poet biorefining - glenville west (ethanol facility) environmental

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Page 1: POET Biorefining - Glenville West (Ethanol Facility) Environmental
Page 2: POET Biorefining - Glenville West (Ethanol Facility) Environmental

POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 1 Worksheet

ENVIRONMENTAL ASSESSMENT WORKSHEET Note to reviewers: The Environmental Assessment 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 651-297-8510. An electronic version of the completed EAW is available at the MPCA Web site http://www.pca.state.mn.us/news/eaw/index.html#open-eaw. 1. Project Title: POET Biorefining – Glenville West 2. Proposer: POET Biorefining – Glenville West 3. RGU: Minnesota Pollution Control Agency Contact Person Erin B. Heupel, P.E. Contact Person Steven W. Sommer and Title Lead Environmental Engineer and Title Project Manager Address 4615 North Lewis Avenue. Address 520 Lafayette Road North Sioux Falls, South Dakota 57104 St. Paul, Minnesota 55155-4194 Phone 605-965-3591 Phone 651-282-5851 Fax 605-965-2203 Fax 651-297-2343 4. Reason for EAW Preparation:

EIS Scoping

Mandatory EAW

X

Citizen Petition

RGU Discretion

Proposer Volunteered

If EAW or EIS is mandatory give EQB rule category

subpart number and name: Minn. R. 4410.1000, subp. 2 and Minn. R. 4410.4300, subp. 5.B. Fuel Conversion Facilities

5. Project Location: County Freeborn Twp Freeman 1/4 1/4 Section Township 101 North Range 21 West

The proposed project is located between 160th Street (north) and 150th Street (south) in the W½ of the W½ (except the SW¼ of the SW¼ ) of Section 1, and the NE¼ and the SE¼ of Section 2, Township 101 North, Range 21 West, Freeman Township.

Page 3: POET Biorefining - Glenville West (Ethanol Facility) Environmental

POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 2 Worksheet

Figures and Exhibits attached to the EAW: Figures Figure 1 – Site Location Map Figure 2 – Process Flow Diagram Figure 3 – Land Use Map Figure 4 – Potential Receptors Map Figure 5 – Site Layout Figure 6 – Wetlands Map Figure 7 – Area Well Location Map Figure 8 – Geologic Cross Section in Vicinity of Facility Figure 9 – Facility Water Balance Figure 10 – Utility Connection Map Figure 11 – Outfall Location Map Exhibits Exhibit 1 – Minnesota Department of Natural Resources (DNR) Natural Heritage Inventory Response Letter,

dated April 6, 2007 Exhibit 2 - Freeborn County Natural Resource Conservation Service, Highly Erodible Soils and Wetland

Response Letter Dated May 30, 2007 Exhibit 3 - Minnesota State Historic Preservation Office (SHPO) Correspondence

6. Description:

a. Provide a project summary of 50 words or less to be published in the EQB Monitor.

POET Biorefining–Glenville West (Glenville West), proposes to construct a dry mill ethanol facility (Facility) located in Freeborn County, near the city of Glenville, Minnesota. The Facility will have the capacity to produce 65.7 million gallons per year (MMGPY) of undenatured ethanol (69 MMGPY denatured), 200,000 tons per year (TPY) of Distillers’ Dried Grains with Solubles (DDGS), and up to 30,000 TPY of Wet Distillers’ Grains with Solubles (wetcake) for use as a high protein animal feed. Glenville West proposes to withdraw a maximum of 650 gallons of water per minute (GPM) from two ground-water sources and will be a zero-discharge facility (i.e., no process or non-process utility wastewater will be discharged).

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. Overview Glenville West proposes to construct a dry mill ethanol production facility near the city of Glenville, Minnesota, in Freeborn County (Figure 1). The Facility will process approximately 24.4 million bushels of corn (683,280 tons) per year to produce approximately 65.7 MMGPY of undenatured ethanol (69 MMGPY denatured). In addition to fuel grade ethanol, the Facility will produce DDGS. DDGS is a co-product of ethanol production generated from spent grain. DDGS will be sold as animal feed. The DDGS production rate will be approximately 200,000 TPY. The Facility may also generate up to 30,000 TPY of wetcake. Wetcake is spent grain that has not been dried and is also sold as animal feed. The Facility will burn natural gas for steam generation. Corn and ethanol will be transported by trucks and rail.

Page 4: POET Biorefining - Glenville West (Ethanol Facility) Environmental

POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 3 Worksheet

The Facility will be located to the northwest of the city of Glenville on a 235-acre parcel, generally bound by 160th Street (Township Road Number T-51) to the north and by 780th Avenue to the east. The existing POET Biorefining-Glenville East (Glenville East) facility is located southeast of the proposed Glenville West Facility (Figure 1). Glenville East is also a fuel ethanol plant with the capability of producing 50 MMGPY of ethanol. Glenville East formerly did business as EXOL. EXOL changed its name to POET Biorefining–Glenville East in 2007. Glenville East and Glenville West are independent facilities and will not share local management, operating staff, utilities, process equipment, grain receiving, or storage systems. However, both plants will be franchised under the POET Biorefining name and operated by POET Plant Management. SoyMor is a biodiesel fuel production facility that is located just south of Glenville East. SoyMor is an independent facility with its own local management. Construction Construction of the Glenville West Facility is expected to be completed within 14 to 16 months of receiving all required permits. Site development will include removal of the existing residence and construction of new process buildings, roads, and a new rail spur. Approximately 31 acres of the site will be covered with bituminous paving. An additional 30 acres of the site will be covered by buildings or structures. The project will also require expanding an existing rail siding that runs along the eastern boundary of the proposed site. Summary of Ethanol Production Process The following process description summarizes each process as it will exist at the Facility upon completion of construction. Figure 2 shows the Facility’s process flow diagram. Corn Receiving and Storage Glenville West will receive corn in a receiving building from hopper-bottom and end-dump type trucks. The trucks will off-load grain into one of two grain receiving pits. Hopper-bottom trucks will off-load via choke flow. Glenville West anticipates that over 90 percent of the trucks will be hopper-bottom trucks. The grain will be removed from the receiving pit by an enclosed conveyor or grain auger and transferred to a grain leg. The grain leg will elevate the grain to a head house and distribution conveyor. The grain will be conveyed to three grain storage bins. The grain receiving system will have a maximum capacity of 840 tons per hour. The grain receiving building, grain auger and leg, upper grain conveyor, and grain bins will be aspirated to a fabric filter for dust control. The grain receiving area will be equipped with negative air aspiration to a dust collector both in the grain receiving pit itself and in the general above grade area around the grain receiving pit designed to minimize any fugitive dust emissions. In addition, the grain receiving building will be equipped with high-speed doors that will be closed during receiving operations. Corn will be removed from the storage bins using an enclosed conveyor or grain auger and then transferred to a grain leg. The grain will be fed into a corn scalper to clean the grain of dirt and debris. Following cleaning, the grain will be transferred into a surge bin. The grain cleaning system will have a maximum capacity of 140 tons per hour. The grain conveyor, leg, scalper and surge bin will be aspirated to a fabric filter for dust control. Hammermills The corn will be gravity fed from the surge bin via spouts into one of five hammermills. The hammermills grind the corn to the appropriate size for optimal fermentation. Each hammermill will be aspirated to its own fabric filter for dust control and will have a maximum processing capacity of 20 tons per hour for a total capacity of 100 tons per hour.

Page 5: POET Biorefining - Glenville West (Ethanol Facility) Environmental

POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 4 Worksheet

Fermentation The ground corn is mixed with water to form a mash and is pumped to one of five batch fermentation tanks. Yeast and gluco-amylase enzyme is added to the mash. The enzymes break down the dextrins in the mash to glucose, which is converted to ethanol and carbon dioxide (CO2) by the yeast. The fermented mixture is called beer. The beer contains approximately 12 percent ethanol. After the fermentation process is complete, the entire contents of the fermentation tank are pumped to the beer well. The CO2, which is saturated with ethanol, is vented from the fermentation tanks to a single pass wet scrubber. The ethanol is adsorbed in the water. The fermentation process also produces small amounts of methanol and acetaldehyde. These compounds, when emitted to the atmosphere, are hazardous air pollutants (HAPs). The scrubber water also adsorbs these pollutants. The scrubber is designed to remove 95 percent of the ethanol and 50 percent of the HAPs. The scrubber water is pumped to the mash tank for reuse. The gases from the fermentation scrubber are vented to a regenerative thermal oxidizer (RTO) to further reduce the ethanol and HAPs emitted to the atmosphere. The RTO will achieve a 98 percent destruction efficiency for the ethanol and HAPs. Distillation/Dehydration Beer is pumped continuously from the beer well to the top of the distillation column. The beer flows down through the distillation column. Steam is injected at the bottom of the distillation column. The steam evaporates the ethanol from the water and remaining corn solids. The ethanol vapor rises through the column into a rectifier, where it is further concentrated to approximately 186 proof. Following the rectifier, the ethanol vapor is pumped through a vaporizer/superheater and then to one of three molecular sieve beds. The molecular sieve beds adsorb the remaining water from the ethanol vapor. The ethanol vapor is condensed resulting in 200-proof ethanol. The condensed ethanol is pumped into storage tanks. The molecular sieves are regenerated by imposing a vacuum on the bed. The water and any remaining ethanol are extracted from the bed and condensed. This condensate is approximately 110 proof and is recycled back to the rectifier. The water from the distillation column and rectifier (also called stillage), along with the remaining solids (spent grain), are pumped to four centrifuges for separation into a thin stillage fraction and a solids fraction. The thin stillage is pumped to an evaporator. The evaporator uses steam to make syrup that contains approximately 30 percent solids. The syrup is pumped to a mixer where it is mixed back into the solids fraction. The solids fraction and syrup mixture is sent from the centrifuges to dryers and then to the co-product processing. The non-condensable gases from the distillation system, the beer well, and the centrifuges are vented to the RTO. The RTO will remove at least 98 percent of the ethanol and HAPs contained in the non-condensable gases. Following distillation and dehydration, the ethanol is pumped into aboveground storage tanks. Each tank is equipped with an internal floating roof for volatile organic compound (VOC) control. Four storage tanks (T001 to T004) are designed for ethanol storage. The fifth aboveground storage tank, T005, is designed to store a denaturant, either natural gas liquids or unleaded gasoline. All ethanol produced at this Facility will be denatured prior to shipping. Co-Product Processing The solids fraction and syrup mixture is conveyed into one of two natural gas-fired ring flash dryers operated in parallel. The dried product, called DDGS, is dropped out of the dryers through drop boxes into a pneumatic fluid bed cooler. The cooler has two purposes, to cool the DDGS and to pneumatically convey the DDGS product to a storage silo.

Page 6: POET Biorefining - Glenville West (Ethanol Facility) Environmental

POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 5 Worksheet

The combustion products and water vapor from the dryers are vented to product recovery cyclones to remove the remaining entrained DDGS. This DDGS also goes into the pneumatic fluid bed cooler. The exhaust gases from the DDGS cyclones are vented to the RTO for pollution control. The air from the DDGS pneumatic fluid bed cooler is vented through a fabric filter to the atmosphere. After drying, the DDGS contains a small amount of ethanol. This ethanol is emitted with the air from the pneumatic cooler. From the pneumatic cooler, the DDGS is transferred into a storage silo. The air from the storage silo is vented through a fabric filter. The DDGS will be loaded into rail cars and trucks in a DDGS loadout building. The dust emissions from rail loading operations will be controlled by a fabric filter. Occasionally, due to process upsets, off-spec DDGS may be generated from the dryers. In this event, the off-spec DDGS will be separated from the pneumatic cooler by a filter/receiver and transferred to flat storage inside a building. The off-spec DDGS will be sold into the marketplace as off-spec product. Off-spec DDGS is a dry product and is not expected to cause odor or other problems. Additional Facility Components Boilers Two 143-million British thermal units (MMBTU)/hour natural gas fired boilers will provide process steam for the Facility. Emergency Diesel Generator The Facility will have one 2,000-kilowatt diesel-fired electric generator for emergency power. The generator is of sufficient size to operate emergency shutdown systems, lighting systems, cooling tower water pumps and limited ancillary equipment. The DDGS dryers, RTO, centrifuges, boilers, and other process systems will not be powered by the emergency generator. Cooling Towers The Facility will operate a four-cell cooling tower that will use fresh ground water and treated, recycled process water to cool process equipment. The cooling water will not come into direct contact with any materials used in the process. Product Shipping Ethanol will be shipped from the Facility by both rail and truck. Rail and truck loading racks will be constructed for this purpose. Glenville West will install a flare system to control VOC emissions from the ethanol loading racks. The rail and truck loadouts will be connected to the flare. Sanitary Wastewater Sanitary wastewater for Glenville West will be discharged to the city of Albert Lea’s Publicly-Owned Treatment Works (POTW). Process Wastewater Treatment System All process wastewater used in producing ethanol will be treated and recycled within the Facility. No process wastewater will be discharged. Non-process Utility Wastewater Non-process utility wastewater (i.e., reverse osmosis [RO] reject water, cooling tower blowdown water, cooling tower filter backwash, and water polishing softener regenerant) will be recycled for reuse in the Facility using a cold lime softening (CLS) system, sand filters, and RO systems. No non-process utility wastewater will be discharged from the Facility.

