ENVIRONMENTAL ASSESSMENT WORKSHEET

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2 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: 2. Proposer: Biofuel Solutions, LLC 3. RGU: Minnesota Pollution Control Agency Contact Person Scott Pearce Contact Person Jim Sullivan and Title President and Title Planner Principal Address 263 McLaw Circle, Suite 100 Address 520 Lafayette Road North Williamsburg, Virginia St. Paul, Minnesota Phone (757) Phone (651) Fax (757) Fax (651) 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: Minn. R , subp. 5B - Fuel Conversion Facilities 5. Project Location: County Martin County City/Twp City of Fairmont E 1/2 Section 1 Township 102N Range 31W TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing 30% fibers from paper recycled by consumers

3 Figures and Exhibits attached to the EAW: FIGURES Figure 1 County Location Map; Figure 2 Site Location Map; Figure 3 Site Layout; Figure 4 Aerial Photograph of Proposed Site; Figure 5 Water Intake/Discharge Locations; Figure 6 National Wetland Inventory Map; Figure 7 Soils Map; Figure 8 Well Location Map; and Figure 9 Geologic Cross Section. EXHIBITS Exhibit 1 Minnesota Department of Natural Resources (DNR) Review Letter; Exhibit 2 Best Management Practices Plan; and Exhibit 3 Minnesota State Historic Preservation Office (SHPO) Review Response & Database Search. 6. Description: a. Provide a project summary of 50 words or less to be published in the EQB Monitor. (BLE) proposes to construct a dry mill ethanol production facility co-located with an existing Cargill Ag Horizons grain handling facility in Martin County, with a maximum capacity of 118 million gallons per year of 200-proof ethanol (Project). The facility will produce 360,000 tons per year of distiller s dried grains with solubles (DDGS) as a co-product that would be used as animal feed. 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. Process Description: BLE will construct a dry mill ethanol production facility in Martin County (see Figures 1 and 2) using the following four basic steps: Starch Conversion. This process converts all starch available in the corn to sugar. Milled corn is blended with re-used process water and alpha-amylase enzyme. This is then diluted with backset (re-used stillage) and cooled for moving to the fermentation process. The proposed facility would process approximately 43.7 million bushels (approximately 1,223,704 tons) of corn per year. Fairmont, Minnesota 2 Worksheet

4 Batch Fermentation. The process of fermentation involves converting sugars (dextrins) in the mash to ethanol. To begin the process, yeast and glucoamylase enzyme 1 are added to the mash and the resulting mixture is transferred to one of eight fermentation tanks. The enzyme breaks down the dextrins into glucose, a simple sugar, which is then converted by the yeast to ethanol and carbon dioxide (CO 2 ). The CO 2 moves to a scrubber, which captures the entrained ethanol and then vents the remaining CO 2 to the atmosphere. Approximately 48 hours in the fermentation tanks is required to consume all the sugars. The entire contents of the fermentation tank are then pumped to the beerwell. The empty fermentation tank is rinsed and cleaned for the next batch. The proposed Project will use eight fermentation tanks each with an 814,800-gallon capacity and one 1,058,000-gallon capacity beerwell. Exhaust from the fermentation process will be routed through a fermentation scrubber before being vented to the atmosphere. See Table 2 for stack heights. Distillation/Dehydration. In this process, the ethanol is separated from the beer and purified to 200-proof (anhydrous ethanol). The beer is pumped continuously from the beerwell to the top of the beer stripper column. Steam is used to indirectly heat the column using a heat exchanger, causing the ethanol to vaporize and rise in the column. Water and remaining corn solids travel down and out of the stripper as a liquid. At the top of the column, the ethanol, now at 125-proof, is removed and sent to the rectifier column. Rectified column overhead vapor at 186-proof is sent through a superheater. It then flows through molecular sieve beds, which absorb the remaining water, leaving 200-proof ethanol. The flow of 186-proof ethanol alternates from one bed to another every five minutes. The bed not in use is regenerated by a vacuum, which cleans the bed and recovers 130-proof ethanol. This material is then condensed and pumped back into the rectifying column. The 200-proof ethanol emerging from the beds is condensed and pumped through a cooler to a storage tank. The Project will include two beer stripper columns, two strippers, two rectifier columns, four molecular sieves and two condensers. Exhaust from the distillation/dehydration process would be routed to one of the two Thermal Oxidizer (TO)/Heat Recovery Boilers. By-product Processing. Stillage, a by-product of distillation, consists of the remaining solids and water coming off the bottom of the stripper column. The stillage is dried to allow for storage and shipping. First the stillage is centrifuged to yield thin stillage and solids fractions. This thin stillage is used to feed the evaporator and as backset water for the starch conversion system. The evaporator concentrates the thin stillage to create a syrup containing approximately 40 percent dry matter. Syrup is pumped to the mixing auger to be combined with the wet distiller s grains (solids coming off the centrifuge). The mixture is conveyed into the dryers. Cyclone separators are used to control particulate emissions. The resulting DDGS is cooled in a fluid bed cooler. Fifty percent of the exhaust from the dryers is recycled back to the dryer inlet, while the balance is vented to one of the two TO/Heat Recovery Boilers for volatile organic compounds (VOCs) and Particulate Matter (PM) control. The DDGS exits the cyclone and is transferred to the DDGS conveyor, where it is placed the DDGS storage building. Two natural-gas dryers (in series), two cyclone separators, DDGS conveyors and two DDGS storage silos will be used at the proposed facility. The exhaust from both dryers will be routed to one of the two TO/Heat Recovery Boilers. Baghouse control will be used on the DDGS conveyance and storage systems. 1 An enzyme that breaks down starches and dextrins into glucose. The enzyme is produced by fungi, especially those in the Aspergillus genus. Fairmont, Minnesota 3 Worksheet

5 The Project proposers have designed an alternative operating scenario producing wetcake instead of drying the stillage. In this scenario, the stillage would be centrifuged to yield thin stillage and solids fractions. The thin stillage would continue to be used to feed the evaporator and as backset water for the conversion process; however, the wet distillers grain is sold as wetcake instead of being sent to the drying process. In this scenario, the syrup coming off the evaporator would be added to the wetcake prior to being sold as animal feed. Based upon a testing protocol reviewed by the MPCA and completed at another ethanol facility, a limited evaluation of wetcake emissions was conducted. Based on this limited dataset, wetcake emissions have been estimated for this operating scenario. As addressed in the air permit application, wetcake production results in lower air emissions relative to drying the same unit of wet product and routing the dryer air through the TO/Heat Recovery Boilers. Therefore, the Project proposer has estimated emissions based upon 100 percent DDGS production, but has proposed a flexible operating scenario allowing either 100 percent DDGS production, 100 percent wetcake production, or any combination of the two products. Additional Facilities Proposed: TO/Heat Recovery Boilers. Two 145-million British Thermal Unit (MMBTU) per hour TO/Heat Recovery Boilers would be used to control air emissions routed from the distillation and DDGS drying processes, and to provide steam for cooking, distilling, evaporating, and other plant uses. These two units would be routed to one common stack. See Table 2 for stack heights. Corn Conveyance/Storage Facilities. Corn would be mechanically conveyed from corn received at the existing Cargill Ag Horizon facility. The Proposed facility would have one corn storage silo with the capacity to hold sufficient corn for approximately one day of production. Corn would be transferred to hammermilling either directly from the Cargill facility, or from the corn storage silo. These corn conveyance and storage facilities would be controlled using baghouses. Hammermill. The proposed Project would include four hammermills. A hammermill is a mechanical device using rotating hammers and stationary anvils to smash, crush and tear large biomass pieces (i.e., corn) into smaller fragments. See Table 2 for stack heights. Storage Tanks. Five ethanol product storage tanks would be included as part of the proposed Project including: two 1,227,100-gallon denatured ethanol storage tanks; two 213,700-gallon shift tanks; and a 248,500-gallon denaturant tank. These tanks would be located in a lined tank farm providing secondary containment to protect ground and surface water resources in the event of an accidental release and would be fitted with internal floating roofs to help control emissions. Product Shipping. Both ethanol and DDGS would be transferred to trucks and/or rail cars for shipping offsite. Ethanol truck and rail load-out emissions will be routed to a natural gas-fired load-out flare. Wetcake, if produced, would be loaded onto trucks and shipped to local animal feed operations. Water Outfall Pipeline. The Project proposer plans to construct an eight-inch diameter pipeline from the facility to the city of Fairmont s municipal storm sewer system. The inlet to the storm sewer system is within the proposed property boundaries. The storm sewer discharges to Judicial Ditch 18 east of the property, which flows to Center Creek. The facility discharge would be comprised of non-process Fairmont, Minnesota 4 Worksheet

