Minnesota Soybean Cooperative Oilseed and Refining Facility - Brewster

Transcription

1 August 30, 2002 TO: RE: INTERESTED PARTIES - Brewster Enclosed is the Worksheet (EAW) for the proposed Minnesota Soybean Cooperative Oilseed and Refining Facility - Brewster, Nobles County. The EAW was prepared by the Minnesota Pollution Control Agency (MPCA) and is being distributed for a 30-day review and comment period pursuant to the Environmental Quality Board (EQB) rules. The comment period will begin the day the EAW availability notice is published in the EQB Monitor, which will likely occur in the September 2, 2002, issue. Comments received on the EAW will be used by the MPCA in evaluating the potential for significant environmental effects from this project and deciding on the need for an Environmental Impact Statement (EIS). A final decision on the need for an EIS will be made by the MPCA Commissioner after the end of the comment period. If a request for an EIS is received during the comment period, or if the Commissioner recommends the preparation of an EIS, the nine-member MPCA Citizens Board (Board) will make the final decision. The final EIS need decision will also be made by the Board if so requested by the project proposer, other interested parties or MPCA staff and if this request is agreed to by one or more members of the Board or the MPCA Commissioner. The Board meets once a month, usually the fourth Tuesday of each month, at the MPCA office in St. Paul. Meetings are open to the public and interested persons may offer testimony on Board agenda items. A listing of Board members is available on request by calling (651) In addition, the public notice announcement for the air emission permit is enclosed. The permit public comment period asks for comments or petitions on the air emissions from the proposed facility. This is a separate public comment process from the EAW. The air emission permit s public notice is limited in scope to the proposed facility s air emissions. The permit s public comment period begins on September 3, 2002, and is open for 30 days. All comments on the permit must be received within the 30- day public comment period to be considered. There are four formal procedures for public participation in the MPCA s consideration of the permit application. The enclosed public notice announcement for the air emission permit explains how to utilize these procedures. The permit cannot be issued, however, until the environmental review process has concluded. Please note that comment letters submitted to the MPCA do become public documents and will be part of the official public record for this project.

2 INTERESTED PARTIES Page Two If you have any questions on the EAW, please contact Barbara Conti of my staff at (651) Sincerely, Beth G. Lockwood Supervisor, Environmental Review Unit Operations and Environmental Review Section Regional Environmental Management Division BGL:sjs Enclosures

3 ENVIRONMENTAL ASSESSMENT WORKSHEET Note to reviewers: The Worksheet (EAW) provides information about a project that may have the potential for significant environmental effects. This EAW was prepared by the Minnesota Pollution Control Agency (MPCA), acting as the Responsible Governmental Unit (RGU), to determine whether an Environmental Impact Statement (EIS) should be prepared. The project proposer supplied reasonably accessible data for, but did not complete the final worksheet. Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) Monitor. Comments on the EAW should address the accuracy and completeness of information, potential impacts that are reasonably expected to occur that warrant further investigation, and the need for an EIS. A copy of the EAW may be obtained from the MPCA by calling (651) An electronic version of the completed EAW is available at the MPCA Web site 1. Project Title: Minnesota Soybean Processors Cooperative Oilseed Processing Facility Brewster 2. Proposer: Minnesota Soybean Cooperative 3. RGU: Minnesota Pollution Control Agency Contact Person John Prohaska Contact Person Barbara Jean Conti and Title Engineering Coordinator and Title Project Manager Address 100 Caspian Street Address 520 Lafayette Road North Volga, SD St. Paul, Minnesota Phone (605) Phone (651) Fax (605) Fax (651) jprohask@sdsbp.com Fax barbara.conti@pca.state.mn.us 4. Reason for EAW Preparation: EIS Scoping Mandatory EAW X Citizen Petition RGU Discretion Proposer Volunteered If EAW or EIS is mandatory give EQB rule category subpart number and name: Subp. 15.A. Air Pollution 5. Project Location: County Nobles City/Twp Brewster SE ¼ Section 24 Township 103 Range 39 Tables, Figures, and Appendices attached to the EAW: Figure 1. County map showing the general location of the project; Figure 2. United States Geological Survey 7.5 minute, 1:24,000 scale map indicating project boundaries; Figure 3. Site plan showing all significant project and natural features; and Figure 4. Minnesota Department of Natural Resources (DNR) Natural Heritage Review Letter. TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing 30% fibers from paper recycled by consumers

