November 23, 2011 TO: INTERESTED PARTIES

November 23, 2011 TO: INTERESTED PARTIES RE: Perham Resource Recovery Facility Expansion Project Environmental Impact Statement A voluntary Environmental Impact Statement (EIS) is being prepared by the Minnesota Pollution Control Agency (MPCA) on a proposal by the Prairie Lakes Municipal Solid Waste Authority to modify the Perham Resource Recovery Facility by adding a second heat boiler, as well as a material recovery facility at the site. The expansion would increase the municipal solid waste processing capacity of the facility from 116 to 200 tons per day. The MPCA is the responsible governmental unit for this EIS. Enclosed are the Scoping Environmental Assessment Worksheet (SEAW) and Draft Scoping Decision Document (SDD) for the proposed Perham Resource Recovery Facility Expansion Project. The SEAW and Draft SDD were prepared by the MPCA for a review and comment period ending on January 5, 2012, in compliance with the Environmental Quality Board (EQB) rules. The comment period will be extended for an additional eight days to allow for the holidays. A public scoping meeting will be held at the Perham City Council Chambers, 125 2nd Avenue NE, Perham, Minnesota, on Wednesday, December 14, 2011, from 6:30 p.m. to 9:00 p.m. The event will begin with informal discussions from 6:30 to 7:30 p.m. This public meeting will be open to interested parties who wish to comment on and ask questions regarding the SEAW and Draft SDD for the preparation of the EIS. Minn. R. 4410.2100 provides that an EIS scoping process be implemented for any EIS. The purpose of the scoping process is to reduce the scope and bulk of the EIS; identify only those potentially significant issues relevant to the proposed project; define the form used; determine the level of detail needed; define the content of the document; examine the alternatives to the proposed project; establish the timetable for preparation of the EIS; and determine the permits for which information would be developed concurrently with the EIS. The purpose of the EIS is the evaluation and disclosure of information about the significant environmental effects of a proposed action. The EIS is not intended to justify either a positive or negative decision on a project, but may be utilized by government units as a guide in issuing or denying permits or approvals for the project and in identifying measures to avoid or mitigate adverse environmental effects. Mitigation measures that could reasonably be applied to eliminate or minimize adverse environmental effects will be identified in the EIS in both the section describing environmental effects and in a separate section for permitting reference. Please note that comment letters submitted to the MPCA do become public documents and will be part of the official public record for this project.

p-ear2-30a

TDD (for hearing and speech impaired only): 651-282-5332 Printed on recycled paper containing 30% fibers from paper recycled by consumers

p-ear2-30a

SCOPING ENVIRONMENTAL ASSESSMENT WORKSHEET

Note to reviewers: This Environmental Assessment Worksheet (EAW) provides information about a project for the purpose of scoping a voluntary Environmental Impact Statement (EIS). This EAW and the accompanying draft Scoping Decision Document (SDD) were prepared by the Minnesota Pollution Control Agency (MPCA), acting as the Responsible Governmental Unit (RGU). The EAW addresses the nature of the EIS to the extent that information is readily available. The purpose of the draft SDD is to facilitate the delineation of issues and analyses to be contained in the EIS. The information in the EAW and the draft SDD is preliminary and subject to revision based on the entire scoping process. Comments on the EAW and draft SDD must be submitted to the MPCA during the comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) EQB Monitor on December 5, 2011, and will end on January 5, 2012. Comments should address the accuracy and completeness of information and the potential impacts that that warrant further investigation in the EIS. A copy of the EAW and draft SDD may be obtained from the MPCA by calling 651-757-2101. An electronic version of the completed EAW is available at the MPCA website at http://www.pca.state.mn.us/news/eaw/index.html#open-eaw. 1. Project Title: Perham Resource Recovery Facility Expansion Project 2.

Proposer:

Prairie Lakes Municipal Solid Waste Authority

3.

RGU:

Minnesota Pollution Control Agency

Contact Person Mike Hanan Contact Person Kevin Kain and Title Executive Director and Title Project Manager Address 1115 North Tower Road Address 520 Lafayette Road North Fergus Falls, Minnesota 56537 St. Paul, Minnesota 55155-4194 Phone 218-998-4898 Phone 651-757-2482 Fax 218-998-4899 Fax 651-297-2343 E-mail [email protected] E-mail [email protected] 4. Reason for EAW Preparation:

EIS Scoping

X

Mandatory EAW

CitizenPetition

RGUDiscretion

ProposerVolunteered X

If EAW or EIS is mandatory give EQB

rule category subpart number and name:

Minn. R. 4410.4300, subp. 17 – Solid Waste, Energy Recovery Facility or Incinerator – The Prairie Lakes Municipal Solid Waste Authority has volunteered to proceed with an EIS for its proposed project.

5. Project Location: County Otter Tail City Perham NE 1/4 SW 1/4 Section 14 Township 136 North Range 39 West

http://www.pca.state.mn.us/news/eaw/index.html#open-eaw

mailto:[email protected]


Perham Resource Recovery Facility Expansion Project Scoping Environmental Perham, Minnesota 2 Assessment Worksheet

GPS Coordinates: N 46.59071 W 95.56402

Tax Parcel Number 77000140001003

Attach each of the following to the EAW: • Figure 1 – State Map showing general location • Figure 2 – County map showing the general location of the project • Figure 3 – U.S. Geological Survey 7.5 minute, 1:24,000 scale map indicating project boundaries • Figure 4 – Site map showing project boundaries • Figure 5 – Site Plan • Figure 6 – Materials Recovery Facility (MRF) Process Flow Diagram

Attachment A – Minnesota Department of Natural Resources (DNR) Natural Heritage Review Attachment B – Minnesota State Historic Preservation Office (SHPO) letter Attachment C – Draft Scoping Decision Document

6. Description

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

The Prairie Lakes Municipal Solid Waste Authority (PLMSWA) proposes to modify the Perham Resource Recovery Facility (or PRRF) by adding a second waste heat boiler as well as a material recovery facility at the site. The expansion would increase the municipal solid waste (MSW) processing capacity of the facility from 116 to 200 tons per day (tpd).

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.

Existing facility description Through a joint powers agreement between Becker, Otter Tail, Todd, and Wadena Counties, the PLMSWA owns and operates a waste-to-energy (WTE) facility located in Perham, Minnesota (Otter Tail County), which receives and processes MSW from the four counties. This facility was previously owned by the city of Perham, which transferred ownership to the PLMSWA in June 2011. The PRRF consists of four major components: 1) waste receiving, processing, and storage; 2) combustion; 3) energy generation (i.e., steam and electricity); and 4) air pollution control (APC) equipment. The facility sells steam generated through the process to local customers and currently does not do any power generation. 1. Waste receiving, and processing and storage

The facility receives MSW on a regular basis from incoming trucks that unload inside a tipping building. The delivered waste is inspected and bulky waste, other unprocessable


materials and other unacceptable waste are removed. The tipping building is operated under negative air pressure, which means that air is drawn into the building from the outside to prevent the escape of dust and odors.

2. Combustion The facility currently consists of two municipal waste combustion (MWC) units (South Unit and North Unit), one waste heat boiler, and one APC system. Waste is moved from a hopper onto a grate that travels through a furnace where the waste is incinerated. Combustion is controlled by regulating the amount of waste fed to the grates, along with controlling the amount of combustion air that is provided through and above the grate surface. Once the waste reaches the end of the grate, combustion is complete, and the remaining material is bottom ash. The bottom ash is collected using a submerged drag chain conveyor that is essentially a trough filled with water (i.e., leachate). The bottom ash is quenched using collected leachate (i.e., seepage water from the Northeast Otter Tail Landfill), which cools the ash before it is removed for transport to the Northeast Otter Tail Landfill. Fly ash is also collected in the submerged drag chain conveyor. However, fly ash is light weight and, therefore, has a tendency to float on top of the water, unlike bottom ash which sinks to the bottom of the trough. Each week, fly ash laden water is pumped from the conveyor and sprayed at the Northeast Otter Tail Landfill. Prior to disposal, ferrous metals are recovered from the ash and sold to markets for recycling. The Northeast Otter Tail Landfill has a dedicated lined ash cell, where the PRRF ash is disposed of, and leachate is collected to replenish the conveyor water and reused in the ash quenching process.

The facility processes approximately 35,000 tons per year (tpy) of MSW, which is burned to produce steam. The steam is produced as hot flue gases leaving the combustion units, which then flow through the waste heat boiler, where heat is transferred from the gases to water flowing through tubes that are located in the hot flue gas path within the boiler.

3. Power generation

PRRF also has a steam turbine generator used to produce electricity, and a natural gas fired boiler that is used to supplement the production of steam to meet the demand of the customers. The steam turbine generator is a potential revenue source; however, it is not currently being operated because all of the steam produced in the waste heat boiler is sold to local consumers. Approximately 300,000,000 pounds of steam is produced and sold annually by the PRRF using a combination of the waste heat boiler and a natural gas fueled auxiliary boiler. Of the annual steam produced at the PRRF, approximately 200,000,000 pounds is generated by the waste heat boiler, and 100,000,000 pounds is generated by the auxiliary boiler. Currently the steam turbine generator is only operated for a short duration each year to determine its condition and ability to generate electricity if the need arises.

4. APC equipment

After leaving the waste heat boiler, the flue gas generated by the combustion of MSW enters into an APC system before being dispersed into the atmosphere through a stack. The PRRF APC system consists of powdered activated carbon, dry lime injection, and a spray dryer/fabric filter for particulate control. The cleaned gases exiting the stack are monitored continuously and tested periodically according to permit conditions by a third party contractor to verify compliance with regulatory standards.


Proposed project description PLMSWA proposed to add a second waste heat boiler and associated APC system to the existing south combustion unit so each combustion unit would have the capacity to combust up to 100 tpd of waste. The new waste heat boiler would include a superheater and economizer. The APC system would include a dry lime injection system for sulfur dioxide (SO2) and hydrogen chloride (HCl) control, activated carbon injection for mercury control, and a fabric filter baghouse for particulate control. These are the same types of air pollution controls that are used for the existing MWC units and waste heat boiler. The new boiler and APC system would be installed on the west side of the existing facility (see Figure 5).

The proposed boiler/baghouse building, approximately 65 feet by 82 feet, would house new equipment including the new waste heat boiler, economizer, acid gas removal equipment, baghouse, and induced draft fan. New refractory lined ducting would be added to direct the flue gas from the existing South Unit to the new equipment.

A new air emissions stack would be required for the new boiler. There are currently two air emissions stacks at the PRRF, one for the existing MWC units and the other for the auxiliary boiler. The existing MWC stack would remain associated with the existing North Unit. The new stack would be associated with the new waste heat boiler and APC system for the South Unit. The height and diameter of the new stack are expected to be similar to the existing stack associated with the existing waste heat boiler, which is 75 feet tall and has an exit diameter of four feet. The new stack would be located on the north side of the new building, aligned with and adjacent to the existing stack. Additionally, the existing powdered lime storage silo would be relocated to the southwest corner of the new boiler/baghouse building.

Because the proposed project would increase combustion capacity, additional processed MSW would be burned, which would produce additional ash. The existing ash system would meet the needs of the proposed project, and would not require modifications.

The existing ash system currently requires extra maintenance to remove fly ash laden water and extra hauling by leachate trucks to remove and replenish leachate water and, therefore, an ash conditioning system is being planned as part of the proposed project to further process the ash. An ash conditioning system mixes dry, dusty, fly ash residue thoroughly with water to allow the fly ash to meet the requirements for safe ash disposal. In the ash conditioning system, fly ash residue from the waste heat boiler, acid gas control equipment, and fabric filter hoppers is conveyed in fully enclosed conveyors to an enclosed holding hopper. When the holding hopper is full, it empties into a paddle mixer where the dry ash residue is mixed with water. The wet fly ash is then discharged onto a conveyor and sent to the roll-off container with the bottom ash for disposal. The paddle mixer would have a control system to assure proper mixing ratios of water to fly ash.

MRF The PRRF does not currently have a Materials Recovery Facility (MRF). The proposed project would add an MRF to presort incoming material in an effort to remove certain undesirable waste and recyclable components prior to combustion of the remaining material. The proposed MRF building would extend north from the existing tipping floor (Figure 5). Additionally, the existing tipping floor would be extended to the east (Figure 5).


The MRF system would be designed to recover ferrous (magnetic) metal, non-ferrous metals including aluminum and old corrugated containers (OCC) as the primary products. Undesirable waste and fines, including much of the glass and grit in the MSW, would be separated and removed from the fuel supply. The remaining material would be the fuel supply for the WTE plant, and would be conveyed to the existing refuse pit. The undesirable waste and fine material contains little combustible material and contains higher ash and abrasive material. Removing the aluminum and ferrous material from the fuel supply can also provide operating benefits for the combustion units.

The MRF requires new equipment, which would be housed in a new building, approximately 100 feet by 275 feet in size. The MRF equipment may include a trommel, an eddy current separator, a baler, two magnetic belt conveyors, manual picking stations, and various conveyors, as shown on Figure 6. Through the use of this equipment, the MRF is expected to recycle approximately five to eight percent of the incoming MSW in the form of OCC, ferrous metal, and aluminum. The trommel would be used to open trash bags and separate materials into three streams, fines (material less than two inches in size), middlings (material less than seven inches in size), and trommel discharge. The fines are conveyed directly to a dumpster for disposal. The middlings are sent to a belt magnet and the eddy current separator. The belt magnet would remove ferrous material, while the eddy current separator would remove non-ferrous metals, such as aluminum. Manual sorting could be used to recover OCC, and a baler would bail recovered material for recycling, such as corrugated cardboard and aluminum cans.