6 waters 2 which include: cooling tower blowdown, reverse osmosis reject water, boiler blowdown, and multimedia filter backwash. These non-process discharge streams would be regulated by the National Pollutant Discharge Elimination System (NPDES)/State Disposal System (SDS) Permit Program. This permit authorizes the Permittee to treat and dispose of reverse osmosis reject waters, cooling tower blowdown, multimedia filter backflush, and stormwater associated with an industrial activity. All waste streams, including the discharge of stormwater are discharged to Judicial Ditch No. 18 approximately 0.80 miles upstream of its inflow into Center Creek. Figure 5 shows the location and route of the proposed pipeline, as well as the route of the storm sewer to Judicial Ditch 18. Emergency Generator. The Project proposer plans to install a 27.2 MMBTU/hr diesel-fired emergency generator for backup power. The use of this generator has been estimated at 100 hours per year. Fire Water Storage and Pump. Project proposer plans to install a fire water storage tank and associated fuel oil-fired fire water pump to provide on-site water pressure for fire suppression activities. Summary of Construction Activities: Table 1 Proposed Equipment List for the BLE Project Equipment Location Equipment Location Four Hammermills Outside Two DDGS Dryers Outside Corn Elevator Outside Two DDGS Coolers Outside Corn Bulk Weigher Outside Two TO/Heat Recover Boilers Outside Corn Day Storage Outside Cooling Towers Outside Corn Conveyor Outside Wetcake Storage Pad Outside Scalper Outside Two DDGS Elevators Outside Eight Fermenters Outside Two DDGS Conveyors Outside Fermentation Scrubber Outside One DDGS Truck Load-Out Inside Two Rectifier Columns Outside One DDGS Truck/Rail Load-Out Inside Beerwell Outside Two Denatured Ethanol storage tanks Outside Slurry Tank Inside Two 200 Proof Condenser Inside Liquefaction Tank Inside Two 200 Proof Day Tanks Outside Two Beer Strippers Outside Denaturant Tank Outside Two Strippers Outside Ethanol Truck Load-Out Outside Four Molecular Sieves Outside Ethanol Rail Load-Out Outside Six Centrifuges Inside Various Baghouse Controls Varies Evaporators Outside Fire Water Storage Tank Outside Two DDGS Cyclones Outside Fire Water Pump Outside Ethanol Load-Out Flare Outside Emergency Generator Outside 2 Non-process wastewater means any water which during manufacturing or processing, does not come into contact with, does not have the potential to come in contact with or result from the production or use of any raw material, intermediate product, finished product, byproduct or waste product. Cooling tower and boiler blowdown is defined as water that is lost by evaporation from the cooling tower. Natural occurring minerals from the water source are concentrated in the remaining tower water. There is a practical limit of concentration of the substances if scale corrosion and general deterioration of the cooling structures are to be prevented. To avoid such problems, a certain amount of the cooling water customarily is drained off. This water, termed blowdown, is replaced by fresh makeup water. Blowdown as it comes from the tower contains concentrated solids and dissolved salts and minerals present in the original makeup water, and possibly residuals of any special chemicals used for control of scale, corrosion and biofouling. Multi-media filter backwash is clean water that is periodically backwashed across the filters to clear them of build-up which may have collected during the filtration cycle. This process extends the life of the filter. This is the same process that is used with reverse osmosis systems, which creates the reverse osmosis reject water waste stream. Fairmont, Minnesota 5 Worksheet

7 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. 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. 7. Project Magnitude Data Total Project Area (acres) 203 acres or Length (miles) Number of Residential Units: Unattached na Attached na maximum units per building na Commercial/Industrial/Institutional Building Area (gross floor space): total square feet 105,950 Indicate area of specific uses (in square feet): Office 1,400 Manufacturing 104,550 Retail Other Industrial Warehouse Institutional Light Industrial Agricultural Other Commercial (specify) Storage Tanks (including secondary containment), Cooling Tower, Thermal Oxidizers/Boilers, and Wet Cake Storage: 129,750 Building height If over 2 stories, compare to heights of nearby buildings Table 2 Proposed BLE Equipment, Building, and Major Stack Heights Location/Description Height (in feet) Corn Storage Day Silo 120 Process Building 55 Employee Facilities/Laboratory 20 Fermentation Building 33 Fermenter Tanks and Beerwell 48 DD&E Buildings 55 DD&E Electric Room 18 Maintenance Building 30 DDGS Storage Building 45 DDGS Rail & Truck Loadout Building 40 Corn Storage Silo Baghouse 150 DDGS Handling Baghouse #2 122 DDGS Handling Baghouse #3 122 TO/Heat Recovery Boiler Stack 140 Fairmont, Minnesota 6 Worksheet

8 8. 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. Table 3 Permits and Regulatory Approvals required for the Proposed BLE Project Unit of Government Type of Application Status City of Fairmont Industrial Stormwater Agreement Yet to be finalized Martin County Conditional Use Permit To be submitted Martin County Building Permit To be submitted Martin County Utility Permit To be submitted Minnesota Department of Utility Permit To be submitted Transportation (MNDOT) MPCA NPDES Individual Industrial Discharge Permit Submitted MPCA NPDES Construction Stormwater Permit To be submitted (Notice of Intent) MPCA Major Facility Above Ground Storage Tank Submitted Permit MPCA Very Small Hazardous Waste Generator Permit To be submitted DNR Water Appropriation Permit To be submitted State Fire Marshall Above Ground Storage Tank Permit To be submitted 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 Project would be located approximately one-mile west of the city of Fairmont. The site was previously used for agricultural purposes and is surrounded by existing industrial facilities, including the adjacent Cargill Ag Horizons facility. Approximately 101 acres of the site would remain unchanged after the ethanol facility is constructed. There are several residences and the Martin County fairgrounds within a one-mile radius of the proposed facility. There are no known environmental hazards due to past site uses. 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 Wooded/forest 0 0 Impervious Surfaces Brush/grassland Other (Residence) 0 0 Cropland Pond TOTAL Fish, Wildlife, and Ecologically Sensitive Resources. Fairmont, Minnesota 7 Worksheet

9 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. A review request was submitted for both the site and the discharge route to the DNR Natural Heritage Database to determine if any rare or endangered species or other sensitive natural resources would be affected by this project. The results of this review are attached as Exhibit 1. Additionally, a notification letter was sent to the U.S. Fish and Wildlife Service (USFWS) allowing the opportunity to comment regarding sensitive species, natural resources, or fish and wildlife habitats during the planning phase of the project. A comment response was not received from the USFWS. Lily Creek and Lake George are the surface water bodies nearest to the site. Best Management Practices (BMPs) for erosion control and stormwater management would be used during construction and operation of the facility to protect these surface water resources. Both non-contact utility water and stormwater associated with an industrial activity would be discharged to the municipally-owned industrial storm sewer which discharges into Judicial Ditch No. 18. Stormwater associated with an industrial activity is first collected into an on-site storm detention pond for detention and treatment, and monitored to ensure compliance with treatment-based effluent limitations prior to discharge to the industrial storm sewer. The storm sewer system does not flow into the chain of lakes surrounding the city of Fairmont, of which Lake George is included. 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. Five rare species or significant natural resources were identified from the Minnesota Natural Heritage database as being in the vicinity of the proposed Project. The species are as follows: Mesic Prairie (Southwest) two occurrences Asclepias Sullivantii (Sullivant s Milkweed) Juncus Gerardii (Black Grass) Speotyto Cunicularia (Burrowing Owl) Rallus Elegans (King Rail) As identified by the Natural Heritage database search, the only species that may be impacted by the proposed project are the mesic prairie remnants located within the rights of way of the Union Pacific Railroad. Sullivant s Milkweed, a state-listed threatened plant species, and Rattlesnake-Master, a statelisted special concern plant species, have been associated with prairie remnants of this type. The Project, as currently proposed, does not appear to impact these prairie remnants; however, BMPs would be implemented to minimize off-site migration of sediment, which could impact these resources. If, during the course of construction, temporary disturbance of these prairie remnants becomes necessary, the Project proposer will contact the DNR prior to disturbance to obtain a botanical survey and develop a plan for resource preservation and restoration. Fairmont, Minnesota 8 Worksheet