4 6. Description: a. Provide a project summary of 50 words or less to be published in the EQB Monitor. Minnesota Soybean Processors (MnSP) proposes to construct a soybean oil extraction and refining facility (facility) located in Brewster, Minnesota (City). The proposed capacity of the facility would be 3,000 tons per day (tpd). The crude soybean oil would be refined into various products for human consumption or made into biodiesel, a replacement fuel. Air emissions would include particulate matter (dust), volatile organic compounds (VOC), and hexane. The facility s draft air emission permit will also be open for public comment. The MPCA permit contact person is Bruce Braaten, (507) Wastewater would be treated at the City s wastewater treatment facility (WWTF). b. Give a complete description of the proposed project and related new construction. Attach additional sheets as necessary. Emphasize construction, operation methods and features that will cause physical manipulation of the environment or will produce wastes. Include modifications to existing equipment or industrial processes and significant demolition, removal or remodeling of existing structures. Indicate the timing and duration of construction activities. Proposed Project MnSP proposes to construct a soybean oil extraction facility located in Brewster, Minnesota. The proposed capacity of the facility would be 3,000 tpd. Site Description The proposed project site is a triangular property in the northeast portion of the City. Minnesota Highway 60 borders the site on the northwest side. A set of tracks from the Union Pacific Railroad runs parallel to the highway and between the highway and the property. The east boundary of the property is the border with Jackson County (see Figure 2). Most of the proposed site is currently used for crop farming. The total site area is approximately 60 acres. Of that total, approximately 30 acres would be impervious surfaces and approximately 21 acres would be grass or brush areas. The plant and associated buildings, driveways, truck parking, etc. would cover the majority of the property (see Figure 3). Power lines would be brought to the site along with an electrical substation. Fresh water would be piped from the City. Wastewater, both domestic and process, would be discharged to the City s WWTF. A spur line would be split from the present railroad line that runs along the northeast edge of the property to the proposed facility. Process Description The proposed facility would receive raw soybeans and process them, extracting crude soybean oil from the beans. By-products of the oil processing are soy meal and hulls, which are sold for animal feed. Soybeans would be delivered from the local farmers or grain storage facilities by semi-trailer truck. The soybeans are off-loaded and stored in grain elevators. Storage is planned to be 2.3 million bushels. From storage, the beans are sent to a screening and cleaning area in the preparation building where trash accompanying the beans is removed. From there, the beans are routed to the dehulling process. The hull of the bean would be ground. The ground soybean hulls are usually formed into a pellet and eventually Brewster, Minnesota 2 Worksheet

5 sold as animal feed. The meat of the bean is cracked into larger chunks, conditioned (heated) and then pressed into a flake or extruded as a pellet. These materials are then sent to the extraction building. The flakes are washed in the extraction building with a solvent, commercial hexane, to strip the oil from the flakes. The mixture of solids and solvent are separated. The solids, which are still laden with hexane, are sent to a meal desolventizer where they are heated and the solvent is volatilized. The solvent-free solids are then cooled, ground, and stored as meal. This meal is later sold as animal feed. The liquid removed from the solids consists of hexane, soybean oil, and water and is called the miscella. The miscella is separated into its components using distillation. The hexane is reused, the water disposed of, and the oil, termed crude oil, is stored. The crude oil would be shipped offsite and refined into various products. The products of meal, oil, and biodiesel would be shipped from the facility by rail and truck. Besides receiving, preparation, and extraction there would be other facilities at the plant. There would be a weigh station, offices and a lab, a steam generation plant, maintenance, and warehousing. The steam plant would use primarily natural gas with No. 2 fuel oil as back up. Construction Major construction is expected to commence in Fall 2002 with facility start-up in c. 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 help meet the demand for soybean products. This facility would provide processing close to producers and would have access to established transportation systems. d. Are future stages of this development including development on any outlots planned or likely to happen? Yes No If yes, briefly describe future stages, relationship to present project, timeline and plans for environmental review. The project proposer believes that the market for soybean products would continue to grow. If so, the plant would likely expand to 4,200 tpd to keep pace with the continued growth of that market. In addition, the facility may add the capability to formulate biodiesel fuel. The timing of such an expansion is unknown at present. The need for additional environmental review would be evaluated when or if an expansion is planned. e. Is this project a subsequent stage of an earlier project? Yes No If yes, briefly describe the past development, timeline and any past environmental review. A vegetable oil storage tank built by South Dakota Soybean Processors (SDSP) is adjacent to the project site. MnSP is a separate cooperative and its project was determined not to be a subsequent stage of the SDSP tank project. Brewster, Minnesota 3 Worksheet

6 7. Project Magnitude Data Total Project Area (acres) 60 or Length (miles) Number of Residential Units: Unattached Attached maximum units per building Commercial/Industrial/Institutional Building Area (gross floor space): total square feet Indicate area of specific uses (in square feet): Office 9,750 Manufacturing Retail Other Industrial 61,680 Warehouse 11,220 Institutional Light Industrial Agricultural Other Commercial (specify) 7488 (Shop, pumphouse, cooling tower) Building height see below If over 2 stories, compare to heights of nearby buildings The building heights vary from 15 feet to 97 feet. The height of the main building would be about 90 feet. The height of the tallest stack would be 120 feet. The closest business is the oil storage tank owned by SDSP. This tank is about 50 feet in height. Presently there is a grain elevator located ¼ of a mile southwest of the site. With its superstructure, it stands approximately 180 feet tall. There is a water tower within the City, about ½ mile from the site, which stands 140 feet in height. Building Height in feet Office/Lab 16 Receiving 35 Grain storage 97 Steam plant 35 Load-out 40 Meal storage 95 Preparation 90 Extraction 80 Pumphouse 15 Shop 25 Cooling tower Permits and approvals required. List all known local, state and federal permits, approvals 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. Unit of Government Type of Application Status U.S. Environmental Protection Agency (EPA) Spill prevention, control and countermeasure plan In preparation EPA Hazardous Waste Generator Identification Number To be submitted MPCA Air emissions permit Drafted and scheduled for public notice on September 3, 2002 MPCA Above ground storage tank registration over 110 gals To be submitted MPCA Sanitary sewer permit To be submitted Unit of Government Type of Application Status Brewster, Minnesota 4 Worksheet