A new fence would be installed to the north, west, and east of the proposed MRF building based on surveyed property boundaries, as shown on Figure5.

Overall, the proposed project would reduce the amount of unprocessed MSW that is currently sent to landfills by Becker, Otter Tail, Todd, and Wadena Counties.

Construction of the proposed project

Construction of the proposed project would occur on an existing site, consisting of primarily impervious surface. Site grading would be required for construction of the proposed buildings (i.e., boiler/baghouse building and MRF building), but would be considered minimal. Construction is expected to begin after all permits are obtained, which is after the appropriate environmental review process is completed. Assuming a typical 18-month construction period, commercial operation could begin as early as May 2014, pending the outcome of environmental review and permitting. It should be noted that the air permit for this project will be developed during the EIS process.

Aside from potential changes in vehicle traffic patterns during construction, the operations would be largely unchanged with the proposed project. The majority of construction would occur while the facility continues to operate. There would likely be one or more brief facility outages for utility interconnections and separating the South Unit from the North Unit. These outages could be coordinated with a scheduled PRRF maintenance downtime and would not cause a significant impact on PRRF operations. Proposed treatment of topic in the EIS The EIS will include a complete project description, including the projected timing of all phases of construction and operation.


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.

Due to the availability of additional waste from Otter Tail County and other surrounding counties, and additional steam demand by customers, an expansion of the PRRF is being proposed. The proposed project would increase the MSW processing capacity of the facility from 116 tpd to as much as 200 tpd.

The purpose of the project is to increase the capacity of the existing PRRF. This would reduce the landfilling MSW through the increased capacity of the MWC Units and the addition of the MRF. The increased MWC capacity would allow the PRRF to produce additional steam using primarily processed MSW as the fuel source. The auxiliary boiler currently used in addition to the waste heat boiler is fueled by natural gas. The proposed project would reduce the use of the auxiliary boiler for meeting normal steam demand and, therefore, reduce the need for the PRRF to purchase and use natural gas, a fossil fuel. The proposed project would also have the ability to meet potential future increased demand for steam using processed MSW as the main fuel source.

Beneficiaries of the increased steam production from the proposed project are Tuffy’s Pet Foods, Incorporated (Tuffy’s Pet Foods) and Bongards’ Creameries (Bongards’) in Perham. In the long term, residents of Otter Tail and adjacent counties would benefit from the reduction of landfilled MSW and recyclables. This would extend the life of landfills. The proposed project also reduces the need for natural gas use. This ultimately reduces the cost to operate the facility and provides a means to dispose of MSW that reclaims the energy from the waste. Economic development benefits to these four counties would be realized through the creation of new jobs required for the construction of the proposed project, employment of additional on-site employees for operation of the facility, and through the beneficial energy generated and used by local food processing industrial customers.

The steam produced by PRRF is currently sold to two local industries: Tuffy’s Pet Foods and Bongards’. PRRF also has a steam turbine generator used to produce electricity, and a natural gas fired boiler, which is used to supplement the production of steam to meet the demand of the customers. The steam turbine generator is not currently being operated because all of the steam produced in the waste heat boiler is sold to local consumers. Approximately 300,000,000 pounds of steam is produced and sold annually by the PRRF using a combination of the waste heat boiler and natural gas fueled auxiliary boiler. Of the annual steam produced at the PRRF, approximately 200,000,000 pounds is generated by the waste heat boiler, and 100,000,000 pounds is generated by the auxiliary boiler.

Table 1 summarizes the current, projected, and maximum potential MSW processing compared to incinerator ash and steam production. The proposed project would allow more processed MSW to be burned in order to produce the same amount of steam that is currently produced, while using less natural gas. Meeting customer steam demand would be accomplished using a combination of the MWC and the auxiliary boiler. The proposed project would be able to accommodate the combustion of additional processed MSW to produce additional steam by primarily using the MWC if demand for steam increases. The use of processed MSW and the MWC would reduce the use of the auxiliary boiler and, therefore, the need for natural gas. The proposed project would also have the ability to meet potential future increased demand for steam using processed MSW as the main fuel source.


Table 1: Comparison of Existing Facility and Proposed Project Product Existing Facility

(2010 Actual)

Proposed Project Projected Actual Maximum Potential

at 200 tpd MSW 35,000 tpy 55,000 tpy 73,000 tpy Ash 8,800 tpy 11,754 tpy (3) 15,600 tpy (3) Steam Production From MSW From Natural Gas

200,000,000 lbs 100,000,000 lbs

336,600,000 lbs (1) 24,550,000 lbs (2)

411,020,000 lbs. Future amount unknown

Steam Sales/Demand

300,000,000 lbs. 300,000,000 lbs. Future demand unknown

Notes: 1. Excess steam produced from MSW to be condensed by the steam dump condenser. 2. Steam from the auxiliary boiler required to allow for maintenance downtime of the

MWCs assumed at 8.0 percent. 3. The ratio of ash generation to total MSW is estimated to be approximately 15 percent

less with the proposed project compared to the existing facility. This is because the MRF would remove 5-8 percent of the recyclable materials and approximately 10 percent of the fines prior to combustion.

d. Are future stages of this development including development on any other property planned or likely to happen? Yes No If yes, briefly describe future stages, relationship to present project, timeline and plans for environmental review.

There are no future stages of development planned. As part of the proposed project, the parcel adjacent to the north of the existing PRRF facility property has been purchased. This parcel would be used for expansion of the MRF and as entry and exit of the facility from Sixth Avenue Northeast.

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.

The existing facility started operation in 1986, and made technology improvements in 2002. The proposed project is an expansion of the existing facility. No previous environmental review has been done on this facility.

7. Project magnitude data Total Project Area (acres) 4.2 or Length (miles) NA

Number of Residential Units:

Unattached

0

Attached

0

Maximum Units Per Building:

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

total square feet

55,000

Indicate area of specific uses (in square feet):

Office 2,300 Manufacturing 0 Retail 0 Other Industrial See below* Warehouse 0 Institutional Light Industrial 0 Agricultural Other Commercial (specify) Building height See below * If over 2 stories, compare to heights of nearby buildings

* MRF: 27,500 square feet Tipping Floor: 3,000 square feet Boiler/Baghouse: 5,395 square feet Office Area: 2,300 square feet Warehouse (bale storage): 3,772 square feet Existing Building: 13,000 square feet

Existing building: 58 feet Existing cooling towers: 71 feet Existing waste heat boiler stack: 75 feet Existing auxiliary boiler stack: 89 feet Proposed MRF building: 31 feet Proposed other buildings: 21-25 feet Proposed stack: 75 feet

Proposed treatment of topic in the EIS The expected project magnitude data information is adequately described in this document. The topic will not be carried forward into the EIS.

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. All of these final decisions are prohibited until all appropriate environmental review has been completed. See Minnesota Rules, Chapter 4410.3100.



Table 2: Permits and Approvals Required for the Proposed Project

Unit of Government Type of Application Status

Federal Federal Aviation Administration (FAA)

FAA Notification Form 7460-1 To be obtained, if needed

State of Minnesota MPCA National Pollutant Discharge

Elimination System/State Disposal System (NPDES/SDS) Industrial Stormwater Permit

To be amended

NPDES/SDS Stormwater Construction Permit

To be applied for

Air Emissions Permit To be amended

Capital Assistance Grant Program - $8.075 million

Awarded in 2010

DNR Minnesota Natural Heritage Database Review

Complete

SHPO Cultural Resources Review Complete Local City of Perham Building Permit and Zoning

Certificate To be obtained

Conditional Use Permit To be obtained

Proposed treatment of topic in EIS An updated list of known governmental permits and/or approvals required for the proposed project and the responsible government unit will be included in the EIS.

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 project site is located within the city limits of Perham, Minnesota in a fully developed portion of the city’s industrial park. This 4.2-acre, triangular shaped property (Figure 4) has been the site of the PRRF since it was constructed and began operation in 1986. It is compatible with its immediately adjacent land uses. The Burlington Northern Santa Fe (BNSF) Railroad line runs southeast to northwest along the south property boundary, which separates the facility from commercial development on the other side of County Highway 80 (i.e., Main Street), which travels northwest into downtown Perham. To the west of the project site is the Bongards’ facility, while directly north is vacant and partially developed land, currently owned by Bongards’. The PRRF supplies Bongards’ and Tuffy’s Pet Foods (just west of Bongards’) with steam for use in their facilities. The north and east sides of the PRRF are zoned as an industrial district and are currently developed for commercial and industrial type land use. These directly adjacent land uses are compatible with the existing facility and proposed project.


The proposed project would include the purchased of Bongards’ property (1.8 acres) directly north of the existing PRRF facility. This property would be used for expansion of the MRF facility. It would include two-way road access from Sixth Street Northeast. The proposed project would expand the existing structure of the PRRF and add one new emissions stack. Residential areas with single and two-family homes are within 600 feet of the PRRF, but are located beyond the expansion property and the BNSF Railroad line. With the exception of a few homes to the north of the project site, most residential areas are screened from direct view of the PRRF by trees and existing commercial and light industrial-type buildings. In the southern corner of the PRRF property, Otter Tail County owns and operates the Perham Recycling Redemption Center. This facility accepts glass, plastic bottles, aluminum, tin, magazines, newspaper and telephone books, corrugated cardboard, and office paper. It is open Friday afternoons and Saturday mornings. In the northwest corner of the property is the Perham City Substation, which connects to a 115 kilovolt (kV) transmission line that runs from the city of Perham to the 115 kV transmission line in the city of Frazee and beyond. The substation is owned and maintained by Great River Energy and currently has a capacity of approximately 42 kV.

Proposed treatment of topic in the EIS The expected land use impacts are adequately described in this document. Based on the information provided, the anticipated effects would be negligible. No further review in terms of land use is warranted. The topic will not be carried forward into the EIS.

10. Cover types. Estimate the acreage of the site with each of the following cover types before and

after development: Table 3: Cover Types for Existing Facility and Proposed Project

Cover Type Before (acres)

After (acres)

Cover Type Before (acres)

After (acres)

Types 1-8 wetlands

0 0 Lawn/landscaping 2.67 0.55

Wooded/forest 0 0 Impervious surfaces 1.53 3.65 Brush/Grassland 0 0 Stormwater Pond 0 0 Cropland 0 0 Other (describe) TOTAL 4.2 4.2

Proposed treatment of topic in the EIS The expected cover types are adequately described in this document. Based on the information provided, the anticipated effect would be negligible. No further review in terms of cover types is warranted. The topic will not be carried forward into the EIS.


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.

The proposed project is the expansion of an existing WTE facility. The project site is located within the city of Perham. The proposed project would increase the size of the overall property by 1.8 acres. The existing facility consists mainly of impervious surfaces, including buildings and paved areas, as well as some grass. The area where the expansion would occur consists mainly of grass and some paved surfaces. Both the existing and proposed expansion portions of the project site are located within a fully developed part of the city of Perham. There is little to no habitat value for aquatic or terrestrial plants or animals at either the existing facility or the proposed parcel where the expansion would occur. There are no ecologically sensitive habitats or resources located on the project site. There may be some plants or wildlife typical of an urban setting, such as song birds or small mammals and rodents that may occasionally utilize the grass at the project site; however, due to the absence of wildlife habitat on the project site, the proposed project would not result in a significant impact to terrestrial or aquatic plant or wildlife populations.

b. Are any state-listed (endangered, threatened or special concern) species, rare plant communities or other sensitive ecological resources on or near the site? Yes No

If yes, describe the resource and how it would be affected by the project. Describe any

measures that will be taken to minimize or avoid adverse impacts. Provide the license agreement number (LA-___) and/or Division of Ecological Resources contact number (ERDB 20110417) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources. Indicate if any additional survey work has been conducted within the site and describe the results.

The results of the DNR Natural Heritage database query indicated no known occurrences of rare

features within a one-mile radius of the proposed project. Appendix A provides the DNR query results.

Proposed treatment of topic in the EIS The expected impacts to fish, wildlife, and ecologically sensitive resources are adequately

described in this document. Based on the information provided, the anticipated effects would be negligible. No further review in terms of fish, wildlife, and ecologically sensitive resources is warranted. The topic will not be carried forward into the EIS.

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

Proposed treatment of topic in the EIS An assessment of the physical impacts of the project on water resources is not warranted and will not be addressed in the EIS.


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 PRRF obtains water from the city of Perham municipal water supply. Water from the municipal water supply is currently used at the facility for drinking/sanitary/maintenance, cooling tower make-up, and boiler make-up purposes. The PRRF currently has 15 employees, and drinking/sanitary/ maintenance water makes up a small annual percentage of the total water used at the PRRF. It is estimated that approximately 161,000 gallons of water per year would be used for the ash conditioning system based on the estimated ash production and MSW combustor use of the proposed project. The proposed project would require an additional 12 employees to operate the facility. This would increase the domestic water use at the facility. This increase, however, would not be significant compared to the current quantity of water that is used and, therefore, no significant changes to domestic water usage would result from the proposed project. It is not anticipated that temporary dewatering of local groundwater would be required during construction of the proposed project. Proposed treatment of topic in the EIS The existing and estimated future water uses will be described in the EIS.

14. Water-related land use management district. Does any part of the project involve a shoreland

zoning district, a delineated 100-year flood plain, or a state or federally designated wild or scenic river land use district? Yes No

If yes, identify the district and discuss project compatibility with district land use restrictions.

The project site is not located in a shoreland zoning district, delineated 100-year floodplain, or state or federally designated wild or scenic river land use district. Proposed treatment of topic in the EIS The topic is not relevant and will not be addressed in the EIS.

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.