10 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 involves the discharge of non-contact cooling water, as well as stormwater runoff associated with industrial activity to the city of Fairmont municipal storm sewer. The inlet to the storm sewer is within the proposed property boundaries. The storm sewer discharges to Judicial Ditch 18, which in turn flows to Lily Creek, which flows into Center Creek. Center Creek is listed on the DNR PWI; however a PWI number is not given. The proposed Project includes the use of a stormwater pond for managing the additional run-off generated by the impervious surfaces constructed along with the ethanol facility. In addition, the city of Fairmont requires post-construction peak runoff conditions to be equal to pre-construction peak runoff conditions. These design and management practices, along with limitations included in the facility s individual NPDES/SDS discharge permit will minimize impacts of the development on these resources. 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. Predicted Water Consumption Based on the operational assessment and output goals for this Project, an annual need of million gallons per year (MMGY) will be required to operate the Project at full production. The estimated service life of the proposed Project is 25 years. As a result, the Project, assuming no expansion or change in water consumption and conservation practices, will require 16,977.5 million gallons for the estimated service life of the Project. In an effort to reduce the total amount of water demanded by the facility, the Project proposer has proposed to use multiple cycles of concentration in the cooling tower and re-use all process wastewater generated by the facility. Ground Water Appropriation A water appropriation permit is required from the DNR for the use of more than 10,000 GPD, or one MMGY, which includes agricultural uses. The purpose of the permit program is to ensure water resources are managed so that adequate supply is provided to long-range seasonal requirements for domestic, agricultural, fish and wildlife, recreational, power, navigational, and quality control. The DNR review and approval process is designed to determine whether a project will have adequate supply, adversely impact surface waters or adversely impact surrounding wells. Under Minn. Stat. 103G.261, domestic water use has the highest priority of the state's water when supplies are limited. The program exists to balance competing management objectives, including both the development and protection of water resources. The DNR has a well interference resolution process available to address usage conflicts, which includes a questionnaire and an evaluation by the DNR Area Hydrologist. The Project proposers have Fairmont, Minnesota 9 Worksheet

11 conducted an assessment of the existing ground water resources with respect to projected need as part of the DNR permit process and the analysis of potential environmental impact under the Minnesota Environmental Policy Act. The Project will include two ground water wells that are proposed to be finished in the Cretaceous Sandstone aquifer, located below the site (See Figure 9). The Project proposers have conducted a pump test and completed a ground water supply model to determine that an adequate supply of water is available to accommodate the production needs of the Project without adversely impacting surrounding domestic and municipal drinking water wells. Pump Test and Ground Water Assessment The Project proposers conducted a seven-day pump test within the Cretaceous sandstone unit located beneath the Project site. The test well was penetrated the Cretaceous sandstone unit and was screened to provide for withdrawal of ground water specifically from this source. The pump test began on December 9, 2006, at a pump rate of 900 gallons per minute. The pump test was completed on December 16, The pumping well was monitored along with six other nearby wells to observe draw down and recovery effects of the pump test on the local ground water system. The pump test data, including additional aquifer characteristics derived from other geologic investigations was reviewed and evaluated to determine whether an adequate ground water supply existed for the Project. Based on the aquifer characteristics, the field data collected from the seven-day pump test and the related ground water modeling analysis, the Project will be able to operate at capacity for the service life of the facility without adversely impacting municipal or residential drinking water wells. 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. 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: 48.3 acres; ~78,000 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. Construction of the Ethanol Plant Based on a site survey, the majority of the project area is relatively flat with slopes not exceeding eight percent. A disturbance of more than one-acre of soil requires a NPDES General Stormwater Permit for Construction Activity. As a requirement for coverage under this general permit, a site-specific Construction Stormwater Pollution Prevention Plan (SWPPP) must be developed. BMPs, including silt fences, straw bales and a temporary stormwater pond, would be identified in the Construction SWPPP to reduce surface water runoff and off-site migration of sediments during construction. Fairmont, Minnesota 10 Worksheet

12 Operation of the Ethanol Plant Stormwater runoff from the proposed facility would be discharged to the city of Fairmont s municipal storm sewer system. Although the city s system is not covered under the MPCA s State stormwater program for Municipal Separate Storm Sewer Systems (MS4), they will be required to gain coverage under this program within the next two years. In order to ensure compliance with the future permit, the city will require industries contributing to the municipal storm sewer system to demonstrate compliance with state standards. The NPDES/SDS Permit contains requirements for the development and implementation of a SWPPP to address specific conditions at the facility, with the goal being to eliminate or minimize contact of stormwater with significant materials that may result in pollution of the runoff. The permit requires weekly site inspections, the routing of all stormwater to the storm detention pond, and monitoring of the stormwater prior to discharge to the municipally-owned industrial storm sewer. As such, the Project proposer will work with the city to develop an Industrial SWPPP. One of the purposes of the SWPPP would be to minimize erosion from stormwater during facility operations, as well as to treat stormwater prior to entering the municipal storm sewer system. The temporary stormwater pond used during construction would be converted to a permanent stormwater pond for containing stormwater discharges resulting from the facility footprint. In addition, inspections and maintenance would be used to ensure proper vegetative cover in areas not stabilized by impervious surfaces. 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 stormwater pollution prevention plans. The majority of the property being purchased for development, along with the Cargill property, has been allocated approximately 30 cubic feet per second, or 25 percent of the total peak design capacity of the adjacent storm sewer system. However, an additional requirement of the city of Fairmont for development is that post-improvement runoff conditions not exceed pre-development runoff conditions. Therefore, peak runoff from the site after development would be limited to the lesser of the two levels described above. Although stormwater runoff would be discharged through the city of Fairmont s municipal storm sewer system, the city would require development of an Industrial SWPPP that conforms to state stormwater permit requirements. The SWPPP would be drafted prior to commencement of operations and would be subject to review and approval by the city. The SWPPP would require the project proposers to identify all sources of possible stormwater contamination for the project. BMPs would be identified and implemented, along with a schedule and criteria for routine inspections. The SWPPP would be modified based on actual operations. Stormwater from precipitation and snow melt events would be collected, contained, controlled and, if necessary, treated, prior to discharge to the municipal storm sewer. An annual summary of industrial stormwater discharges would be transmitted to the city for review, including any spills occurring during the year, additional BMPs implemented over the course of the year, and the results of all facility stormwater inspections. Adherence with the city of Fairmont s standards and practices described with the site-specific Industrial SWPPP would insure that post-development stormwater quality would not violate water quality standards. Fairmont, Minnesota 11 Worksheet

13 Construction of the Ethanol Plant Based on a review of published topographic information, the majority of the project area is relatively flat, with slopes between zero and eight percent. The majority of the runoff generated from impermeable surfaces associated with the facility would flow into the detention pond located on the northwest corner of the facility footprint. This detention pond will have a riprapped inlet and outlet to protect from erosion. The pond would retain the runoff from the site and allow time for accumulated sediment to settle prior to discharge. A large portion of the property would be not be impacted by the proposed development, and so the quantity and quality of runoff from the undeveloped portion of the property would not change significantly. 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. The entire property is in the Blue Earth watershed. Although runoff would increase as a result of the impervious areas associated with the facility, the majority of land on the site would remain vegetated, allowing for infiltration of a portion of the runoff prior to exiting the site. Also, site grading would direct the runoff generated from the facility footprint toward the stormwater detention pond, where it would be captured and treated through settling. Discharge from the municipal storm sewer into which the facility would discharge enters Judicial Ditch 7 near the eastern side of the proposed property boundary. Because industrial stormwater standards, as identified by the city of Fairmont, would need to be met prior to discharging into the municipal system, the discharge of treated stormwater is not expected to impact the Blue Earth River or its tributaries. 18. Water Quality Wastewater. a. Describe sources, composition and quantities of all sanitary, municipal and industrial wastewater produced or treated at the site. Process Wastewater The Project proposer will recycle all process water in an effort to reduce the wastewater generated as part of the proposed project. Nonprocess Wastewater Nonprocess wastewater, including cooling tower blowdown, multi-media filter backwash, reverse osmosis reject water, and boiler blowdown would be discharged from the facility. Approximately 354 gallons per minute, or 509,760 GPD, would be discharged to the municipal storm sewer as described in the NPDES/SDS Permit. Nonprocess discharge volumes are summarized in the following table: Fairmont, Minnesota 12 Worksheet

14 Table 4 - Wastewater Discharge Sources and Composition Source Maximum Volume (GPD) Cooling Tower Blowdown 332,640 RO Reject 162,720 Multi-media filter Backwash 7,200 Boiler Blowdown 7,200 Total NPDES Load 509,760 Because the proposed discharge is greater than 200,000 GPD, a nondegradation review and variance has been prepared for the proposed discharge. A specific discussion is provided in Item 18.B. A cold lime softener would be used to treat all facility make-up water. This treatment process would not generate a discharge stream, but would generate a non-hazardous sludge, which would be dewatered and disposed of as a solid waste. Additional information regarding this waste stream is found in Item 20.B. 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 point of discharge for non-process waste water would be the city of Fairmont s municipal storm sewer system, which discharges to Judicial Ditch 7 (see Figure 5), which in turn flows to Lily Creek and Center Creek, all of which are unlisted as respects Minn. R. 7050, which means the following water use classes apply: 2B; 3B; 4A; 4B; 5; and, 6. Class 2 waters are protected for aquatic or terrestrial life or their habitats, or public health, safety, or welfare. Class 3 waters are protected for industrial consumption. Class 4 waters are protected for agricultural and wildlife purposes. Class 5 waters are protected for aesthetic enjoyment and navigation. Class 6 waters are protected for other unlisted beneficial uses that the MPCA may deem proper. Center Creek has been identified by the MPCA as an impaired water at the proposed discharge location, with ammonia, fish Index of Biotic Integrity (IBI), turbidity, and fecal coliform listed as the main pollutants. Effluent discharge limits have been included in the draft NPDES/SDS discharge permit with these to these impairments. Variance and Nondegradation The source of water for the Project is ground water. The concentration levels of the salinity and other related pollutants in the ground water are very high, such that treatment of the water supply prior to discharge to surface waters would violate existing water quality discharge standards. As a result, the Project proposers are seeking a variance from water quality standards. Minn. R , subp. 1 allows the MPCA Citizen s Board to grant a variance if it finds that: by reason of exceptional circumstances the strict enforcement of any provision of these standards would cause undue hardship that disposal of the waste is necessary for the public health, safety, or welfare and that strict conformity with the standards would be unreasonable, impractical, or not feasible under the circumstances. Fairmont, Minnesota 13 Worksheet

