TO INTERESTED PARTIES: RE: Heartland Corn Products Ethanol Plant Expansion

Transcription

1 TO INTERESTED PARTIES: RE: Heartland Corn Products Ethanol Plant Expansion The Minnesota Pollution Control Agency (MPCA) has approved the Findings of Fact for the Environmental Assessment Worksheet (EAW) on the proposed Heartland Corn Products Ethanol Plant Expansion, Sibley County, which concludes that this project does not have the potential for significant environmental effects. The decision for a Negative Declaration concludes the state environmental review process under the revised Environmental Quality Board rules, Minn. R , subp. 7. This project can now proceed to permitting. We want to express our appreciation to those of you who submitted comments on the EAW. Your comments and responses to them have been incorporated into the Findings of Fact, and will assist MPCA staff in drafting permits for the proposed project. Sincerely, Beth G. Lockwood District Planning Supervisor Operations and Planning Section North, South, and Metro Districts BGL:gs Enclosure

2 STATE OF MINNESOTA MINNESOTA POLLUTION CONTROL AGENCY In the Matter of the Decision on the Need for an Environmental Impact Statement for the Proposed Heartland Corn Products Ethanol Plant Expansion FINDINGS OF FACT AND CONCLUSIONS Heartland Corn Products Ethanol Plant (Heartland) is proposing to expand the existing ethanol production facility and increase ethanol production from 19 million gallons per year (MGY) to 35 MGY in Alfsborg Township, Sibley County. Pursuant to Minn. R , Minnesota Pollution Control Agency (MPCA) staff has prepared an Environmental Assessment Worksheet (EAW) for the project. Based on the EAW and comments or information received during the EAW comment period, the MPCA hereby makes the following Findings of Fact and Conclusions. PROJECT DESCRIPTION FINDINGS OF FACT 1. Currently, Heartland processes approximately 7.5 million bushels of corn per year. Postexpansion processing will increase to approximately 13.1 million bushels of corn per year. 2. Heartland currently uses four fermentation vessels of 250,000-gallon capacity each and one 250,000-gallon beer well. That beer well will be converted to use as a fermenter, two additional 300,000-gallon fermenters and one 300,000-gallon beer well will be added. 3. The expansion project will add one new beer column, one new rectifier column, one new molecular sieve, and one new distillation vent wet scrubber. The existing rectifier column will remain in use as the new side stripper. The existing beer column, molecular sieve, and distillation-wet scrubber will be replaced with new equipment. The three sieve beds will be replaced by larger ones. 4. A new dryer will be added to the facility and both dryers will exhaust into a common stack. The new stack diameter will be 60 inches and the stack height will be 150 feet above grade. 5. The facility currently has a 84 million British Thermal Unit capacity boiler. A second boiler of the same capacity will be added. 6. Heartland will add two 68,000-bushel grain storage bins and a second hammermill. A new, larger dust filter will be added to serve both mills. Grain handling dust collection equipment will remain unchanged. Heartland is also considering increasing current grain truck unloading capacity from 7,500 bushels per hour (BPH) to 15,000 BPH. TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 100% fibers from paper recycled by consumers

3 Heartland Ethanol Plant Expansion Findings of Fact and Conclusions A second cooling tower (same size as existing tower) will be added along with a 500,000-gallon denatured ethanol storage tank. An existing 40,000-gallon tank may be converted to denaturant storage. Both tanks will have floating covers to control emissions. JURISDICTION AND PROCESS 7. The project involves the expansion of a fuel conversion facility, for the production of alcohol fuels, which would increase its capacity by 16 million gallons per year of ethanol produced. The preparation of an EAW by the MPCA was mandatory pursuant to Minn. R , subp. 5B. 8. An EAW was prepared on the proposed project and distributed to the Environmental Quality Board mailing list and other interested parties on June 23, The EAW and its appendices are hereby incorporated by reference. 9. A press release containing the notice of availability of the EAW for public review was provided to media serving the project area on June 26, The public comment period for the EAW began on June 26, 2000, and ended on July 26, Comment letters from: Mr. James Echstein, the Minnesota Department of Transportation, Mr. Norville Stuber, the city of Winthrop, the Minnesota Department of Natural Resources, and the Minnesota Department of Health were received during the 30-day comment period. Responses to comments received have been prepared by MPCA staff and are hereby incorporated by reference. CRITERIA FOR DETERMINING THE POTENTIAL FOR SIGNIFICANT ENVIRONMENTAL EFFECTS 11. In deciding whether a project has the potential for significant environmental effects, the MPCA must consider the four factors set out in Minn. R , subp. 7.A. These criteria are: A) the type, extent, and reversibility of environmental effects; B) cumulative potential effects of related or anticipated future projects; C) the extent to which the environmental effects are subject to mitigation by ongoing public regulatory authority; and D) the extent to which environmental effects can be anticipated and controlled as a result of other available environmental studies undertaken by public agencies or the project proposer, including other Environmental Impact Statements (EISs). The MPCA findings with respect to each of these issues are set forth below

