Resources Conservation Service (NRCS) soil survey the majority of the soils at the Project site consist of Lester loam, Le Sueur Loam and Webster clay loam. Lester loam covers approximately 53% of the Project site and is classified as a well-drained soil with high available water storage. Le Sueur loam covers approximately 16% of the project site and is classified as a somewhat poorly-drained soil with high available water storage. Webster clay loam covers approximately 19% of the project site and is classified as a poorly-drained soil with high available water storage. The NRCS designation for the Project site is Not Highly Erodible Land/Not a Wetland. The Proposer will employ the following mitigation measures at the Facility to prevent soil contamination: 1) all aboveground storage tanks have secondary containment. 2) The Facility has a permanent stormwater retention pond that passively treats surface water run-off. 3) The Facility applied for and has received a No Exposure Exclusion from Minnesota s industrial stormwater Multi-Sector General Permit (Permit No. MNRNE37C7 See Appendix B). NOTE: For silica sand projects, the EAW must include a hydro geologic investigation assessing the potential groundwater and surface water effects and geologic conditions that could create an increased risk of potentially significant effects on groundwater and surface water. Descriptions of water resources and potential effects from the project in EAW Item 11 must be consistent with the geology, soils and topography/land forms and potential effects described in EAW Item Water resources: a. Describe surface water and groundwater features on or near the site in a.i. and a.ii. below. i. Surface water - lakes, streams, wetlands, intermittent channels, and county/judicial ditches. Include any special designations such as public waters, trout stream/lake, wildlife lakes, migratory waterfowl feeding/resting lake, and outstanding resource value water. Include water quality impairments or special designations listed on the current MPCA 303d Impaired Waters List that are within 1 mile of the project. Include DNR Public Waters Inventory number(s), if any. The Proposer determined there are no protected water resources on the property, nor are there any ditches or impoundments. The closest water resources are two excavated basins located approximately 1,500 feet to the east of the proposed Facility which are listed on the National Wetlands Inventory. Glenville Minnesota 7 Worksheet

10 The Facility recycles most process wastewaters within the system and discharges blow down water from the cooling tower and miscellaneous wash waters to the city of Albert Lea Wastewater Treatment Facility (WWTF) and/or trucks waste water to the city of Des Moines WWTF. ii. Groundwater aquifers, springs, seeps. Include: 1) depth to groundwater; 2) if project is within a MDH wellhead protection area; 3) identification of any onsite and/or nearby wells, including unique numbers and well logs if available. If there are no wells known on site or nearby, explain the methodology used to determine this. There are two production wells located at the Facility for non-irrigation purposes. (PWSID ). currently uses approximately 45,000 to 50,000 gallons of water per day (approximately MGY) for operation of the Facility. 1) Depth to groundwater is 37 feet. 2) The Facility is not located within a Minnesota Department of Health Wellhead Protection area. 3) There is a nearby production well located at the adjacent Poet Ethanol facility. b. Describe effects from project activities on water resources and measures to minimize or mitigate the effects in Item b.i. through Item b.iv. below. The Facility discharges its wastewater to the city of Albert Lea WWTF located approximately one and one-half miles north of the Facility for treatment. In addition, the Facility is also permitted to truck wastewater to the Des Moines, Iowa WWTF. The maximum amount of wastewater to be discharged from the Facility is 50,000 gallons per day. This will include wastewater from the following processes: pretreatment process, bio-diesel production process, plant wash down, and cooling tower blow down. i. Wastewater - For each of the following, describe the sources, quantities and composition of all sanitary, municipal/domestic and industrial wastewater produced or treated at the site. 1) If the wastewater discharge is to a publicly owned treatment facility, identify any pretreatment measures and the ability of the facility to handle the added water and waste loadings, including any effects on, or required expansion of, municipal wastewater infrastructure. Wastewater from the Facility consists primarily of clear water, with some vegetable oil and dissolved solids. The Facility utilizes an oil skimmer to remove the vegetable oil component prior to discharge to the city of Albert Lea WWTF. The wastewater leaving the Facility will include minor amounts of oil that is not captured during the skimming process, and some dissolved solids from the cooling water blow down. Wastewater also includes wastewater from the on-site sanitary facilities (typical municipal waste water). Glenville Minnesota 8 Worksheet