15 The variance application is reviewed by the MPCA and placed on public notice for a 30-day review and comment. The water quality variance for this Project is currently on notice concurrent with the EAW. Upon completion of the 30-day notice, the variance is presented to the MPCA Citizen s Board for a final decision. BLE has submitted a signed application requesting a variance for proposed Project, with a discharge to Judicial Ditch 18. The request asks variances from seven water quality standards based on provisions in Minn. R and in conformance with the provisions included in Minn. R , subp. 2. The variance request is directed at the final effluent limitations for total hardness; specific conductance; total dissolved salts (solids, or TDS); sodium; total salinity; sulfate; and boron derived from the underlying water quality standards in Minn. R and The MPCA, in proceeding to grant a variance, must consider the items listed in Minn. R and Minn. R BLE has provided information on the ground water concentrations of the salinity and related pollutants, found in Table 5. Four of the seven pollutants found in the ambient ground water would exceed surface water quality standards if discharged directly to surface waters without treatment. Table 5 - Ground water quality Pollutant Ground Water Surface water quality standard Total Hardness (mg/l) Specific Conductivity ( mhos/cm) 1,250 1,000 Total Dissolved Salts (Solids) TDS (mg/l) Sodium (meqs/l) 81.4 mg/l; 19% of cations- meq/l 60% of cationsmeq/l Total Salinity (mg/l) 622 1,000 Sulfates (mg/l) 468 1,000* Boron (ug/l) The pollutant concentrations will increase through the advent of their role in the ethanol process. Both cooling tower operations and reverse osmosis systems generate a waste stream that concentrate the naturally occurring elements found in the local ground water. Because the levels of salinity related parameters is already high in the ground water and the receiving water is a noncontinuous flow stream, it is reasonable, to expect the discharge to contain a suite of nonconventional pollutants at high levels which would cause or contribute to a violation of a water quality standard. As a result, it is expected that the post-process pollutant concentrations would be greater than the existing pollutant concentrations found in the source water. Another factor in this analysis is the function that stream flow plays with respect to water quality and effluent discharge. The greater the flow within receiving water, the greater amount of dilution can occur when an effluent stream is introduced. The discharge point for the Project is Judicial Ditch 18, located approximately Fairmont, Minnesota 14 Worksheet

16 0.69 miles from the ditch confluence with Center Creek. The outfall location is in the NW¼, SW¼, NW¼, Section 6, T102N, R30W. Judicial Ditch #18 has a low flow condition of 0.0 cubic feet per second, thereby making adequate dilution of the Project effluent stream unattainable even after treatment. As a result, the Project proposers will seek a variance from water quality standards. Flow rate in Judicial Ditch No. 18 will be dependent on precipitation, snow melt, any waters which might be discharged into the industrial storm sewer, and stormwater runoff from the industrial park and surrounding area. With the industrial storm sewer discharging at the headwaters into the ditch, there will be periods when the waste stream has the potential to essentially become the receiving stream. Variance Information and Assessment BLE has provided information on current uses of water in the area. No industrial, agricultural, or livestock surface water users have been identified from the proposed discharge point to the Blue Earth River confluence. The total hardness standards protects for industrial consumption, however, the receiving stream flow is too low to be used for industrial consumption. The specific conductivity, total dissolved salts, sodium and boron standards protect irrigation uses. The low flow condition prohibits irrigation uses. The total salinity and sulfate limits protect for livestock and wildlife watering uses; however, the receiving waters are not currently used to water livestock. The potential for wildlife to use the water for drinking is presumed to exist. This use cannot be controlled in the same manner that use for irrigation can be controlled, and it is possible that ambient sulfate concentrations in excess of the 1,000 mg/l water quality standard may occur during low flow situations. The MPCA has determined that 1,000 mg/l sulfate is the criterion that will protect wildlife from exposure to elevated sulfate concentrations as part of the narrative Class 4B standards (Minn. R , subp. 3) that permit their use by livestock and wildlife without inhibition or injurious effects. Elevated levels of total dissolved salts and sulfates can cause diarrhea in young animals like deer and upland game birds if these are the only water sources available. However, these animals are likely to be drinking from other streams and lakes, and not solely from this unnamed intermittent stream (Judicial Ditch No.18). The current ionic make-up projected for the effluent is difficult to evaluate for aquatic life, based on using simple proportional additivity of individual ion effects. The combination of the various major ions does not appear to suggest that toxicity is indicated. Sulfate and sodium ions will predominate in the effluent, but represent some of the least toxic of the major ions to aquatic life. MPCA staff does not believe that the proposed treatment at the plant will represent significant environmental harm to aquatic organisms that would be exposed to high salinity wastes in the receiving water. There is, however, no literature available that evaluates the effects of this particular combination and proportion of ions. Therefore, whole effluent toxicity (WET) testing is a better means of measuring the aggregate effects, including other pollutants (i.e., chemical additives) that may be in the effluent. WET monitoring requirements will be placed in the permit to evaluate the potential for toxicity to occur. An evaluation was completed for the occurrence of federally listed endangered and threatened species in the area and for conditions that could jeopardize endangered or threatened species. There are no identified endangered or threatened species on the federal list in the area that would be affected by the discharge. This information has been supplied by the Minnesota Department of Natural Resources. Fairmont, Minnesota 15 Worksheet

17 Interim Permit Limits The interim permit limitations applicable to the discharge at permit issuance are found in the following table. The monthly average limitation is based on applying the projected effluent concentration as a long term average plus an allowance (~ 15 percent) for a monthly average upper bound limit. This limit accounts for aquifer water quality and system performance variability, which reflects the higher postprocess pollutant concentrations with respect to the initial ground water concentrations found in Table 6. Table 6 - Interim effluent limitations based on currently achievable treatment Pollutant Interim Effluent Limitations Total Hardness (mg/l) 340 Specific Conductivity ( mhos/cm) 4,340 Total Dissolved Salts (Solids) TDS (mg/l) 3,061 Sodium (meq/l) 90 % Total Salinity (mg/l) 2,290 Sulfates (mg/l) 1,980 Boron (ug/l) 2,860 The mass limitations are calculated from these concentration limits and the Project design flows. There will be a permit condition requiring submission to the MPCA of an annual status report outlining the review of the status of potential new treatment technologies that may result in further reasonable progress towards attaining the standards for any or all of these pollutants. There will also be a requirement to conduct chronic WET test monitoring. These tests will evaluate whether there is any toxicity to live aquatic organisms that indicate that class 2 aquatic life uses are not being met. These tests will be scheduled quarterly for the first year and annually thereafter to determine the magnitude and variability of toxicity, if any were to exist. Conclusion In sum, information provided in the proposal on the discharge indicates that projected pollutant levels will exceed the water quality-based effluent limits. BLE has applied for a variance from the surface water standards on the basis that compliance with the limits is unreasonable and impractical. MPCA staff believes that if the variance is granted, discharge at the interim effluent limitations will have minimal impact on the existing beneficial uses of Judicial Ditch #18 and ultimately, Center Creek. Interim limits are based on levels currently anticipated as achievable. The receiving stream is not used for stock watering, and young deer or upland game birds have other streams and lakes that also could be utilized for watering purposes. The final water quality-based effluent limitations effective at the end of the variance are placed in the permit (See Table 7). The final WQBEL for each pollutant was derived using the water quality standard set as the waste load allocation, and then as the monthly average permit limit. Progress Fairmont, Minnesota 16 Worksheet