7 MPCA Construction stormwater permit To be obtained prior to construction MPCA Stormwater discharge permit To be obtained prior to operation MPCA Spill response plan In process MPCA Very small quantity Hazardous Generator license To be submitted Heron Lake Watershed District Permit In preparation - comply with reporting City of Brewster Grading and Building permits To be obtained prior to construction City of Brewster Wastewater discharge permit To be obtained prior to operation City of Brewster Utility permits In process Fire Marshall (State and Local) Plan approval To be determined Public Funding US RDA grant In place 9. Land use. Describe current and recent past land use and development on the site and on adjacent lands. Discuss project compatibility with adjacent and nearby land uses. Indicate whether any potential conflicts involve environmental matters. Identify any potential environmental hazards due to past site uses, such as soil contamination or abandoned storage tanks, or proximity to nearby hazardous liquid or gas pipelines. The proposed site is presently zoned by Nobles County as Agricultural. The land on and around the site is agricultural and has been for over 50 years. The proposed site has been annexed by the City. An auto repair facility is on the west side of the proposed site. This repair facility and associated land is about 2 acres. Northeast of the proposed site is a large tank, spill containment area and run-off retention pond belonging to SDSP. This tank and associated structures take up about 20 acres. Approximately ¼ mile southwest of the site and along the railroad tracks is a grain elevator that stores and ships grain. The western corner of the proposed project site is within one-quarter mile of a residential area in the City. In addition to the City, there are approximately 4 homesteads within a one-mile radius around the site. Other than buried drain tile, there are no known utilities that cross the site. There are no past land uses known to result in any environmental hazards on the site. 10. Cover Types. Estimate the acreage of the site with each of the following cover types before and after development: Before After Before After Types 1-8 wetlands 0 0 Lawn/landscaping 0 5 Wooded/forest 0 0 Impervious Surfaces 0 30 Brush/grassland Other (storm water Cropland 60 0 detention basin) TOTAL Brewster, Minnesota 5 Worksheet

8 11. Fish, Wildlife, and Ecologically Sensitive Resources. a. Identify fish and wildlife resources and habitats on or near the site and describe how they would be affected by the project. Describe any measures to be taken to minimize or avoid impacts. No significant fish or wildlife resources are known to exist on or near the site. b. Are any state (endangered or threatened) species, rare plant communities or other sensitive ecological resources such as native prairie habitat, colonial waterbird nesting colonies or regionally rare plant communities on or near the site? Yes No If yes, describe the resource and how it would be affected by the project. Indicate if a site survey of the resources has been conducted and describe the results. If the DNR Natural Heritage and Nongame Research program has been contacted give the correspondence reference number. ERDB Describe measures to minimize or avoid adverse impacts. The DNR Natural Heritage database review found three known occurrences of rare species or natural communities within approximately one mile of the project site. Several prairie remnants ranked as very good were found just outside the project limits and along the railroad. The DNR recommended that the project proposer implement several measures to ensure the prairie is protected. These measures include: notifying construction crews not to drive, park, or stockpile equipment in prairie areas; preventing runoff from the site to the prairie; and planting areas adjacent to the prairie areas with prairie species native to Minnesota or some other non-invasive cover. Impacts on the prairie remnants are not expected from the proposed project because no rare features are along the railroad right-of-way that is adjacent to the proposed project. The project proposer has indicated that only work related to the construction of the rail spur would be in the railroad right-ofway along the project boundary. No materials storage or construction vehicles are expected in the rights-of-way during construction of the buildings or tanks. 12. Physical Impacts on Water Resources. Will the project involve the physical or hydrologic alteration (dredging, filling, stream diversion, outfall structure, diking, and impoundment) of any surface waters such as a lake, pond, wetland, stream or drainage ditch? Yes No If yes, identify water resource affected. Describe alternatives considered and proposed mitigation measures to minimize impacts. Give the DNR Protected Waters Inventory (PWI) number(s) if the water resources affected are on the PWI. The proposed project includes a grading and surface water control plan that would direct surface water drainage from the facility into a sedimentation pond. Surface water runoff from the facility would increase above that of the natural ground surface, as the improved surface (gravel and pavement) would have a lower infiltration rate than the natural soil/vegetative ground surface. Potential impacts from the facility are minimized by construction of the surface water drainage controls as designed and through implementation of best management practices (BMPs) of vehicles, equipment, site maintenance, National Pollutant Discharge Elimination System (NPDES) permitting, and completion of Stormwater Pollution Prevention Plans as are required for this type of facility. Brewster, Minnesota 6 Worksheet