The project site is not located near any water bodies and, therefore, would not impact water surface use.

Proposed treatment of topic in the EIS The topic is not relevant and will not be addressed in the EIS.

16. Erosion and sedimentation. Give the acreage to be graded or excavated and the cubic yards of soil

to be moved: >1 acre; cubic yards: 3,000. Describe any steep slopes or highly erodible soils and identify them on the site map. Describe any erosion and sedimentation control measures to be used during and after project construction.

The existing project site is approximately 2.4 acres, and the proposed project would include expanding onto an adjacent parcel that is approximately 1.8 acres. The existing parcel is primarily impervious surface, while the adjacent parcel has both impervious surface and turf grass areas. The project area is relatively flat with no steep slopes and no highly erodible soils and, therefore, erosion and sedimentation are expected to be minimal. It is anticipated that the site would be graded on the adjacent parcel for construction of the proposed project. It is estimated that the proposed project would disturb more than one acre of land, and as a result would be required to obtain an NPDES/SDS Stormwater Construction Permit. The NPDES/SDS Construction Permit requires the development of a Stormwater Pollution Prevention Plan (SWPPP) prior to construction, which would require best management practices for erosion and sedimentation control.

Temporary erosion and sediment control measures would be used where applicable. Areas for equipment staging and materials may prove to be needed. These areas would be treated with the same erosion and sediment control measures as the construction areas. Temporary erosion and sediment control measures such as silt fences, check dams, mulching, etc. would be used where applicable. Soils tracked from the construction site by motor vehicles and equipment would be cleaned from paved surfaces throughout the duration of construction. All disturbed vegetated areas of the site would be seeded and mulched as soon as practical upon completion of final grading work.

Proposed treatment of topic in the EIS The expected impacts to erosion and sedimentation are adequately described in this document. Based on the information provided, the anticipated effect would be negligible. No further review in terms of erosion and sedimentation is warranted. The topic will not be carried forward into the EIS.

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 existing site is almost completely impervious surface. The adjacent parcel where the MRF would be constructed is also primarily impervious surface with some turf grass areas and, therefore, the quantity and quality of the stormwater site runoff is not anticipated to change


significantly as a result of the proposed project. There are no stormwater ponds or other stormwater management infrastructure or treatment in place at the site. The proposed project does not plan to add new stormwater management measures to the site outside of what is required by the NPDES/SDS permits and the SWPPP once it is created. Most operational activities at the PRRF occur indoors where there is less likelihood of stormwater coming into contact with MSW, ash, or household hazardous waste. This minimizes the potential for stormwater to carry pollutants from PRRF activities off site. Some incidental materials received, such as tires and steel are accumulated in a roll-off container outside of the building before being hauled off site. The storage of these incidental materials in a container is temporary and not likely to cause significant impacts to stormwater runoff. The PRRF currently has an NPDES/SDS Permit (MN0064715) for the operation of the facility. This permit outlines conditions that the PRRF must meet in order to operate within compliance. The permit requirements include items such as surface discharge requirements, monitoring, and reporting. This permit would be amended to reflect the proposed project. The NPDES/SDS Permit requires a SWPPP, which would outline best management practices and erosion and sedimentation control measures for the facility. Additionally, as described in Question 16 above, an NPDES/SDS Construction Permit and SWPPP would be required for the proposed project.

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 currently flows toward the southwest corner of the site, where it eventually flows off of the property. There are no stormwater ponds or city storm sewer in place on site. Surface water runoff is allowed to naturally flow into grassy areas adjacent to the project site. The nearest water body to the project site is the Otter Tail River, which is located approximately 1.25 miles to the east and southeast of the site. Several lakes are located downstream of the Otter Tail River. Rush Lake is approximately seven miles downstream, then Otter Tail Lake is about 3.5 miles downstream of Rush Lake. The Otter Tail River eventually joins the Red River of the North at its confluence with the Bois De Sioux River at the North Dakota border. The surface water runoff from the site is not likely to change significantly with the proposed project. Discharge during construction and operation of the project would continue to be regulated by NPDES/SDS permits, which would include SWPPP requirements. The water quality of the runoff is not anticipated to change from existing conditions and, therefore, no significant impacts to surface water runoff and potential receiving water bodies is anticipated. Proposed treatment of topic in the EIS The expected impacts to water quality from surface water runoff are adequately described in this document. Based on the information provided, the anticipated additional effects from the project would be negligible. No further review of impacts related to stormwater runoff is warranted. The topic will not be carried forward into the EIS.


18. Water quality: wastewaters

a. Describe sources, composition and quantities of all sanitary, municipal and industrial wastewater produced or treated at the site.

The existing PRRF produces domestic wastewater from the 15 employees working at the plant, along with process wastewater consisting of cooling tower blowdown, boiler blowdown, water softener discharge, and reverse osmosis (RO) reject water. Floor drains at the facility also produce some minimal wastewater. Upon completion of the proposed project, the facility would employ approximately 12 additional people, increasing the quantity of domestic wastewater discharges, but by a relatively small amount in comparison to the overall quantity of wastewater at the facility. Process wastewater is anticipated to increase from the cooling tower blowdown (see question 13). The quantity of cooling tower blowdown is anticipated to be approximately 185,000 cubic feet (1,382,000 gallons) annually. Cooling tower blowdown is discharged to the city of Perham sanitary system. The PRRF currently operates under an NPDES/SDS Permit that regulates wastewater discharge. This permit would be amended for the proposed project and wastewater discharge would continue to be regulated. According to the existing PRRF NPDES/SDS Permit, the facility currently discharges RO reject water at an average rate of 32,500 gallons per day (gpd). Unless steam sales were to increase in the future, which would require additional steam production, wastewater discharge for the proposed project is estimated to remain similar to existing conditions.

b. Describe waste treatment methods or pollution prevention efforts and give estimates of composition after treatment. Identify receiving waters, including major downstream water bodies (identifying any impaired waters), 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. Domestic wastewater generated at the PRRF is directed to the city of Perham municipal sanitary sewer system. Process wastewater, with the exception of RO reject water, is also discharged to the city of Perham sanitary sewer system. No pretreatment of wastewater occurs at the PRRF prior to discharge. Floor drains discharge to a sand and oil interceptor prior to entering the sanitary sewer system. The sand and oil interceptor captures most of the grit (i.e., ash, sand, etc.) and oil that could potentially flow into the floor drain. Additionally, drains are protected from spills and leaks that may occur during normal operations at the facility by utilizing standard spill prevention and control measures. The PRRF operates under an NPDES/SDS Permit that regulates discharge of wastewater. The permit indicates that the waste stream authorized for discharge consists of reject waters from the RO system at an average rate of 32,500 gpd and a maximum daily discharge of 60,000 gpd. For industrial water treatment/cooling process water, the PRRF is authorized to discharge reject waters from the RO system at a rate that shall not exceed 200,000 gpd. These discharge limits would not be exceeded by the proposed project.


As described by the NPDES/SDS Permit, the RO system is used to produce ultra-pure water for use in the PRRF boilers. Incoming city water passes through a set of pre-filters where chemicals are added for dechlorination and anti-scaling. Water is then pressed through the RO membranes where the minerals are removed and the reject water is routed to storage tanks, which are eventually pumped to the drain basin. From the drain basin, the reject waters are routed to the municipal storm sewer system. The city of Perham storm sewer system eventually discharges to a wetland area upstream of the Otter Tail River east of the city of Perham approximately 1.5 miles, near U.S. Highway 10.

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. The city of Perham’s Wastewater Treatment Plant (WWTP) serves four significant industrial users: Barrel O’ Fun Snack Foods, Kenny’s Candy Company, Primera Foods Corp., and Tuffy’s Pet Foods. The average 2010 inflow to the WWTP exceeded the system’s currently permitted average wet weather (AWW) flow of 0.580 million gallons per day and influent loadings. Domestic flow into the city’s WWTP makes up slightly half of the total flow into the facility. The city is in the process of increasing its WWTP capacity. The city of Perham has identified the WWTP in their 2010 Capital Improvement Plan. The proposed improvements to the city’s WWTP include a 20-year design that would double the size of the facility and, therefore, would accommodate future growth and development in the city. The EAW process was completed for this project in June 2011. The city WWTP does not discharge to any surface water bodies. The WWTP includes a pond system where waste is treated and land applied at several sites. A system of groundwater monitoring wells is in place as required by the WWTP permit. There have been no compliance issues with these wells. Sanitary sewer lines are cleaned yearly, and lift stations are maintained on a regular basis. Based on their current capacity and anticipated future capacity, the treatment plant is expected to have an adequate capacity to handle and treat the additional wastewater discharges from the PRRF proposed project and, therefore, no additional improvements to the treatment plant are necessary. Currently proposed improvements to the Perham WWTP would be able to handle any future increased discharge from the proposed project.

Proposed treatment of topic in the EIS The changes in wastewater generation by the facility and the potential impacts of the increase in wastewater generation will be carried into the EIS.

19. Geologic hazards and soil conditions Approximate depth to groundwater: 20 feet minimum, 30 feet maximum

Approximate depth to bedrock: 200 feet minimum, 300 feet maximum


a. 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.

The facility is located in glacial outwash deposits. In this type of geology, there is low sinkhole probability and, therefore, problems with sinkholes or karst topography-type features are not anticipated. The Minnesota Department of Health (MDH) database lists nine wells in Section 14 in the city of Perham. All of the wells indicate water between 20 and 30 feet deep. Groundwater flows in an easterly direction toward the Otter Tail River. All of the wells were installed into sands and gravels, which is typical for glacial outwash deposits. Bedrock is greater than 152 feet deep. Geologic maps indicate that bedrock in the area is Precambrian igneous and metamorphic rock, which is not a viable water source. The Hydrologic Atlas HA-296 indicates that bedrock is between 200 and 300 feet deep with the water table occurring at about 1,340 above mean sea level, which is about 24 feet deep in this area.

b. Describe the soils on the site, giving NRCS (SCS) classifications, if known. Discuss soil

granularity and potential for groundwater contamination from wastes or chemicals spread or spilled onto the soils. Discuss any mitigation measures to prevent such contamination.

Based on soil survey maps of Otter Tail County, the general soil associated with the project area

is the Hubbard series. These soils tend to be excessively drained, consisting of sand and mixed loams. The soils are typically located within outwash plains, such as the Detroit Lakes Pitted Outwash Plain, that are nearly level with slopes ranging between 0 to 2 percent. Permeability is rapid and available water holding capacity is low. The soils have deep water tables and are not conducive to flooding or ponding.

There have been no soil borings completed at the site in the recent past. The surface of the

project site is primarily impervious. Minimal excavation would be necessary for the proposed project. Footings would be placed for expansion of the building, but no deep excavation would be necessary. The construction of the proposed project is not anticipated to encounter groundwater. Groundwater in the area is typically 20 to 30 feet deep and flows in an easterly direction toward the Otter Tail River.

Construction and operation of the proposed project would comply with NPDES/SDS Permits to

minimize surface water runoff and potential groundwater contamination. Permeability of the soils at the project site is considered moderately slow to moderately rapid. The Minnesota Hydrogeologic Atlas indicated that the project site is located in an area rated as high sensitivity to groundwater contamination. This means that the estimated vertical travel time to reach groundwater from pollution located at or near the surface is likely weeks to months. This is dependent, however, on a site’s soil conditions. As previously stated, the project site is primarily impervious surface. For the existing facility and the proposed facility spills would be addressed as soon as possible and contained as defined in the facility’s spill response procedures. Groundwater contamination is not anticipated from the proposed project.


Proposed treatment of topic in the EIS The expected impacts related to geologic hazards and soil conditions are adequately described in this document. Based on the information provided, the anticipated effect would be negligible. No further review in terms of geologic hazards and soil conditions is warranted. The topic will not be carried forward into the EIS.

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 MSW, 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.

As described in the response to Question 6, the PRRF is an existing solid waste processing facility, and the proposed project would include expansion and upgrades of that facility. Existing facility The PRRF accepts municipal solid waste for processing in its facility from contracted counties, including Becker, Otter Tail, Todd, and Wadena Counties. Each of these counties operates under a solid waste management plan as required by state regulations. Further discussion on state and county policy is provided below. PRRF currently processes approximately 35,000 tpy of MSW. The PRRF is able to process almost all of the waste it receives. Of the 35,000 tpy of MSW processed at the PRRF, Otter Tail County sent approximately 22,450 tons and Todd and Wadena Counties each sent approximately 6,175 tons. The following table provides a summary of the MSW that was processed at the PRRF in 2010, which only included Otter Tail, Todd, and Wadena Counties. Becker County is discussed under the proposed project, but did not dispose of MSW at the PRRF in 2010. Becker County began delivering MSW to the PRRF in mid-2011.

Table 4: MSW Processed at PRRF in 2010 and Projected Becker County MSW

Otter Tail, Todd, and Wadena Counties

Becker County (Projected) (1)

Total

Total tpy 34,805 14,000 48,805 Average tons per day (based on a 7-day week)

101 35 136

Average tons per day (based on a 5-day work week)

141 50 190

Source: Wilson, March 2011 (1) Becker County MSW was included in this table to illustrate the quantity of waste that would be

available for the proposed project. Becker County did not deliver MSW to the PRRF in 2010.