18 towards achieving the standards will be evaluated by the submittal of annual reports on technology advances and any additional monitoring activities that may be taken. Table 7 - Final water quality-based effluent limitations effective at the end of the variance Pollutant Final Effluent Limitations Total Hardness (mg/l) 250 Specific Conductivity ( mhos/cm) Total Dissolved Salts (Solids) TDS (mg/l) Sodium (mg/l) 1, % of cations-meq/l Sanitary Wastewater Total Salinity (mg/l) 1,000 Sulfates (mg/l) 1,000* Boron (ug/l) 500 * Numeric interpretation of the narrative water quality standard for class 4B waters Sanitary wastewater from the proposed Project will be routed and discharged to the Fairmont Waste Water Treatment Plant (WWTP). An on-site sanitary sewage treatment system is not planned. Waste from a Potential Plant Upset If the alcohol content of the product is low, the facility can recycle product at numerous stages within the process to adjust the alcohol content. The proposed Project will recycle product whenever possible. In the rare event that the feedstock becomes sour (i.e., no longer functional for ethanol production), the materials would be sold to local livestock farmers to be used as animal feed. 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. Domestic wastewater is planned to be discharged to the Fairmont WWTP. The estimated total domestic wastewater is up to 5,500 GPD 45 to 55 employees at 100 gallons per person per day. A written agreement detailing any pre-treatment provisions is not anticipated since only domestic wastewater would be discharged. The Fairmont WWTP was designed to accommodate 3.9 million GPD of effluent discharging to the Blue Earth River via Center Creek. Their current NPDES permit was issued in October of 2002 and will be current until September of Due to the relatively small quantity of domestic wastewater discharge proposed, no modifications to the existing NPDES/SDS Permit for the WWTP are expected as a result of the proposal. Fairmont, Minnesota 17 Worksheet

19 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. 19. Geologic hazards and soil conditions. a. Approximate depth (in feet) to Ground water: 80 minimum; 85 average. Bedrock: 285 minimum; 318 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. Average depth to ground water and bedrock was obtained from well logs of surrounding wells and verified during the installation of the facility production well. The potential also exists for areas of perched shallow ground water in certain locations within the property boundaries; however, published information seems to indicate that these areas are isolated and no nearby wells are finished in a surficial aquifer formation. The assessment for potential geologic hazards was based on information obtained from the University of Minnesota, Department of Geology and Geophysics and the DNR Division of Waters. According to these sources, no known geologic hazards or karst conditions exist on the site. b. Describe the soils on the site, giving SCS classifications, if known. Discuss soil granularity and potential for ground water contamination from wastes or chemicals spread or spilled onto the soils. Discuss any mitigation measures to prevent such contamination. Based on the National Resource Conservation Service s Soil Survey Geographic Database (SSURGO), the following soils at the site are identified as being present at the site: Table 8 Soils Encountered at the BLE Site Soil Map Soil Name Highly Erodible 1 Hydric Soil Prime Farmland 2 Unit Symbol 102B Clarion loam (1-6% slopes) No No Yes 113 Webster clay loam No Yes Yes 118 Crippin loam No No Yes 130 Nicollet clay loam No No Yes 336 Delft loam No Yes Yes 886 Nicollet-Crippin complex No No Yes 887B Clarion-Swanlake loams (2-6% No No Yes slopes) 921C2 Clarion-Storden loam (6-12 % No No Yes slopes, eroded) 956 Canistee-Glencoe clay loams No Yes Yes Fairmont, Minnesota 18 Worksheet

20 Notes: 1 Hazard for erosion was determined using K factors and wind erodibility groups for each soils. A soil with a K factor greater than 0.33 and/or a wind erodibility group less than 4 was considered highly erodible. 2 Includes soils listed as prime farmland if irrigated or drained and farmland of statewide importance. Exact locations of these soils with respect to the property boundaries and proposed facility location are represented on Figure 7. Mitigation measures for preventing soil and ground water contamination include the development of both a construction and operational SWPPP, as well as a Spill Prevention Control and Countermeasures (SPCC) Plan for facility operations. The facility would use storage tank and load-out containment structures as part of spill prevention planning for the operations. 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. Waste resulting from construction debris would be properly disposed of at an approved demolition landfill. A cold lime softener would be used to treat the facility make-up water. This unit would generate approximately 12.2 tons per day of non-hazardous dewatered lime softener waste. Approximately three tons of this material would be water. This material would be sent to a local landfill; however, it has the potential to be land applied as a soil additive. If the facility pursues land application once operation has begun, an individual or general SDS permit would be required for the land application activities. The only hazardous waste generated by the proposed Project would be from solvents used for washing parts, lubricating oils and laboratory wastes. 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 ground water. 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. An 8,100-gallon aqueous ammonia storage tank would be included in the development. Ammonia is used for ph adjustment and within the ethanol production process. A 248,500-gallon denaturant tank containing gasoline would also be added. Both ammonia and pentane, a component of the denaturant, are regulated chemicals with respect to Risk Management Planning. The facility would be required to develop a Risk Management Plan (RMP), as well as a Process Safety Management plan, which would identify risks associated with the presence of these materials and establish protocols for the prevention of releases, as well as response procures in the unlikely event of a release. The implementation of these procedures, as well as other BMPs, would be used to help prevent potential contamination of the ground water from these materials. Fairmont, Minnesota 19 Worksheet

21 As previously described, the only hazardous waste generated by the proposed Project would be from solvents used for washing parts, lubricating oils and laboratory wastes. A very small quantity hazardous waste generator permit is required. Application for that permit would be submitted prior to startup. These wastes would only be stored temporarily on site in appropriate containers then transported and disposed of by a licensed hazardous waste disposal or recycling company. 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. The following tanks would be included as part of the proposed BLE project: Table 9 List of Major Tanks for the Proposed BLE Project Tank Description/Contents Construction Capacity (gallons) Fermenter #1 Water/corn solids/ethanol Stainless Steel 814,800 Fermenter #2 Water/corn solids/ethanol Stainless Steel 814,800 Fermenter #3 Water/corn solids/ethanol Stainless Steel 814,800 Fermenter #4 Water/corn solids/ethanol Stainless Steel 814,800 Fermenter #5 Water/corn solids/ethanol Stainless Steel 814,800 Fermenter #6 Water/corn solids/ethanol Stainless Steel 814,800 Fermenter #7 Water/corn solids/ethanol Stainless Steel 814,800 Fermenter #8 Water/corn solids/ethanol Stainless Steel 814,800 Beerwell Water/corn solids/ethanol Stainless Steel 1,058,000 Ethanol Day Tank Ethanol Carbon Steel 213,700 Ethanol Day Tank Ethanol Carbon Steel 213,700 Denaturant Tank Gasoline Carbon Steel 248,500 Denatured Ethanol Tank Denatured Ethanol Carbon Steel 1,227,100 Denatured Ethanol Tank Dentaured Ethanol Carbon Steel 1,227,100 One secondary containment area is planned for regulated ASTs at the facility. The tank farm would contain the two ethanol day tanks, the denaturant tank, and the two denatured ethanol storage tanks. It would be a lined and bermed secondary containment structure with the capacity to contain at least the entire contents of the largest tank plus ten percent excess capacity for stormwater containment. No underground piping is planned for the facility. Product transfer would be carried out on impervious surfaces within a dike to contain potential releases at the tank connection and at the transfer vehicles. Any liquid in the diked secondary containment would drain into a sump. On an as needed basis, the liquid would be tested for contamination and then discharged to the detention pond. In the event that the liquid is contaminated, the liquid would be pumped out and disposed of properly by a licensed professional. Storage tanks located within buildings would be designed and managed according to AST regulations. The facility would have a SPCC plan that would include: a description of the facility, tank capacities, spill prevention and secondary containment measures at the facility, and maximum potential discharge that could occur at the facility. Documentation that adequate personnel and equipment are available to respond to a discharge along with evidence that prearrangements for such response have been made would also be included in the plan. A copy of the plan would be retained on-site at all times. Also, as described in Minn. Stat. 20.B, an RMP plan would be required to address aqueous ammonia and pentane potentially present in the denaturant. Fairmont, Minnesota 20 Worksheet

22 21. Traffic. Parking spaces added: 56 (includes 30 spaces for Existing spaces (if project truck staging) involves expansion): NA Estimated total average daily traffic generated: 144 vehicles Estimated maximum peak hour traffic generated (if known) and its timing: 90 % between Provide an estimate of the impact on traffic 8:00am and 5:00pm 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. County State Aid Highway (CSAH) 39 and Interstate 90 would be the primary transportation routes for trucks traveling to and from the facility. CSAH 39 is currently rated as a 10-ton road, and Interstate 90 is rated as a 10-ton road. BLE representatives have had preliminary discussions with the City of Fairmont regarding the proposed project, include the increased truck traffic. The Project proposers would work with both the city of Fairmont and MNDOT to negotiate road upgrade with may be required to address the proposed traffic increases. 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. The following table summarizes potential to emit emission estimates from truck traffic at the proposed facility: Table 10 Estimated Truck Traffic Emissions PM PM 10 (tpy) (tpy) Truck Traffic Tons per year (TPY) Particulate Matter (PM) The estimates calculated above are based on truck traffic activity summarized in the following table: Activity Quantity Transported per truck Table 11 BLE Truck Traffic Analysis No. of Trucks (truck/yr) Approx. Miles Traveled On-site per Truck (miles/truck) Annual Mileage (VMT/yr) DDGS load-out* 25 tons 7, ,481 Ethanol load-out* 8,000 gal 7, ,320 Denaturant delivery* 8,000 gal VMT - vehicle miles traveled * Ethanol and DDGS load out and Denaturant delivery will be a maximum of 50 percent by truck. 23. Stationary Source Air Emissions. Describe the type, sources, quantities and compositions of any Fairmont, Minnesota 21 Worksheet