4 Heartland Ethanol Plant Expansion Findings of Fact and Conclusions TYPE, EXTENT, AND REVERSIBILITY OF ENVIRONMENTAL EFFECTS The first factor that the MPCA must consider is the "type, extent, and reversibility of environmental effects," Minn. R , subp. 7.A. The MPCA findings with respect to each of these issues are set forth below. 12. Potential Impacts to Ground Water: The Minnesota Department of Natural Resources (DNR) and the Minnesota Department of Health are evaluating the potential for lowering of the ground water due to the proposed expansion within the city of Winthrop s well field and surrounding aquifer. Based on area hydrogeologic information and local well logs, there is potentially a deeper and more extensive ground water resource in the sand and gravel deposits to the east of Winthrop. This is the direction Heartland's well would be placed. To determine if adequate ground water resources are available, Heartland has proposed to run a pump test to determine the local aquifer's water producing capability. The test will utilize observation wells to measure changes in ground water elevation while pumping occurs at Heartland's anticipated production rates. If drawdown exceeds 2.5 feet in the observation well one-half mile from the city of Winthrop's municipal well field, the pumping rate will be reduced to maintain a three-foot drawdown limit in this well. Based on the pump test findings, the DNR will determine if the aquifer can provide an adequate water supply for Heartland's production needs without significantly impacting the city of Winthrop's water supply. If adequate aquifer resources exist, the DNR will issue an Appropriations Permit for Heartland's production well that will include any limitations or criteria on ground water use. 13. Effect of Odors: A modeling study was performed to analyze the effects of the new distillers dried grains and solubles dryer stack. The purpose of the study was to determine what stack height would relieve the effect of building downwash on dispersion of the stack emissions. The Environmental Protection Agency SCREEN 3 (SCREEN) model was used. Building downwash causes the stack gas to be pulled to the ground in the recirculating cavity on the leeward side of the building, increasing emission concentrations at ground level. Raising the stack height from 70 to 150 feet eliminates all downwash effects, lowering odor concentrations at ground level. The SCREEN model used worst-case weather data, consisting of 54 combinations of wind speed and stability. The decreased odor concentrations, due to increased stack height, are conservative since worst-case weather conditions are rare. Conservative modeling results show a lowering of odor concentrations by 25 percent at a distance of one mile from the stack

5 Heartland Ethanol Plant Expansion Findings of Fact and Conclusions 14. Effect of Air Emissions: An analysis of the potential increases in the emission of air pollutants has been performed in conjunction with Heartland s application for an air emissions permit amendment. Preliminary estimates of air emissions that were submitted to the MPCA by Heartland indicate that the plant will remain a minor source for Title V air permitting purposes; the plant will not emit 100 or more Tons per Year (TPY) of any Title V air pollutant. The facility will emit more than 100 TPY of particulate matter emissions. The facility will become a major source of particulate emissions with respect to the Prevention of Significant Deterioration rules. The application for an air emissions permit was submitted for this project and is being reviewed by the MPCA. The air emission permit for the facility will contain specific operational and performance standards for each emissions unit. 15. Potential Impacts to Endangered Species: Based on information in the December 1992 EAW for the original project, there are no significant fish or wildlife resources on or near the site which would be disturbed or affected by the expansion of the plant. There are no wetlands within onefourth mile of the plant site. Letters have been received from the DNR and U.S. Fish and Wildlife Services which support this information. 16. MPCA Findings: The MPCA finds that the project, as it is proposed, does not have the potential for significant environmental effects. CUMULATIVE POTENTIAL EFFECTS OF RELATED OR ANTICIPATED FUTURE PROJECTS The second factor that the MPCA must consider is the "cumulative potential effects of related or anticipated future projects," Minn. R , subp. 7.B. The MPCA findings with respect to this factor are set forth below. 17. The proposed project is intended to increase the capacity of Heartland Corn Processing Ethanol Plant by 16 million-gallons per year of ethanol produced. 18. The MPCA finds that there are no related or anticipated future actions which could result in cumulative, adverse, environmental effects