11 2) If the wastewater discharge is to a subsurface sewage treatment systems (SSTS), describe the system used, the design flow, and suitability of site conditions for such a system. 3) If the wastewater discharge is to surface water, identify the wastewater treatment methods and identify discharge points and proposed effluent limitations to mitigate impacts. Discuss any effects to surface or groundwater from wastewater discharges. ii. Stormwater - Describe the quantity and quality of storm water runoff at the site prior to and post construction. Include the routes and receiving water bodies for runoff from the site (major downstream water bodies as well as the immediate receiving waters). Discuss any environmental effects from storm water discharges. Describe storm water pollution prevention plans including temporary and permanent runoff controls and potential BMP site locations to manage or treat storm water runoff. Identify specific erosion control, sedimentation control or stabilization measures to address soil limitations during and after project construction. The current Project will not involve any construction. A permanent stormwater retention pond is located onsite. Under normal conditions, the retention pond passively treats surface water run-off. As such, the Facility applied for, and has received a No Exposure Exclusion from Minnesota s Industrial Stormwater Multi-Sector General Permit (Permit No. MNRNE37C7). All surface water drains through a subsurface tile system that consists of farm tile buried in the ground that carries the water to a tile outlet in the field to the south of the property. Any surface runoff that does not drain through the tiling system flows across the surface to a catch pond in the northeast corner of County Road 13 and 780th Avenue or to a catch pond directly east of our property. Both of these ponds are owned by POET and they perform monthly water testing on the ponds. All waters drained from the tank farm after checking phs prior to release flow through the same system. iii. Water appropriation - Describe if the project proposes to appropriate surface or groundwater (including dewatering). Describe the source, quantity, duration, use and purpose of the water use and if a DNR water appropriation permit is required. Describe any well abandonment. If connecting to an existing municipal water supply, identify the wells to be used as a water source and any effects on, or required expansion of, municipal water infrastructure. Discuss environmental effects from water appropriation, including an assessment of the water resources available for appropriation. Identify any measures to avoid, minimize, or mitigate environmental effects from the water appropriation. The Proposer originally submitted a permit application for Appropriation of Waters of the State Non-irrigation permit on August 22, 2012, and updated the application on April 30, The application requested appropriation of well water for commercial/industrial use. The water source would be two manifold wells pumping 170 gallons per minute. The Proposer requested an appropriation for both continuous 24/7 Glenville Minnesota 9 Worksheet

12 usage and seasonal. The Proposer calculated the total annual maximum use was 89,352,000 gallons (based on pump capacity). The estimated annual usage was 50,000,000 gallons of all season water usage. A copy of the appropriations permit (Permit No ) for the Facility is located in the attached Appendix G. The proposed Project will not appropriate surface or groundwater. iv. Surface Waters a) Wetlands - Describe any anticipated physical effects or alterations to wetland features such as draining, filling, permanent inundation, dredging and vegetative removal. Discuss direct and indirect environmental effects from physical modification of wetlands, including the anticipated effects that any proposed wetland alterations may have to the host watershed. Identify measures to avoid (e.g., available alternatives that were considered), minimize, or mitigate environmental effects to wetlands. Discuss whether any required compensatory wetland mitigation for unavoidable wetland impacts will occur in the same minor or major watershed, and identify those probable locations. The Facility has a surface water drainage system. This system directs any surplus surface water flow through graded or vegetated areas to the permanent stormwater detention pond. As such adverse impacts are not anticipated. b) Other surface waters- Describe any anticipated physical effects or alterations to surface water features (lakes, streams, ponds, intermittent channels, county/judicial ditches) such as draining, filling, permanent inundation, dredging, diking, stream diversion, impoundment, aquatic plant removal and riparian alteration. Discuss direct and indirect environmental effects from physical modification of water features. Identify measures to avoid, minimize, or mitigate environmental effects to surface water features, including in-water Best Management Practices that are proposed to avoid or minimize turbidity/sedimentation while physically altering the water features. Discuss how the project will change the number or type of watercraft on any water body, including current and projected watercraft usage. Since runoff will be directed to the detention pond and/or to graded or vegetated areas surrounding the plant/impervious surfaces, adverse impacts are not anticipated. 12. Contamination/Hazardous Materials/Wastes: a. Pre-project site conditions - Describe existing contamination or potential environmental hazards on or in close proximity to the project site such as soil or ground water contamination, abandoned dumps, closed landfills, existing or abandoned storage tanks, and hazardous liquid or gas pipelines. Discuss any potential environmental effects from preproject site conditions that would be caused or exacerbated by project construction and operation. Identify measures to avoid, minimize or mitigate adverse effects from existing contamination or potential environmental hazards. Include development of a Contingency Plan or Response Action Plan. Glenville Minnesota 10 Worksheet