Seasonal variations in waste quantities normally occur. This region is the location of many lakes and seasonal homes and residents. During summer months, waste generation is typically greater than during the winter season. These fluctuations in waste quantities are managed at the PRRF by using a multi-day waste-storage capacity onsite and by scheduling facility maintenance for periods of the year when waste generation is low. Data provided by Otter Tail County indicates that in 2010 the County generated a total of 29,718 tons of MSW. A large percentage of this waste was delivered to and processed at the PRRF (i.e., 22,447 tons), while 7,271 tons was disposed of in the Dakota Landfill in Gwinner, North Dakota. Of the MSW hauled to the Dakota Landfill, it is estimated that 1,500 tons is of a composition that could be combusted at the PRRF. The remaining waste (about 5,800 tpy) would likely always be bypassed to the landfill due to its composition. In 2010, Todd County sent 6,174 tons of MSW to the PRRF, while 3,883 tons were hauled to the Morrison County Landfill in Little Falls, Minnesota for disposal. It is estimated that of the MSW that was landfilled, approximately 1,700 tons could be combusted at the PRRF. Wadena County has a solid waste management plan in place. In 2009, Wadena County delivered 6,165 tons of MSW to the PRRF for processing, while 1,998 tons were hauled to the Dakota Landfill in Gwinner for disposal. Of the MSW sent to the landfill, it is estimated that approximately 400 tons could be combusted at the PRRF. Table 5 summarizes the amount of MSW and recyclables generated by each of the four counties in the region that bring MSW to the PRRF. The information presented in the table was obtained from the 2009 SCORE Report published by the MPCA in December 2010, which collected data and information from counties throughout Minnesota.

Table 5: Summary of MSW and Recyclables Generated by Each County in 2009

County Total MSW Collected

(tons)

Total Recyclables

Collected (tons)

Recycling RateWith Credits 1

Problem Materials Collected

(tons) Becker 29,445 11,932 48.5% 1,058 Otter Tail 39,511 8,645 29.9% 1,102 Todd 26,001 13,975 60.7% 400 Wadena 14,235 6,220 49.7% 325 Minnesota 5,650,780 2,456,856 50.6% 126,638 Greater Minnesota

2,456,730 1,045,082 49.6% 67,760

Source: SCORE Report (MPCA, 2009) 1 The recycling rate with credits includes a source reduction credit and a yard waste credit. The existing PRRF also collects incidental recyclable materials, such as steel, that comes in with the delivered MSW. These recyclable materials are sold to various vendors throughout the region for market value.


Unprocessable waste Unprocessable waste is transported primarily to the Dakota Landfill located in Gwinner, North Dakota. The Dakota Landfill also serves as the bypass landfill for the PRRF in the event of a shutdown or other reason that waste cannot be handled. Unprocessable waste at the PRRF includes those wastes that cannot be incinerated or recycled, such as tires, mattresses, and other items. Waste generation Combustion ash is the byproduct after the processed MSW has been burned. In 2010, approximately 8,800 tons of ash was generated at the PRRF. Combustion ash is temporarily stored at the PRRF in 20 cubic yard roll-off containers until disposal. The ash is disposed of in the Northeast Otter Tail Landfill (permit SW-544). This landfill is owned and operated by Otter Tail County and is located approximately two miles west of New York Mills on U.S. Highway 10. In addition to ash from the PRRF, the landfill also accepts demolition debris. Leachate from this landfill is collected and transported to the PRRF to quench the incinerator ash. The quenched ash from the PRRF is currently disposed of in a dedicated ash cell at the Northeast Otter Tail Landfill. The landfill is currently permitted to accept incinerator ash. Based on the 2010 Northeast Otter Tail Phase II Ash and Demolition Landfill Annual Report, it has a remaining ash capacity of 169,363 cubic yards. At the current disposal rate of approximately 8,800 tons of ash per year, the life expectancy of the ash landfill is approximately 21 years. This calculation is based on an average of 1.1 tons (i.e., 2,200 pounds) of ash is equal to one cubic yard.

Proposed project The proposed project would continue to use the existing PRRF, but would burn more processed MSW and have the potential to produce steam at an increased rate. The proposed project would allow the PRRF to process up to 200 tpd of MSW. As described in more detail in the response to question 6, the proposed project would make improvements to and expand the existing PRRF. It would also include the addition of a MRF. Installation of the MRF would improve the characteristics of the MSW by removing non-combustibles and undesirable waste items from the trash before burning it in the existing plant combustors, which in turn reduces the percentage of ash generated per ton of MSW processed. It would also remove recyclable materials.

MSW Through the partnership established by the PLMSWA with Becker, Otter Tail, Todd, and Wadena Counties, agreements have been made to accept additional waste for incineration at the PRRF once the proposed project is in place. Becker County has recently begun delivering MSW to the PRRF. Previously, MSW generated in Becker County was landfilled via transfer station in Detroit Lakes to the city of Fargo landfill for disposal. Table 5 above provides a summary of the annual MSW produced in each of the partnering counties. Additionally, Table 4 shows the projected quantity of MSW that Becker County would deliver to the PRRF for processing after the proposed project was in operation. The proposed project is currently projected to begin operations by processing approximately 55,000 tpy of MSW, and would have the capacity to handle more MSW if the need arises. The maximum capacity of the PRRF with the proposed project would be up to 73,000 tpy MSW.


Recyclable materials As part of the proposed project, the MRF could potentially result in a small increase in the quantity of recyclables. MRFs typically recover approximately six percent by weight of the MSW processed as recyclables, but the actual recovery and disposal rates of materials is dependent on the characteristics of the waste stream delivered to the facility. Large cardboard (OCC), ferrous and non-ferrous metals would be recovered from the waste stream in the MRF for recycling. If operating at maximum capacity, up to 280 tpd of MSW would be processed through the MRF. The PRRF would seek appropriate market vendors for any increase in recyclable materials. Table 6 shows the recyclable materials recovered in the four-county area based on the 2009 SCORE Programs Report. Table 6: Annual Quantities of Recyclable Materials (tons/year)

Aluminum Co-mingled Metal

Other Ferrous and Non-ferrous

Steel/Tin Cans

Glass

Total 406 2,230 5,189 236 1,482 Overall Total 9,543

Source: SCORE Report, 2009 The purpose of the MRF is not to change the existing county recycling programs, but to compliment the programs. The public has developed a key role in successful implementation of those programs. The MRF has two main purposes. The first is to improve the characteristics of the MSW by removing non-combustibles and undesirable waste items from the MSW prior to burning it in the PRRF combustors, which would reduce operational and maintenance costs. The second objective is to capture a portion of the recyclables in the MSW, which would lead to a reduction in ash quantities sent to the landfill and provide a means to recycle more materials. Unprocessable waste The process for handling unprocessable waste at the PRRF would remain the same under the proposed project. Because the quantities of MSW processed by the PRRF would increase under the proposed project, a proportionate amount of unprocessable and hazardous waste is also likely to increase, which would either be hauled to the Dakota Landfill or handled according to State regulations. Waste generation Under the proposed project, incinerator ash would be produced at a rate slightly less than is currently produced for the total amount of MSW. This is because an estimated five to eight percent of recyclables and 10 percent of fines would be removed from the MSW in the MRF prior to combustion. This means approximately 15 percent less ash is produced for the same total amount of MSW using the MRF. Because the proposed project would process more MSW, it is estimated that the projected operational rate would be approximately 12,000 tpy of ash, compared to approximately 9,000 tpy with the existing PRRF. A maximum estimated quantity of ash produced with the proposed project would be up to 15,500 tpy.. Table 1 in the response to question 6 provides a summary of comparison between the existing PRRF and the proposed project. Based on the 2010 Northeast Otter Tail Phase II Ash and Demolition Landfill Annual Report, the remaining ash capacity is 169,363 cubic yards. At the proposed disposal rate of approximately 11,700 tons of ash per year, the life expectancy of the ash landfill is approximately 16 years. The life expectancy of the landfill could be decreased if the PRRF


operated at maximum capacity. Additionally, the PRRF intends to implement ash utilization as an ash reduction program, which could utilize as much as 50 percent of the ash generated for beneficial use rather than disposal. This would extend the life expectancy of the landfill.

Construction of the proposed project would produce solid waste, which would be disposed of off site. The contractor would be responsible for solid waste disposal. The solid waste would include normal construction debris such as scrap wood, plastics, wallboard, packing material, cardboard, scrap metals, and electrical wires. These materials would likely be disposed of in the Northeast Otter Tail Landfill, which is a demolition landfill located toward the east between the city of Perham and the city of New York Mills. Recycling of construction waste material would be the responsibility of the contractor. No hazardous waste is expected to be encountered during construction; however, if hazardous material is encountered during the construction, it would be the responsibility of the contractor to dispose of such material according to all applicable rules and regulations.

Minnesota solid waste policy The state of Minnesota has a solid waste policy in place which guides and regulates solid waste management by local governments. Counties are designated the solid waste authority and are regulated and monitored by the state. The MPCA is the lead agency for the administration and implementation of solid waste policy in Minnesota. The MPCA ensures that the Minnesota Waste Management Hierarchy (Minn. Stat. § 115A.02b) is carried out in solid waste management decisions across the state.

The Minnesota Waste Management Hierarchy sets the goals and policies from which solid waste management activities are measured. Waste management activities at the bottom (i.e., number six) of the hierarchy are less desirable in Minnesota compared to waste management activities at the top of the hierarchy. Waste management activities closer to the top of the hierarchy are viewed as having a greater environmental benefit, such as reducing greenhouse gas and consumption of resources.

Minnesota Waste Management Hierarchy (Minn. Stat. § 115A.02b) The waste management goal of the state is to foster an integrated waste management system in a manner appropriate to the characteristics of the waste stream and thereby protect the state's land, air, water, and other natural resources and the public health. The following waste management practices are in order of preference: (1) waste reduction and reuse; (2) waste recycling; (3) composting of yard waste and food waste; (4) resource recovery through mixed MSW composting or incineration; (5) land disposal which produces no measurable methane gas or which involves the retrieval of methane gas as a fuel for the production of energy to be used on-site or for sale; and (6) land disposal which produces measurable methane and which does not involve the retrieval of methane gas as a fuel for the production of energy to be used on-site or for sale.

The MPCA is required by Minn. Stat. § 115A.411 to prepare a solid waste policy report on odd numbered years. The purpose of the report is to review the current status of solid waste management, to evaluate the state’s progress toward accomplishing state policies and goals,


and to make recommendations for changes relative to solid waste management in Minnesota. The 2009 Solid Waste Policy Report discussed the Integrated Solid Waste Management Stakeholder work group, which was formed based on recommendations from the 2007 Solid Waste Policy Report and the Minnesota Climate Change Advisory Group (MCCAG). Through the 2007 Next Generation Energy Act, greenhouse gas emissions goals were set in Minnesota that would reduce 2005 levels by 30 percent by 2025 and by 80 percent by 2050. Improving waste management practices was one of the tools listed by MCCAG as being feasible to meeting this goal. Additionally, the 2009 Solid Waste Policy Report concluded that “continued local leadership is important.” Going on to state that, “In particular, stronger intergovernmental partnerships and regional governments can be effective and efficient in providing waste management services in accordance with the hierarchy and corresponding environmental benefits to their constituents.”

Proposed treatment of topic in the EIS A technical report will be prepared on the solid waste management programs and practices of the regional and local governing bodies in Otter Tail, Wadena, Todd, and Becker Counties. b. Identify any toxic or hazardous materials to be used or present at the site and identify

measures to be used to prevent them from contaminating groundwater. If the use of toxic or hazardous materials will lead to a regulated waste, discharge or emission, discuss any alternatives considered to minimize or eliminate the waste, discharge or emission.

The PRRF uses and stores diesel fuel and used oil in quantities necessary to maintain and operate equipment. The PRRF obtained a Hazardous Waste Generator License from MPCA (License# MND985666122) for disposal of parts washer solvent used for maintaining the facility. The PRRF has since changed the parts washer solvent and now uses a non-hazardous cleaning solvent that is maintained by Safety-Kleen. Volumes of these materials would be expected to increase in proportion to the operating and maintenance needs of the proposed project. These materials are properly stored and handled by appropriately trained employees. However, a Hazardous Waste Generator License is no longer required due the change in chemicals used at the PRRF.

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 PRRF stores diesel fuel used for the front end loader in one 560-gallon aboveground storage tank on site. There are two decommissioned backup fuel oil tanks that are being removed from the project site as part of the proposed project. No new tanks would be added as part of the proposed project. There is also a 10,000-gallon leachate storage tank inside the facility. The size and content of the tanks at the PRRF does not require state permitting. Aboveground Storage Tank permitting is required if there is greater than one million gallons of storage capacity, which is not the case for the PRRF or the proposed project. Registration is required, however, for aboveground storage tanks that are 500 gallons or larger. The 560-gallon diesel fuel tank and 10,000-gallon leachate tank are currently registered. Total oil products stored at the site are less than 1,320 gallons and, therefore, a Federal Spill Prevention Control and Countermeasure Plan is not required.


Proposed treatment of topic in the EIS The expected impacts of the project related to the on-site generation of solid wastes, hazardous wastes, and storage tanks are adequately described in this document. Based on the information provided, the anticipated effect would be negligible. No further review of project-specific solid and hazardous waste generation, and storage tanks is warranted. The topic will not be carried forward in the EIS.

21. Traffic. Parking spaces added: 10 Existing spaces (if project involves expansion): N/A

Estimated total average daily traffic generated: 150 projected; 169 worst-case Estimated maximum peak hour traffic generated and time of occurrence: N/A Indicate source of trip generation rates used in the estimates. Trip generation estimates were derived from truck hauling records for 2010 and the number of

employees currently working at the PRRF. Additional employees would be needed to operate the proposed project, which were also factored into the trip estimates. Table 7 provides a summary of the actual and estimated truck haul loads and associated trip generation rates.