9 13. Water Use. Will the project involve installation or abandonment of any water wells, connection to or changes in any public water supply or appropriation of any ground or surface water (including dewatering)? Yes No If yes, as applicable, give location and purpose of any new wells; public supply affected, changes to be made, and water quantities to be used; the source, duration, quantity and purpose of any appropriations; and unique well numbers and DNR appropriation permit numbers, if known. Identify any existing and new wells on the site map. If there are no wells known on site, explain methodology used to determine. A water supply would be required from the City for the proposed facility for processing of soybeans and for potable and sanitary purposes. The proposer estimates the water requirements for the facility at approximately 600,000 gallons per day (gpd) at a rate up to 600 gallons per minute (gpm). Water use would be for the soybean processing season or approximately 310 days per year. Water use in excess of 10,000 gpd or 1,000,000 gallons per year requires a Water Appropriation Permit from the Minnesota DNR. The specific source of the proposed water supply has not been identified. Water usage estimates by MnSP are based on rates for similar facilities. The MnSP facility would install a Minimum Waste Water Discharge System that would reuse wastewater in the plant processes. This system would save approximately 35 gpm and has been considered in the City s water allocation request. The cooling tower will recycle water approximately three times before that water would need to be discharged. The City s permit application is expected to request an annual appropriation of 200 million gallons per year at a rate of up to 600 gpm to serve the facility. MnSP is currently in the process of investigating potential water supply sources in conjunction with the City and Nobles County. At this time, a preliminary water supply investigation has been completed and a meeting with the City is scheduled to discuss the results and to initiate the next phase of investigation. This investigation is centered on the 56 square miles surrounding the City and is designed to investigate the possibility for developing the required water supply as an expansion of the City s existing system. This includes assessing the possibilities for obtaining more supply capacity from the aquifer currently utilized by the City and identification and development of potential new groundwater sources. It is expected that subsequent phases of work would be directed towards delineation of potential buried drift aquifers through the use of surface geophysics, test drilling, and aquifer testing. The potential for a sandstone bedrock aquifer may also be assessed during the test drilling and aquifer testing procedures. Other potential sources of water supply include a buried drift aquifer approximately 3 miles west of the City that was identified and previously tested by Worthington Public Utilities (WPU). At that time, it was determined that estimated available quantities of water would not make the project economically feasible for WPU. However, this source may be feasible for other water suppliers requiring lesser quantities of water. The maximum yield of this aquifer has not yet been determined. Other efforts are also underway to identify and develop additional water resources on a regional Southwest Minnesota basis that may eventually result in the availability of a rural water supply in this area. Test drilling for this project is currently underway. However, it would likely be years before any water from those alternatives would be available. 14. Water-related land use management districts. Does any part of the project involve a shoreland zoning district, a delineated 100-year flood plain, or a state or federally designated wild or scenic river land use district? Yes No If yes, identify the district and discuss project compatibility with district land use restrictions. Brewster, Minnesota 7 Worksheet

10 15. Water Surface Use. Will the project change the number or type of watercraft on any water body? Yes No If yes, indicate the current and projected watercraft usage and discuss any potential overcrowding or conflicts with other uses. 16. Erosion and Sedimentation. Give the acreage to be graded or excavated and the cubic yards of soil to be moved: 40 acres; 200,00 cubic yards. Describe any steep slopes or highly erodible soils and identify them on the site map. Describe any erosion and sedimentation control measures to be used during and after project construction. The project site is relatively level, with a difference in elevation throughout of about 10 feet. Steep slopes or highly erodible soils are not present. The building pad areas would be leveled. However, the remainder of the site is not anticipated to require extensive grading. A general permit for the discharge of construction storm water is required when five or more acres are disturbed. BMPs would be employed during construction to minimize or prevent erosion or sedimentation. BMPs may include surface water runoff controls, such as silt fencing and hay bales. If ten or more acres are disturbed by construction, and all drain to a discernible discharge point, a temporary detention pond may be required. A storm water detention pond will be used for sedimentation control. MnSP would coordinate with the City and the MPCA to protect water resources from storm water impacts related to project development, change in land use, or changed ground cover as required to meet Minnesota Rules. Erosion and sedimentation control would be accomplished by replacing vegetation in areas disturbed by construction activities as soon as possible. Some areas would be paved or covered with gravel. 17. Water Quality Surface Water Runoff. a. Compare the quantity and quality of site runoff before and after the project. Describe permanent controls to manage or treat runoff. Describe any storm water pollution prevention plans. Judicial Ditch No. 76 has two drain tiles that run near the proposed site. One is northwest of the site paralleling Minnesota Highway 60 along its northwest side. The Branch Kll from this tile goes under Highway 60 and touches the northeast corner of the site from the east. The other portion of Judicial Ditch No. 76 is south of the property, running parallel to Nobles County Highway 414 on its south side. Branch K10 from this tile touches the Southwest corner of the site. The site would remain relatively flat after construction. About 30 acres of new impervious surfaces would be added (pavement, gravel or buildings). Vegetation would be established on the remaining acres as soon as practical. MnSP plans to have the 30 acres of new impervious surfaces surrounded by bands of managed perennial cover grasses that would act as a filter strip for runoff. Chemical storage area at the site would have secondary containment. For permanent storm water management, MnSP would construct a detention pond. This pond would settle solids prior to a controlled release. The release would be to the existing drainage system. A permanent pond would have to meet the requirements of the MPCA s general permit, as well as any local requirements. With the implementation of the storm water control pond, no significant change is expected in the quality of the runoff from the overall site. The quantity of runoff may be reduced due to some runoff being held by the detention pond. Brewster, Minnesota 8 Worksheet