13 In 1996, an ethanol plant was constructed on an adjacent industrial park site located northwest of the proposed Facility. Surrounding lands include: the ethanol plant, railroad tracks, Highway 65, and agricultural lands to the north; railroad tracks, Highway 65, and commercial buildings to the east; agricultural lands, farmsteads and Highway 13 to the south, and agricultural lands and farmsteads to the west. Prior to the construction of the existing biodiesel production facility, the land was utilized for agricultural purposes. It was undeveloped with the exception of a Lecithin plant for which construction was initiated in December 2003 and completed in June The construction permit for the SoyMor biodiesel plant was issued September 14, There was no evidence of recognized environmental conditions such as contaminated soil or groundwater related to the proposed SoyMor property or the surrounding areas at the time of initial construction of the biodiesel facility. b. Project related generation/storage of solid wastes - Describe solid wastes generated/stored during construction and/or operation of the project. Indicate method of disposal. Discuss potential environmental effects from solid waste handling, storage and disposal. Identify measures to avoid, minimize or mitigate adverse effects from the generation/storage of solid waste including source reduction and recycling. There are several materials produced as part of the biodiesel production process. The majority of these materials are co-products, marketed as saleable products to customers. A spent filter aid material is produced which is landfilled. Solid wastes (office waste, paper, cardboard, plastic, etc.) is segregated for recycling and disposal off-site by a local solid waste contractor. c. Project related use/storage of hazardous materials - Describe chemicals/hazardous materials used/stored during construction and/or operation of the project including method of storage. Indicate the number, location and size of any above or below ground tanks to store petroleum or other materials. Discuss potential environmental effects from accidental spill or release of hazardous materials. Identify measures to avoid, minimize or mitigate adverse effects from the use/storage of chemicals/hazardous materials including source reduction and recycling. Include development of a spill prevention plan. Methanol, hydrochloric acid, sodium methylate, and caustic soda are utilized in the biodiesel production process and are regulated substances. Methanol, hydrochloric acid, sodium methylate, and other solvents are stored in above ground storage tanks located on-site. The above ground storage tanks are equipped with secondary containment and permitted by the MPCA as a Major Facility (permit #123782). The Facility has the following above ground storage tanks and associated capacities on-site: Glenville Minnesota 11 Worksheet

14 Type of Tank Number Capacity (gallons) Rework Storage Tank 2 20,000 Methanol Storage Tank 2 40,000 Recycled Methanol Storage Tank 1 18,000 Bio-Diesel Storage Tank 4 500,000 Soybean Oil Storage Tank 2 500,000 Refined Oil Storage Tank 1 80,000 Glycerin Storage Tank 2 110,000 Fatty Acid Distillate Storage Tank 1 100,000 Fatty Acid Storage Tank 2 11,000 Hydrochloric Acid Storage Tank 2 15,000 Sodium Methylate Storage Tank 1 39,000 Distillation Bottoms tank 1 25,000 Soap Stock Storage Tank 1 20,000 Skimmings Tank 1 10,000 Cooling Tower Reservoir Tank 1 5,000 Nitrogen 1 9,000 Liquid Propane Tank 1 1,000 d. Project related generation/storage of hazardous wastes - Describe hazardous wastes generated/stored during construction and/or operation of the project. Indicate method of disposal. Discuss potential environmental effects from hazardous waste handling, storage, and disposal. Identify measures to avoid, minimize or mitigate adverse effects from the generation/storage of hazardous waste including source reduction and recycling. 13. Fish, wildlife, plant communities, and sensitive ecological resources (rare features): a. Describe fish and wildlife resources as well as habitats and vegetation on or in near the site. b. Describe rare features such as state-listed (endangered, threatened or special concern) species, native plant communities, Minnesota County Biological Survey Sites of Biodiversity Significance, and other sensitive ecological resources on or within close proximity to the site. Provide the license agreement number (LA- ) and/or correspondence number (ERDB ) from which the data were obtained and attach the Natural Heritage letter from the DNR. Indicate if any additional habitat or species survey work has been conducted within the site and describe the results. The proposed Project will not involve any physical changes. According to the County Distribution of Federally listed Threatened, Endangered, Proposed, and Candidate Species (copy attached See Attachment D) does not list any such species for Freeborn County. A Natural Heritage Information System Data Request Form was submitted (via ) on December 9, A copy of this submission is included in Attachment E of this report. c. Discuss how the identified fish, wildlife, plant communities, rare features and ecosystems may be affected by the project. Include a discussion on introduction and spread of invasive species from the project construction and operation. Separately discuss effects to known threatened and endangered species. Glenville Minnesota 12 Worksheet