23 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. Sources of Air Emissions and Pollution Control Equipment The following is a summary of air emission sources and emission control equipment at the facility. The Project proposers would hold an Air Emission Permit, granted by the MPCA, and would operate according to the requirements listed in this permit. Grain Receiving and Handling. Grain for the facility would be provided by the adjacent Cargill Ag Horizons grain elevator. Corn would be transferred from elevator storage bins via a closed conveyance system directly to the facility corn weighing and transfer facilities, where it would be sent directly to milling. A small, approximately 120,000 bushel, corn storage bin would be located at the ethanol facility in the event of transfer equipment failure. Fugitive particulate emissions from conveyors, the corn bulk weigher, corn elevator, and corn storage bin would be exhausted through negative pressure ventilation systems which continuously pull air from these sources through baghouses. Grain Milling and Handling. Grain leaving the Cargill Ag Horizon elevator, and/or grain transferred from the on-site day storage bin, would be weighed and fed directly into the hammermill system. Milled grain from the hammermills would be mechanically conveyed in a closed system to the slurry mix tank. The hammermills would be controlled via baghouses. Batch Fermentation. The process of fermenting sugar to ethanol produces carbon dioxide as a major byproduct. For the Project operation, fermentation would occur in eight batch fermentation tanks. Vents from the fermenters, along with vents from other atmospheric vessels associated with fermentation and mash cooling, would be tied to the inlet of a direct contact counter-current water scrubber. The gas entering this scrubber flows upward and water flows downward through a bed of polypropylene packing entraining VOCs present in the gas stream. The water is returned to the process stream via a continuous blow-down. CO 2 and other non-condensing gases exiting the scrubber would be vented to the atmosphere. Distillation/Dehydration. The fermentation process results in beer, which would be ran through a continuous distillation system to separate and purify the ethanol. The vapor from the distillation columns is piped to a set of condensers that discharge liquid back to the columns. Non-condensable gases and CO 2 contained in the beer are exhausted to the fermentation scrubber to control emissions before being discharged to the atmosphere. DDGS and Handling Wet solids from the distillation process would move into one of six centrifuges where liquids are separated from the solids. The liquids are evaporated to a syrup. Wet distillers grain are dried in a dryer system, consisting of two natural gas fired-dryers connected in parallel, where wet material is moved through the dryer. Syrup produced by the evaporators is mixed with the dried grain solids to produce DDGS. Forced air and solids leaving the dryer are sent to cyclones used to separate the dried grain. The excess exhaust gases not recycled to the dryer inlet would be routed to one of the two TO/Heat Recover Steam Boilers. Emissions generated from the centrifugation and evaporation process would be routed through the fermentation scrubber. DDGS would be transferred from the coolers to the DDGS storage building via closed conveyance systems. Product would then be conveyed to load-out for shipping either via truck or unit train. DDGS Fairmont, Minnesota 22 Worksheet

24 conveyance, storage, and load-out systems would be controlled through baghouse controls. As previously described, the Project will employ an alternative operating scenario of wetcake production. Emissions resulting from the production, storage and load-out of wetcake have been estimated in the air permit application; however, since the production of this product results in less overall emissions than does the production of the same unit of DDGS using the proposed controls, DDGS production was considered worse-case for total facility potential to emit. Ethanol Storage Tanks. The product would pumped daily from the 200-proof condenser into one of the two 213,700-gallon day tanks. A small amount, approximately 5 percent, of unleaded or natural gasoline is pumped from the 248,500-gallon denaturant storage, mixed in-line with ethanol from the day tanks, and transferred to one of the two 1,227,100-gallon denatured ethanol storage tanks. All storage tanks referenced above would be located above ground and in a lined diked area. Each tank would be equipped with a fire valve, a level gauge, overfill protection, an emergency vent and a pressure vacuum vent. VOCs emissions from these tanks are included in the total facility emissions. Emissions from ethanol truck and rail load-out would be routed to the ethanol load-out flare. TO/Heat Recovery Boiler. Two, 145 MMBtu/hour natural gas-fired TO/Heat Recovery Boilers would be used to provide steam for cooking and as air emission control devices. Emissions from the DDGS driers, the distillation and dehydration process, the syrup evaporation process, and the ethanol load-out process would be routed through these units, which would be vented to the atmosphere through a common stack. Additional Facilities. The Project has included the installation of a 27.2 MMBTU/hr diesel-fired emergency generator. The generator would provide emergency power to operate essential processes in the event of a power outage. For the purpose of emissions estimation, 100 hours per year of operation has been assumed. In addition, the Project will include the installation of a fuel oil-fired fire water pump associated with a fire water storage tank. The pump would deliver water for fire suppression purposes and has been assumed to operate 100 hours per year for the purpose of emissions estimation. The Project will be a synthetic minor source with respect to both the prevention of significant deterioration (PSD) and the Title V Permitting process under the federal Clean Air Act (CAA), meaning the facility would not emit 100 or more tons per year of any of the Title V CAA air pollutants based on the proposed air emission control technology. Emissions for criteria pollutants resulting from the ethanol facility and the Cargill operations are predicted to be as follows: Fairmont, Minnesota 23 Worksheet

25 Table 12 - Total Potential Facility Emissions Pollutant Proposed Emissions (TPY) Particulate Matter (PM) Particulate Matter less than 10 Microns (PM 10 ) Carbon Monoxide (CO) Nitrogen Oxides (NO x ) VOCs Sulfur Dioxide(SO 2 ) Total HAPs Individual HAP (Acetaldehyde) 9.06 Ambient Air Quality and PSD Increment Analysis. Due to the close proximity of the facility to a major source for air emissions, the proposed facility completed an ambient air quality and PSD increment analysis to ensure that the proposal meets ambient air quality standards and federal PSD regulations regarding new air pollution sources. The U.S. Environmental Protection Agency (USEPA) and the state of Minnesota have established National and Minnesota Ambient Air Quality Standards (NAAQS and MAAQS, respectively). These standards are designed to protect public health and the environment. Air dispersion modeling was used to determine if the proposed project would violate either NAAQS or MAAQS standards. The modeling used site and project-specific factors, such as topography, meteorological data, emission projections, and stack information, to predict ambient air concentrations at and beyond the facility boundary. Because the neighboring source is a significant contributor of PM 10 emissions, and not other criteria pollutants, and because the proposed facility would be a minor source with respect to PSD and Title V Permitting, only PM 10 was considered in the NAAQS/MAAQS modeling; there are no specific MAAQS PM 10 standards. As shown in Table 13, the Project as proposed would not violate ambient air quality standards. PSD Increment Analysis. The federal PSD regulations include an increment consumption program that places a ceiling on the total amount of new air pollution allowed resulting from new sources to prevent significant deterioration of air quality. Once a baseline date is established, all new sources of that pollutant combined are not allowed to exceed the PSD increment as determined by a dispersion modeling analysis. For Class II areas, as Fairmont is classified, NO 2, PM 10, and SO 2 would be considered in the analysis. However, as previously mentioned, because the neighboring source is a significant contributor of PM 10 emissions, and not other criteria pollutants, and because the proposed facility would be a minor source with respect to PSD and Title V Permitting, only PM 10 was considered in the PSD increment analysis. As shown in Table 10, the proposed project would not consume excess increment. Fairmont, Minnesota 24 Worksheet