Page 7: POET Biorefining - Glenville West (Ethanol Facility) Environmental

POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 6 Worksheet

Stormwater Stormwater associated with the developed areas of the Facility will be routed to three on-site detention basins. The stormwater basin located near in the northwestern area of the site will discharge to an unnamed ditch that flows west, approximately three-quarters of a mile toward County Ditch 16, which is a tributary of the Shell Rock River. The stormwater basins located in the northeast and south central areas of the site will discharge to an unnamed ditch that flows south approximately three-quarters of a mile to County Ditch 16. The following list summarizes the proposed equipment for the Glenville West Facility: (a) One (1) grain receiving and handling operation consisting of the following:

1. Two (2) truck dump pits 2. Two (2) grain legs and conveying system 3. Three (3) grain bins

(b) One (1) corn scalper (c) One (1) surge bin (d) Five (5) hammermills (e) One (1) fermentation process. This process consists of the following:

1. One (1) slurry tank 2. Five (5) fermenters 3. One (1) yeast propagation tank 4. One (1) beer well

(f) One (1) regenerative thermal oxidizer using natural gas as fuel (g) One (1) distillation process consisting of the following:

1. One (1) beer stripper 2. One (1) rectifier column 3. One (1) side stripper 4. One (1) set of three (3) molecular sieves 5. One (1) set of four (4) evaporators

(h) One (1) set of four (4) centrifuges (i) Two (2) natural gas fired DDGS dryers (j) Two (2) natural gas fired boilers (k) One (1) fluidized DDGS cooler (l) One (1) DDGS handling and storage operation consisting of the following:

1. One (1) DDGS storage silo 2. One (1) DDGS silo bypass 3. One (1) DDGS storage building

(m) One (1) DDGS loadout operation consisting of the following: 1. One (1) DDGS conveyor 2. One (1) DDGS truck loadout spout 3. One (1) DDGS rail loadout spout

(n) One (1) ethanol loading system consisting for one (1) rack for trucks and two (2) racks for railcars (o) One (1) diesel powered emergency generator (p) One (1) diesel fuel tank (q) One (1) off spec ethanol tank for 190-proof ethanol, with a maximum capacity of 250,000 gallons (r) One (1) 200-proof ethanol tank with a maximum capacity of 250,000 gallons (s) One (1) denatured ethanol tank with a maximum capacity of 2,000,000 gallons

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POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 7 Worksheet

(t) One (1) denatured ethanol tank with a maximum capacity of 2,000,000 gallons (u) One (1) denaturant tank with a maximum capacity of 126,900 gallons of natural gasoline (v) One (1) thin stillage tank with a maximum capacity of 500,000 gallons (w) One (1) syrup tank with a maximum capacity of 61,000 gallons

c. Explain the project purpose; if the project will be carried out by a governmental unit, explain the need for the project and identify its beneficiaries. The purpose of this project is to initiate ethanol manufacturing and its co-product DDGS and increase economic development in Glenville, Minnesota. The Facility will employ approximately 40 full-time employees.

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)

235

or Length (miles)

~ 1 mile rail spur along existing Glenville East/ SoyMor rail spur & ~ 500 foot extension of 780th Avenue

Number of Residential

Units: Unattached

NA

Attached

NA

Maximum Units Per Building:

NA

Commercial/Industrial/Institutional Building Area (gross floor space):

total sq. feet

79,800

Indicate area of specific uses (in square feet):

Office

~5,000 Office and Scale House

Manufacturing ~46,500 under roof ~7,500 Fermentation Tank Area

Retail

Not Applicable

Other Industrial ~20,800 Mechanical Buildings 75,000 Ethanol Storage Tank Area

Warehouse Not Applicable Institutional Not Applicable Light Industrial Not Applicable Agricultural Not Applicable Other Commercial (specify) NA Building height See Below If over 2 stories, compare to heights of nearby buildings See Below

Height of Proposed New Buildings/Structures

Equipment/Building Name Height (feet above grade) Grains Building 47 Mechanical Building A 44 Mechanical Building B 36 Process Building A (Motor Control Center) 50 Process Building B (Fermentation Support Equipment) 67 Process Building C (Slurry/Evaporation) 72 Process Building D (Dryer Building) 95 Distillation Building 95

- continued -

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POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 8 Worksheet

Equipment/Building Name Height (feet above grade)

Cooling Tower Motor Control Center 30 Grain Bins 105 Storage Tanks 60 Cooling Tower 35 Stack 001 – Grain Receiving, Conveyors, Storage Bins 105 Stack 002 – Hammermill Conveyors, Surge Bin 68 Stack 003 – Corn Hammermill #1 15 Stack 004 – Corn Hammermill #2 15 Stack 005 – Corn Hammermill #3 15 Stack 006 – Corn Hammermill #4 15 Stack 007 – Corn Hammermill #5 15 Stack 008 – Fermentation Stack Bypass 68 Stack 009 – RTO Stack 100 Stack 010 – DDG Fluid Bed Cooler 100 Stack 011 – DDG Silo Loading 112 Stack 012 – DDG Silo Bypass 30 Stack 013 – Boiler #1 75 Stack 014 – Boiler #2 75 Stack 015 – Diesel Generator 10 Stack 016 – Truck and Rail Ethanol Loading Rack 20 Stack 017 – DDGS Rail Loadout 115 Stack 018 – Lime Silo 60

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.

Unit of Government Type of Application Status Air Emissions Permit Submitted Individual Industrial Stormwater Permit Submitted State Operating Permit for Zero Discharge System Submitted Hydrostatic Test Water Discharge Permit Submitted Stormwater Construction Permit To be submitted Above Ground Storage Tank Permit Submitted

MPCA

Small Quantity Hazardous Waste Generator License Submitted DNR Water Appropriation Permit To be submitted U.S. Army Corps of

Engineers (USACE) Wetland Jurisdictional Determination(1) Submitted

Freeborn County Highly Erodible Soil and Wetland Certification Complete/No highly erodible soils present

Rezoning Request/Conditional Use Permit Complete/Property rezoned

Building Permit Submitted Utility Permit Submitted

Wetland Conservation Act Permit To be submitted (1) If the USACE determines that the wetland to be permanently impacted by the project is within USACE

jurisdiction, a wetland permit will be obtained from the USACE.

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POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 9 Worksheet

Permitting for the natural gas pipeline is the responsibility of the natural gas supplier through its contract with Glenville West. Glenville West has applied for Tax Increment Financing (TIF) from Freeborn County. Freeborn County has not made a determination regarding the TIF as of the date of this EAW. Glenville West contacted the Minnesota Department of Transportation (MNDOT), Freeborn County, and Freeman Township to determine if permits are required for the construction of roads or access ways to the proposed Facility. No permits or authorizations are required from these governmental agencies.

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 Glenville West Facility will be located in Freeman Township, Minnesota, which is approximately one mile northwest of the city of Glenville. Figure 3 shows the land use within an approximate six-mile or ten-kilometer radius of the proposed Facility location. A total of 18 potential sensitive receptors, consisting of farmsteads/residences, were identified within one mile of the proposed site (Figure 4). The nearest residence is located approximately one-third mile northeast of the proposed Facility.

The 235-acre Facility site consists of a single farmstead and two very small wooded areas. The site has historically been used for farming. The farmstead consists of a single residence with outbuildings and water well. The well will either be abandoned (sealed) in accordance with the Minnesota Department of Health (MDH) regulations or be used as a potable water supply for the Facility. The remainder of the property is agricultural land. The agricultural land has been used for row crops, primarily corn and soybeans. Approximately 25 acres of the site is grassland.

Site development will include the removal of the existing residence. Construction of the following items will also occur: grain handling/storage systems, ethanol processing building, ethanol storage/loadout systems, associated rail spurs, and paved roads. Approximately 31 acres of the site will be covered with bituminous paving. An additional 30 acres of the site will be covered by buildings or structures. As shown on Figures 1 and 5, Glenville West will be installing approximately 10,000 linear feet of rail spurs on the property as well as approximately 9,000 linear feet of rail in a corridor that will run parallel to the existing rail spur that serves Glenville East and SoyMor. The new rail spur corridor is approximately 5,000 feet long and will connect to the existing Union Pacific rail line to Glenville West without disrupting rail operation at Glenville East and SoyMor.

The property to the southeast of the proposed Facility is occupied by Glenville East, a fuel ethanol production facility and SoyMor, a 30-MMGPY soybean oil based biodiesel facility. The remaining properties surrounding the Glenville site are agricultural in nature with several residences present. Most of the land is used for row crops, such as corn and soybeans. No change is expected to these land uses as a result of the construction of the Glenville West Facility.

The MPCA databases for leaking underground storage tanks, aboveground storage tanks, and the ‘What’s in my Neighborhood’ database of potential sources of soil and ground-water contamination were reviewed. There is no known soil or water contamination on the project site from past land uses.

The Glenville West project will require expanding an existing rail siding that runs along the eastern boundary of the proposed site. This rail siding is currently used by the Glenville East and SoyMor facilities. The proposed Glenville West Facility is being designed to receive and handle trains of approximately 70-80 cars at a time. Based on the projected production capacity of Glenville West, it is

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POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 10 Worksheet

anticipated that the area will see a maximum increase of one train per day (100-150 trains on an annual average basis). The proposed site and railroad spur are located within 1,000 feet of the Union Pacific Railroad mainline tracks. According to the Union Pacific Railroad, the nearby section of the mainline currently handles an average of 11 trains per day, which typically travel at 50 miles per hour. As shown in Figure 4, the nearest residence is approximately one-third mile northeast from the proposed site. Due to the relatively high train traffic currently passing through the area, it is not expected that any nearby residence will experience a significant increase in noise or light disturbance as a result of this project. Due to the low degree of expected impact, no noise or light mitigation measures are proposed for this project.

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 2.4 1 Lawn/landscaping <1 <1 Wooded/forest <1 <1 Impervious Surfaces <1 ~61 Brush/grassland 25 ~168 Other (describe) Rail

Spurs 0 ~7.4

Cropland 210 0 TOTAL ~237.4 ~237.4

Construction of the proposed off-site rail spur will result in permanent impacts to 1.4 acres of Type 1 wetland. Glenville West will apply to Freeborn County for permission to permanently impact this wetland area. The proposal will protect the wetland areas that are not proposed to be impacted and ensure that wetland mitigation, if approved, is completed at a 2:1 ratio (minimum) per acre of impacted wetland. Final approval rests with Freeborn County.

11. Fish, Wildlife, and Ecologically Sensitive Resources.

a. Identify fish and wildlife resources and habitats on or near the site and describe how they would

be affected by the project. Describe any measures to be taken to minimize or avoid impacts.

Project Site/Rail Spur and 780th Avenue Extension Corridors Existing wildlife species within the vicinity of the project area are typical of this type of land use in southern Minnesota, including deer, squirrels, rabbits, small mammals, snakes, turkeys, songbirds, amphibians, raptors, and waterfowl. In the short term, animals will leave the area due to Facility construction activities. After construction is completed, undeveloped areas of the proposed site will no longer be cropped. The proposed site is currently in use as agricultural cropland and is not considered high quality wildlife habitat. Glenville West proposes to plant grasses in the cropland not used for project facilities. Thus, it will become available for use as habitat by the species currently found in the project vicinity.