15 d. Identify measures that will be taken to avoid, minimize, or mitigate adverse effects to fish, wildlife, plant communities, and sensitive ecological resources. 14. Historic properties: Describe any historic structures, archeological sites, and/or traditional cultural properties on or in close proximity to the site. Include: 1) historic designations, 2) known artifact areas, and 3) architectural features. Attach letter received from the State Historic Preservation Office (SHPO). Discuss any anticipated effects to historic properties during project construction and operation. Identify measures that will be taken to avoid, minimize, or mitigate adverse effects to historic properties. There are no historic structures, archeological sites, and/or traditional cultural properties on or in close proximity to the Facility. Please see Attachment F, the from the Minnesota State Historic Preservation Office. 15. Visual: Describe any scenic views or vistas on or near the project site. Describe any project related visual effects such as vapor plumes or glare from intense lights. Discuss the potential visual effects from the project. Identify any measures to avoid, minimize, or mitigate visual effects. Since there is no construction related activities associated with this Project, there will be no additional visual impacts. The Facility architectural structure was designed to minimize potential glare from outside lighting in the track staging area, contractor and employee parking lots. The facilities flare may be noticeable during night time hours. A plume from the cooling tower stack may be noticeable under certain atmospheric conditions (cold weather). The prevailing winds at the site vary from the north and northwest during the year, such that a plume of steam would be expected to travel to the south and southeast, across property. The plume, as currently operated, dissipates quickly. 16. Air: a. Stationary source emissions - Describe the type, sources, quantities and compositions of any emissions from stationary sources such as boilers or exhaust stacks. Include any hazardous air pollutants, criteria pollutants, and any greenhouse gases. Discuss effects to air quality including any sensitive receptors, human health or applicable regulatory criteria. Include a discussion of any methods used assess the project s effect on air quality and the results of that assessment. Identify pollution control equipment and other measures that will be taken to avoid, minimize, or mitigate adverse effects from stationary source emissions. The Facility includes mainly stationary emission sources that emit VOCs. In addition to VOC, the Facility emits emissions associated with the combustion of natural gas, various processes, storage tanks and cooling tower operation. VOC sources include fugitive emissions from pipe fittings/equipment leaks: as a result of equipment losses, there will be a release of VOCs to the ambient air, both inside and outside the buildings. In addition, the cooling tower will provide VOC stripping. Hydrochloric acid vapors will be emitted from the storage tank. Other emission sources include the vacuum pump and nitrogen blanket. Glenville Minnesota 13 Worksheet

16 VOC emissions from the production process and above ground storage tanks is collected and sent to the on-site flare for destruction. VOC emissions from the load out process and vacuum pump are also sent to the flare for VOC destruction. The flare captures 100% of the emissions for these sources, and has a destruction capacity of 98%. Facility Emissions: Pollutant Tons/Yr (Uncontrolled) Ton/Yr (Controlled) VOC CO CO2 18,931 18,931 Nitrous Oxide NOx PM PM PM SOx Methanol Total HAPs Ammonia a Lead 1.08E E-05 Mercury b 1.8E E-08 Methane Other HAP a Not evaluated for air permitting purposes. b Not included in air permitting analysis because values are less than 0.01 tpy. Ambient Air Quality Impacts - Air Dispersion Modeling. The U. S. Environmental Protection Agency ( EPA ) established ambient air quality standards for certain pollutants, called National Ambient Air Quality Standards ( NAAQS ). The standards represent the allowable amount of pollution per volume of air and are set to protect public health and the environment. No facility may cause or contribute to violations of these standards. Often air dispersion modeling is done to predict a facility s compliance with the standards. The Proposer conducted a Significant Impact Level ( SIL ) analysis using air dispersion modeling following an MPCA-approved modeling protocol. The EPA established the SILs for criteria pollutants with a NAAQS and typically 4-6% of NAAQS depending on the pollutant. SILs are a non-regulatory threshold and only used for evaluating the significance of an emission source or sources. The Proposer used AERMOD modeling software for the air dispersion modeling exercise. The EPA developed, validated, and approved AERMOD for air dispersion modeling. Applying worst-case hourly emissions allowed by the MPCA air permit to predict potential pollution levels in the air, pollutants with predicted levels below the EPA s SIL are screened out from further refined modeling as insignificant contributions. See Table 16-4 for the results of the Proposer s modeling. Glenville Minnesota 14 Worksheet