11 In addition to storm water management, mitigative measures to prevent and/or control contaminant release are required. These include BMPs and compliance with local, state and federal regulations. Such regulations include preparation of an NPDES permit and development of a Stormwater Pollution Prevention Plan (SWPPP). The preparation of a SWPPP is a requirement of the State of Minnesota General Storm Water NPDES Permit that would be required for the proposed project. The SWPPP includes identification of all potential surface water pollutant sources and written procedures for the implementation of best management practices to protect from potential contaminant sources. Potential contaminants may include oils, grease, maintenance chemicals, fuel storage, product additives/admixtures, and sediment. BMPs include non-structural measures such as general housekeeping, regular facility inspections, preventative maintenance and spill prevention, and response training. Structural measures such as installation of spill controls and erosion/sedimentation controls, secondary containment for above ground storage tanks are also included. Additional requirements of the NPDES Permit include annual reporting, record keeping, and employee training. b. Identify routes and receiving water bodies for runoff from the site; include major downstream water bodies as well as the immediate receiving waters. Estimate impact runoff on the quality of receiving waters. Runoff from the site would either drain to the Judicial Ditch or to Elk Creek, which drains into Okebena Creek as part of the Heron Lake Watershed. This eventually drains into Heron Lake. No significant impact on the quality of the receiving waters is expected to occur from surface water runoff from the site. 18. Water Quality Wastewater. a. Describe sources, composition and quantities of all sanitary, municipal and industrial wastewater produced or treated at the site. The proposed facility would discharge its wastewater to the City s WWTF. The City proposes to expand its WWTF to have additional capacity to process MnSP s wastewater flow. The proposed expansion of the WWTF is currently under review (EAW public notice started August 5, 2002). The discharges from the proposed soybean plant are as follows: Wastewater Source Outfall in gpm Plant washdown 25 Boiler blowdown 24 Extraction process water 65 Bathroom/Showers 30 Discharge of non-contact cooling tower water after recycling is included in the process water numbers. No chromium is used in the cooling tower or other processes. Chemicals used in the boilers include ph balancers, anti-scalants, and sodium bisulfate to treat chlorine in the water. Brewster, Minnesota 9 Worksheet

12 b. Describe waste treatment methods or pollution prevention efforts and give estimates of composition after treatment. Identify receiving waters, including major downstream water bodies, and estimate the discharge impact on the quality of receiving waters. If the project involves on-site sewage systems, discuss the suitability of site conditions for such systems. The anticipated wastewater composition from the plant is noted below. Wastewater would be routed to an on-site lift station and then pumped through 4,500 feet of force main to the City s WWTF. The lift station would be capable of recording flow information. Sampling would be possible both at the lift station and at the discharge into the City s WWTF. Component Prep/Ext Temp (F) 70 Biochemical Oxygen Demand milligrams per liter (mg/l) 1200 Total Suspended Solids (mg/l) 14 Total Dissolved Solids (mg/l) 1070 Fat/Oil/Grease 6.5 The City proposes to add wastewater treatment capacity to accept the soybean facility s discharge. The City proposes to direct the soybean plant s wastewater to an aerated treatment pond. The aerated pond would handle only MnSP wastewater. After the MnSP wastewater is treated, it would be discharged with the City s treated domestic wastewater in the spring and fall. Handling the plant wastewater in this way would also avoid routing the industry wastewater through the community, which can sometimes result in odor complaints. Phosphorus is a concern since the receiving stream for the City s treatment facility flows into Heron Lake. Heron Lake is impaired due to excess nutrients and algal growth. The proposed permit for the City s WWTF would include a phosphorus limit of 1 mg/l. c. If wastes will be discharged into a publicly owned treatment facility, identify the facility, describe any pretreatment provisions and discuss the facility s ability to handle the volume and composition of wastes, identifying any improvements necessary. MnSP s industrial wastewater would be pretreated at the City s wastewater treatment facility prior to being intermixed with the City wastewater. Pretreatment would be accomplished in aerated lagoons, which would reduce the strength of the industry wastewater to near that domestic wastewater. The City has a three-celled lagoon system sized to store all wastewater flows between spring and fall discharges. This lagoon system would need to be expanded significantly to handle the additional hydraulic loading from the soybean plant. Two new cells are proposed as well as raising the dikes on the existing cells one-foot to provide the additional storage required. The proposed expansion of the City s WWTF was described in a separate EAW, as noted above. d. If the project requires disposal of liquid animal manure, describe disposal technique and location and discuss capacity to handle the volume and composition of manure. Identify any improvements necessary. Describe any required setbacks for land disposal systems. Not applicable. Brewster, Minnesota 10 Worksheet