Fish – County Ditch 16 Glenville West will discharge stormwater to County Ditch 16 via two outfalls. Outfall 001 will be located along the south edge to the site and will direct stormwater via a manual overflow valve to an unnamed ditch that flows south to County Ditch 16. Outfall 002 will be located near the northwest corner of the site and will direct its stormwater via a manual overflow valve to a ditch that flows west parallel to County Road 51 (160th Avenue) to County Ditch 16. County Ditch 16 is located west and south of the Facility and is an unlisted water, as defined in Minn. R. 7050.0430. County Ditch 16 is tributary to the Shell Rock River and has a drainage area of approximately 1.4 square miles, with 86 percent coming from agricultural lands. Biologically, County Ditch 16 has not been evaluated or rated by the MPCA or DNR in terms of its quality as fish and invertebrate habitat. An increase in total suspended solids and excess nutrients typically occurs during times of high rainfall as a result of increased runoff from agricultural lands. Increased turbidity and decreased levels of oxygen provide poor habitat for aquatic species. Stormwater discharges

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POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 11 Worksheet

from the stormwater outfalls will be controlled through the installation and operation of stormwater detention basins and manual shutoff valves at the outfalls. The outfall structure will incorporate best management practices (BMPs), such as rock riprap, to minimize and potential erosion at the discharge point and will not result in a degradation of County Ditch 16.

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 20070625 Describe measures to minimize or avoid adverse impacts.

The DNR Natural Heritage and Nongame Research Program completed a database analysis of the site for the potential presence of rare plant communities, threatened, or endangered species or species of concern at the project site, rail spur corridor, and 780th Avenue extension corridor.

In a letter dated April 6, 2007 (Exhibit 1), the DNR identified two plant species, Sullivant’s Milkweed (Asclepias sullivantii) and Valerian (Valeriana edulis ssp. Ciliate) as having been observed on prairie remnants within the right-of-way of the Union Pacific Railroad. The Union Pacific railroad right-of-way is located along the south side of Highway 65 and joins the northeast section of the site, shown in Figure 1.

Glenville West completed surveys of the site, along the Union Pacific railroad track right-of way, along the proposed rail spur corridor, and 780th Avenue extension corridor for these two plant species. Neither species was observed on the site, along the railroad track right-of way, along the proposed rail spur corridor, or along the 780th Avenue extension corridor. Based on land use and history, no threatened or endangered species or species of concern are expected to be on the project site.

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. Wetlands Wetland delineations were completed in November 2006 and May 2007. Figure 6 shows the location of the wetlands identified during the delineations. Table 12-1 below, quantifies the temporary and permanent impacts resulting from the proposed project.

November 2006 Delineation The November 2006 wetland delineation (report dated January 26, 2007) surveyed an area that includes the Facility’s proposed rail spur corridor. The delineation identified three wetland areas (i.e., A, B, and C) within the delineated area, including one wetland within the rail spur corridor. Glenville West submitted a jurisdictional determination request to the USACE regarding the wetlands delineated in November 2006 on October 23, 2007. A formal response to the jurisdictional determination request has not been received by the date of this EAW. However, the following summary indicates Glenville West’s proposed impacts to these wetlands:

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POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 12 Worksheet

Wetlands A and C will not be impacted. Wetland B is proposed to be permanently impacted by Glenville West’s proposed rail spur corridor.

Approximately 1.4 acres along the southern edge of this wetland will be permanently affected by the construction of the rail spur. The permanent impacts to Wetland B will require an approval from Freeborn County Environmental Services as the local governmental unit responsible to implement the Wetland Conservation Act. In addition, if the USACE determines that the wetland is within USACE jurisdiction, the permanent impacts will require a wetland permit from the USACE.

May 2007 Delineation The May 2007 wetland delineation surveyed an area that includes the proposed Facility site. The delineation identified three additional wetlands (i.e., 1, 2, and 3) within the delineated area, including one wetland within the proposed Facility site. Glenville West submitted a jurisdictional determination request to the USACE regarding the wetlands delineated in May 2007. Glenville West received verbal response on September 27, 2007, concluding that none of these delineated wetlands were within the USACE’s jurisdiction. Wetlands 1-3 will not be impacted.

Table 12-1 Summary of Identified Wetlands and Impacts

Wetland ID

Wetland Type Wetland Area (acres)

Temporary Impacts (acres)

Permanent Impacts (acres)

A PUBNx, Type 4 1.1 0 0 B PEMAdf, Type 1 2.6 0 1.4 C PEMBdf/PUBHx, Type 2 5.9 0 0 1 PEMA, Type 1 0.3 0 0 2 PEMC, Type 3 6.4 0 0 3 PEMC, Type 3 0.7 0 0

Surface Water Bodies Glenville West will not discharge process or non-process utility wastewater to any surface water bodies. Glenville West will direct stormwater runoff to on-site stormwater detention basins via storm drains and surface flow. Stormwater detention basins will be located in the northeast, south, and northwest areas of the site, as shown on Figure 5. Stormwater collected in the northeast detention basins will overflow to the south stormwater detention basin via an on-site drainage channel along the rail spur. The south stormwater detention basin will overflow (Outfall 001) via a manual shutoff valve to an unnamed ditch that flows south to County Ditch 16. The northwest stormwater detention basin will overflow (Outfall 002) via a manual shutoff valve to a ditch that flows parallel to County Road 51 (160th Avenue) west to County Ditch 16. Figure 11 shows the location of Outfalls 001 and 002 and the proposed surface flow to County Ditch 16.

The stormwater detention ponds will be designed to allow sediment in the stormwater to settle out before the water is discharged. The timing and flow of stormwater will be controlled using manual shutoff valves at the outfalls. The outfall structures will incorporate BMPs, such as rock riprap, to minimize any potential erosion at the discharge point and will not result in a degradation of County Ditch 16.

The Facility National Pollutant Discharge Elimination System/State Disposal System (NPDES/SDS) Permit will require that Glenville West prepare a Stormwater Pollution Prevention Plan (SWPPP) that will detail the BMPs, spill response actions, and routine inspections that Glenville West will use to prevent adverse impacts to the stormwater.

Sanitary wastewater will be discharged to the city of Albert Lea’s POTW.

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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. The source of water for the proposed Glenville West Facility will be ground water from two new process water wells (PW1 and PW2) and one existing potable well. The existing potable well is identified as Minnesota Unique Well (MUW) #226727 and is located at a former farmhouse on the proposed Facility property. PW1 is identified as MUW #51006 and is located in the northwest corner of the property. PW2 is identified as MUW #751018 and is located in the southwest corner of the property. See Figure 7 for the location of PW1, PW2, and the potable well (labeled as ‘8’ on the figure). The DNR requires a Water Appropriation Permit for all water users withdrawing more than 10,000 gallons per day (GPD) or 1 MMGPY. Table 13-1 summarizes the projected maximum water use for Glenville West.

Table 13-1

Glenville West - Water Use GPM GPD MMGPY Maximum Make-up Water Demand 650 936,000 342

Glenville West will apply for a Water Appropriation Permit from the DNR. The permit application will request authorization to appropriate a maximum of 650 GPM and a total annual appropriation of 342 MMGPY. There will be no connections or changes to any public water supply due to this project. Glenville West has designed and constructed the make-up water system to supply 650 GPM from either process water well. Therefore, only one process well will be used at a time. The second process well will be used as a backup when the primary well is being maintained. The two new process water wells were installed according to the proposed 2007 MDH potable water well rules. Hydrogeology The area is underlain by less than 100 feet of Quaternary deposits that consist of till layers, lenses of sand, and gravel alluvium. In general, two distinct clay units of significant thickness are present across the project area that may protect the underlying aquifers from surface contamination, prevent direct recharge to the aquifer during testing, and separate surface water features and wetlands from the underlying aquifers. Ground water in sand and gravel lenses at shallow depths is used by domestic and farmsteads within the area. The primary source of ground water for the area is the Upper Cedar Valley aquifer, which is approximately 100 feet thick and composed of dolomite and dolomitic limestone. The Upper Cedar Valley aquifer is separated from the Lower Cedar Valley aquifer by the Chickasaw shale formation. The Lower Cedar Valley aquifer is underlain by the Spillville Formation, which is also composed of dolomite and dolomitic limestone. Figure 8 contains a representative cross-section of the hydrogeology of the project area. The cross-section was obtained from the Mower County Geologic Atlas, Part B and Part C County Geologic Atlas Series C-11. While the project area is located in Freeborn County, the bedrock geology is similar to that presented in the Mower County Geologic Atlas.

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The two process wells (PW1 and PW2) at the Facility are each approximately 300 feet deep and will draw water from the Devonian Upper Cedar Valley, Lower Cedar Valley, and the Spillville aquifers, known as the Cedar Valley Aquifer. To supplement the available record on the area hydrogeology and support the water appropriation, Glenville West completed site-specific studies to evaluate the underlying aquifers and the impact of operating the process water well. This evaluation consisted of the completion of an existing well inventory, an aquifer test, and data analysis. Area Wells Prior to initiation of the aquifer test, an inventory of water supply wells was completed to determine the use, location, and depth of all wells within a 1.5-mile radius of each of the Facility’s production wells. Sources used to complete the inventory included the County Well Index, aerial photography, previous aquifer testing reports, field reconnaissance and discussions with local residents. This research indicated that 59 residential wells and 3 process water wells (Glenville East) were present within a 1.5-mile radius of the proposed Facility (Figure 5). In addition, two (2) municipal wells for the city of Glenville lie just outside the 1.5-mile search radius. The Glenville East and city of Glenville wells were the only large appropriators of ground water located in the project vicinity. The Glenville East wells are regulated under Water Appropriation Permit No. 98-5102 and the city of Glenville wells are regulated under Water Appropriations Permit No. 75-5108. The SoyMor facility does not have its own process water well. SoyMor purchases its process from the Glenville East facility. The results of the inventory indicated that of the residential wells identified within the 1.5-mile radius, 30 withdraw ground water from the Upper and Lower Cedar Valley Aquifers and 4 withdraw ground water from the Quaternary deposits. The aquifer of the remaining wells could not be determined due to lack of published information, the well owner denying access, or the structural condition of the well. The three wells operated by Glenville East and the two wells operated by the city of Glenville withdraw ground water from the Upper Cedar Valley, Lower Cedar Valley, and Spillville Aquifers. Aquifer Test The DNR required the completion of an aquifer test to evaluate water availability. An aquifer test is completed to determine potential impacts on the source aquifer, surrounding water supply wells, and any nearby surface water features. The aquifer test was completed from June 26 to July 13, 2007, according to DNR protocols. The DNR required that 14 of the wells identified as part of the water supply well inventory be observed for aquifer drawdown as part of the aquifer test. To be conservative and ensure that the aquifer can produce the requested water appropriation on a sustained basis, the aquifer test was performed by pumping PW2 at 800 GPM until the DNR was satisfied that the aquifer drawdown at PW2 had stabilized (seven days) and then allowing the aquifer to recover. Water levels were recorded continuously at PW2 and the 14 observation wells throughout the test to evaluate the amount of drawdown across the area. After the PW2 pump was shut off on July 3, 2007, water level data was collected for an additional nine days to monitor the recovery of hydraulic head across the area. The data indicate that water levels recovered in approximately five days and that regional hydraulic head had declined approximately one foot due to lack of recharge. Table 13-2 summarizes the aquifer drawdown and its relationship to the pumping level in each of the observation wells.