If the peak hour traffic generated exceeds 250 vehicles or the total daily trips exceeds 2,500, a

traffic impact study must be prepared as part of the EAW. Using the format and procedures described in the Minnesota Department of Transportation’s Traffic Impact Study Guidance (available at: http://www.oim.dot.state.mn.us/access/pdfs/Chapter%205.pdf) or a similar local guidance, provide an estimate of the impact on traffic congestion on affected roads and describe any traffic improvements necessary. The analysis must discuss the project’s impact on the regional transportation system.

Based on 2010 records, the PRRF managed 5,094 loads of material (i.e., MSW, specialty waste,

recyclable steel, leachate, and ash), totaling 45,000 net tons. The facility operates 52 weeks per year and on average seven days per week. This generates an estimated average daily traffic rate of 94 trips per day, which includes entry and exit of the facility (i.e., each counting as one trip) related to hauling of waste on a five-day per week average schedule. Of the 94 trips per day, 32 are related to receiving MSW, totaling approximately 35,000 tons in 2010. Hauling of ash results in an average of six trips per day, and miscellaneous other activities results in an average of about one trip per day. Employees account for an additional 55 trips per day on a five-day per week average schedule, which represents a worst-case scenario, as summarized in Table 7 below.

Based on current MSW agreements among the four counties for potential waste disposal and

existing truck capacity, it is anticipated that truck trips would increase with the proposed project. The projected maximum number of loads per year of MSW (based on a maximum capacity of 73,000 tons of MSW) with the proposed project is estimated to be 7,468. This results in approximately 57 truck trips per day based on a five-day per week average schedule, which is considered a worst case scenario. It is also anticipated that the quantity of recyclables would increase to a maximum of 926 loads per year, which equals about seven trips per day. Ash and fines hauling would also increase, resulting in approximately 13 truck trips per day.

The projected actual waste volumes to be processed after the proposed project are approximately

55,000 tpy of MSW. This would likely result in 44 trips per day related to MSW based on a five-day per week average schedule as a worst case. Employee trips would increase as a result due to the

http://www.oim.dot.state.mn.us/access/pdfs/Chapter%205.pdf


addition of 12 more employees needed to operate the proposed project. Table 7 provides a summary of the estimated annual and daily traffic at the facility. This shows that the proposed project projected actual MSW-related trips per day would likely be 44, while if the proposed project operated at its maximum capacity, those trips would increase by 13, for a total of 57 trips per day related to MSW.

While the PRRF typically operates seven days per week, the majority of traffic associated with the operation of the PRRF occurs on weekdays, and this is expected to continue with the operation of the proposed project. MSW, fines, and ash are typically hauled during the Monday through Friday work week. Traffic on Saturdays and Sundays is primarily from employees needed to operate the facility. The following table presents the average daily traffic counts based on five days per week when traffic is likely heaviest. Table 7: Traffic Summary

Truck Type 2010 Truck Loads

2010 Avg. Daily

Trips 1,2

Projected Actual Truck Loads

Projected Actual

Avg. Daily Trips 1,2

Maximum Capacity

Truck Loads

Maximum Capacity

Avg. Daily Trips 1,2

MSW Truck 8 4,146 32 5,746 44 7,468 57

Ash and Fines Trucks

780 6 1,226 9.4 1,627 13

Leachate Truck 7

147 1.13 70 0.5 93 0.71

MRF Trucks4 7 0.05 698 5.4 926 7

Misc. Truck3 14 0.11 14 0.11 14 0.11

Employee Related

15 employee

s 555

27 employees

6 915

27 employees

6 91

Total 5,094 94 7,781 150 10,128 169 1 Entry and exit from the facility are counted as two trips. 2 Although burner operates continuously, assume five days per week with truck traffic (Monday-Friday) for a worst-case scenario, therefore 260 days of truck traffic per year. 3 Miscellaneous Trucks include “Adopt A Highway” haul loads. These trips are not expected to increase as a result of the proposed project. 4 Material Recovery Facility (MRF) Trucks include any truck traffic due to the proposed MRF related to steel recycling, glass recycling, aluminum recycling, etc. 5 It is assumed that 50 percent of the employees likely go to lunch or run errands during the noon hour each work day, and that five deliveries occur per day. This creates additional trips determined by the equation Additional Trips per Day = (# of employees*50% of employees leaving for lunch)*2 trips per day)+(5 deliveries per day*2 trips). 6 The current number of full and part-time employees operating the PRRF is 15. An additional 12 employees are to be hired as a result of operation of the proposed project. 7 Under the proposed project, less leachate would be required due to the installation of an ash conditioner. It is conservatively estimated that 70 loads (140 trips), or a 50 percent reduction in leachate loads, are likely under the proposed project scenario for 55,000 tpy of processed waste. 8 All additional MSW brought to PRRF (any increase in waste volume with the proposed project) would arrive in 20-ton trucks and 5-ton trucks after the completion of the proposed project. Eighty percent of the additional waste would arrive in the 20-ton trucks while the remaining 20 percent would arrive in 5-ton trucks.


Overall, the proposed project is estimated to increase projected actual truck trips at the facility by approximately 56 trips per day based on a five-day per week average schedule as a worst case. MSW delivery trucks and employees would comprise most of the traffic into and out of the PRRF. Although truck trips would be added for hauling of fines from the MRF, the quantity of ash generated by the proposed project would not increase at a rate proportional to the total quantity of MSW. This means that the number of ash hauling trips and fine hauling trips would be approximately the same as ash hauling without the MRF for the same total quantity of MSW. Before delivering MSW to the PRRF, trucks are weighed on a scale located approximately two blocks to the east on Seventh Avenue Northeast near the intersection of First Street Northeast. Under the proposed project, all MSW trucks would enter and exit the facility using the access driveway off of Sixth Avenue Northeast. The trucks would enter the facility, back into the MRF, unload the MSW, and drive out in the direction that they came in. Currently, there is one main entrance to the PRRF, which is at the intersection of 6th Avenue Northeast and 2nd Street Northeast. There is also an access driveway just north of the PRRF that is currently owned and used by Bongards’ to access their scale and facility. The proposed project would eliminate this Bongards’ driveway and move it further north. This access would be owned by the PRRF, but would allow Bongards’ access to their scale and facility. The Bongards’ trucks would enter the PRRF driveway and cross through to the Bongards’ scale, located to the west of the PRRF property boundary. The Bongards’ trucks would exit near the Bongards’ facility and would only cross the PRRF property for entry and access to their scale. This is not anticipated to cause problems for either facility. The main entrance driveway to the PRRF would be moved slightly south. This driveway would be used for ash hauling and fines hauling purposes, and would no longer be used as the main entrance to the PRRF. The truck route for the proposed project would require all trucks to access the PRRF from County Highway 80, turning north on 7th Avenue Northeast, then west on 2nd Street Northeast. At the intersection of 2nd Street Northeast and 6th Avenue Northeast, MSW trucks would turn north and enter the PRRF on the north side at the MRF. Ash trucks would enter on the south side of the PRRF slightly south of the former main entrance of the existing facility. The route used by hauling trucks proceeds through an existing industrial park. This minimizes potential disturbance to residential neighborhoods, which are not located within the current or proposed truck route. The current total number of full and part-time employees operating the PRRF is 15. An additional 12 employees would be hired as a result of constructing and operating the proposed project. The additional traffic expected from these employees would not significantly impact the facility or the surrounding area. It is estimated that 10 new parking spaces would be added to accommodate the increased number of employees at the PRRF. Operation and maintenance vehicles also generate traffic at the PRRF site. Traffic volumes due to the proposed project are expected to increase as summarized in Table 7 above. The duration and quantity of the service calls may also increase as a result of operating the proposed project, but is not expected to be significant. Additional traffic would be generated during the construction of the proposed project, but this increase in traffic would be temporary.


Proposed treatment of topic in the EIS The expected impacts of traffic on affected roads in the vicinity of the Project will be evaluated in the EIS.

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.

All MSW, fines, and ash disposal truck traffic would occur on paved roadways on the site. Truck haul

traffic entering and exiting the facility use existing paved city streets and highways before leaving the city limits of Perham in route to the ash landfill and bypass landfill locations. These existing paved roadways minimize potential dust/particulate matter impacts on air quality from truck hauling.

With respect to idling trucks, the waste haulers schedule their routes so trucks arrive at the PRRF during different times of the day. The majority of the time, there are no trucks at the facility or a single truck arrives, dumps its load, and leaves. It takes about two minutes for a truck to dump its load into the receiving area. During normal operation, when a truck is on site, there is a short duration of idling time estimated at less than five minutes.

With the construction of the MRF, recycled materials truck traffic is expected to increase in proportion with the increased amount of MSW processed at the facility and the ability of the facility to recycle more materials (aluminum, glass, etc.). The proposed project would also increase the total capacity of the facility to combust processed MSW; therefore, the number of MSW trucks as well as the number of ash trucks (a product of the combustion of processed MSW) would also increase, although not in direct proportion to the amount of processed MSW combusted. The PRRF would process 55,000 tpy of MSW, but of that total, 5-8 percent would be recycled and approximately 10 percent would fall out as fines in the MRF prior to combustion. This would reduce the amount of ash generated by approximately 15 percent compared to MSW combustion without the MRF. This is reflected in Table 1 as provided in the response to question 6. Proposed treatment of topic in the EIS The expected impacts from on-site vehicle-related air emissions will be included in the EIS.

23. Stationary source air emissions. Describe the type, sources, quantities and compositions of any

emissions from stationary sources of air emissions such as boilers, exhaust stacks or fugitive dust sources. Include any hazardous air pollutants (consult EAW Guidelines for a listing) and any greenhouse gases (such as carbon dioxide, methane, nitrous oxide) and ozone-depleting chemicals (chloro-fluorocarbons, hydrofluorocarbons, perfluorocarbons or sulfur hexafluoride). Also describe any proposed pollution prevention techniques and proposed APC devices. Describe the impacts on air quality.

The proposed project involves the addition of a new waste heat boiler and APC equipment to the South MWC Unit. The North MWC Unit would remain unchanged as part of the proposed project, continuing to be associated with the existing waste heat boiler and APC equipment. The total facility capacity after the proposed project would be 200 tpd. The current facility capacity from both the South MWC Unit and the North MWC Unit is 116 tpd, annual average. An air emission permit


amendment would be required before commencement of construction for the proposed project. The permit amendment would be issued, by the MPCA, for the construction and operation of the PRRF with both MWC operating at maximum capacity (100 tpd each). The combustion of MSW produces air emissions including criteria pollutants and hazardous air pollutants from both stationary and fugitive dust sources. The proposed modification of the South Unit includes the addition of a new APC system including:

• dry lime injection system or equivalent for acid gas control • carbon injection for mercury control • a fabric filter baghouse for particulate control

Similar APC equipment would remain in place for the North Unit.

The existing North MWC Unit would continue to be subject to the 40 CFR Part 62 Federal Implementation Plan Subpart JJJ requirements as well as the Minnesota Waste Combustor Rule. The modified South MWC Unit would be subject to the 40 CFR Part 60 New Source Performance Standards (NSPS) Subpart AAAA as well as the Minnesota Waste Combustor Rule. Subpart JJJ and AAAA both contain emission limits for:

• Dioxins/furans • Cadmium • Lead • Mercury • Opacity • Particulate Matter • Hydrogen chloride • Nitrogen oxides • Sulfur dioxide • Carbon monoxide • Fugitive ash

If warranted, federal air emission limits may be lowered due to results from the site-specific health risk analysis.

Human Health Risk Assessment (HHRA) The MPCA developed the Air Emissions Risk Analysis (AERA) process to provide for: (1) a standardized health review of facility air emissions; and (2) a consistent format for presenting the quantitative risk estimates, along with qualitative information to provide context to these risk estimates. An AERA estimates cancer and non-cancer risks to human health from a proposed project and/or an existing facility. Facility risk guidelines have been developed by the MPCA, in consultation with the MDH, which are generally consistent with U.S. Environmental Protection Agency (USEPA) guidance.