13 19. Geologic hazards and soil conditions. a. Approximate depth (in feet) to Ground water: 15 minimum; 50 average. Bedrock: 170 minimum; 260 average. Describe any of the following geologic site hazards to ground water and also identify them on the site map: sinkholes, shallow limestone formations or karst conditions. Describe measures to avoid or minimize environmental problems due to any of these hazards. There are no known sinkholes, shallow limestone formation, or karst features associated with the facility location or the general area. b. Describe the soils on the site, giving SCS classifications, if known. Discuss soil granularity and potential for groundwater contamination from wastes or chemicals spread or spilled onto the soils. Discuss any mitigation measures to prevent such contamination. Soil information for the area of the facility was obtained from the 1981 New Ulm Sheet of the Minnesota Soil Atlas series. The area of the site lies within the clayey portion of the Blue Earth Till Plain. Dominant soil types are Marna, Lura, and Webster series, which are silty clay loam to silty clay soils formed from the silty clayey glacial till. These soils are typically dark colored and poorly to very poorly drained. The nature of the clayey soil types at the proposed facility site would tend to decrease the potential for groundwater contamination from a release. Item 17 includes information on spill management. 20. Solid Wastes, Hazardous Wastes, Storage Tanks. a. Describe types, amounts and compositions of solid or hazardous wastes, including solid animal manure, sludge and ash, produced during construction and operation. Identify method and location of disposal. For projects generating municipal solid waste, indicate if there is a source separation plan; describe how the project will be modified for recycling. If hazardous waste is generated, indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments. Construction materials, including solid wastes or hazardous materials, would be managed in accordance with local, state, or federal requirements. MnSP has indicated that the general contractor would be responsible for minimizing construction materials and debris and that MnSP would monitor the contractor. Solid wastes generated at the facility during operation, including office waste, packing, etc., would be managed and removed by a licensed solid waste hauler. As appropriate, materials would be recycled to the extent possible. Hazardous wastes generated from the facility operations include solvents used for parts cleaning and laboratory wastes. Waste lubricating oils from the plant are recycled. Lab waste, consisting of waste chemicals, would be refined and reused. Still wastes are collected. These wastes are stored in steel barrels for transportation, via a licensed hauler, to a commercial recycler. Hazardous waste quantities generation at the facility is expected to be similar to other soybean facilities in Minnesota, approximately 200 gallons of parts cleaner and approximately 450 gallons of still bottoms. Brewster, Minnesota 11 Worksheet

14 b. Identify any toxic or hazardous materials to be used or present at the site and identify measures to be used to prevent them from contaminating groundwater. If the use of toxic or hazardous materials will lead to a regulated waste, discharge or emission, discuss any alternatives considered to minimize or eliminate the waste, discharge or emission. The following major process toxic or hazardous materials would be present at the site. The major chemicals used are commercial hexane, fuel oil, methanol, sodium hydroxide, phosphoric acid, and hydrogen peroxide. Hexane and methanol are flammable liquids. Hexane vapors can be explosive. Proper storage and handling would minimize these risks. Item 20.c. has storage and tank information for the remainder of these materials. In addition, small amounts of laboratory and maintenance products that may be considered hazardous would be used, hauled, and disposed of appropriately. Storage tanks for most of these materials are located above ground within containment areas, as required. Typical containment consists of either earthen dikes or concrete containment walls and floors capable of containing 110 percent of the volume of the largest tank. The secondary containment system also controls stormwater run-off. c. Indicate the number, location, size and use of any above or below ground tanks to store petroleum products or other materials, except water. Describe any emergency response containment plans. A Spill Prevention, Control, and Containment Plan would be developed and implemented for emergency containment. All tanks would have spill containment areas as described above to meet MPCA permit requirements. Tank/Description No. 2 Fuel Oil Vegetable Oil storage Shift oil tanks Hexane tanks Caustic Mineral oil Phosphoric acid Hydrogen peroxide Capacity 2 16,700 gallons each MM gallons each 4 22,800 gallons each 4 12,500 gallons each 1 8,000 gallons 1 12,000 gallons 1 8,000 gallons 1 12,000 gallons 21. Traffic. Parking spaces added: Existing spaces (if project involves expansion): Estimated total average daily traffic generated: trucks (one-way) and cars (one-way) Estimated maximum peak hour traffic generated (if known) and its timing: M-F: 90 percent between 6:00 am and 5:00 pm and 5 percent between 5:00 pm and 6:00 am Weekends: 5 percent Provide an estimate of the impact on traffic congestion affected roads and describe any traffic improvements necessary. If the project is within the Twin Cities metropolitan area, discuss its impact on the regional transportation system. Truck traffic to the site would be routed to State Highway 60 or County Road 1. Highway 60 has Annual Average Daily Traffic (AADT) on the southwest edge of the City of 4,500. On the northern edge of the City it has an AADT of 4,050. County Road 1 has an AADT of 950 north of Highway 60 and 2,500 south of Highway 60. Brewster, Minnesota 12 Worksheet