17 Table Project Modeled Impacts Pollutant Averaging Time Max Modeled Concentration (µg/m 3 ) SIL (µg/m 3 ) Air Quality Standard (µg/m 3 ) NO 2 1-hr Annual CO 1-hr ,000 8-hr ,000 PM hr Annual PM hr Annual SO 2 1-hr hr hr Annual Because the SIL was exceeded for PM 2.5, PM 10 and NO 2 the Proposer conducted refined air dispersion modeling for those criteria pollutants. Refined air dispersion modeling includes emissions from the Project, the Facility, nearby sources and a background concentration. The Proposer s refined modeling results predicted maximum modeled concentration did not exceed the EPA NAAQS standards for NO 2 (see Table 16-4). However, for PM 10 and PM 2.5 the results exceeded the EPA standard, thus prompting the MPCA to require the Proposer to do a culpability analysis. A culpability analysis breaks out the contributions to a modeled exceedance by each individual emissions source. If the sum of the contributions from Project s emissions sources is below the SIL, then the Project is determined to not be a culpable source to the modeled exceedance. The culpability analysis demonstrated that the Project contributed below the SIL for PM 10 and PM 2.5 (See Table 16.5 for modeled culpability results) to the predicted exceedances; therefore, the Facility is not a culpable source. These findings support the conclusion that the Project s cumulative air emissions do not have the potential for significant environmental effects on ambient air. Table 16-5 Pollutant Averaging Time REGs Max Contribution at Ambient Receptors showing Modeled Exceedances (µg/m 3 ) SIL (µg/m 3 ) PM hour Annual PM hour Annual The MPCA s modeling exercise conducted here measures cumulative predicted air concentrations. The MPCA must apply four criteria to determine whether a project s cumulative potential effects have the potential for significant environmental effects under Minn. R , subp. 7.B: Glenville Minnesota 15 Worksheet

18 Whether the cumulative potential effect is significant. Whether the contribution from the Project is significant when viewed in connection with other contributions to the cumulative potential effect. The degree to which the Project complies with approved mitigation measures specifically designed to address the cumulative potential effect. The efforts of the proposer to minimize the contributions from the Project. While the total cumulative modeled effect of PM 10 and PM 2.5 emissions exceeds the NAAQS, the contribution from the Project alone is below the SIL. Based upon the air dispersion modeling and culpability analysis the MPCA determined that air emissions from the Project do not have a potential for significant cumulative effects. b. Vehicle emissions - Describe the effect of the project s traffic generation on air emissions. Discuss the project s vehicle-related emissions effect on air quality. Identify measures (e.g. traffic operational improvements, diesel idling minimization plan) that will be taken to minimize or mitigate vehicle-related emissions. Particulate matter air emissions due to vehicles and railway engines are as follows. The Facility applies dust suppressant onto the roadways to minimize dust. Pollutant Uncontrolled Emissions (Tons per Year) Controlled Emissions (Tons per Year) PM PM PM c. Dust and odors - Describe sources, characteristics, duration, quantities, and intensity of dust and odors generated during project construction and operation. (Fugitive dust may be discussed under item 16a). Discuss the effect of dust and odors in the vicinity of the project including nearby sensitive receptors and quality of life. Identify measures that will be taken to minimize or mitigate the effects of dust and odors. Dust is generated by the vehicles that visit the site daily. The MPCA does not anticipate that dust and odors will cause adverse impacts to the surrounding facilities. The Facility is located approximately 1,500 feet from the nearest residence, and approximately one mile from the city of Glenville. The Facility applies dust suppressant onto the roadways to minimize dust. 17. Noise: Describe sources, characteristics, duration, quantities, and intensity of noise generated during project construction and operation. Discuss the effect of noise in the vicinity of the project including 1) existing noise levels/sources in the area, 2) nearby sensitive receptors, 3) conformance to state noise standards, and 4) quality of life. Identify measures that will be taken to minimize or mitigate the effects of noise. The majority of noise generated by the Facility operation is from machinery that is housed within the Facility s building structure. Noise generated within the plant will be less noticeable since it will originate inside of buildings. The majority of machinery that will be used outdoors will be similar to the adjacent industrial facility and similar to that normally found in agricultural operations Glenville Minnesota 16 Worksheet