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Table 13-2 Summary of Aquifer Test Results

Site ID

Depth (feet)

Aquifer Distance from PW2 (feet)

Drawdown Attributable to Pumping (feet)

Lowest Head Observed

(feet AMSL)

Pump Intake Elevation

(feet AMSL)

Water Above Pump Intake

(feet)

PW2 300 Cedar Valley 0 4.00 NA NA NA PW1 300 Cedar Valley 2,330 2.00 NA NA NA 10 142 Cedar Valley 5,000 1.88 1,219.19 1,192 20.19 68 370 Cedar Valley 10,000 1.88 1,210.95 1,070 140.95 17 285 Cedar Valley 4,700 1.85 1,211.47 1,187 24.47 8 87 Cedar Valley 3,330 1.84 NA NA NA

56 165 Cedar Valley 6,450 1.60 1,210.41 1,195 15.41 46 120 Cedar Valley 4,200 1.49 1,213.54 1,201 12.54 23 160 Cedar Valley 8,530 1.47 1,208.42 1,160 48.42 53 125 Cedar Valley 8,500 1.45 1,210.96 1,174 36.69

35A 71 Quaternary 1,150 1.44 1,212.69 1,185 27.69 2 156 Cedar Valley 7,600 1.41 1,212.49 1,165 47.41

12 165 Cedar Valley 7,800 1.32 1,209.46 1,174 35.46 4 184 Cedar Valley 2,560 1.15 1,209.78 1,146 63.78

65 100 Cedar Valley 7,500 0.94 1,210.74 1,196 14.74 40 120 Cedar Valley 8,200 NI 1,200.60 1,200 0.60

Site ID: Internal reference number that corresponds to wells shown on Figure 7 AMSL: Above Mean Sea Level NI: Not Influenced – well does not appear to be influenced by pumping at PW2 NA: Not Applicable – well is on the proposed site Quaternary – Well in sand and gravel aquifer

The confined nature of the aquifers is apparent as water level changes attributed to pumps turning on and off were observed at distances over one mile. Although the production wells influence the pressure head across the area, the magnitude of the head decrease is relatively small. As indicated in Table 13-2, four feet of drawdown was observed at PW2 and less than two feet of drawdown was observed off site. The measured aquifer drawdown attributable to pumping during the aquifer test was significantly less than the amount of water above the pump intake in each of the observation wells that were influenced by the test. Therefore, the withdrawal at a maximum of 650 GPM from process water wells at Glenville West will not cause well interference. Based on the analysis of drawdown data, the confined nature of the source aquifers, the depth of the aquifers, and the presence of clay layers above the aquifers, no adverse impacts are anticipated to nearby surface water features, including wetlands, as a result of the pumping at this site. The aquifer was stressed to a steady state condition during the test. Modeling showed the aquifer having sufficient capacity for present and future uses. The aquifers are capable of supporting the multiple uses in the area, including the proposed Glenville West ethanol plant, the city of Glenville, the Glenville East ethanol plant, and domestic/farmstead use. Safe Yield Evaluation The DNR Division of Waters uses a two-tiered aquifer threshold to manage water use and protect confined aquifers. The first threshold, at an elevation representing 50 percent of the pre-pumping available head, acts as a warning light to the appropriator. If water levels in the aquifer drop to the 50 percent threshold, Glenville West would be required to commence such actions as increasing the frequency of water level monitoring, investigating bringing an additional water source online, and planning to cut back the appropriation rate. The second threshold identifies the water elevation when pumping has lowered the water level such that only 25 percent of the pre-pumping available head remains. If the water levels drops

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to 25 percent threshold level, pumping must cease from the appropriate production well. Appropriation from the aquifer could not recommence until the static water level has returned to above the 50 percent threshold. Modeling based on the aquifer test showed that the safe yield thresholds will not be approached.

14. Water-related land use management districts. Does any part of the project involve a shoreland zoning district, a delineated 100-year floodplain, 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: ~100 acres; ~880,000 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.

Grading for the Glenville West Facility will be completed on approximately 180 acres of the 235-acre site. The site has areas of moderate terrain with slopes of 4:1. Therefore, deep grading zones are anticipated, and moderate grades will be created. The proposed construction will disturb greater than one acre. Therefore, a Stormwater Construction Permit is required from the MPCA. Glenville West will prepare and implement a SWPPP for the construction operations in accordance with the requirements of this permit. The SWPPP will focus on BMPs for erosion control, sedimentation control, and elimination of spills or releases of petroleum products from construction equipment. These BMPs may include installation of silt fences, temporary dams or weirs, maintaining existing vegetation or installation of a stormwater detention basin on site at the Facility. The specific erosion controls are described in the MPCA Publication, “Protecting Water Quality in Urban Areas.”

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 proposed project site is currently used for the production of row crops, generally corn and soybeans. As such, surface water runoff from the site may currently contain sediment and agricultural chemicals. Surface water runoff currently flows across the property to roadside ditches and then to County Ditch 16, which ultimately flows to the Shell Rock River. The project will add approximately 61 acres of new impervious surface and remove the remainder of the site from agricultural use. This will change the quality and quantity of stormwater runoff generated on the site. The BMPs, both structural and non-structural, will provide mitigation of these impacts.

Facility Construction During construction of the Glenville West Facility, runoff from the site will be handled as described in Question 16 to minimize adverse impacts to surface water quality.

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Facility Operation Production and storage of ethanol will take place either indoors or within secondary containment to prevent the mixture of process waste or finished product with stormwater. The opportunity for products and wastes to mix with stormwater would occur only with equipment failure or catastrophic weather events. The main opportunity for stormwater contamination at the Facility will be associated with material transfer. In an attempt to minimize contact of stormwater with raw or finished products, good housekeeping, maintenance, inspection, and training procedures will be implemented as directed by the SWPPP. As described in Question 12, stormwater detention basins will be included to help mitigate any spills that may occur. The stormwater outfalls will be manually controlled, using a shutoff valve, to allow for monitoring prior to discharge.

Wetcake will be stored outside in a concrete floored, open three-walled structure, which is equipped with a drive-over concrete containment berm on the fourth side. Wetcake will not be stored on site for more than 72 hours after its production. Any accumulation of stormwater in the wetcake storage pad will be captured and used in the ethanol production process.

The stormwater discharge requirements for the Glenville West Facility will be contained in the NPDES/SDS Permit. In accordance with the requirements of the permit, Glenville West will prepare an SWPPP. The SWPPP must include the BMPs, spill prevention procedures, spill response actions and routine inspections that Glenville West will use to prevent adverse impacts to the downstream surface water. The NPDES/SDS Permit will establish discharge standards, secondary water quality limits, for any industrial stormwater discharged.

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.

Stormwater runoff from Glenville West will be directed to on-site stormwater detention basins via storm drains and surface flow. Stormwater detention basins will be located in the northeast, south and northwest areas of the site as shown on Figure 5. Stormwater collected in the northeast detention basins will overflow to the south stormwater detention basin via an on-site drainage channel along the rail spur. The south stormwater detention basin will overflow (Outfall 001) via a manual shutoff valve to an unnamed ditch that flows south to County Ditch 16. The northwest stormwater detention basin will overflow (Outfall 002) via a manual shutoff valve to a ditch that flows parallel to County Road 51 (160th Avenue) west to County Ditch 16. Figure 11 shows the location of Outfalls 001 and 002 and the proposed surface flow to County Ditch 16. County Ditch 16 joins the Shell Rock River approximately 2.5 miles southeast of the Facility. The Shell Rock River is currently listed by the MPCA as impaired for turbidity and has been proposed to be listed as impaired for pH. The limits and monitoring conditions contained in the NPDES/SDS Permit will ensure that the proposed stormwater discharge from Glenville West will not contribute to the turbidity or pH impairments of the Shell Rock River.

18. Water Quality – Wastewater.

a. Describe sources, composition and quantities of all sanitary, municipal and industrial

wastewater produced or treated at the site. Sanitary Wastewater Sanitary wastewater will be generated from restrooms, kitchens, and the quality assurance laboratory. Glenville West estimates this flow will be approximately 1,000 GPD. This wastewater will be discharged to the city of Albert Lea’s POTW. Albert Lea’s POTW has sufficient capacity to treat Glenville West’s sanitary wastewater.

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Process Wastewater Industrial process wastewater will be generated from process operations, clean in place (CIP) operations for process equipment and operation of the wet scrubber for the fermentation system. The process is designed to recycle all of this water back into the process on site. Therefore, the Facility will not discharge process wastewater.

Non-Process Utility Wastewater The Facility will generate non-process utility wastewater consisting of RO reject water, cooling tower blowdown water, cooling tower filter backwash, and water polishing softener regenerant. The non-process utility wastewater will be recycled for reuse in the Facility using a CLS system, sand filters, and RO systems. Therefore, the Facility will not discharge non-process utility wastewater. A water balance of the proposed Facility is included as Figure 9.

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.

Sanitary Waste No on-site sewage treatment system is planned for the proposed Glenville West Facility. Sanitary wastewater generated by the estimated 40 employees of Glenville West will be discharged to the city of Albert Lea sewer system to be treated by the municipal POTW.

Stormwater Glenville West will direct stormwater runoff to on-site stormwater detention basins via storm drains and surface flow. Stormwater detention basins will be located in the northeast, south, and northwest areas of the site, as shown on Figure 5. Stormwater collected in the northeast detention basins will overflow to the south stormwater detention basin via an on-site drainage channel along the rail spur. The south stormwater detention basin will overflow (Outfall 001) via a manual shutoff valve to an unnamed ditch that flows south to County Ditch 16. The northwest stormwater detention basin will overflow (Outfall 002) via a manual shutoff valve to a ditch that flows parallel to County Road 51 (160th Avenue) west to County Ditch 16. Figure 11 shows the location of Outfalls 001 and 002 and the proposed surface flow to County Ditch 16.

The stormwater detention ponds will be designed to allow any sediment in the stormwater to settle out before the water is discharged and the off-site discharge of stormwater will be controlled using manual shutoff valves at the outfalls. The outfall structures will incorporate BMPs, such as rock riprap, to minimize potential erosion at the discharge point and will not result in a degradation of County Ditch 16.

Hydrostatic Test Water A one-time discharge of hydrostatic test water will occur during project start-up. The water will be discharged to surface water via one of the stormwater detention pond outfalls. The hydrostatic test water will be sampled prior to discharge as required under the state NPDES/SDS Permit and treated, if necessary.

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.

Sanitary wastewater will be generated from restrooms, kitchens, and the quality assurance laboratory. Glenville West estimates this flow will be approximately 1,000 GPD. This wastewater will be discharged to the city of Albert Lea POTW. No pretreatment is required for this wastewater discharge. The Albert Lea POTW has sufficient capacity to treat the sanitary wastewater from the Glenville West facility.

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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: 13 minimum; 36 average. Bedrock: 87 minimum; 97 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.

Based on reported static water levels at twelve nearby existing water wells, including the existing potable well located on the proposed site, the estimated depth to ground water is 36 feet. The estimated depth to the upper-most bedrock unit is 100 feet. The project site is underlain by approximately 100 feet of Quaternary glacial deposits consisting of till and some sand and gravel (summarized from Anderson, Farrel, Broussard, and Hult, 1975) overlying flat to gently warped sedimentary bedrock. Ground water exists in local sand lenses at shallow depths within the glacial and bedrock units. The primary source of ground water for the area is the Cedar Valley Aquifer. Regional ground water flow in the bedrock is to the southwest. The bedrock consists of early Paleozoic carbonate rocks, mainly dolomitic limestone and shaly dolomotic limestone, and includes Cedar Valley Formation. The Upper Cedar Valley aquifer is approximately 100 feet thick and composed of dolomite and dolomitic limestone. The Upper Cedar Valley aquifer is separated from the Lower Cedar Valley aquifer by the Chickasaw shale. The Lower Cedar Valley aquifer is underlain by the Spillville Formation, which is also composed of dolomite and dolomitic limestone. There are no known geologic hazards existing at 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 drill logs from nearby wells, unconsolidated glacial drift sediments are approximately 100 feet thick at the site. Alternative clay and sand and gravel layers are present between grade and the upper bedrock. Ground water is present in the unconsolidated sediments and also the bedrock units There is potential for contamination from a surface spill to reach ground water. Glenville West will prepare a SWPPP associated with Industrial Activities and Spill Prevention Control and Countermeasure (SPCC) Plan. The Facility’s design incorporates secondary containment for its tanks. The U.S. Geological Survey Hydrogeologic Investigations Atlas (HA-552 Cedar River) describes the surficial deposits in the area as the following:

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The glacial drift overlying the bedrock is about 100 feet thick or less in the southern part of Freeborn County (including this site). Most of the glacial drift material belongs to a unit referred to as the Des Moines lobe drift. The Des Moines lobe drift, especially the clayey lacustrine and till deposits, is oxidized and has a brown or yellowish-brown color to depth of about 6 to 15 feet. Below, the drift is dark gray in color. The till part of the drift deposited by the Des Moines lobe has been designated as the New Ulm Till.