The guidelines for cancer-related risks were established such that the increased risk of a person getting cancer over the course of their lifetime due to exposure to the carcinogenic chemicals emitted from a given facility should not exceed 1 in 100,000 (1E-05). The non-cancer risks (called hazard quotients) are calculated by dividing the modeled air concentrations by the health benchmarks from MDH, the USEPA, and the California EPA. The facility guideline for non-carcinogenic chemicals is that the sum of the hazard quotients (called the hazard index) should not exceed 1. If emissions from a facility result in estimated risks in excess of these levels, MPCA staff evaluates whether further refinement of the analysis, further investigation, modifications to the facility, or stricter air emissions limits, are warranted. All quantitative risk estimates have uncertainty related to the following factors: air emission estimates, air dispersion modeling, exposure assumptions, and toxicity information. These uncertainties are considered qualitatively within the AERA process and assumptions are made to minimize the potential for underestimating risks. Interested readers can find more detailed information on the air risk analysis process at http://www.pca.state.mn.us/air/aera.html. For the proposed project, the facility will conduct a refined HHRA scoped by an AERA. The AERA will be performed according to MPCA guidance, found at http://www.pca.state.mn.us/ktqh42a, including the MPCA Air Emissions Risk Analysis Guidance (Version 1.1, September 2007). The HHRA will be performed following the USEPA Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities (USEPA 2005) and relevant MPCA requirements that either supersede aspects of the HHRAP or supplement the protocol. The AERA and HHRA will evaluate risk from before and after the proposed project. The specific methods and assumptions used in the AERA and HHRA will be submitted to the MPCA for approval, using the AERA forms. Section 2.7.3 of the AERA guidance will be followed for scoping out emission sources, such as the Auxiliary Boiler, or pollutants not regulated with pollutant specific limits. Each compound identified in the sources below will be considered for the designation of compounds of potential interest (COPI). The hierarchy below will be used to select emission factors for COPIs. Any air emission rate limit used in the HHRA will be incorporated into the air permit. 1. 40 CFR 62 Subpart JJJ or Minn. R. 7011.1227, as applicable 2. NSPS Subpart AAAA or Minn. R. 7011.1229, as applicable 3. Stack test results performed on the existing MWC Units at PRRF 4. Continuous Emission Monitoring System data for the existing MWC Units at PRRF 5. Emission factors provided by the MPCA such as the Olmsted County Waste to Energy Facility,

Stanislaus and Huntington or other emission factors from relevant stack testing 6. Chapter 2.1, “Refuse Combustion” in USEPA’s AP-42, Fifth Edition, “Compilation of Air Pollutant

Emission Factors” (October 1996) 7. USEPA Factor Information Retrieval System, Version 6.23 for standard classification code

50100104 8. Supplement C, Table 2.1-1, of USEPA’s AP-42, Fourth Edition, “Compilation of Air Pollutant

Emission Factors” (October 1990)

http://www.pca.state.mn.us/air/aera.html

http://www.pca.state.mn.us/ktqh42a


The purpose of the HHRA will be to calculate quantitative estimates of COPI concentrations in air and COPI doses that are used with acute and chronic toxicity factors to estimate excess risks for carcinogens and hazards for noncarcinogens. Air concentrations and doses will be estimated for four exposure scenarios evaluated for specific locations in the areas most impacted by the facility. The specific locations to be evaluated and a description of the method used to select these locations will be included in the AERA forms. The anticipated four scenarios will include acute inhalation, resident and resident child, farmer and farmer child, and fisher and fisher child. Direct depositions to soil, plants, and surface water will be calculated and indirect exposures are calculated for relevant pathways. If there is the potential for one pound/year or more of mercury emissions and there are fishable water bodies in the area, then the risks associated with ingesting impacted fish will be assessed through the Minnesota Mercury Risk Estimation Method (MMREM), in lieu of the methods in the HHRAP (USEPA 2005). If MMREM is used, then a MMREM protocol (AERA form 27) shall be submitted to the MPCA for approval. Stationary source greenhouse gas emissions In May 2010, the USEPA added greenhouse gases (GHGs) to permitting regulations for the New Source Review Prevention of Significant Deterioration (PSD) program, commonly referred to the Tailoring Rule. In January 2011, MPCA incorporated GHG regulations related to the Tailoring Rule into Minnesota Rule. The PSD major source threshold for GHGs was set at 100,000 tpy carbon dioxide equivalent (CO2e). A facility was required to calculate its current potential to emit (PTE) of GHGs by July 1, 2011, and determine if GHG PTE was less than or greater than the 100,000 tpy CO2e threshold. The GHG emissions generated from all Minnesota sources is estimated at 153.7 million tons of CO2 equivalents (CO2e) in 2004. While it is not possible to directly link GHG emissions from a specific proposed project to specific regional or global climate change, the GHG emissions from the facility can be measured and evaluated in relation to other facilities or fuels that emit GHG. Table 8 summarizes the GHG emissions for the existing facility and the total facility after the Proposed Project.


TABLE 8: Project Greenhouse Gas Emissions Existing Facility Potential to Emit

CO2 CH4 N20 HFCs PFCs SF6 Aggregate

(TONS/YEAR) TOTAL PROJECT

EMISSIONS 57,814 14.2 1.8 0 (N/A) 0 (N/A) 0 (N/A)

CO2e CONVERSION FACTOR

1 21 310 N/A N/A N/A

TOTAL PROJECT EMISSIONS

(CO2e)1

57,814 299 572 0 0 0 58,685

Future Facility Potential to Emit CO2 CH4 N20 HFCs PFCs SF6 Aggregate

(TONS/YEAR) TOTAL PROJECT

EMISSIONS 78,447 29.1 3.8 0 (N/A) 0 (N/A) 0 (N/A)

CO2e CONVERSION FACTOR

1 21 310 N/A N/A N/A

TOTAL PROJECT EMISSIONS

(CO2e)1

78,447 612 1,177 0 0 0 80,236

1 Total Project Emissions (CO2e) = TOTAL PROJECT EMISSIONS X CO2e CONVERSION FACTOR

The no-build alternative was not quantitatively analyzed for this EAW; however, it is expected that for this scenario, the incremental waste volumes expected by the proposed project would be diverted to a different location for management (either a landfill or another MWC facility). There is a greater net GHG benefit for using a waste-to-energy facility compared to a landfill, because landfills generate higher rates of methane GHG emissions. In addition, due to the increased travel distances to alternative landfill disposal sites primarily located in North Dakota, GHG emissions from mobile sources would increase. Proposed treatment of topic in the EIS The impacts air emissions from stationary sources will be evaluated in the EIS. Two analyses will be conducted: 1) A determination of the potential to exceed Minnesota Ambient Air Quality Standards (MAAQS)

and National Ambient Air Quality Standards (NAAQS) 2) A scoping AERA and a refined HHRA These analyses will follow MPCA and USEPA guidance and procedures for air dispersion modeling, AERA, and HHRA.

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 Odors generated at the PRRF are minimal and the proposed project would not increase odor generation. The PRRF has been specifically designed to contain odors within the facility in order to minimize impacts outside of the facility. Delivery trucks unload the waste into the enclosed MRF and tipping area. The combustion air is drawn from the tipping building to maintain a negative pressure and to help prevent the escape of dust and odors. At the temperatures that are encountered within the combustion furnace, odors that are associated with the wastes are removed. The PRRF has not had any odors complaints from adjacent property owners in the recent past. Proposed treatment of topic in the EIS The expected impacts from odors are adequately described in this document. Based on the information provided, the anticipated effect would be negligible. No further review in terms of odors is warranted. This topic will not be carried forward into the EIS. Noise Noise is defined as unwanted sound. Sound travels in wave motion and produces a sound pressure level. This sound pressure level is commonly measured in decibels (dB) and uses the ‘A’ weighted scale, which is the range of sounds heard by the human ear. The range of sounds measured in decibels is a logarithmic as opposed a linear scale of readings. A as result, a sound increase of 3 dB) is barely perceptible to the human ear, a 5 dBA increase is clearly noticeable, and a 10 dBA increase is heard twice as loud.

Current noise standards for the state of Minnesota are located in Minn. R. 7030.0040, subp. 2. There are three “Noise Area Classification” (NAC) categories identified by Minnesota Rules (see Table 9). The rules for permissible noise vary according to which NAC is involved. In a residential setting, for example, the noise restrictions are more stringent than in an industrial setting. The rules also distinguish between nighttime and daytime noise, with less noise permitted at night. The standards list the sound levels not to be exceeded for more than 10 and 50 percent of the time in a one-hour survey (L10 and L50) for each noise area classification. The current Minnesota Noise Standards are presented in Table 9.

Table 9: Applicable Minnesota Noise Standards

Noise Area Classification

Noise Standard, dB(A) Daytime (7 am to 10

pm) Nighttime (10 pm to 7

am) L50 L10 L50 L10

1 Residential 60 65 50 55 2 Commercial 65 70 65 70 3 Industrial 75 80 75 80

The standards are given in terms of the percent of time during a measurement period (typically one hour) during which a particular decibel dBA level may not be exceeded. A daytime L50 of 60 dBA, for example, means that during the daytime, noise levels may not exceed 60 dBA more than 50 percent of the time (i.e., 30 minutes of an hour).


The Minnesota Noise Standards also require that noise generated from a source meet the standards within an NAC for receptors adjacent to the source. For example, noise generated by an industrial facility would have the meet the Industrial NAC-3 standards at the edge of the facility property line, but would also be required to meet the Residential NAC-1 standards at individual residential receptors located near the facility. Noise levels at the existing facility were studied in 2003 (SBP Associates, 2003). The study used the L50 standard for the PRRF since that is the most restrictive. For residential receptors, which are located to the north of the PRRF, the L50 nighttime standard of 50 dBA was applied. The study monitored noise around the perimeter of the PRRF in six different locations to determine if noise impacts above the Minnesota Noise Standards would occur. The six monitoring sites included both residential and industrial sites. The results of the study determined that noise levels at the three sites near the facility were below NAC-3 levels for industrial facilities with measured L50 values ranging from 54.5 and 73 dBA. Of the three sites located near a residential neighborhood within 500 to 600 feet from the PRRF, the study found that noise levels were within the daytime standard, but exceeded the nighttime standard. The results of the noise monitoring in the sites near the residential area range between 56 to 58.5 dBA. However, the noise measurements for the study were taken for only a short duration of time during daytime hours. No additional measurements were taken during nighttime hours to measure actual nighttime noise levels at these residential receptors. The study determined that the main sources of noise generation at the PRRF are from the steam valve, cooling tower, stack, ID fan, facility doors, and general facility noise. The study recommended that noise could be reduced by making modifications to the steam valve, stack, and cooling tower. Recommendations were made in the 2003 noise study to lower noise levels. These recommendations included improvements for the steam valve, stack, and cooling tower, and ensuring facility doors are closed at night. The PRRF replaced internal equipment on the steam valve line. This reduced the noise generated at the facility. There have been no complaints about noise generated at the facility since the 2003 improvements were completed. The proposed project would be required to operate in compliance with Minnesota Noise Standards. Measures would be taken with the design and operation of the facility to ensure that standards are met. Proposed treatment of topic in the EIS The ability of the Proposed project to operate in compliance with Minnesota Noise Standards will be carried into the EIS. Dust Dust would be generated on a temporary basis during the construction of the proposed project. However, the amount is expected to be minimal given that much of the site is paved. Some topsoil and gravel would be moved during grading of the site for construction of the proposed project. As needed, reasonable measures (e.g., watering of dusty surfaces, sweeping of paved areas) would be taken to minimize dust emissions during construction. Dust would also be generated during operation of the PRRF and proposed project. Truck haul traffic entering and exiting the PRRF would use existing paved city streets and highways.


Further discussion on potential impacts from dust and particulate matter is provided in the response to questions 22 and 23 of the EAW. Proposed treatment of topic in the EIS The expected impacts from dust relating to operations of the proposed plant are adequately described in this document. Based on the information provided, the anticipated effect would be negligible. No further review in terms dust is warranted. This topic will not be carried forward into the EIS.

25. Nearby resources. Are any of the following resources on or in proximity to the site? Archaeological, historical or architectural resources? Yes No Prime or unique farmlands or land within an agricultural preserve? Yes No Designated parks, recreation areas or trails? Yes No Scenic views and vistas? Yes No Other unique resources? Yes No

If yes, describe the resource and identify any project-related impacts on the resource. Describe any measures to minimize or avoid adverse impacts.

The Minnesota State Historic Preservation Office (SHPO) was contacted and requested to query the Minnesota Archaeological Inventory and Historic Structures Inventory to identify any properties in Township 136 North, Range 39 West, Section 14. No archaeological records were identified in the query results. A number of historic properties were identified in Section 14. Upon further review, these properties were located in the main part of the city of Perham away from the proposed project and, therefore, no adverse impacts are anticipated to archaeological, historical, or architectural resources. The SHPO query results are provided in Appendix B. The proposed project would occur on an already developed site and, therefore, would not impact prime or unique farmlands. The proposed project is not located near any parks or public open space. Proposed treatment of topic in the EIS The expected impacts from these nearby resources are adequately described in this document. Based on the information provided, the anticipated effect would be negligible. No further review in terms of nearby resources is warranted. The topic will not be carried forward into the EIS.

26. Visual impacts. Will the project create adverse visual impacts during construction or operation?

Such as glare from intense lights, lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks? Yes No

If yes, explain.

The existing facility currently has two emissions stacks, which each create steam plumes. As flue gas is emitted from a stack, water vapor present in the flue gas can condense to form a visible steam plume. Certain weather conditions make a plume more or less visible. Temperature, relative humidity, and wind speed all affect the persistence of a plume. A plume is more persistent and most visible during winter months when cold and damp conditions typically occur. During typical operating days, however, a steam plume will quickly dissipate.


An additional emissions stack would be added for the proposed project. This stack would be similar in height and measurement to the existing stack on the waste heater boiler/APC system, and would be located adjacent to it on the expanded building. Although this would create the potential for an additional visible plume, the impact of this is not considered adverse. Existing neighborhoods are mostly screened from the view of the existing PRRF by mature trees and other large buildings that are in close proximity to the facility. It is anticipated that from nearby neighborhoods and adjacent developed areas of the city, it would be difficult to distinguish whether there are two or three visible plumes, if a plume or stack is visible at all. On most days at the PRRF, the existing stacks do not produce visible plumes. It is anticipated that the addition of another emissions stack also would not produce a visible plume on most days.

Lighting is used for plant operational purposes. Minimal lighting is used at the facility and is in place for operations and safety. The typical outdoor lighting used at the existing facility is attached to the outside walls and pointed downward. The proposed project would use lighting on the outside of the MRF building expansion. It is anticipated that lighting similar to that of the existing facility would be used for the proposed project. Potential impacts from lighting are expected to be minimal. Proposed treatment of topic in the EIS The expected impacts from visual impacts are adequately described in this document. Based on the information provided, the anticipated effects would be negligible. No further review in terms or visual impacts is warranted. The topic will not be carried forward into the EIS.

27. Compatibility with plans and land use regulations. Is the project subject to an adopted local

comprehensive plan, land use plan or regulation, or other applicable land use, water, or resource management plan of a local, regional, state or federal agency? Yes No

If yes, describe the plan, discuss its compatibility with the project and explain how any conflicts

will be resolved. If no, explain.