19 (motorized vehicles, fans, pumps, etc.). The source of noise generated outside of the Facility is from traffic. 18. Transportation: a. Describe traffic-related aspects of project construction and operation. Include: 1) existing and proposed additional parking spaces, 2) estimated total average daily traffic generated, 3) estimated maximum peak hour traffic generated and time of occurrence, 4) indicate source of trip generation rates used in the estimates, and 5) availability of transit and/or other alternative transportation modes. 1) The Facility has 20 parking spaces. 2) Truck traffic at the Facility is, at a maximum, 5 trucks per hour between the hours of 7:00 a.m. and 3:00 p.m. 3) Peak traffic may be vehicles per day (including trucks and cars). The Facility is located south of State Highway 65 between Glenville and Albert Lea in southern Minnesota. Access for vehicles into the Facility is via an access road from existing County Highway 13 located east of the proposed site. This private access road was installed by an existing industrial facility currently located in the Glenville Industrial Park, and the access road was built to County specifications. The intersection of State Highway 65 and County Highway 13 is located in the central part of Glenville, Minnesota. Traffic on both State Highway 65 and County Highway 13 is relatively light and most traffic in the area occurs on Interstate 35W located approximately three miles northwest of the Facility. Warning lights for a railroad crossing at County Highway 13, and stop signs for the County Highway 13 crossing at State Highway 65 exist. Based on projected traffic for the Facility of approximately vehicles per day, improvements such as turn lanes, warning lights, or acceleration lanes may be installed if necessary to manage trucks entering and leaving the site. Such improvements will be installed as directed by Freeborn County Highway Engineers if traffic flow makes such improvements necessary. There is currently a Union Pacific Railroad railway siding at the adjacent Poet Industrial Facility. This railway siding enters the Poet site from the existing railway line located north of the property. The Facility utilizes this railway siding for the shipment of materials. b. Discuss the effect on traffic congestion on affected roads and describe any traffic improvements necessary. The analysis must discuss the project s impact on the regional transportation system. If the peak hour traffic generated exceeds 250 vehicles or the total daily trips exceeds 2,500, a traffic impact study must be prepared as part of the EAW. Use the format and procedures described in the Minnesota Department of Transportation s Access Management Manual, Chapter 5 (available at: or a similar local guidance, Traffic flow at the Facility is not anticipated to increase above what has been projected above. Glenville Minnesota 17 Worksheet

20 c. Identify measures that will be taken to minimize or mitigate project related transportation effects. N/A 19. Cumulative potential effects: (Preparers can leave this item blank if cumulative potential effects are addressed under the applicable EAW Items): a. Describe the geographic scales and timeframes of the project related environmental effects that could combine with other environmental effects resulting in cumulative potential effects. REG Environmental Services personnel conducted a search of both the city of Albert Lea Planning Department s new Project and 5-year planning documentation. The city of Albert Lea Planning Department has jurisdiction for Freeborn County, including the city of Glenville. According to the 2014 construction projects and the Capital Improvement Plan, there are no proposed projects that would have a cumulative effect with the proposed production increase for the Facility. In addition, a search of the MPCA public notices and other website sources has not indicated any proposed projects that would have a cumulative effect with the proposed REG Albert Lea production increase. Water Resources Water resources include the water found on the surface and below the ground. This Project does not include the construction or modification of any sources that would have a cumulative impact on groundwater or surface water. Groundwater Although there is an existing water appropriation permit for the Facility (Permit Number ), the proposed increase in production will not result in a need to modify the currently permitted withdrawal rate of 50.0 million gallons of water per year (Actual water usage to date in 2014 is 16.7 million gallons). Surface Water All surface water drains through a subsurface tile system that consists of farm tile buried in the ground that carries the water to a tile outlet in the field to the south of the property. Any surface runoff that does not drain through the tiling system flows across the surface to a catch pond in the northeast corner of County Road 13 and 780th Avenue or to a catch pond directly east of the property. Both of these ponds are owned by POET, which performs monthly water testing on the ponds. All waters drained from the tank farm after checking the ph prior to release flow through the same system. A small creek is located approximately a quarter mile west of the REG Albert Lea property. However, REG Albert Lea surface runoff is not directed towards that creek. Air Quality This Project includes the operation of equipment currently covered by the existing MPCA Air Emission Permit No The proposed Project does not include the addition of Glenville Minnesota 18 Worksheet