The U.S. Soil Conservation Service (SCS) Map Unit Symbols and Names for soils within the project site are listed below. (113) Webster clay loam – nearly level soil, poorly drained, on broad flats and in drainage ways of till plains and uplands; comprises 25 percent of the site soil.

(106B) Lester loam - 2 to 6 percent slopes – undulating soil, well drained, on low knolls and gently sloping hilltops of till plains in uplands; comprises 22 percent of the site soil.

(114) Glencoe clay loam – nearly level soil, very poorly drained, in depressions and low-lying, sluggish drainage ways of upland till plains, subject to flooding; comprises 18 percent of the site soil.

(106C2) Lester loam – 6 to 12 percent slopes – rolling soil, well drained, on knolls, hilltops, and side slopes of till plains in uplands; comprises 9 percent of site soil.

(525) Muskego muck – nearly level organic soil, very poorly drained, in lake basins and depressions on upland and outwash plains; comprises 8 percent of site soil.

(239) LeSueur loam – 1 to 3 percent slopes – nearly level soil, moderately well drained and somewhat poorly drained, on low knolls, flat hilltops, and slight rises of till plains in uplands; comprises 5 percent of site soil.

(106D2) Lester loam – 12 to 18 percent slopes eroded – hilly soil, well drained, on knolls and side slopes of hills of till plains and moraines in uplands; comprises 5 percent of site soil.

Other soils are present on the site but are not listed here because they comprise less than five percent of the project area soils.

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.

During construction, the Glenville West Facility will generate paper waste from office operations and construction debris. Construction debris will include, scrap metal, wood, paper, plastic products, and empty containers for construction supplies. Some waste concrete may also be generated. Glenville West and their contractors will recycle their waste products to the extent practical. The landfill in Lake Mills, Iowa, or other landfills are capable of handling the construction debris generated by Glenville West.

During operations, Glenville West will be a small quantity generator of hazardous waste. The hazardous waste will consist primarily of flammable liquids and laboratory chemicals. The Facility will also infrequently generate universal wastes, including used oil, fluorescent and high intensity discharge light bulbs, and batteries. The Facility will acquire a hazardous waste generators identification number and a hazardous waste generators license from the MPCA. Glenville West will manage the hazardous and universal wastes in accordance with the appropriate regulations.

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The Facility will generate nonhazardous solid wastes including scrap metal, wood, plastic products, paper from office operations, and empty containers (i.e., drums, totes, and boxes). Glenville West will recycle their waste products to the extent practical. The remaining nonhazardous solid waste, approximately 10-20 cubic yards per week, will be disposed through a licensed waste transportation company. The Lake Mills Iowa landfill or other landfills would be capable of handling the nonhazardous solid wastes generated by Glenville West.

The Facility will also generate solid wastes from water treatment as a result of the CLS system operation. The lime softening filter press solids contain the following compounds: calcium carbonate, magnesium hydroxide, and ferric hydroxide. Approximately 6,000 pounds (3 tons) of solids will be generated by the CLS process on a daily basis. The solid waste will be stored within a roll-off container. Glenville West will dispose of the waste at a licensed landfill (Lake Mills, Iowa and or other). If sampling of the filter press solids indicates that the material can be used for land application, Glenville West will apply for a permit from the MPCA to land apply this material.

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.

Table 20-1 Hazardous Material Aboveground Storage Tanks

Tank No.

Contents Spill Control Measure Construction Material

Storage Capacity (gallons)

231 Bulk Enzyme Tank is located indoors Stainless Steel 12,000

232 Bulk Urea Tank is located indoors Stainless Steel 12,000

902 50% Caustic Tank is located indoors Carbon Steel 5,800

903 CIP Makeup Water (Caustic)

Tank is located indoors Carbon Steel 24,000

905 Waste CIP Water (Caustic)

Tank is located indoors Carbon Steel 24,000

920 Sulfuric Acid Tank is outdoors with secondary containment system

High Density Polyethylene

12,500

In addition to the above listed storage tanks for hazardous materials, Glenville West will use lubricants, greases, cleaning solvents and detergents, cooling water, and boiler treatment chemicals. These chemicals will be stored in 55-gallon drums, totes, or pails, as appropriate. Glenville will have dedicated storage areas for the chemicals with appropriate spill control procedures and equipment.

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 Facility will maintain the following aboveground storage tanks that will contain petroleum products or other materials, except water:

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Table 20-2 Aboveground Storage Tanks

Tank #

Substance Capacity (gallons)

Year Installed

Material Fabrication Primary Spill

Control

Secondary Spill

Control 801 190 Proof

Ethanol 250,000 2008 Stainless

Steel Field Erected

Level Control & High Liquid Level Alarm

Secondary Containment

802 190 Proof Ethanol

250,000 2008 Stainless Steel

Field Erected

Level Control & High Liquid Level Alarm

Secondary Containment

803 Denatured Ethanol

2,000,000 2008 Stainless Steel

Field Erected

Level Control & High Liquid Level Alarm

Secondary Containment

804 Denatured Ethanol

2,000,000 2008 Stainless Steel

Field Erected

Level Control & High Liquid Level Alarm

Secondary Containment

805 Denaturant 125,900 2008 Stainless Steel

Field Erected

Level Control & High Liquid Level Alarm

Secondary Containment

852 Corrosion inhibitor

1,200 2008 Steel Shop Fabricated

Level Control & High Liquid Level Alarm

Secondary Containment

920 Sulfuric Acid

12,500 2008 Plastic tank in Stainless Steel 2ndary containment

Shop Fabricated

Site Gauge Secondary Containment

1200 Diesel Fuel 2,000 2008 Double Wall Steel

Shop Fabricated

Site Gauge Double Wall Tank

United States Federal regulation 40 CFR 112 (Oil Pollution Prevention) requires that facilities having aboveground oil storage, in containers larger that 55-gallons, exceeding 1,320 gallons, prepare an SPCC Plan. Glenville West will prepare an SPCC Plan for the oil containing bulk storage tanks, the oil drum storage areas, and the oil filled equipment. This Plan will specify the location of the oil storage areas, the inspections, tests, training, spill prevention procedures, spill response procedures, and spill response equipment for the oil containing equipment at the Facility. A copy of the SPCC Plan will be available at the site at all times.

Additionally, the site grading is being designed to direct any spills that occur outside of the secondary containment areas to the stormwater detention pond. The outfall from the pond is equipped with a valve that can be closed in the event of a spill.

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21. Traffic. Parking spaces added: ~50 Existing spaces (if project involves expansion): Estimated total average daily traffic generated: ~200 Trucks and cars per day Estimated maximum peak hour traffic generated (if

known) and its timing: ~80% between 6:00 am & 8:00 pm

Provide an estimate of the impact on traffic congestion affected roads and describe any traffic improvements necessary. If the project is within the Twin Cities metropolitan area, discuss its impact on the regional transportation system. As shown in Figure 5, primary access to the Facility will be from 780th Avenue (existing north-south road that provides access to only the Glenville East and SoyMor facilities) via the east-west County Road 13 (151st Street). Glenville West is proposing to extend 780th Avenue along the southern and western site boundaries to provide Facility access. Since 780th Avenue will only provide access to Glenville West, Glenville East, and SoyMor, it is not anticipated that the increased vehicle traffic on this road will adversely affect the general public.

According to the MNDOT 2004 Trunk Highway Traffic Volume Map, the average daily flow of traffic on County Road 13 is 1,750 vehicles. The percentage of increased traffic using County Road 13 due to the Glenville West Facility would be approximately ten percent.

State Highway 65 runs roughly north-south and intersects County Road 13 approximately one mile east of 780th Avenue. According to the MNDOT 2004 Trunk Highway Traffic Volume Map, the average daily flow of traffic on State Highway 65 is 3,050 vehicles. If all vehicles used this route to access County Road 13, the percentage of increased traffic due to the Glenville West Facility would be approximately six percent along State Highway 65.

The project proposer has consulted with MNDOT and the Freeborn County Highway Department regarding the project. According to MNDOT and the Freeborn County Highway Department, the anticipated traffic increase along County Road 13 and State Highway 65 from the Facility is not considered significant and is not expected to contribute to increased congestion on these roads.

County Road 51 (160th Street) is an unimproved gravel road that runs east-west along the northern boundary of the Glenville West proposed site. It is anticipated that limited amounts of construction equipment will access the project site using this road and an access drive from the Facility to County Road 51 is planned. However, once in operation, Glenville West expects that access to the Facility via County Road 51 will be limited and intermittent.

Glenville West truck traffic will primarily be for grain delivery to the Facility. Additional truck traffic will be for ethanol and DDGS shipping and denaturant delivery. Approximately 80 percent of the ethanol and DDGS will be shipped off site by rail car.

The Glenville West Facility plans to obtain rail service by constructing a new rail spur corridor parallel to the rail spur currently used by the nearby Glenville East and SoyMor facilities. The rail spur does not currently cross any public roads and the proposed construction will not result in the rail spur crossing any public roads. It is not anticipated that the rail spur expansion will directly impact vehicle traffic. The rail siding is connected to an existing Union Pacific railroad line that runs parallel to Highway 65 and is currently used by an average of 11 trains per day. It is anticipated that any increases in train traffic resulting from construction of the Facility, an expected maximum of one train per day (100-150 trains per year), will not cause any significant congestion where the Union Pacific railroad crosses County Road 13 near its intersection with State Highway 65.

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The grain deliveries will generally occur from approximately 7:00 a.m. through 5:00 p.m. five days per week. Seasonally during harvest, some grain deliveries will be completed on weekend days. The ethanol and DDGS shipping may occur any day of the week but will generally occur from approximately 6:00 a.m. through 8:00 p.m. The Glenville West Facility will employ approximately 40 people. The exact shift structure will be decided at a later date. However, employees will be on site 24 hours per day, 365 days per year. Generally, 20 to 25 people will work Monday through Friday during normal business hours. The remaining staff will work night shifts and weekends.

Vehicle Type

Quantity Transported per

Truck

Maximum Number of

Trucks per year Average Number

of Daily Trips DDGS Haul Out 25 ton 4,030 16 Ethanol Haul Out 8,000 gal 4,313 17 Denaturant Delivery 8,000 gal 431 ~1 Grain Delivery 25 tons 27,331 109 Employee Traffic NA NA ~40 Miscellaneous Delivery and Visitors NA NA ~5

The planned access pathway for all vehicles to the Facility will direct traffic away from surrounding residences to reduce noise and odor issues. The access road is long enough that grain delivery trucks will not stand on County Road 13.

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.

Traffic on County Road 13 will increase by approximately 200 vehicles per day, on average, with a maximum daily increase of 290 vehicles per day. This level of increased traffic is not expected to have a significant impact on air quality. Fugitive road dust will be minimal because the Facility’s road will be paved and truck speed is limited to 5 mph. Also, air dispersion modeling indicates that the National Ambient Air Quality Standard (NAAQS) of particulate matter will not be exceeded due to the operation of the proposed Facility. In addition to the criteria pollutants, a risk analysis was performed for toxic air pollutants emitted by diesel idling from vehicles at the Facility. Idling trucks on the Glenville West Facility are expected to be very minimal due to the facilities use of multiple truck unloading pits. This will allow multiple trucks to dump grain at one time, which will reduce the likelihood of a line of trucks waiting to unload grain. Glenville West does not include any staging area for idling trucks to park. This, along with the multiple dump pits is expected to effectively minimize any idling.

23. Stationary Source Air Emissions. Describe the type, sources, quantities and compositions of any emissions from stationary sources of air emissions such as boilers, exhaust stacks or fugitive dust sources. Include any HAPs (consult EAW Guidelines for a listing), any greenhouse gases (such as CO2, 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.