15 While the frequency of trains may not change as a result of the proposed project, the number of train cars may increase. There will also be switches of rail cars on or off the MnSP rail spur. 22. Vehicle-related Air Emissions. Estimate the effect of the project s traffic generation on air quality, including carbon monoxide levels. Discuss the effect of traffic improvements or other mitigation measures on air quality impacts. Note: If the project involves 500 or more parking spaces, consult EAW Guidelines about whether a detailed air quality analysis is needed. Air emissions from vehicles were considered in the detailed air quality computer modeling conducted for the facility. The majority of the traffic increase consists of truck traffic that uses diesel fuel. The two pollutants for which vehicle-related air emissions were evaluated were particulates less than 10 microns (PM 10 ) and nitrogen oxides (NOx). For PM 10, the model considered both vehicle exhaust and fugitive dust from driving on the roads. All roads at the facility would be paved to reduce fugitive dust emissions from traffic. The modeling results showed that emission of PM 10 and NOx from vehicles met federal Prevention of Significant Deterioration (PSD) increment standards and state and federal ambient air quality standards. Ambient air quality standards limit the concentrations of a pollutant that can be in the air to protect health and welfare. Carbon monoxide (CO) levels around the facility are not expected to increase significantly. The majority of the carbon monoxide emissions would occur from the two 90 Million British Thermal Units per hour (BTU/hr) boilers used for generating steam. Emissions from these two boilers were less than PSD de minimus levels for CO. 23. Stationary Source Air Emissions. Describe the type, sources, quantities and compositions of any emissions from stationary sources of air emissions such as boilers, exhaust stacks or fugitive dust sources. Include any hazardous air pollutants (consult EAW Guidelines for a listing), any greenhouse gases (such as carbon dioxide, methane, and nitrous oxides), and ozone-depleting chemicals (chlorofluorocarbons, hydrofluorocarbons, perfluorocarbons or sulfur hexafluoride). Also describe any proposed pollution prevention techniques and proposed air pollution control devices. Describe the impacts on air quality. The proposed facility would be a major new source of air emissions with respect to federal PSD Part 70 permit regulations. The potential maximum emissions for the facility under the proposed permit are summarized below. These emissions represent the maximum emissions for the initial year of operation. Following a six-month shakedown period, more stringent emission limits will apply under the National Emission Standard for Hazardous Air Pollutants for Vegetable Oil Extraction. Therefore, subsequent years VOC and Hazardous Air Pollutants (HAPs) emissions will be lower than the totals listed below. The HAPs emissions are primarily n-hexane. Less than one ton per year of HAPs would be from combustion byproducts. Pollutant Amount (tons per year) Particulate matter (PM) 244 PM Sulfur oxides (SOx) 22 NOx 69 VOC 1085 CO 66 HAPs 949 Brewster, Minnesota 13 Worksheet

16 The following are groups of equipment that will emit regulated air pollutants: Headhouse Particulate emissions: Receiving pits and conveyors. Preparation Particulate emissions: Screeners, pod grinders, aspirators, crackers, heaters, hull grinders, conveyors, pelletizers, coolers, expanders, flakers. Solvent Extraction VOC and particulates: Extractors, desolventizers, MOS, reboilers, work tank. Meal Preparation Particulate emissions: Meal conveyors, grinders, loadout. Steam Plant The boilers emit PM, VOCs, PM 10, sulfur dioxide, NO x, and CO. The project is subject to state and federal PSD requirements because the facility qualifies as a major stationary source under the PSD rules as defined in 40 CFR 52.21(b)(1)(i). As a major stationary source subject to PSD review, Minnesota Soybean Processors must satisfy the following requirements specified in 40 CFR 52.21, which include the following: Apply Best Available Control Technology (BACT) to control emissions of each regulated pollutant for which the potential emissions exceed the PSD de minimus threshold; Perform air emission dispersion modeling to demonstrate that the potential emissions will not cause or contribute to an exceedance of the National Ambient Air Quality Standard (NAAQS) or PSD Increment Standard; Evaluate the impact of air, ground, and water pollution on soils, vegetation, and visibility caused by emissions from the facility and from associated growth; and The two 90 Million BTU/hr boilers at the facility will each be equipped with dry low-nox burners and flue-gas recirculation devices to control emissions of NOx. The BACT evaluation resulted in controls and emission limits being placed on many of the processes at the proposed facility. Most process equipment that generates particulates (dust) would be controlled with fabric filters. Certain other sources of dust would not have fabric filters. Those would instead have cyclones that are inherent to the process equipment. Cyclones would be used for processes that have exhaust streams with high moisture contents, such as grain drying and conveying, hot dehulling, flaking, and pellet cooling. Particulate emissions from the cooling tower and soybean storage pile are also controlled to a level consistent with BACT. This includes high efficiency drift eliminators for the cooling tower and best management practices to minimize dust generation for the storage pile. In addition, the facility is a major source of HAPs and is required to comply with the National Emission Standard for Hazardous Air Pollutants for Solvent Extraction for Vegetable Oil Production. This standard establishes emission limits and other monitoring, record keeping, and reporting requirements designed to limit emissions of n-hexane, the solvent used to extract oil from the soybeans. Brewster, Minnesota 14 Worksheet

17 Air dispersion modeling of the MnSP facility was performed for PM, PM10, NOx and hexane. Emissions from the proposed facility were added to background concentrations except for hexane. Background concentrations represent the amount of the pollutants already in the air. Those amounts were taken from monitoring data from other parts of the state. As noted in Item 23, the model also considered the impacts from truck exhaust and fugitive dust emissions from traffic. The air modeling results show whether the predicted concentrations in the air of these compounds would meet state and federal air quality requirements. These requirements include: 1) federal PSD increment standards; 2) NAAQS; 3) Minnesota Ambient Air Quality Standards (MAAQS); and 4) the Minnesota Department of Health s n-hexane Health Risk Value. PSD increment standards are regulations that are designed to limit degradation of air quality in areas that currently have clean air. The modeling indicated that the concentrations of PM, PM 10, NOx and n-hexane were below the applicable standard or health risk value. No significant impacts on health or welfare would therefore be expected from these four pollutants. A summary of the projected impacts from the facility is provided in the table below: MINNESOTA SOYBEAN PROCESSORS AMBIENT AIR IMPACTS AND AMBIENT AIR QUALITY STANDARDS NO x PM 10 n-hexane Impact Annual Average (µg/m 3 ) a 24-Hour Average (µg/m 3 ) Annual Average (µg/m 3 ) a Annual Average (µg/m 3 ) a Minnesota Soybean Processors (There are no other Increment Consuming Sources) Increment Standard b Minnesota Soybean Processors and Background Sources Background Concentration Minnesota Soybean Processors and Background Sources Maximum Ambient Impact NAAQS c MAAQS or Health Risk Value d 50 2,000 a Never to be exceeded. b Not to be exceeded more than once per year per receptor location. c Not to be exceeded for more than 1 percent of values, equivalent to the annual average fourth-high for dispersion modeling. d Not to be exceeded more than five times during a five-year period. Brewster, Minnesota 15 Worksheet