6 Heartland Ethanol Plant Expansion Findings of Fact and Conclusions THE EXTENT TO WHICH THE ENVIRONMENTAL EFFECTS ARE SUBJECT TO MITIGATION BY ONGOING PUBLIC REGULATORY AUTHORITY The third factor that the MPCA must consider is "the extent to which the environmental effects are subject to mitigation by ongoing public regulatory authority," Minn. R , subp. 7.C. The MPCA findings with respect to this factor are set forth below. 19. The following permits or approvals will be required for the project: Unit of Government Permit or Approval Required a. MPCA Air Emission Permit b. MPCA National Pollution Discharge Elimination System Stormwater Permit c. MPCA Aboveground Storage Permit d. DNR Water Appropriations Permit e. City of Winthrop Utility Use Agreement 20. The MPCA finds that the permits and monitoring reports required by public regulatory authority will provide additional opportunity to mitigate the environmental effects of the project, if necessary. THE EXTENT TO WHICH ENVIRONMENTAL EFFECTS CAN BE ANTICIPATED AND CONTROLLED AS A RESULT OF OTHER AVAILABLE ENVIRONMENTAL STUDIES UNDERTAKEN BY PUBLIC AGENCIES OR THE PROJECT PROPOSER, INCLUDING OTHER EISs. The fourth factor that the MPCA must consider is "the extent to which environmental effects can be anticipated and controlled as a result of other available environmental studies undertaken by public agencies or the project proposer, including other EISs," Minn. R , subp. 7.D. The MPCA findings with respect to this factor are set forth below. 21. The proposed ethanol plant expansion has been reviewed by the MPCA staff. 22. There are no elements of the project that pose the potential for significant environmental effects which cannot be addressed in the project design and permit development processes. 23. The MPCA finds that the environmental effects of the project can be anticipated and controlled as a result of environmental review, previous environmental studies, and permitting processes undertaken by the MPCA on similar projects

7 Heartland Ethanol Plant Expansion Findings of Fact and Conclusions CONCLUSIONS 1. The EAW, the permit development process, the facility planning process, and responses prepared by MPCA staff in response to comments on the Heartland Corn Processing Ethanol Plant Expansion EAW (the project), have generated information adequate to determine whether the project has the potential for significant environmental effects. 2. Areas where the potential for significant environmental effects may have existed have been identified and appropriate mitigative measures have been incorporated into the project design and permits. The project is expected to comply with all MPCA standards. 3. Based on the criteria established in Minn. R , the project does not have the potential for significant environmental effects. 4. An Environmental Impact Statement is not required. 5. Any findings that might properly be termed conclusions and any conclusions that might properly be termed findings are hereby adopted as such. Karen A. Studders, Commissioner Minnesota Pollution Control Agency Date - 6 -

8 LIST OF COMMENT LETTERS RECEIVED for Heartland Corn Products Ethanol Plant Expansion James Echstein, dated July 5, 2000 Lawrence Filter, Minnesota Department of Transportation, dated July 14, 2000 Norville Stuber, dated July 21, 2000 Sam Shult, City of Winthrop, dated July 24, 2000 Thomas W. Balcom, Minnesota Department of Natural Resources, dated July 24, 2000 David Wulff, Minnesota Department of Health, dated July 26, 2000

9 Comments Received and Responses to Comments For the Heartland Corn Products Ethanol Plant Expansion Mr. James Echstein, letter received on July 10, 2000 Comment1-1: The commentor identified himself as a shareholder in the Heartland Corn Products Ethanol Plant (Heartland) and stated that he does not believe the proposed expansion is in the best financial interest of the shareholders. Response 1-1: An Environmental Assessment Worksheet (EAW) does not assess financial issues. According to Minn. R , subp.1, Purpose of an Environmental Assessment Worksheet, the EAW is a brief document, prepared in worksheet format, which is designed to rapidly assess the environmental effects which may be associated with a proposed project. Comment 1-2: The commentor expressed concerns that the proposed expansion may result in doubling the current water usage rate, potentially resulting in lowering the groundwater table. Response 1-2: The Minnesota Department of Natural Resources (DNR) and the Minnesota Department of Health (MDH) are evaluating the potential for lowering of the ground water due to the proposed expansion within the city of Winthrop s well field and surrounding aquifer. Based on area hydrogeologic information and local well logs, there is potentially a deeper and more extensive ground water resource in the sand and gravel deposits to the east of Winthrop. This is the direction Heartland's well would be placed. To determine if adequate ground water resources are available, Heartland has proposed to run a pump test to determine the local aquifer's water producing capability. The test will utilize observation wells to measure changes in ground water elevation, while pumping occurs at Heartland's anticipated production rates. If drawdown exceeds 2.5 feet in the observation well one-half mile from the city of Winthop's municipal well field, the pumping rate will be reduced to maintain a three foot drawdown limit in this well. Based on the pump test findings, the DNR will determine if the aquifer can provide an adequate water supply for Heartland's production needs without significantly impacting the city of Winthrop's water supply. If adequate aquifer resources exist, the DNR will issue an Appropriations Permit for Heartland's production well that will include any limitations or criteria on ground water use. Comment 1-3: The commentor expressed concern with the use of trucks for shipping. He believes that using a train would be a more environmentally friendly method of transporting products and receiving supplies. Response 1-3: All of the ethanol produced at the plant currently moves, and will continue to move, to the Twin Cities via back-haul gasoline transport. These trucks are already on the road and would otherwise return to the Twin Cities empty. Shipping via this method does not add to existing traffic. Also, the counties adjacent to the existing rail line are attempting to gain title to the property. If they are successful, state and federal programs may be available to upgrade the line and enable Heartland to utilize the line for shipping distiller's grains to the western dairy market.