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Sources of Air Emissions and Pollution Control Equipment The proposed Glenville West Facility will be a natural gas-fired ethanol plant and will be a new source of air emissions in the Glenville area. Table 23-4 lists air emission sources and emission control equipment at the Facility. Item 6.b. of this EAW describes the air emission equipment in more detail. Glenville West will hold an Air Emission Permit issued by the MPCA, and will operate according to the requirements listed in the permit.

Table 23-4 Glenville West – Emission Sources and Associated Control Equipment

Emission Unit Description Pollutants Control Equipment

EU001 Grain Receiving TSP/PM10 Fabric Filter EU002 Two (2) Grain Legs and Conveying System TSP/PM10 Fabric Filter EU003 Four (4) Grain Bins TSP/PM10 Fabric Filter EU004 One (1) Corn Scalper TSP/PM10 Fabric Filter EU005 Surge Bin TSP/PM10 Fabric Filter EU006 Corn Hammermill #1 TSP/PM10 Fabric Filter EU007 Corn Hammermill #2 TSP/PM10 Fabric Filter EU008 Corn Hammermill #3 TSP/PM10 Fabric Filter EU009 Corn Hammermill #4 TSP/PM10 Fabric Filter EU010 Corn Hammermill #5 TSP/PM10 Fabric Filter EU011 One (1) slurry tank VOC Wet Scrubber, RTO EU012 Fermenter #1 VOC Wet Scrubber, RTO EU013 Fermenter #2 VOC Wet Scrubber, RTO EU014 Fermenter #3 VOC Wet Scrubber, RTO EU015 Fermenter #4 VOC Wet Scrubber, RTO EU016 Fermenter #5 VOC Wet Scrubber, RTO EU017 Yeast Propagation Tank VOC Wet Scrubber, RTO EU018 Beer Well VOC Wet Scrubber, RTO EU019 Beer Stripper VOC Wet Scrubber, RTO EU020 Rectifier Column VOC Wet Scrubber, RTO EU021 Side Stripper VOC Wet Scrubber, RTO EU022 One (1) Set of Three (3) Molecular Sieves VOC Wet Scrubber, RTO EU023 One (1) Set of Four (4) Evaporators VOC Wet Scrubber, RTO EU024 One (1) Set of Four (4) Centrifuges VOC RTO, under normal operation

EU025 DDGS Dryer #1 TSP, PM10, NOx, SOx, VOC Multiclone and RTO EU026 DDGS Dryer #2 TSP, PM10, NOx, SOx, VOC Multiclone and RTO EU027 Boiler #1 TSP, PM10, NOx, SOx, VOC Low NOx Burner EU028 Boiler #2 TSP, PM10, NOx, SOx, VOC Low NOx Burner EU029 DDG Fluid Bed Cooler TSP/PM10, VOC Fabric Filter EU030 DDGS Storage Silo TSP/PM10 Fabric Filter EU031 DDGS Silo Bypass TSP/PM10 Fabric Filter EU032 DDGS Storage Building TSP/PM10 Fabric Filter EU033 DDGS Conveyor TSP/PM10 Fabric Filter EU034 DDGS Truck Loadout TSP/PM10 None EU035 DDGS Rail Loadout TSP/PM10 Fabric Filter EU036 Truck and Rail Loading Rack TSP, PM10, NOx, SOx, VOC Flare

- continued -

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Emission

Unit Description Pollutants Control Equipment

EU037 Diesel Generator TSP, PM10, NOx, SOx, VOC None EU038 Lime Silo TSP/PM10 None T001 190 Proof Ethanol Storage Tank VOC Internal Floating Roof T002 200 Proof Ethanol Storage Tank VOC Internal Floating Roof T003 Denatured Ethanol Storage Tank VOC Internal Floating Roof T004 Denatured Ethanol Storage Tank VOC Internal Floating Roof

T005 Denaturant Storage Tank VOC Internal Floating Roof Fugitive Source Description Pollutants Control Equipment

F001 Grain Receiving TSP/PM10 None

F002 DDG Loading TSP/PM10 None F003 Paved Roads TSP/PM10 None

F004 Equipment leaks VOC Leak Detection and Repair Program

F005 Cooling Towers TSP/PM10 High Efficiency Mist Eliminators

F006 Tank Fugitives VOC Leak Detection and Repair Program

TSP = Total suspended particulates PM10 = Particulate Matter less than 10 μm in size NOx = Nitrogen Oxides SOx = Sulfur Oxides μm = micrograms Prevention of Significant Deterioration (PSD) PSD applicability regulations require grouping of all of the pollutant-emitting activities that: (1) belong to the same industrial grouping (i.e., share the same major group 2-digit SIC code); (2) are located on contiguous or adjacent property; and (3) are under common control (40 C.F.R. § 52.21(b) (5) and (b) (6)). Since Glenville East and West facilities meet these criteria, they are considered as a single stationary source for evaluating PSD applicability. This means that the potential emissions from the facilities are added together to determine if PSD regulations apply to the construction of the proposed Glenville West Facility.

The PSD threshold for a fuel ethanol plant is 250 TPY for all criteria pollutants. Glenville West will limit the emissions of criteria pollutants from the proposed Facility to less than the thresholds shown in Table 23-1 through the installation and operation of pollution control devices and by accepting federally enforceable emission limits. Glenville West will demonstrate compliance with the limits through monitoring, recordkeeping, and reporting activities. Glenville East has a current air permit that limits emissions of criteria pollutants to less than the thresholds shown in Table 23-1. Glenville East has demonstrated compliance with its air permit limits through performance testing, monitoring and recordkeeping.

Table 23-1 Potential-to-Emit for Glenville East and West – Criteria Pollutants

Source TSP PM10 VOC CO NOX SO2 Glenville East 95.0 95.0 95.0 95.0 95.0 95.0 Glenville West 80.5 69.6 93.3 98.9 95.1 1.7 Total 175.5 tpy 183.9 tpy 188.3 tpy 193.9 tpy 190.1 tpy 96.7 tpy PSD Major Source Threshold 250 tpy 250 tpy 250 tpy 250 tpy 250 tpy 250 tpy

PSD Major Source? No No No No No No

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The PSD regulations also contain a second source category that requires an applicability determination. The determination includes fossil fuel boilers (or combination thereof) totaling more than 250 MMBTU/hour heat input. The Glenville East facility has a total of 261 MMBTU/hour of fossil fuel boilers fired on natural gas (Boiler #1 = 62 MMBTU/hour, Boiler #2 = 74 MMBTU/hour, TO/HRSG = 125 MMBTU/hour). Glenville West is proposing to install a total of 286 MMBTU/hour of fossil fuel boilers fired on natural gas. As such, a major source applicability determination for the co-located boiler plants at Glenville East and Glenville West is required. Potential permitted emission rates from all of the boilers combined are compared against the major source threshold of 100 TPY. These potential to emit inventories for the boiler plants at both Glenville East and West are summarized below in Table 23-2.

Table 23-2 Potential-to-Emit for Glenville East and West (Boilers Only)

Source PM10

ton/year VOC

ton/yearCO

ton/year NOX

ton/year SO2

ton/year Glenville East Boiler Plant 8.5 8.5 45.7 40.0 0.2 Glenville West Boiler Plant 9.3 6.8 50.1 43.8 0.7 Total 17.8 17.8 95.8 83.8 0.9 PSD Major Source Threshold 100 tpy 100 tpy 100 tpy 100 tpy 100 tpy

PSD Major Source? No No No No No As demonstrated above, the combination of emissions from the existing Glenville East facility and the proposed Glenville West Facility do not exceed the major source threshold for PSD regulations. Therefore, the construction of the Glenville West Facility is not subject to PSD requirements. If in the future, either facility wishes to expand, the MPCA will re-evaluate the PSD applicability.

National Emission Standards for Hazardous Air Pollutants (NESHAPs) The U.S. Environmental Protection Agency (EPA) requires new facilities to evaluate applicability of NESHAP standards. Table 23-3 identifies the highest individual HAP, which is Acetaldehyde, and the combined emission rate of all HAPs for the proposed Glenville West Facility. Table 23-3 also compares these emission rates against the major source threshold for the NESHAP program. The NESHAP program considers the existing Glenville East and proposed Glenville West Facility as separate facilities when looking at the major source thresholds. This determination is based on the different definitions of source within the PSD and NESHAP programs.

Table 23-3 Potential-to-Emit for Glenville West – HAPs

Source Acetaldehyde Total HAPs Glenville West 7.84 13.37 Major Source Threshold 10 TPY 25 TPY NESHAP Major Source? No No

The EPA has not developed a NESHAP for fuel ethanol production facilities. However, if a new facility will emit more than 10 TPY of any single HAP or more than 25 TPY of all HAPs combined, a case-by-case Maximum Achievable Control Technology (MACT) analysis must be completed. As detailed in Table 23-3, the proposed Glenville West Facility will limit the HAP emissions from the proposed Facility to less than the NESHAP applicability thresholds through the installation and operation of pollution control devices and by accepting federally-enforceable emission limits. Glenville West will demonstrate compliance with the limits through monitoring, recordkeeping, and reporting activities. Due to the federally-enforceable emission limits, Glenville West is not a major source of emissions related to the NESHAP program and is not applicable to any NESHAP standards.

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Air Dispersion Modeling Air dispersion modeling was performed for criteria pollutants to demonstrate compliance with the NAAQS and the Minnesota Ambient Air Quality Standards (MAAQS). The modeling took into consideration the emissions from the Glenville West Facility, as well as the background pollutant level. The criteria pollutant that resulted in concentrations closest to air quality standards was particulate matter.

PM10

The maximum modeled 24-hour concentration of PM10 is 95.7 micrograms per cubic meter (μg/m3). When adding in the background level of 33 μg/m3, the total concentration is 128.7 μg/m3, which is lower than the NAAQS standard of 150 μg/m3.

PM2.5 The maximum modeled 24-hour concentration of PM2.5 is 15 μg/m3. When adding in the background level of 20 μg/m3, the total concentration is 35 μg/m3, which is equal to the NAAQS standard of 35 μg/m3.

The potential increase in air emissions from the proposed Glenville West Facility and nearby existing industrial sources, mobile sources, and existing natural conditions are unlikely to exceed ambient air quality standards for criteria pollutants.

Air Emission Risk Assessment (AERA) The MPCA developed risk analysis tools to evaluate human health risks from a facility’s are emissions. The AERA process provides for: (1) a streamlined review of facility air emissions; (2) a consistent format for presenting the quantitative risk estimates, along with qualitative information to provide context to these risk estimates; and (3) flexibility in the manner in which the quantitative risks are calculated (the input parameters may be worst-case or routine such that the risk estimates may fall along a continuum between a more conservative upper bound assessment (screening) vs. a more precise (refined) assessment of the risks). The results of the AERA for this Facility are more precise or refined.

In general, the risk level deemed to be acceptable for emissions from an individual facility or an expansion project, for the risks of all carcinogenic chemicals added together is less than 1 chance in 100,000 of additional lifetime cancers based on MDH and EPA guidance. The level of risk deemed to be acceptable for all non-carcinogenic chemicals added together is a hazard index of 1.0. If a project shows a risk in excess of these levels, the MPCA examines the project analysis to determine whether future investigation or project modification is warranted. Interested readers can find more detailed information on the air risk analysis process at http://www.pca.state.mn.us/air/aera.html.

Glenville West has completed an AERA in accordance with MPCA guidance. The AERA was performed based on a modeling protocol developed by the project proposer and accepted by the MPCA in August 2007. This modeling protocol requires the use of the state-of-science AERMOD dispersion model developed and distributed by the EPA. Emissions from surrounding sources (Glenville East and SoyMor) were also included in the cumulative impact analysis.

Potential risks to nearby residences were evaluated from inhalation and indirect (e.g., vegetable consumption) exposure. The location of maximum annual and acute concentrations related to the operation of the proposed Glenville West Facility is predicted to occur just to the north of the proposed Facility along Township Road 51.

A cumulative effects analysis of potential air emissions from the proposed Glenville West Facility was performed in addition to the AERA. The cumulative effects analysis is detailed in section 29 of this EAW.

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Table 23-5 details the maximum modeled risk levels for emissions from Glenville West.