18 24. Odors, noise and dust. Will the project generate odors, noise or dust during construction or during operation? Yes No If yes, describe sources, characteristics, duration, quantities or intensity and any proposed measures to mitigate adverse impacts. Also identify locations of nearby sensitive receptors and estimate impacts on them. Discuss potential impacts on human health or quality of life. (Note: fugitive dust generated by operations may be discussed at item 23 instead of here.) Dust Dust would be generated as part of the facility s construction, including construction traffic. Dust from traffic generated by the facility operation would be minimized because access roads, on-site roads, and parking areas would be paved. Dust from grain handling and processing would be controlled according to federal BACT requirements (see Item 23). Odor A noticeable toasted soybean meal odor is commonly associated with crushing and extraction plants. Prevailing winds tend to be from the west and southwest, meaning soybean meal odors would normally be carried away from the City. The exhaust smells from idling diesel trucks in the staging area would normally also be carried away from the City. Noise There would be noise produced during the construction of the facility. Acoustical silencers would be installed on exhaust stacks and fans as needed during the construction phase of the project. Noisy process equipment, such as rotating or reciprocating equipment, would be housed in the buildings. The facility would be required to comply with the state daytime and nighttime noise level limits. These limits are based on the land use of the receiving property. Higher traffic levels would result in increased local traffic noise. To minimize idling noise, an on-site truck holding area would be used so that trucks would not have to wait off site (such as on nearby roads) to unload. Noise may also be generated from switching rail cars on or off the MnSP rail spur. 25. Nearby resources. Are any of the following resources on or in proximity to the site? a. Archaeological, historical, or architectural resources? Yes No b. Prime or unique farmlands or land within an agricultural preserve? Yes No c. Designated parks, recreation areas, or trails? Yes No d. Scenic views and vistas? Yes No e. Other unique resources? Yes No If yes, describe the resource and identify any project-related impacts on the resources. Describe any measures to minimize or avoid adverse impacts. All soils within the site boundary are considered prime farmland. After the proposed project is built, approximately 30 acres would be impervious surfaces (buildings and pavement) and the remaining acreage would be either grassland or landscaping around the buildings and drives. Brewster, Minnesota 16 Worksheet

19 26. Visual impacts. Will the project create adverse visual impacts during construction or operation? Such as glare from intense lights, lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks? Yes No If yes, explain. The height of the main building would be about 90 feet, while the height of the tallest stack would be 120 feet. The closest business is the oil storage tank owned by SDSP. This tank is about 50 feet in height. Presently there is a grain elevator located ¼ of a mile southwest of the site. With its superstructure it stands approximately 180 feet tall. There is a water tower within the City, about ½ mile from the site, which stands 140 feet in height. Moist process emissions from stacks can result in water vapor plumes under low dewpoint conditions. Condensation plumes from cooling towers may be visible. 27. Compatibility with plans and land use regulations. Is the project subject to an adopted local comprehensive plan, land use plan or regulation, or other applicable land use, water, or resource management plan of a local, regional, state or federal agency? Yes No If yes, describe the plan, discuss its compatibility with the project and explain how any conflicts will be resolved. If no, explain. The site is zoned agricultural by Nobles County. The City has annexed the property and the site will be rezoned industrial. 28. Impact on infrastructure and public services. Will new or expanded utilities, roads, other infrastructure or public services be required to serve the project? Yes No If yes, describe the new or additional infrastructure or services needed. (Note: any infrastructure that is a connected action with respect to the project must be assessed in the EAW; see EAW Guidelines for details.) The Union Pacific Railroad (formerly the Chicago and Northwestern Railroad) owns the mainline track along the northwest side of the property. A rail spur to the facility would be constructed. The spur would take up an area of about 100 feet by 1,700 feet. The east side of the site has a dirt road running along side (Zeh Avenue). This dirt road is the boundary between Nobles and Jackson County. These two counties have informally spoken of up-grading this road to a county road (asphalt) and extending it from Highway 60 south about 2 miles to an intersection with County Road 1. The road upgrade would be a separate project from the MnSP. The timing of such a road project is to be determined. County Road 1 connects to Interstate Highway 90 about 4 miles south of the City. The fresh water utility is available close to the site, at the corner of 2 nd Avenue and 6 th Street. Wastewater would be piped directly to the WWTF located south-southeast of the site approximately 1 mile. The water utilities would be installed in present right-of-ways. Electricity would come from the City along easements southwest of the site. At present, it is thought that the natural gas pipeline would come from the south, along the County Road 1 right-of-way. Brewster, Minnesota 17 Worksheet