26 Table # 13- Ambient Air Quality and PSD Increment Standards and the Modeled Results Pollutant PM 10 Averaging Period 24-Hour Annual Category Modeled Impact [1] ( g/m 3 ) Standard ( g/m 3 ) Primary/Secondary NAAQS PSD Increment/Class II Primary/Secondary NAAQS [2] PSD Increment/Class II Notes: [1] Modeled impact values are maximum predicted concentrations including the respective background air concentration for comparison to the NAAQS and MAAQS. [2] Maximum predicted concentration for receptors not located on Cenex Harvest States property. See BLE Air Dispersion Modeling Analysis for additional information. g/m 3 = microgram per cubic meter An Air Emissions Risk Analysis (AERA) has been developed for the Project. The AERA process was developed by the MPCA with the intention of screening air emissions from facilities with the potential to pose unacceptable risks to the public. Air quality modeling was used to develop site-specific dispersion factors to complete the Risk Analysis Screening Spreadsheet. As demonstrated in the project AERA, the potential emissions screen below MPCA-established health risk benchmarks. 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.) Odors: Fermentation tanks and the DDGS dryers are generally considered to be the main contributors to odor issues at ethanol facilities. Emissions directly from the fermentation process would be controlled by the fermentation scrubber. BLE is proposing to install two TO/Heat Recovery Boilers through which exhaust from the DDGS dryers would be routed. No impact to neighbors is expected, except if unlikely process upsets occur. BLE has completed a Best Management Plan which addresses BMPs that will be required at the facility to further reduce odors. The draft Best Management Plan has been attached as Exhibit 2. Noise: Noise or sound is a mixture of tones of varying amplitude, frequency and duration. The intensity of sound waves produces a Sound Pressure Level (SPL), which is commonly measured in a unit called the Decibel (db). An A-weighting scale (dba) is applied to the sound measurements to adjust for the sensitivity of the human ear. For comparison purposes, a rural residential area is approximately dba, conversational speech is 60 dba and a chainsaw is 90 dba. Actual measured rural SPLs may be higher due to insect or highway noise. A doubling of similar sound pressure levels will result in an increase of 3 db. When a distance is doubled from a point source, the sound pressure level is decreased by six db. Fairmont, Minnesota 25 Worksheet

27 Operational Noise Impacts. Noise monitoring completed by Natural Resource Group at a similar ethanol facility designed by the same engineering firm has been used to assess future impacts from as the proposed BLE facility. Noise levels obtained from operational equipment has indicated that cooling towers (80.8 dba), hammer mills pumps (85.6 dba for two hammer mill pumps) and conveyor systems/motors (77.5 dba) are generally the highest noise sources. Although these noise sources may not be directly next to each other, to determine the worst case scenario, the noise sources of cooling towers, four hammer mills, and conveyor systems/motors are logarithmically added together to produce a combined noise source in A- weighted decibels. Using a map that identifies all receivers within a one-mile radius of the facility, the shortest distance from the receivers to the nearest noise producing equipment is used to calculate a sound level at the receivers, taking credit for distance attenuation. The calculated distance attenuated sound level is then compared to the Minn. R. ch This method of calculation is usually more conservative than noise modeling efforts, which also factor sources of noise attenuation such as vegetative cover, topography, nearby buildings, and exact noise source locations. The logarithmic addition of the potential noise sources that will be present at the facility gives a total predicted noise contribution of 89.6 dba from the facility. Noise loss from the noise source to the noise sensitive area (NSA) is calculated using the equation SPL 2 = SPL 1+20Log 10 (d 1 /d 2 ), where SPL 2 is the sound pressure level at the NSA, SPL 1 is the sound pressure level contribution from the noise source, d 1 is the distance from the noise source that the reading was taken, and d 2 is the distance to the NSA. The results of the noise analysis are contained in the following table: Noise from Source (dba) Table 14 - Estimated Future Noise Levels BLE Distance from noise generating unit (ft) Direction to noise sensitive area Background noise (dba)* Applicable MN Noise Standard (dba) Contribution from facility (dba) NSA ,300 Northeast NSA ,330 Southeast NSA ,580 North NSA ,830 Northwest *Estimate of background noise for suburban area. Additional noise would be generated as a result of truck and rail traffic to and from the facility to deliver raw materials and loadout finished products. These noise levels would be intermittent, with the bulk of the traffic occurring during the daytime hours. The main truck receiving and shipping route for the facility would be County State Aid Highway 39, which connects to I-90. To limit the amount of noise contributed from the truck traffic, drivers would be instructed not to use Jake brakes for deceleration. Applicable Noise Regulations. Minnesota regulates noise through Minn. R. ch The state noise rules establish Noise Area Classifications (NACs). The nearest noise sensitive area (NSA) to the proposed BLE project site is a residence, which is regulated under NAC #1. To be in compliance with NAC #1 standards, the facility cannot contribute greater than a daytime (7 AM - 10 PM) L 50 SPL of 60 dba and a nighttime L 50 of 50 dba. The L 50 is defined as a sound level, expressed in dba, which is exceeded 50 percent of the time for a one-hour survey. Less stringent L 10 SPLs also apply; however, since the facility will be a constant noise source (i.e., operating 24 hours per day), the more stringent L 50 is used for regulatory purposes. As shown in table 10, the estimated future noise levels would be at or below acceptable continuous noise levels. Fairmont, Minnesota 26 Worksheet

28 There are no applicable noise regulations for Martin County or the city of Fairmont. However, a conditional use permit would be required from the city of Fairmont. When making a decision to grant a conditional use permit, a facility must demonstration that it would not cause offensive odors, fumes, dust, noise, and vibration that would be injurious or a nuisance to adjacent uses and the surrounding area. Although the project site is currently zoned agricultural, the area is set to be annexed into the city limits and zoned as industrial. As previously mentioned, the general project vicinity contains other industrial and/or commercial businesses, as well as fairgrounds and I-90, which also contribute to the sound characteristics of the area. For this reason, a suburban noise level of 45.6 dba was estimated from the March 1974 USEPA document, Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. According to the document, A Guide to Noise Control in Minnesota, published by the MPCA and revised in March 1999, an increase or decrease of three decibels is the threshold of perceived noise change for the human ear. As demonstrated by Table 10, the estimated future noise attributable to the facility at the nearest NSA would be 2.6 dba higher than the estimated background noise, which would be near or less than the threshold of perceived noise change. Noise Mitigation Measures. No specific noise mitigation measures were included when estimating the future noise attributable to the proposed facility at nearby receptors, with the exception of distance attenuation. Additional potential sources of noise attenuation such as vegetative cover, topography, or other constructed features were not considered in the evaluation. Construction Noise Impacts. The construction of the proposed facility would generate temporary noise impacts. The main source of construction noise would be heavy equipment. The use of this equipment would be restricted to daylight hours. Dust: Some dust would be generated during the construction process. BMPs for dust management would be included in the SWPPP for construction activities, including wetting disturbed areas and revegetation. Emissions of particulate matter resulting from operation of the facility have been included in the potential to emit calculations, submitted with the air permit application. Sources of particulate matter emissions, as well as emission controls, have been described in Minn. Stat 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. Fairmont, Minnesota 27 Worksheet

29 An archaeological review request was submitted to the SHPO. As indicated by SHPO, no properties listed on either the National or State Registers of Historic Places, and no known or suspected archaeological properties in the area would be impacted by the development of the proposed project (see Exhibit 3). Based on data received from the U.S. Department of Agriculture Natural Resources Conservation Service SSURGO database, all soils located within the property boundaries are listed as prime farmland or farmlands of statewide importance, either directly, or if drained or irrigated. Once construction is complete, approximately 101 acres of prime farmland would remain. These areas would continue to be used for agricultural purposes as part of the proposed project. 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. Visible water vapor plumes would be emitted from stack associated with the TO/Heat Recovery Boilers and potentially from the cooling towers. The height of the boiler stack would be 140 feet. The water vapor may condense creating a visible plume depending on weather conditions. Cold weather tends to cause condensation of water vapor before it disperses, creating a visible plume. While the relatively high stack heights would create a large visibility distance for the potential plumes, the high stack heights, along with thermal destruction of VOCs, reduce the potential for odor problems or health impacts associated with the facility. The cooling towers are somewhat less likely to create a visible plume as the emitted water vapor is less saturated than that originating from the dryers. 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. Although the project is not subject to a local comprehensive plan, the proposed project area is currently zoned as a JobZ development area. In addition, the proposed project area is adjacent to an existing industrial park and is consistent with the city of Fairmont s long-range planning goals for the area. Project proposers have met with city of Fairmont officials regarding the project, and utilities and infrastructure are being planned with the city engineer and city administrators. 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.) Electric, natural gas, potable water and sewer are available in the general vicinity of the site. Some or all of these services would likely need to be expanded to meet development needs. 29. Cumulative impacts. Minn. R , subp. 7, item B requires that the RGU consider the cumulative potential effects of related or anticipated future projects when determining the need for an environmental impact statement. Identify any past, present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative impacts. Describe the nature of the cumulative impacts and summarize any other available information relevant to Fairmont, Minnesota 28 Worksheet