Table 23-5 Maximum Modeled Risk Levels – Glenville West Facility Only

Maximum Modeled Risk

Health Guideline

Risk Analysis Averaging

Period (unit-less) (unit-less)

Acute 1-hour 0.61 1.0

Subchronic Noncancer Monthly 0.03 1.0

Chronic Noncancer Annual 0.23 1.0 Cancer Annual 0.08 1.0

The maximum modeling risk levels drop off very quickly as the distance from the Facility increases. Therefore, the overall risk levels of the proposed Glenville West Facility drop well below 1.0 and are even modeled at levels at 50 percent or less of that threshold at the nearest residence. It should also be noted that the modeled risk levels from the AERA analysis are at 0.1 or lower within the town of Glenville.

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 The fermentation system, distillation system and DDGS dryer emissions are the primary odor sources at an ethanol facility. The odors are associated with the VOCs emitted by these sources. Glenville West will control odors with the use of a RTO. The RTO will destroy 98 percent of the VOCs generated by the Facility. In addition to the RTO, the fermentation and distillation systems have a wet scrubber that will control odors from these processes. This wet scrubber is located prior to the RTO within the process. This placement assures that VOCs and the associated odors will not be released into the atmosphere uncontrolled in the event that the DDGS dryers and RTO are temporarily out of service. The DDGS dryers will not be operated if the RTO is not in service.

Glenville West may produce wetcake when the DDGS dryers are not in service. Wetcake storage areas can be a source of odors. The odors from wetcake develop over a few days time. In order to minimize these odors, Glenville West’s air emission permit will require removal of wetcake from the Facility within 72 hours of its generation. Due to the rapid turnaround necessary for the sale of this product and the air emission permit requirements, odors from wetcake are not expected to be a problem.

Noise The construction and operation of the proposed Facility will contribute noise in the project area. Noise will be generated primarily due to mechanical equipment operations. Noise will also be generated from trucks and rail transport. The highest levels of noise will be from the Facility’s hammermills and cooling tower.

The nearest noise sensitive area (NSA) is a residence approximately one-third mile from the proposed Facility (Figure 4). State rules classify this receptor as a Class 1 Noise Area and specify noise limits. The Glenville West Facility may not contribute greater than a daytime (7:00 a.m. to 10:00 p.m.) sound pressure level of 60 dBA and a nighttime (10:00 p.m. to 7:00 a.m.) sound pressure level of 50 dBA.

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Noise modeling was done to determine if the Facility will meet these noise standards. The modeling indicates that the Glenville West Facility will meet applicable standards (see Table 24-1 below). Based on modeling results, significant noise impacts to surrounding neighbors are not anticipated due to this project.

Glenville West has evaluated noise-generating equipment and included mitigation measures where warranted to minimize off-site potentials. Noise mitigation measures include equipment shielding, enclosures, isolation, and procedures requiring doors to the Facility to be closed when practicable. To minimize noise generated by delivery trucks, Glenville West will instruct drivers not to engine brake (‘Jake’ brake).

Table 24 – 1

Estimated Future Noise Levels NSA Noise

from Source (dBA)2

Distance from Noise Generating Unit (Feet)

Direction to NSA

Background Noise

(dBA)3

Facility Contribution

(dBA)

Contribution plus

Background (dBA)

Applicable MN Noise Standard

NSA1 89.4 1,700 Northeast 38.6 46.4 46.9 50 1 Residence 1/3-mile from Facility 2 Total predicted noise contribution from the Facility 3 Estimate of background noise for agricultural areas

Construction of the Glenville West Facility will create temporary noise impacts. Construction will be limited within the Glenville West property boundary and restricted to daylight hours. Because of the distance to the nearest residence, the construction of the Facility is not expected to cause any violations to the Minnesota Noise Rules, as provided in Chapter 7030 of the Minnesota Noise Pollution Control Rules.

Dust Dust will be generated during the Facility construction process. However, minimal impacts are expected since the Glenville West project area is relatively small when compared to nearby agricultural areas. Construction activities will be temporary. Construction-related dust will be managed thorough the use of water trucks. Once the Glenville West Facility is constructed, ambient dust levels are expected to return to preconstruction levels. All Glenville West Facility haul roads will be paved prior to start-up, which will minimize any fugitive road dust emissions. Also, air dispersion modeling indicates that the NAAQS of particulate matter will not be exceeded due to the operation of the proposed Facility.

25. Nearby resources. Are any of the following resources on or in proximity to the site?

a. Archaeological, historical, or architectural resources? Yes No b. Prime or unique farmlands or land within an agricultural preserve? Yes No c. Designated parks, recreation areas, or trails? Yes No d. Scenic views and vistas? Yes No e. Other unique resources? Yes No If yes, describe the resource and identify any project-related impacts on the resources. Describe any

measures to minimize or avoid adverse impacts. Glenville West retained a federally-qualified archaeologist who completed a Phase I cultural resources investigation of the proposed site. This investigation included off-site review of inventories at the SHPO databases and historic maps at the Minnesota Historical Society, as well as an on-site field survey.

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No known cultural resources are recorded for the proposed site. Additionally, no historically significant cultural materials or features were observed during the field survey. The only cultural artifacts observed and documented during the survey were an isolated tested cobble (a single stone that shows evidence of test flaking by humans during the stone point manufacturing process) of Knife River Flint (assigned site number 21FE0070 by the Minnesota State Archaeologist); an historic windmill and associated sheet metal fragments; modern trash, such as plastic fragments; and a machine-made lip and neck fragment from a clear glass bottle. None of these artifacts qualify as eligible for nomination to the National Register of Historic Places (NRHP).

No historic properties listed on or eligible for listing on the NRHP have been identified on the proposed site. The survey report has been submitted to the SHPO for review. On October 5, 2007, Glenville West was notified by the SHPO’s office that since the Glenville West project does not involve Federal Action, such as a Historic Preservation Act Section 106 review request from the USACE, the SHPO will not review the survey report.

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. Exhaust will be emitted from a 105 foot RTO stack. A water vapor plume from this stack will be visible from varying distances, depending on weather conditions. Water vapor may also be visible from the Facility’s cooling tower. The top of the cooling tower is approximately 35 feet above grade.

Once constructed, the Glenville West Facility will operate 24 hours per day, 7 days per week. Ethanol production will be continuous and overseen 24 hours per day. Since production will be continuous, lighting is required to support operations and to provide security. Lighting will consist of low-level lighting around exit areas and general outside areas, including ground-level operating areas, stairs and platforms, roadways, storage areas, and parking areas. The lighting will be provided for purposes of general operator access and safety under regular operating conditions. Outdoor lights will be a combination of pole-mounted and structure-mounted lights.

Spot lighting will be provided to illuminate operating equipment or access roadways where needed. This lighting will be higher in intensity than general outside lighting, but will be limited to specific areas and usage will be occasional. This lighting will be adjusted to minimize light spillover or direct glare in response to specific site conditions.

Emergency lighting will be provided for workers to find exits and continue critical activities during power failures or emergency conditions. These instances are anticipated to be infrequent. Emergency lighting will be provided for all of the Facility’s buildings associated with critical operations.

The exhaust stack at the Facility and the grain bins will be greater than 100 feet in height above ground level. If necessary, the tall stack and grain bins will be lighted or signed in accordance with the requirements of the Federal Aviation Administration.

Lights and glare impacts on neighboring properties are expected to be minimal. During the day, such impacts are expected to be minimal. The potential for adjusting light directions and the use of supplemental light shields, if necessary, would minimize light spillover at night. No glare impacts are anticipated for drivers on nearby roadways. As an industrial land use, the Glenville West Facility is expected to make a slight contribution to overall ambient light levels in the immediate vicinity. Because of the flat topography of the site, some lights may be seen by distant or elevated viewers. Overall, potential impacts from lighting from the Facility would be negligible.

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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. Freeborn County is currently operating under an approved Land Use Ordinance. The specific area chosen for the placement of the Facility was previously designated for agricultural purposes. The property has been re-zoned for industrial use.

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.) Roads The primary vehicle access to Glenville West is proposed to be obtained by extending 780th Avenue (existing access road to Glenville East and SoyMor facilities) along the southern and western boundaries of the proposed Facility (Figure 1). Roads built on the Facility property will connect with the extended 780th Avenue. County Road 51 (160th Street) is an unimproved gravel road that runs along the northern boundary of the proposed site. This road may be occasionally used by construction vehicles to access the proposed site during the construction phase and an access drive to County Road 51 from the Facility is planned in the final Facility layout. However, once in operation, Glenville West expects that access to the Facility via County Road 51 will be limited and intermittent. Figures 1 and 5 show the Facility’s relationship to the surrounding roads.

Railroad Rail access to Glenville West is proposed to be obtained by connecting on-site tracks to an existing rail spur that runs along the eastern boundary of the proposed site. This rail spur currently serves the existing Glenville East and SoyMor facilities. Figure 1 shows the Facility’s relationship to the adjoining Glenville East/SoyMor rail spur and the Union Pacific railroad.

Utilities Both electric and natural gas utility services are available in the area and connections will be made to the existing utilities (Figure 10). Electricity and natural gas will be purchased from the local utilities. A small substation will be constructed at the Facility and additional transformers will be utilized as required for electrical power for plant equipment. The Facility will initially use 221,000 cubic feet per hour of natural gas. Although the project will increase electric and natural gas usage in the area, the incremental capacity is readily available from local utilities. The city of Albert Lea has municipal sanitary sewer service available in the area of the proposed site. Glenville West is proposing to discharge its sanitary waste to an existing municipal sanitary sewer line located near the southeast corner of the proposed site to the city of Albert Lea POTW.

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29. Cumulative impacts. Minn. R. 4410.1700, 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 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).

Cumulative impacts include those caused by the addition of the project to past, present, and reasonably foreseeable future activities. Glenville West is not currently planning any actions in connection with the proposed project that have not been addressed in this evaluation. Discussions were held by Glenville West with the city of Glenville and Freeborn County to determine if any new industries were planned in the area. City and County staff indicated that they did not know of any industries planned for the area. The following is a summary of the issues included in the overall cumulative effect analysis.

Air Quality Cumulative potential effects to air quality that may result from the proposed Glenville West Facility have been evaluated using dispersion modeling tools that consider potential emissions from the proposed Facility along with the Glenville East and SoyMor facilities. Other regional/background sources, including mobile sources, were also added to the cumulative effects analysis shown below. Potential human health effects from Glenville West, Glenville East, and SoyMor were evaluated using the AERA process.

Criteria Pollutants Air dispersion modeling was conducted in order to determine compliance with air quality standards. The modeling demonstrated that the cumulative emissions from all sources in the area will be in compliance with NAAQS and MAAQS.

Air Toxics A risk analysis was conducted to evaluate the maximum modeled cumulative risks for air toxics in the area surrounding the proposed Glenville West Facility. Cancer and non-cancer risks were evaluated. The results are summarized in the following two tables:

Non-Cancer Risk Analysis

Risk Type Exposure Period

Max Modeled Risk from All Facilities*

Background Total Risk

Threshold

Acute 1-hour 0.8 0.2 1.0 1.0 Chronic Annual 1.4 0.6 2.0 1.0

* All Facilities means Glenville West, Glenville East, and SoyMor facilities.

The potential increases in air emissions from the proposed Glenville West project are not expected to exceed any air quality standard. The elevated chronic risk is predicted to occur west of the Poet Glenville East facility (formerly EXOL) along the adjacent at a point where there are no residences. Based on level of emissions and the location of the elevated risk, the MPCA has no information indicating that the non-cancer impacts from the projects in the area have the potential to be significant.

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POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 34 Worksheet

Cancer Risk Analysis Risk Type Exposure

Period Max Modeled Risk from

All Facilities* Background Total

Risk Threshold

Cancer Annual 0.3 2.5 3.0** 1.0 * All Facilities means Glenville West, Glenville East, and SoyMor facilities. ** Risk estimate rounded to one significant figure.

The maximum cancer risk due to emissions from the proposed Facility, when added to a representative ambient monitored regional/background rural cancer risk, is around three. The elevated cancer risks are predicted to occur west of the Poet Glenville East facility (formerly EXOL). The elevated risks occur along the adjacent at point where there are no residences.