21 equipment or the modification of existing equipment. The proposed Project asks for the increase of the maximum production thru put of biodiesel from 31.5 MGY to 38.0 MGY. This proposed production increase will result a slight emissions increase as detailed in Table 1 below. This increase is the result of an increase in the annual storage tank throughput and an increase in truck traffic at the plant. Table 1 - Facility Emissions Pollutant Current Potential (TPY) Proposed Potential Emissions (TPY) Net Emissions Increase (TPY) PM a PM a PM a NO x b SO b CO b Ozone (VOC) c Lead CO 2 e 19,500 19,500 0 Methanol (HAP) c Total HAPs c a. Increase due to increase in truck traffic. b. Decrease due to using a different conversion factor to convert from lb/mmscf to lb/mmbtu from the previous permit action to the current permit action. Previously, a conversion factor of 1000 Btu/scf was used. This permit action uses a conversion factor of 1020 Btu/scf. The net emissions increase is reported as 0 because the decrease in potential emissions is only due to revision of a conversion factor and is not based on actual emissions. c. Emissions of these pollutants will increase due to an increase in tank throughput. However, the method for calculating emissions from equipment leaks was revised as part of the air permit action. This results in a facility-wide decrease in VOC, methanol and total HAP emissions. For the purposes of the EAW, the net emissions increase reported in Table 1 is the increase due to tank throughput. The proposed potential emissions reported in Table 1 use the new method for calculating emissions. Land Planning and Zoning The property is located outside of both Albert Lea and Glenville city limits. The property is currently zoned as industrial. Wildlife Habitat The proposed Project is on land that is already used for an industrial biodiesel production facility. There will not be any physical changes to the land associated with this Project. Therefore, the Project is not anticipated to have any adverse impacts on wildlife habitats. Glenville Minnesota 19 Worksheet

22 b. Describe any reasonably foreseeable future projects (for which a basis of expectation has been laid) that may interact with environmental effects of the proposed project within the geographic scales and timeframes identified above. There are no known future projects that may share the same geographic scale or timeframe of the proposed Project. c. Discuss the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects. The proposed Project is not expected to result in adverse cumulative impacts with other facilitate in the area. The location of the Facility maximizes the use of available equipment and infrastructure within the industrial park area. Air Quality The MPCA s culpability analysis concluded the Project is not culpable because its contribution to PM 10 and PM 2.5 does not have the potential for significant effects. These findings support the MPCA s conclusion that the Project does not have the potential for significant environmental effects. (See question #16a for more details.) When considering cumulative effects from nearby sources, the Proposer evaluated the MPCA s What s in My Neighborhood website which identified the following: a. Stormwater The following stormwater construction permit sites: CSW Site Subdivision Flying J Travel Plaza Tiger hills Development Sundance subdivision Tiger Hills Construction Chapeau Shores 6th Addition Lake Habben Business/Industrial Park Eagle s Rest Habben Pit Albert Lea Municipal Airport Lot 1, Block 1, pointe AL Sub (Construction Stormwater) Since REG Albert Lea has a non-exclusion permit for stormwater and there is no construction activities associated with the proposed Project, there will be no cumulative impact on stormwater associated with this Project. b. Storage Tanks The following 10 above ground and underground storage tank locations: Ulland Brother Inc Freeborn County Garage Vets Whoa N Go Albert Lea Main Lift Station Kibble Equipment Farm machinery and equipment manufacturing Naeve Fountain Centers Sorensen Brothers Mason Truck Lines Pro Manufacturing, Inc. Hecla Inc/Rathien House Glenville Minnesota 20 Worksheet