30 determining whether there is potential for significant environmental effects due to cumulative impacts (or discuss each cumulative impact under appropriate item(s) elsewhere on this form). The Project is not currently planning any actions in connection with this proposed action that have not been addressed in this evaluation. Cumulative impacts include those caused by the addition of the project to past, present, and reasonably foreseeable future activities. The following is a summary of the issues included in the overall impact analysis. Air Quality: An air permit application identifying the proposed facility as a synthetic minor source with respect to PSD and the Title V Permitting process under the federal Clean Air Act (CAA) has been submitted. The emissions estimated within the permit application include those from the proposed facility, as well as the existing Cargill Ag Horizons facility. An AERA was completed for the potential facility emissions. All constituents analyzed by the AERA process believed to be present in the facility emissions screened under MPCA designated thresholds. Greenhouse Gases (GHG): This facility will not impact atmospheric concentrations of GHGs at any level that might be measurable. Emission sources of GHGs are typically global in nature. In aggregate, human-related emissions of GHGs total approximately 25 billion metric tons, in contrast to which emissions from this facility are miniscule. In addition, the transportation motor fuels produced at this facility will, on a fuel-cycle basis, offset some emissions that otherwise would have resulted from the combustion of motor gasoline. Blended in an E10 mixture, the use of ethanol in place of motor gasoline will result in a fuel-cycle GHG emission reduction of several percent per mile traveled. Water Quality: The Project proposer is introducing a new discharge to an impaired water body, Center Creek via Judicial Ditch 18 and Lily Creek. Center Creek is impaired for ammonia, fish IBI, turbidity, and fecal coliform, to which the proposed discharge would not appreciably contribute. A variance and non-degradation review has been conducted as a means to develop Project specific water quality discharge limits for the Project. An NPDES/SDS discharge permit has been drafted which is protective of designated uses of Judicial Ditch 18, Lily Creek, and Center Creek, as well as the pollutants for which Center Creek is impaired. The water quality discharge developed through the variance process will provide new limits that will be placed in the NPDES discharge permit for the Project and are protective of water quality standards including the protection of beneficial uses. Ground Water: The Project proposer intends to install at least one production well (though likely two) to accommodate the water needs of the facility. The proposal to reuse the cooling tower blowdown and boiler blowdown would lower the overall projected water use for the facility, as compared to other similarly designed facilities. The DNR has been contacted regarding the project and is currently working with the Project proposer regarding well installation, pump testing requirements, and monitoring requirements regarding well interference issues. Surface Water/Stormwater: Although additional impervious surfaces would be generated from the construction of the proposed facility, an industrial stormwater pond would be added, allowing for control of stormwater discharges. Industrial stormwater would be discharged to the City of Fairmont s municipal storm sewer system, and the city of Fairmont would require stormwater planning and controls be implemented to comply with MPCA stormwater permitting requirements. Additionally, the city of Fairmont would require that post-improvement run-off from the site not exceed pre-development run-off conditions. Fairmont, Minnesota 29 Worksheet

31 Transportation: The city of Fairmont has been contacted regarding the Project. Project representatives would work both with the city and MNDOT to determine what, if any, road improvements would be necessary to accommodate the additional traffic generated as a result of the development. Odor: A best management plan for odor management has been generated for the facility. Additionally, dryer emissions would be controlled either by the TO/Heat Recovery Boiler. The Project has proposed wetcake production as an alternative operating scenario. This would result in less overall emissions. Odors would be controlled from wetcake through ensuring that no spoilage occurs. Noise: Noise generating units would be added as a result of the development. All applicable state noise standards would be met at surrounding receptors. Row Crop Agriculture: The proposed Project will process corn, grown locally, into fuel ethanol. Row crop corn production can adversely impact the environment (e.g., surface water) if improperly managed. All acreage that is employed in corn production for this Project has been in agricultural production historically and will continue to stay in production for the lifetime of the Project. The new production capacity for the Project will rely upon existing, rather than new, corn production. The advent of corn production and processing in context to this Project is not reasonably expected to create a significant environmental impact, nor is it likely to contribute to an adverse environmental impact, as there will not be any specific change in historic land use activities. Toxic/Hazardous Chemicals: An aqueous ammonia storage tank and denaturant tank would be included in the development. Both ammonia and pentane, a component of the denaturant, are regulated chemicals with respect to Risk Management Planning. The facility would develop an RMP to address these chemicals. The Project as proposed does not reasonably present a significant and irreversible impact to the environment. The Project includes applicable and effective air emission control technology and environmental management practices that substantially reduce potential impacts to the environment. 30. Other Potential Environmental Impacts. If the project may cause any adverse environmental impacts not addressed by items 1 to 28, identify and discuss them here, along with any proposed mitigation. Not Applicable. 31. Summary of issues. List any impacts and issues identified above that may require further investigation before the project is begun. Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues, including those that have been or may be ordered as permit conditions. None. Fairmont, Minnesota 30 Worksheet

32

33 !!!! Mountain Lake Butterfield FIGURE 1 Windom 60 Cottonwood Watonwan tu 169 Blue Earth Mapleton Truman Trimont Winnebago Jackson Jackson 90 Sherburn Martin Site Location [_ Fairmont Blue Earth Faribault 90 tu 71 Elmore Spirit Lake Estherville !! Miles Buffalo Center This information is for environmental review purposes only. Z Buffalo Lake Energy, LLC Figure 1 County Location Map Fairmont, MN DATE: 09/07/05 REVISED: 09/07/05 SCALE: 1:400,000 DRAWN BY:KJANDERSON M:\Clients\A-C\BFS\Aghorizons\Fairmont \_ArcGIS\2005\09\County.mxd

34 FIGURE 2 Site Boundary Proposed Pipeline 0 1,000 2,000 3,000 Feet This information is for environmental review purposes only. Buffalo Lake Energy, LLC Figure 2 Proposed Ethanol Site Site Location Map Fairmont, MN DATE: 03/10/06 REVISED: 03/10/06 SCALE: 1:35,000 DRAWN BY:RSMcGREGOR M:\Clients\A-C\BFS\Aghorizons\Fairmont\ _ArcGIS\2006\03\_Figure2.mxd

35

36 FIGURE 4 Site Boundary Proposed Pipeline ,000 2,000 Feet This information is for environmental review purposes only. Buffalo Lake Energy, LLC Figure 4 Aerial Photograph of Proposed Site Fairmont, MN DATE: 03/10/06 REVISED: 03/10/06 SCALE: 1:20,000 DRAWN BY:RSMcGREGOR M:\Clients\A-C\BFS\Aghorizons\Fairmont\ _ArcGIS\2006\03\_Figure4.mxd

37 FIGURE 5 SD001 Surface Discharge Location Proposed Pipeline Site Boundary 0 1,000 2,000 3,000 Feet This information is for environmental review purposes only. Buffalo Lake Energy, LLC Figure 5 Water Intake/Discharge Locations Map Fairmont, MN DATE: 09/07/05 REVISED: 02/10/06 SCALE: 1:24,000 DRAWN BY: KRSOLBERG M:\Clients\A-C\BFS\Aghorizons\ Fairmont\_ArcGIS\2005\09\discharge

38 FIGURE 6 Proposed Pipeline Site Boundary NWI Wetland 0 1,000 2,000 Feet This information is for environmental review purposes only. Buffalo Lake Energy, LLC Figure 6 National Wetlands Inventory Map Fairmont, MN DATE: 03/10/06 REVISED: 03/10/06 SCALE: 1:24,000 DRAWN BY:RSMcGREGOR M:\Clients\A-C\BFS\Aghorizons\Fairmont\ _ArcGIS\2006\03\_Figure6.mxd

39 FIGURE B 921C B 921C2 887B 102B B B Site Boundary Soils Data Soil Unit 102B - Clarion Loam (1-6) Webster Clay Loam Crippin Loam Nicollet Clay Loam Delft Loam Nicollet-Crippin Complex 887B - Clarion-Swanlake Loams (2-6) 921C2 - Clarion-Storden Loams Eroded (6-12) Canisteo-Glencoe Clay Loams 0 1,000 2,000 3,000 Feet This information is for environmental review purposes only. Buffalo Lake Energy, LLC Figure 7 Soils Data Map Fairmont, MN DATE: 03/10/06 REVISED: 03/10/06 SCALE: 1:24,000 DRAWN BY:RSMcGREGOR M:\Clients\A-C\BFS\Aghorizons\Fairmont\ _ArcGIS\2006\03\_Figure7.mxd

40 FIGURE 8 Wells Site Boundary Commercial Domestic Irrigation 0 1,000 2,000 Feet This information is for environmental review purposes only. Buffalo Lake Energy, LLC Figure 8 Well Location Map Fairmont, MN DATE: 03/10/06 REVISED: 03/10/06 SCALE: 1:24,000 DRAWN BY:RSMcGREGOR M:\Clients\A-C\BFS\Aghorizons\Fairmont\ _ArcGIS\2006\03\_Figure8.mxd

41 Figure 9 - Aquifer Cross Section Map Source: Geologic Atlas Martin County, Minnesota. Water Resources Center, Mankato State University, 1991

42 EXHIBIT 1