The combined cancer risk from the proposed Glenville West Facility, Glenville East, and SoyMor are at a value of 0.3 (i.e., below thresholds). Most of the risk (2.5) is from background sources. Background values for cancer risks are elevated for all locations throughout the state and are not unique to the Glenville area. The background values are due to heritage pollutants or those that are everywhere in the environment and have persisted for a long time, and not the potential emissions from any of the facilities evaluated in this analysis. In all exposure scenarios examined, Poet Glenville East appears to be the primary contributor to cumulative risk. This is due largely to the proximity of the emission sources to the property boundary resulting in elevated risks at or beyond the property boundary. The elevated cumulative cancer risk is not attributable to Poet Glenville West. Cancer risks are elevated statewide largely because of background pollutants

Though the total cumulative risks are elevated above thresholds, there are numerous factors to consider along with the results of this analysis. One key point is that these risks are predicted to occur at a single point of maximum impact (i.e., roadway west of Poet Glenville East). There are currently no receptors at this location. Risks generally dissipate with distance from the sources of emissions at ethanol facilities. The modeling done for this project indicates that the predicted hazard indices are around 0.2 to 0.3 for the nearest receptors.

Odors The fermentation system, distillation system, and DDGS dryer emissions are the primary odor sources at an ethanol facility. The odors are associated with the VOCs emitted by these sources. Odors from DDGS dryers, distillation system, and fermentation system will be controlled under normal operations by the regenerative thermal oxidizer. The RTO will destroy 98 percent of the organic compounds, believed to be the primary source of odors from ethanol facilities. In addition, the fermentation and distillation systems have a wet scrubber that will control odors from these processes in the event that the DDGS dryers and RTO are temporarily out of service. The DDGS dryers will not be operated if the RTO is not in service.

Glenville West may produce wetcake when the DDGS dryers are not in service. Wetcake storage areas can be a source of odors and develop over a few days time. Glenville West will have operating procedures, which will require that wetcake will be removed from the Facility within 72 hours as part of the approved air permit. Due to the rapid turnaround necessary for the sale of this product, odors are not expected to be a problem.

The combination of pollution control equipment operation, operating procedures and the distance of approximately one-third mile to the nearest residence from the Facility will minimize odors from the Facility. Odors from Glenville East are also controlled by thermal oxidation and are minimized to the maximum extent possible. Sources of odor from SoyMor are controlled by the use of flare on their vacuum pump, nitrogen blanket at different points within the process, and a leak detection program to minimize fugitive emissions.

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POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 35 Worksheet

Ground Water Glenville West will use two on-site process water supply wells and one potable water well, as shown in Figure 7. These wells will supply make-up water for Facility operations. Glenville West will use a maximum of 650 GPM (342 MMGPY) of make-up water from ground-water wells.

A Water Appropriation Permit will be required from the DNR to appropriate this amount of water. The Water Appropriation Permit process requires that an aquifer test be done. The aquifer test establishes aquifer properties for use in models to determine if the project will create interference with other wells in the area, cause adverse affects to surface water features in the area, or damage long-term aquifer sustainability. As part of the Water Appropriations Permit process, the proposer completed an aquifer test from June 26 to July 13, 2007. The aquifer test was done at a well production rate of 800 GPM. As part of the Water Appropriation Permit process, the DNR takes into consideration the other existing water appropriators in the same aquifer. Since the model considers the proposed water appropriation in conjunction with other aquifer users and future planned use, the water appropriation review is considered to be a cumulative assessment.

The following describes the other large water users in the area of the proposed Glenville West Facility. Glenville East operates three industrial supply wells one-half mile to the southeast. These wells operate under Water Appropriation Permit Number 98-5102 and are authorized to pump at up to 600 GPM, with a total annual appropriation of 292 MMGPY. Two water wells are operated by the city of Glenville. These wells are located approximately 1.8 miles southwest of the proposed location of the Glenville West process water wells. The city of Glenville wells operate under Water Appropriation Permit Number 75-5108 and are authorized to pump at up to 425 GPM, with a total annual appropriation of 33 MMGPY. No other large appropriators of ground water were identified within the search radius required by the DNR as part of the aquifer test. The nearby SoyMor facility does not have its own process water well. SoyMor purchases its process from the Glenville East facility. Based on the DNR’s review of the aquifer test and other information regarding the aquifer, adequate ground-water supply for the Glenville West plant exists and no adverse impacts to surface water features are expected.

Surface Water/Stormwater Additional impervious surfaces will be generated from the construction of the proposed Facility. The stormwater detention ponds will provide treatment and control of stormwater discharges. The stormwater ponds have been designed to ensure that post-construction peak flows are less than or equal to pre-construction peak flows. Because tilled soils will no longer be present on the property, the sediment content of the stormwater is expected to be lower than current spring-time conditions.

Glenville West will direct stormwater on the site to stormwater detention basins via storm drains and/or surface flow. Stormwater detention basins will be located in the northeast, south, and northwest areas of the site, as shown on Figure 5. Stormwater collected in the northeast detention basins will overflow to the south stormwater detention basin via an on-site drainage channel along the rail spur. The south stormwater detention basin will overflow (Outfall 001) via a manual shutoff valve to an unnamed ditch that flows south to County Ditch 16. The northwest stormwater detention basin will overflow (Outfall 002) via a manual shutoff valve to a ditch that flows parallel to County Road 51 (160th Avenue) west to County Ditch 16. Figure 11 shows the location of Outfalls 001 and 002 and the proposed surface flow to County Ditch 16.

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POET Biorefining – Glenville West Environmental Assessment Glenville, Freeman Township, Minnesota 36 Worksheet

The Shell Rock River is currently listed by the MPCA as impaired for turbidity and has proposed to be listed as impaired for pH. As discussed in Question #17, Glenville West will be required to develop and implement an SWPPP that will contain BMPs to minimize the Facility impacts to stormwater and ensure that the stormwater discharge will not contribute to the turbidity and pH impairment of the Shell Rock River. The NPDES/SDS Industrial Stormwater Permit will contain effluent limitations for total suspended solids and pH. No future projects are known to be planned in the area that will discharge stormwater. Therefore, no additional cumulative impacts are expected for stormwater discharges from the Facility.

No process wastewater or non-process utility wastewater will be discharged to surface waters from the proposed Facility.

Transportation As discussed in Question 21, an increase in traffic will occur as a result of the Facility. The maximum expected increase in traffic on a daily basis would be six percent along State Highway 65 and ten percent along County Road 13. Glenville West has consulted with MNDOT and the Freeborn County Highway Department regarding the project. According to MNDOT and the Freeborn County Highway Department, the anticipated traffic increase along County Road 13 and State Highway 65 resulting from the Facility is not considered significant and is not expected to contribute to increased congestion on these roads. When contacted by Glenville West, neither Freeborn County nor the city of Glenville was aware of any other planned projects in the area of the proposed project that would impact traffic. Therefore, no significant cumulative impacts regarding transportation are expected from this project.

As discussed in Question 21, an increase in the number of trains in the area will occur as a result of this Facility. According to the Union Pacific, it is anticipated that train traffic along the mainline may increase by an additional one to two trains per day if a proposed biodiesel plant in the area of Winnebago, Minnesota is constructed. The expected cumulative increase in train traffic near the proposed site to a total of 13 to 14 trains per day is approximately 25 percent. Based on conversations with MNDOT, the Freeborn County Highway Department, and Union Pacific, the additional train traffic will not cause any significant congestion where the Union Pacific Railroad crosses County Road 13 near its intersection with State Highway 65.

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. No other impacts have been identified from the proposed project.

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.

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Scale: 1:24:000

Figure 1 Site Location Map

POET Biorefining – Glenville West

Glenville, Minnesota

October 2007 Job No. 12074-011 www.ensr.aecom.com

Proposed POET Biorefining –

Glenville West

County Road 13 (151st Street)

County Road 51 (160th Street)

LEGEND

Existing Glenville East/SoyMor Rail Spur

Proposed Glenville West Rail Spur Expansion Corridor

Existing Glenville East/SoyMor Access Road (780th Avenue)

Proposed 780th Avenue Extension Corridor

State Highway 65

Union Pacific Railroad

POET Biorefining – Glenville East

SoyMor

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Figure 2 Process Flow Diagram

NotTo

Scale

POET Biorefining – Glenville West

Glenville, Minnesota

October 2007 Job No. 12074-011 www.ensr.aecom.com

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Scale: 1:24:000

Figure 4 Potential Receptors Map

POET Biorefining – Glenville West

Glenville, Minnesota

October 2007 Job No. 12074-011 www.ensr.aecom.com

Proposed POET Biorefining – Glenville West Plant

County Road 13 (151st Street)

County Road 51 (160th Street)

LEGEND1-mile Radius from Glenville West Plant

Potential Noise/Sensitive Receptor

1/3-Mile to Nearest Potential Receptor

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Map adapted from FSA NAIP Air Photo: Freeborn County.

Figure 8

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File: 20071024_EAW_Fig8Plot Date: 10/24/07Arc Operator: PRBReviewed by: DMP

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Page 46: POET Biorefining - Glenville West (Ethanol Facility) Environmental

Figure 8 General Geologic Cross-Section in

Vicinity of Project

Not To

Scale

POET Biorefining – Glenville West

POET Biorefining – Glenville West

October 2007 Job No. 12074-011 www.ensr.aecom.com

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Scale: 1:24:000

Figure 11 Outfall Location Map

POET Biorefining – Glenville West

Glenville, Minnesota

October 2007 Job No. 12074-011 www.ensr.aecom.com

Proposed POET Biorefining –

Glenville West

County Road 13 (151st Street)

County Road 51 (160th Street)

Outfall 002 (Stormwater)

Outfall 001 (Stormwater)

Page 50: POET Biorefining - Glenville West (Ethanol Facility) Environmental

Exhibit 1

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Exhibit 2

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Clotts, Aaron

From: Gragg-Johnson, Kelly [[email protected]]

Sent: Thursday, October 11, 2007 3:27 PM

To: Clotts, Aaron

Subject: RE: Minnesota's State Historic Preservation Office Review of Proposed POET Biorefining - Glenville West Facility in Freeborn County

Page 1 of 2

10/11/2007

Aaron - This is correct. We appreciate the copies of the reports. They will be added to our bibliography and into our report files. We review federal undertakings and projects that fall under the field archaeology act and historic sites act. We will review EAW's under state law when the RGU is a state agency that is proposing the project (not like MPCA who is the permitting agency). If you have further questions, please feel free to call me. Kelly Kelly Gragg-Johnson Review & Compliance Associate MNSHPO 651-259-3455 [email protected]

�������������� ����������������� ������������������ ��� ������������������� ����������� �!""# "�! �����$�����%��� ���&��� �'��������� ('���)�*��������� ������ ���+ ,����-� �����.�� ��/������00���1�/��2�0.��3� ��.�4�5����0������$��/��'� �6��������6�������������Ms. Gragg-Johnson, Based on our conversation on October 11, 2007, it is ENSR's understanding that the Minnesota's State Historic Preservation Office (SHPO) has received the Initial and Supplemental Archeological Reconnaissance Survey for the Proposed POET - Biorefining - Glenville West Fuel Ethanol Plant reports. However, since the proposed project does not involve any Federal Action, such as a Historic Preservation Act Section 106 review request from the USACE, the SHPO will not review or comment on the provided reports. ENSR understands that this policy has been implemented since the SHPO's office does not have the staff or funding to complete any reviews other than those mandated by law. In order to provide documentation of the archeological reconnaissance reports being submitted to the SHPO and the SHPO's policy regarding reports that do not involve Federal Action for the project's Minnesota Environmental Assessment Worksheet (EAW), we request the favor of an email reply that ENSR's understanding of this situation is correct. If you have any questions please call me at 952-924-0117. Thank you, Aaron Clotts Project Specialist

Exhibit 3

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ENSR 4500 Park Glen Road, Suite 210 St. Louis Park, MN 55416 T: 952-924-0117 ext. 229 F: 952-924-0317 [email protected] www.ensr.aecom.com

Page 2 of 2

10/11/2007