The proposed project would be regulated by the city of Perham land use zoning ordinance (Ordinance No. 286). The most recent version of this ordinance was adopted July 29, 2009. According to the city of Perham Official Land Use Map, the project site is located in an industrial district. Sections 23, 24, and 25 of Ordinance No. 286 outline the provisions for land use within industrial districts. The current zoning ordinance regulates garbage incineration as a conditional use (Ord. 286, Section 25, subp. 3(H)). The city ordinance also regulates setbacks and minimum lot size. For an industrial district, Table 10 summarizes the lot and building requirements. The proposed project would be required to meet these standards in order to obtain a building permit. Table 10: Lot and Building Requirements in an Industrial District

Regulation Industrial Building Accessory Building Minimum lot area (sq. ft.) 15,000 N/A Minimum lot width (ft) 200 N/A Minimum front yard setback (ft) 20 Not permitted Minimum side yard setback (ft) 10 Same as industrial building side yard Minimum rear yard setback (ft) 20 10 Maximum ground coverage 75% Included in maximum lot coverage Maximum building height (ft) None None


When the existing PRRF was built in 1986, power generation was a permitted use in an industrial zoning district and, therefore, the existing facility did not require a conditional use permit. The city of Perham’s current zoning ordinance (July 2009) would require a conditional use permit for construction and operation of the proposed project. The conditional use permit would be obtained through the local permitting process, which would require an application and public hearing, followed by approval by the City Council. Proposed treatment of topic in the EIS The expected impacts from compatibility with plans and land use regulations are adequately described in this document. Based on the information provide, the anticipated effects would be negligible. No further review in terms of compatibility with plans and land use regulations is warranted. The topic will not be carried forward into the EIS.

28. Impact on infrastructure and public services. Will new or expanded utilities, roads, other

infrastructure or public services be required to serve the project? Yes No If yes, describe the new or additional infrastructure or services needed. (Note: any infrastructure

that is a connected action with respect to the project must be assessed in the EAW; see EAW Guidelines for details.)

The existing infrastructure and public service can accommodate the potential increased demand from the proposed project. No significant or adverse impacts to infrastructure and public services are anticipated as a result of the proposed project. Proposed treatment of topic in the EIS The expected impacts on infrastructure and public services are adequately described in this document. Based on the information provide, the anticipated effects would be negligible. No further review in terms of Impacts on infrastructure and public services is warranted. The topic will not be carried forward into the EIS.

29. Cumulative potential effects. 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 potential effects. (Such future projects would be those that are actually planned or for which a basis of expectation has been laid.)

Describe the nature of the cumulative potential effects and summarize any other available

information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative potential effect under appropriate item(s) elsewhere on this form).

The potential cumulative effects identified during the scoping process are related to air quality and solid waste management.


The EIS will determine potential cumulative effects on ambient air quality from the proposed project by modeling compliance with MAAQS and NAAQS, and by including a Cumulative AERA. The Cumulative AERA will follow the MPCA How to Conduct a Cumulative Air Emission Risk Analysis guidance located at http://www.pca.state.mn.us/lupg42d. One of the purposes of the proposed project is to provide an alternative means to dispose of MSW while implementing the Minnesota Solid Waste Policy in a manner that ranks higher on the Minnesota Waste Hierarchy. The proposed project would reduce the amount of MSW that is landfilled. This would extend the longevity of the existing landfills in the region. Without the project, additional MSW landfill capacity would be needed sooner. Ash generation at the PRRF would increase as a result of the proposed project. The existing ash handling system is adequate to process the increase quantity of ash; however, the longevity of the Northeast Otter Tail Landfill where ash is disposed of would likely be impacted. The PLMSWA, in partnership with Otter Tail County, would likely be required to apply for a permit to expand the ash cell to accommodate more ash sooner than what would occur at existing rates without the proposed project. Also related to solid waste, but addressed in question 21 of this EAW, is MSW truck hauling. Although truck traffic entering and exiting the PRRF would increase as a result of the proposed project, overall the number of miles travelled by each of the trucks would not change significantly from existing conditions. There are no future plans to construct an additional municipal waste combustor or expand the operating capacity of the PRRF beyond the proposed project and, therefore, no “cumulative potential effects of related or anticipated future projects” that must be addressed. Proposed treatment of topic in the EIS Potential cumulative effects to air quality from the proposed project will be addressed in the EIS through ambient air quality modeling for compliance with MAAQS/NAAQS, and the Cumulative AERA.

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 potential environmental impacts outside of those already discussed in this EAW have been identified at this time.

31. Summary of issues. Do not complete this section if the EAW is being done for EIS scoping; instead,

address relevant issues in the draft Scoping Decision document, which must accompany the EAW. 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.

Not applicable.

http://www.pca.state.mn.us/lupg42d

Engineers - ScientistsBusiness Professionalswww.wenck.com

OttertailCounty

ProjectLocation

PERHAM RESOURCE RECOVERY FACILITYState Location Map

NOV 2011Figure 11800 Pioneer Creek Center

Maple Plain, MN 55359-04291-800-472-2232

50 0 5025Miles

WenckPath: L:\2415\03\mxd\EAW\State Location Map.mxd

PERHAM RESOURCE RECOVERY FACILITYCounty Location Map

NOV 2011Figure 2

ProjectLocation

Otter TailCounty

WilkinCounty

WadenaCounty

ToddCounty

GrantCounty Douglas

County

BeckerCounty

ClayCounty


1800 Pioneer Creek CenterMaple Plain, MN 55359-04291-800-472-2232

Wenck

8 0 84Miles

Path: L:\2415\03\mxd\EAW\County Location Map.mxdDate: 11/11/2011Time: 10:08:31 AM User: shujc0243


Existing Property

Proposed Expansion

PERHAM RESOURCE RECOVERY FACILITYUSGS Quadrangle Map


Maple Plain, MN 55359-04291-800-472-2232

2,000 0 2,0001,000Feet

Perham 7.5 Minute Quadrangle (USGS: 1973)

Wenck

LegendExisting PropertyProposed Expansion

Path: L:\2415\03\mxd\EAW\USGS Quadrangle Map.mxd

Area of Detail

Otter TailCounty

BeckerCounty

WadenaCounty

ToddCounty

HubbardCounty

Date: 11/11/2011Time: 9:29:55 AM User: shujc0243


ExistingProperty

ProposedExpansion

80

3rd St NE

6th Av

e NE 2nd St NE

5th Ave

NE

2nd St SE

8th Ave

SE

6th Ave

SE

2nd St NE

PERHAM RESOURCE RECOVERY FACILITYSite Plan


Maple Plain, MN 55359-04291-800-472-2232

200 0 200100Feet

2010 Aerial Photograph (Source: MN GEO)

Wenck

LegendExisting PropertyProposed ExpansionFence Line

Path: L:\2415\03\mxd\EAW\Site Plan.mxdDate: 11/11/2011Time: 9:33:50 AM User: shujc0243

sanem0129

Draft

sanem0129

Text Box

FIGURE 5

B

Text Box

SK-1

sanem0129

Text Box

FIGURE 6

sanem0129

Draft

sanem0129

Text Box

Figure 5

www.mndnr.gov

AN EQUAL OPPORTUNITY EMPLOYER

March 31, 2011 Correspondence # ERDB 20110417 Ms. Amy Denz Wenck Associates, Inc. 1800 Pioneer Creek Center, PO Box 249 Maple Plain, MN 55359-0219 RE: Natural Heritage Review of the proposed Perham Resource Recovery Facility Expansion; T136N R39W Section 14; Otter Tail County Dear Ms. Denz,

As requested, the Minnesota Natural Heritage Information System (NHIS) has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project. Based on this query, there are no known occurrences of rare features in the area searched.

The Natural Heritage Information System, a collection of databases that contains information about Minnesota’s rare natural features, is maintained by the Division of Ecological and Water Resources, Department of Natural Resources. The NHIS is continually updated as new information becomes available, and is the most complete source of data on Minnesota's rare or otherwise significant species, native plant communities, and other natural features. However, the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state. Therefore, ecologically significant features for which we have no records may exist within the project area.

For environmental review purposes, the results of this Natural Heritage Review are valid for one year; the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form. Please contact me if project details change or if an updated review is needed.

Please note that locations of the gray wolf (Canis lupus), federally-listed as threatened and state-listed as special concern, and the Canada lynx (Lynx canadensis), federally-listed as threatened, are not currently tracked in the NHIS. As such, the Natural Heritage Review does not address these species.

Furthermore, the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole. Instead, it identifies issues regarding known occurrences of rare features and potential effects to these rare features. Additional rare features for which we have no data may be present in the project area, or there may be other natural resource concerns associated with the proposed project. For these concerns, please contact your DNR Regional Environmental Assessment Ecologist (contact information available at http://www.dnr.state.mn.us/eco/ereview/erp_regioncontacts.html). Please be aware that additional site assessments or review may be required.

Thank you for consulting us on this matter, and for your interest in preserving Minnesota's rare natural resources. An invoice will be mailed to you under separate cover. Sincerely,

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources, Box 25

500 Lafayette Road

St. Paul, Minnesota 55155-4025

Phone: (651) 259-5109 E-mail: [email protected]

Attachment A

http://www.dnr.state.mn.us/eco/ereview/erp_regioncontacts.html�

From: Cinadr, Thomas [[email protected]] Sent: Wednesday, March 16, 2011 7:25 AM To: Amy J. Denz Subject: RE: Perham Resource Recovery Facility Expansion Project Attachments: Historic.rtf

THIS EMAIL IS NOT A PROJECT CLEARANCE.

This message simply reports the results of the cultural resources database search you requested. The database search produced results for only previously known archaeological sites and historic properties. Please read the note below carefully. No archaeological sites were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for the search area requested. A report containing the historic properties identified is attached.

The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are included in the current SHPO databases. Because the majority of archaeological sites in the state and many historic architectural properties have not been recorded, important sites or structures may exist within the search area and may be affected by development projects within that area. Additional research, including field survey, may be necessary to adequately assess the area s potential to contain historic properties.

If you require a comprehensive assessment of a project s potential to impact archaeological sites or historic architectural properties, you may need to hire a qualified archaeologist and/or historian. If you need assistance with a project review, please contact Kelly Gragg-Johnson in Review and Compliance @ 651-259-3455 or by email at [email protected].

The Minnesota SHPO Survey Manuals and Database Metadata and Contractor Lists can be found at http://www.mnhs.org/shpo/survey/inventories.htm

Attachment B

SHPO research hours are 8:00 AM 4:00 PM Tuesday-Friday. The Office is closed on Mondays.

Tom Cinadr Survey and Information Management Coordinator Minnesota State Historic Preservation Office Minnesota Historical Society 345 Kellogg Blvd. West St. Paul, MN 55102 651-259-3453

From: Amy J. Denz [mailto:[email protected]] Sent: Thursday, March 03, 2011 2:46 PM To: Cinadr, Thomas Cc: Luke N. Taylor; Ed A. Hoefs; [email protected]; Jeff C. Madejczyk Subject: Perham Resource Recovery Facility Expansion Project Mr. Cinadr, On behalf of the Prairie Lakes Municipal Solid Waste Authority, we are requesting that the Minnesota Archaeological Inventory and Historic Structures Inventory be reviewed for be reviewed for the proposed expansion of the Perham Resource Recovery Facility. Please see the attached materials for further detail on this request and the proposed project. If you have questions or need additional information, please feel free to contact me. Thank you, Amy Amy Denz Environmental Planner Wenck Associates, Inc. 1800 Pioneer Creek Circle Maple Plain, MN 55359 (763) 479-5148 FAX: (763) 479-4242 www.wenck.com

History/Architecture Inventory PROPERTY NAME ADDRESS Twp Range Sec Quarters USGS Report NRHP CEF DOE Inventory Number

COUNTY: Otter Tail CITY/TOWNSHIP: Perham Perham City Hall and Fire Station 153 Main St. E. 136 39 14 SE-SW-NW Perham Y OT-PMC-001

commercial building 1xx Main St. W. 136 39 14 SW-SW-NW Perham OT-PMC-002

commercial building 103 Main St. W. 136 39 14 SW-SW-NW Perham OT-PMC-003

Comet Theatre 146 1st Ave. S 136 39 14 SW-SW-NW Perham OT-PMC-005

commercial building 1xx 1st Ave. SW 136 39 14 SW-SW-NW Perham OT-PMC-006

Bauck Block SW corner Main St. & 2nd Ave. SW 136 39 14 NW-SW-NW Perham OT-PMC-007

commercial building 101 Main St. W 136 39 14 SW-SW-NW Perham OT-PMC-008

rooming house 130 2nd Ave. SW 136 39 14 SW-SW-NW Perham OT-PMC-009

city garage SW corner 3rd St. N. & 2nd Ave. NE 136 39 14 NE-SW-NW Perham OT-PMC-010

St. Stanislaus Catholic Church 5th St. N. & 3rd Ave. NW 136 39 14 NE-NW-NW Perham OT-PMC-012

residence NW corner 2nd St. S. & 2nd Ave. SE 136 39 14 SW-SW-NW Perham OT-PMC-015

"312" House NE corner 3rd St. N. & 1st Ave. NE 136 39 14 NE-SW-NW Perham OT-PMC-018

Episcopal Church of the Redeemer SE corner 3rd St. N. & 1st Ave. NE 136 39 14 NE-SW-NW Perham OT-PMC-019

fairgrounds 5th Ave. SE & 4th St. 136 39 14 N-SW-SW, S- Perham OT-PMC-020 NW-SW

Wednesday, March 16, 2011 Page 1 of 1

Attachment C

Draft Scoping Decision Document

Perham Resource Recovery Facility Expansion Project Environmental Impact Statement