10 Mr. Lawrence Filter, Minnesota Department of Transportation, letter received on July 17, 2000 Comment 2-1: The commentor is concerned that if the westerly entrance is used for traffic entering the plant, accommodations for movements at Trunk Highway 19 would have to be made by Heartland Corn Products. Response 2-1: Heartland does not intend to alter current traffic patterns at the plant. The entrance from the plant will be from the east access and will exit via the west access. Comment 2-2: The commentor expressed concern that Heartland Corn Products require only licensed trucks be used for deliveries. Response 2-2: Heartland intends to continue to only accept deliveries by licensed trucks. Mr. Norville Stuber, letter received on July 25, 2000 Comment 3-1: The commentor is concerned that the expansion will increase the level of odors in Winthrop. The commentor does not believe that raising the stack to 150 feet will effect odor. Response 3-1: A modeling study was performed to analyze the effects of the new distillers dried grains and solubles dryer stack. The purpose of the study was to determine what stack height would relieve the effect of building downwash on dispersion of the stack emissions. The Environmental Protection Agency SCREEN 3 (SCREEN) model was used. Building downwash causes the stack gas to be pulled to the ground in the recirculating cavity on the leeward side of the building, increasing emission concentrations at ground level. Raising the stack height from 70 to 150 feet eliminates all downwash effects, lowering odor concentrations at ground level. The SCREEN model used worst-case weather data, consisting of 54 combinations of wind speed and stability. The decreased odor concentrations, due to increased stack height, are conservative since worstcase weather conditions are rare. Conservative modeling results show a lowering of odor concentrations by 25 percent at a distance of 1 mile from the stack. Attachment C of the EAW lists the percent decrease in odor concentrations with respect to distance from the stack. Mr. Sam Shult, City of Winthrop, letter received on July 25, 2000 Comment 4-1: The commentor is concerned that the installation of the proposed well may impact the city of Winthrop's ability to place an additional city well without conflict. Response 4-1: See Response 1-2. This is a valid concern that should be addressed by the aquifer testing Heartland has proposed to determine the impacts of their expansion on the local aquifer. If the city of Winthrop has plans to install an additional well and knows its location, this information should be presented to the DNR immediately for consideration in the evaluation of this situation. 2

11 Mr. Thomas W. Balcom, Minnesota Department of Natural Resources, letter received on July 28, 2000 Comment 5-1: The commentor has no concerns at the present time. However, as indicated in the EAW, commentor noted that a DNR Water Appropriations Permit would be needed for the proposed well. Response 5-1: No response necessary. Mr. David Wulff, Minnesota Department of Health, letter received on July 31, 2000 Comment 6-1: The commentor believes the city wells are tapping a restricted reservoir which may be depleted and require a new water source at some future time. The commentor also believes that the new well proposed for the Heartland ethanol plant expansion would likely tap into the same aquifer, in which case, the aquifer would be depleted much sooner. Therefore, planning and permit requirements should be invoked to prevent adverse effects to the city's water supply. Response 6-1: See Responses 1-2 and 4-1. Comment 6-2: The commentor states that the wellhead protection area delineation was approved in November 1999, and if the proposed well taps the city's aquifer, the well head protection area will change and, will need to be redone. Also, according to Minn. R. 4720, if the proposed well is approved, Heartland will be required to incur the cost of a new Wellhead Protection Plan. Response 6-2: See Responses 1-2 and 4-1. Heartland has stated in their most recent response to the EAW of August 9, 2000, If the long term pump test outlined above indicates that the resulting cone of depression of the production well impacts the delineated Well Head Protection (WHP) Area for the City, HCP will modify the WHP plan in accordance with MDH rules. Heartland is willing to work with the city of Winthrop and MDH to reevaluate the well head protection area should it be impacted by their pumping. It is believed that the additional information collected through Heartland's aquifer testing would provide better ground-water elevation data that would improve the accuracy of the currently known well head protection. 3