23

24 Meeker Hutchinson! McLeod Brown Sibley Nicollet Wright Blue Earth Carver Mankato! Le Sueur Hennepin Scott Waseca Rice Waseca! Anoka Minneapolis! St. Paul Ramsey! Faribault! Dakota Owatonna! Steele Washington Goodhue Dodge Red Wing! Wabasha Text Rochester! Olmsted Wabasha! Winona Legend ATTACHMENT A General Location Map! Cities Winona! Township County Miles Martin Faribault Freeborn Albert Lea! Austin! Mower Fillmore Houston Project Site

25 Topographic Map ATTACHMENT B Legend Miles REG Albert Lea - Facility Copyright: 2013 National Geographic Society, i-cubed

26 ATTACHMENT C. Site Map Eyewash / Shower Evacuation Rally Points HCL Berm Chemical Berm Marley Cooling Tower

27 Minnesota County Distribution of Federally-listed Threatened, Endangered, Proposed, and Candidate Species Revised October 2014 Species Status County Habitat Mammals ATTACHMENT D Canada lynx (Lynx canadensis) Threatened Aitkin, Beltrami, Carlton, Cass, Clearwater, Cook, Itasca, Koochiching, Lake, Lake of The Woods, Marshall, Pine, Roseau, St. Louis Northern forested areas Canada lynx (Lynx canadensis) Critical Habitat Cook, Koochiching, Lake, St. Louis Map of lynx critical habitat in Minnesota Northern long-eared bat Myotis septentrionalis Birds Proposed as Endangered Statewide Hibernates in caves and mines - swarming in surrounding wooded areas in autumn. Roosts and forages in upland forests during spring and summer. Piping plover (Charadrius melodus) Great Lakes Breeding Population Piping plover (Charadrius melodus) Northern Great Plains Breeding Population Endangered St. Louis County Sandy beaches, islands Threatened Lake of The Woods Sandy beaches, islands Piping plover (Charadrius melodus) Great Lakes Breeding Population Critical Habitat St. Louis County Piping plover (Charadrius melodus) Northern Great Plains Breeding Population Critical Habitat Lake of the Woods Map of Critical Habitat Unit (1- page PDF) Rufa Red knot (Calidris canutus rufa) Proposed Threatened St. Louis Coastal areas along Lake Superior Sprague's pipit (Anthus spragueii) Candidate Clay, Polk, and Roseau Large (>350 acre) patches of grassland - prefer native grassland, but also use non-native planted grasslands.

28 Minnesota Department of Natural Resources Division of Ecological and Water Resources, Box Lafayette Road ATTACHMENT E Phone: (651) St. Paul, Minnesota lisa.joyal@state.mn.us December 29, 2014 Correspondence # ERDB Ms. Julie Ingoli Renewable Energy Group 416 South Bell Avenue Ames, IA RE: Natural Heritage Review of the proposed Production Rate Increase; T101N R21W Section 1; Freeborn County Dear Ms. Ingoli, As requested, the above project has been reviewed for potential effects to known occurrences of rare features. A search of the Minnesota Natural Heritage Information System did identify rare features within an approximate one mile radius of the proposed project, but these records did not include any federally listed species and were either historical or not of concern given the project details that were provided with the data request form. As such, I do not believe the proposed project will adversely affect any known occurrences of rare features. The Natural Heritage Information System (NHIS), a collection of databases that contains information about Minnesota s rare natural features, is maintained by the Division of Ecological and Water Resources, Department of Natural Resources. The NHIS is continually updated as new information becomes available, and is the most complete source of data on Minnesota's rare or otherwise significant species, native plant communities, and other natural features. However, the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state. Therefore, ecologically significant features for which we have no records may exist within the project area. For environmental review purposes, the results of this Natural Heritage Review are valid for one year; the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form. Please contact me if project details change or if an updated review is needed. Furthermore, the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole. Instead, it identifies issues regarding known occurrences of rare features and potential effects to these rare features. Additional rare features for which we have no data may be present in the project area, or there may be other natural resource concerns associated with the proposed project. For these concerns, please contact your DNR Regional Ecologist (contact information available at Please be aware that additional site assessments or review may be required. Thank you for consulting us on this matter, and for your interest in preserving Minnesota's rare natural resources. An invoice will be mailed to you under separate cover. Sincerely, Samantha Bump Natural Heritage Review Specialist AN EQUAL OPPORTUNITY EMPLOYER

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