A voluntary Environmental Impact Statement (EIS) is being prepared by Minnesota Pollution Control Agency (MPCA) for the Prairie Lakes Municipal Solid Waste Authority (PLMSWA) proposal to expand the Perham Resource Recovery Facility (PRRF) located in the in the city of Perham, Minnesota. The project site is bound on the north by 3rd Street NE, on the east by 6th Avenue NE, on the south by the Burlington Northern Santa Fe Railroad line, and on the west by Bongards’ Creameries property. Responsible Governmental Unit Proposer Entity MPCA PLMSWA Contact Kevin Kain Mike Hanan Title Project Manager Executive Director Address 520 Lafayette Road North 520 Fir Avenue West City, State, ZIP St. Paul, Minnesota 55155-4194 Fergus Falls, Minnesota 56537 Telephone 651-757-2482 218-998-4898 Fax 651-297-2343 E-mail [email protected] [email protected] Purpose The MPCA distributed a Draft Scoping Environmental Assessment Worksheet (SEAW) and the Draft Scoping Decision Document (SDD) as the initial step in the EIS process. These documents describe the issues, impacts, and the alternatives to be addressed in the EIS, the expected schedule of completion, and any studies that are necessary. The scoping process is intended to focus the scope of the EIS and carry forward only those issues that require additional information and evaluation in the EIS. The scoping process is described in Minn. R. 4410.2100. The purpose of an EIS is the evaluation and disclosure of information about the significant environmental effects of the proposed action. The EIS is not intended to justify a project or to recommend approval or denial of future permits. Rather, the information in the EIS is intended to be used by governmental units as a guide in issuing or denying permits or approvals for the project and in identifying measures necessary to avoid or mitigate adverse environmental effects. The EIS is intended to inform various permitting decisions. PLMSWA and PRRF will submit applications and supporting information for all required MPCA permits and MPCA staff will develop the permits during the EIS process. Preparers The MPCA will conduct the EIS process and the overall preparation, review, and content of the EIS. A preliminary draft EIS will be prepared by the PLMSWA and submitted to the MPCA. The PLMSWA, assisted by its technical consultants, will be responsible for reviewing the adequacy of the available data and reports, preparing technical information on expected impacts of the project, preparing technical reports identified in the SSD, participating in public meetings, assisting the MPCA in responding to comments received during public comment periods, and preparing the Draft and Final EIS. Applications and supporting information for all MPCA permits required by the project will be submitted and permit



2

development will occur during the EIS process. The MPCA will provide technical review of all submittals and approve the Draft and Final EISs prior to distribution. The MPCA Citizens’ Board will adopt the Draft SDD for the EIS and make a determination of adequacy of the Final EIS. Schedule Consistent with Minn. R. 4410.2000, subp. 3.B, the 30-day scoping period began with publication of the notice of availability of the SEAW in accordance with Minn. R. 4410.1500, subps. A and B. The responsible governmental unit (RGU) shall provide the opportunity for at least one scoping meeting during the scoping period. The meeting shall be held not less than 15 days, excluding Saturdays, Sundays, and holidays, after the publication of the notice of availability of the SEAW in the Minnesota Environmental Quality Board (EQB) EQB Monitor. All meetings shall be open to the public. The MPCA Citizens’ Board will adopt the final scoping decision. Tentative EIS Schedule – Perham Resource Recovery Expansion Project

EIS Steps Tentative Date SEAW comment period begins November 28, 2011 Scoping Public Meeting December 14, 2011 Comment period ends January 5, 2012 Final Scoping Decision issued February 2012 EIS Preparation Notice published April 2012 Release of Draft EIS/public meeting September 2012 Final EIS issued January 2013 EIS Adequacy Determination February 2013

RECORD OF DECISION Among the objectives for Minnesota’s environmental review process are the provision of useable information about the primary environmental effects of a proposed project and the encouragement of accountability in public and private decision making. This Draft SDD is obligated to identify those permit/ approval decisions for which a Record of Decision must be maintained to identify how the EIS was considered in reaching the decision. For the proposed expansion EIS, a Record of Decision shall be maintained for the following governmental approvals.

Agency Decision MPCA Prevention of Significant Deterioration Program Minor Modification and

Major Amendment to Part 70 Operating Permit

PROPOSED CONTENT OF THE EIS This section of the scoping document outlines the items to be contained in the PRRF expansion EIS. In accordance with Minn. R 4410.2300, the EIS will include the following: Cover Sheet The cover sheet will include the name of the RGU; the title of the proposed project and project location; name, address, and telephone number of the contact person at the RGU and of the proposers representative; a designation of the statement as a Draft, Final, or supplement; a one paragraph abstract of the EIS; the date of the public meeting on the Draft EIS; and the date following the meeting by which comments on the Draft EIS must be received by the RGU.

3

Summary The summary shall stress the major findings, areas of controversy, and the issues to be resolved including the project as proposed. A project description, environmental impacts, mitigation measures; alternatives; a list of governmental approvals; socio-economic impacts; and direct, indirect, and adverse or beneficial impacts will be identified. List of Preparers The EIS will contain a list that includes the names and qualifications of the persons who were primarily responsible for preparing the EIS or significant background papers. Project Description EQB rules explicitly direct that a proposed project be described only in sufficient detail to identify its purpose, size, scope, environmental setting, geographic location, and anticipated phases of development. Permits and Approvals The EIS will list the known governmental permits and/or approvals required for the expansion, along with the unit of government responsible for each decision. Information necessary for the development of a proposed MPCA Air Emissions Permit will be gathered and presented in the EIS. The EIS will provide specific information useful for permitting and approval decisions; however, it will not provide all data and information required for these actions. Some permit applications and information for the project may be developed and submitted independent of the EIS. Alternatives Minnesota rules require that an EIS include at least one alternative of each of the following types, or provide an explanation of why no alternative is included in the EIS: alternative sites; no action/no build; alternative technologies; modified designs or layouts; modified scale or magnitude; and alternatives incorporating reasonable mitigation measures identified through comments received during EIS scoping and draft EIS comment periods. The EIS will evaluate the build and no build alternatives. Environmental Impacts and Mitigation Air quality Studies The EIS will provide an analysis of the potential air quality impacts of the project by demonstrating compliance with the National Ambient Air Quality Standards (NAAQS) and Minnesota Ambient Air Quality Standards (MAAQS) and evaluating the possible human health effects. Air dispersion modeling will be used to estimate air concentrations of pollutants emitted from the facility. The estimated air concentrations will be compared to applicable air quality standards and health risk benchmark values. The air dispersion modeling will be done in accordance with U.S. Environmental Protection Agency (USEPA) and MPCA guidance and procedures (http://www.pca.state.mn.us/index.php/air/air-monitoring-and-reporting/air-emissions-and-monitoring/air-dispersion-modeling/air-dispersion-modeling.html). The procedures include submittal of a modeling protocol to be approved before the air dispersion modeling is completed. The EIS will include a scoping Air Emission Risk Analysis (AERA) and a refined Human Health Risk Assessment (HHRA). The AERA will be performed according to MPCA guidance, found at http://www.pca.state.mn.us/ktqh42a, including the MPCA Air Emissions Risk Analysis (AERA)

http://www.pca.state.mn.us/index.php/air/air-monitoring-and-reporting/air-emissions-and-monitoring/air-dispersion-modeling/air-dispersion-modeling.html

http://www.pca.state.mn.us/index.php/air/air-monitoring-and-reporting/air-emissions-and-monitoring/air-dispersion-modeling/air-dispersion-modeling.html

http://www.pca.state.mn.us/ktqh42a

4

Guidance (Version 1.1, September 2007). The HHRA will be performed following the USEPA Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities (HHRAP) (USEPA 2005) and relevant MPCA requirements that either supersede aspects of the HHRAP or supplement the protocol. The AERA and HHRA will evaluate risk from before and after the proposed project. The specific methods and assumptions used in the AERA and HHRA will be submitted to the MPCA for approval, using the AERA forms. Section 2.7.3 of the AERA Guidance will be followed for scoping out emission sources, such as the auxiliary boiler, or pollutants not regulated with pollutant specific limits. Each compound identified in the sources below will be considered for the designation of compounds of potential interest (COPI). The hierarchy below will be used to select emission factors for COPIs. Any air emission rate limit used in the HHRA will be incorporated into the air permit.

1. 40 CFR 62 Subpart JJJ or Minn. R. 7011.1227, as applicable 2. NSPS Subpart AAAA or Minn. R. 7011.1229, as applicable 3. Stack test results performed on the existing municipal waste combustion (MWC) units at

PRRF 4. Continuous Emission Monitoring System data for the existing MWC Units at PRRF 5. Emission factors provided by the MPCA such as the Olmsted County Waste to Energy

Facility, Stanislaus, Huntington or other emission factors from relevant stack testing 6. Chapter 2.1, “Refuse Combustion” in USEPA’s AP-42, Fifth Edition, “Compilation of Air

Pollutant Emission Factors” (October 1996) 7. USEPA Factor Information Retrieval System, Version 6.23 for standard classification code

50100104 8. Supplement C, Table 2.1-1, of USEPA’s AP-42, Fourth Edition, “Compilation of Air Pollutant

Emission Factors” (October 1990)

The purpose of the HHRA will be to calculate quantitative estimates of COPI concentrations in air and COPI doses that are used with acute and chronic toxicity factors to estimate excess risks for carcinogens and hazards for noncarcinogens. Air concentrations and doses will be estimated for four exposure scenarios evaluated for specific locations in the areas most impacted by the facility. The specific locations to be evaluated and a description of the method used to select these locations will be included in the AERA forms. The anticipated four scenarios will include acute inhalation, resident and resident child, farmer and farmer child, and fisher and fisher child. Direct depositions to soil, plants, and surface water will be calculated and indirect exposures are calculated for relevant pathways. If there is the potential for one pound/year or more of mercury emissions and there are fishable water bodies in the area, then the risks associated with ingesting impacted fish will be assessed through the Minnesota Mercury Risk Estimation Method (MMREM), in lieu of the methods in the HHRAP (USEPA 2005). If MMREM is used, then an MMREM protocol (AERA form 27) shall be submitted to the MPCA for approval. For the criteria pollutants, ambient air quality modeling relative to the proposed project (i.e., the two waste heat boilers) will be conducted as part of the EIS to support the HHRA and demonstrate compliance with the NAAQS and MAAQS. If adverse impacts are determined, mitigating measures will be identified that prevent or mitigate impacts of such exposure, including changes in building and mechanical system design, heights, and placement of buildings. The EIS will determine potential cumulative effects on ambient air quality from the proposed project by modeling compliance with MAAQS and NAAQS, and by including a Cumulative AERA. The Cumulative AERA will follow the MPCA How to Conduct a Cumulative Air Emission Risk Analysis guidance located at http://www.pca.state.mn.us/lupg42d.

http://www.pca.state.mn.us/lupg42d

5

Wastewater impacts The EIS will describe and discuss any changes in water use and the generation and disposal of wastewater from the proposed project, including the status of the city of Perham’s plans to upgrade and operate its wastewater treatment facility. Traffic The EIS will evaluate the expected increase in traffic due to the proposed projects and its potential impacts on affected roads in the immediate vicinity of the project. Vehicle emissions The EIS will evaluate the expected impacts from on-site vehicle-related air emissions at the site. Noise The EIS will evaluate noise emanating from the proposed site and discuss the ability of the proposed project to meet applicable State Noise Standards. Solid Waste Management Plans A technical report will be prepared on the solid waste management programs and practices of the regional and local governing bodies in Otter Tail, Wadena, Todd, and Becker Counties. This report will be based on information from solid waste management plans and the requirements in applicable Minnesota statutes and rules. This information will be presented in the EIS.

Economic and Social Impacts The EIS will discuss the potential for the project and alternatives to directly and indirectly affect the local economic and sociological impacts.

Economic: The facility’s impact on cost to the user of the facility and general public will be identified. The effect of the proposed facility on regional and county solid waste system costs will be evaluated.

Sociological: Inventories will be completed of any nearby existing and planned recreational resources. Any potential impacts resulting from the expansion will be described.

Historical and archeological resources are not known to exist at or near the site, and there will be no analyses of this issue in the EIS.

Mitigation Measures For those instances where the impact analyses have identified the potential for adverse effects, the EIS will identify reasonably available measures that could lessen or eliminate the adverse effect. The types of measures that may result in significant mitigation of impacts range from facility-specific modifications in design and/or operation or broader policy-based action at all governmental levels. Appendices Appendices may be included in the EIS when applicable: (a) material prepared in connection with the EIS, as distinct from material that is so prepared and that is incorporated by reference; (b) material that substantiates any analysis fundamental to the EIS; and (c) permit information that was developed and gathered concurrently with the preparation of the EIS.

Material Incorporated by Reference Materials may be incorporated by reference to reduce the bulk of the EIS. Such materials will be cited in the EIS, and its content will be briefly described. Generally, these materials will not be distributed for public review, but will be available for inspection at the MPCA office in Saint Paul or be accessible via the MPCA website.

6

Each of these major topical areas – (a) Air Quality – (b) Solid Waste Management Plans – will be the subject of a technical report separate from the EIS. Discussion within the EIS on each of these primary impact areas will be based on the analyses and findings of the reports, but will likely omit much of the technical aspects of the more focused studies. These reports will be incorporated by reference as part of the EIS. The reports will be available for inspection at the MPCA offices in Saint Paul and libraries on the EQB distribution list in accordance with the requirements of the EQB rules. Technical reports will also be accessible via the MPCA website.

Documents

November 23, 2011 TO: INTERESTED PARTIES