Koch Pipeline Company, Clearbrook Tanks Project Environmental ...

Notice of Availability of an Environmental Assessment

Worksheet (EAW) Koch Pipeline Company, Clearbrook Tanks Project

Doc Type: Public Notice

Public Comment Information EAW Public comment period begins: January 5, 2015

EAW Public comment period ends: 4:30 p.m. on February 4, 2015

Notice published in the EQB Monitor: January 5, 2015

Facility Specific Information Facility name and location: Facility contact: Koch Pipeline Company, Clearbrook Tanks Project 46729 179th Avenue Clearbrook, MN 56634-4386 NW ¼, Section 32, T149N, R37W Leon Township Clearwater County, MN

Koch Pipeline Company, L.P. Natalie Schoonover Environmental Manager Koch Pipeline Company, L.P. P.O. Box 64596 St. Paul, MN 55164 Phone: 651-438-1564 Fax: 651-480-3827 Email: [email protected]

MPCA Contact Information

MPCA EAW contact person: Patrice Jensen Resource Management and Assistance Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN 55155 Phone: 651-757-2465 Fax: 651-297-2343 Email: [email protected] Admin staff phone: 651-757-2100

General Information The Minnesota Pollution Control Agency (MPCA) is distributing this Environmental Assessment Worksheet (EAW) for a 30-day review and comment period pursuant to the Environmental Quality Board (EQB) rules. The MPCA uses the EAW and any comments received to evaluate the potential for significant environmental effects from the project and decide on the need for an Environmental Impact Statement (EIS).

An electronic version of the EAW is available on the MPCA Environmental Review webpage at http://www.pca.state.mn.us/oxpg691. If you would like a copy of the EAW <or Permit> or have any questions on the EAW <or Permit>, contact the appropriate person(s) listed above. p-ear2-69a

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Description of Proposed Project The Minnesota Pipe Line Company, LLC (MPL) is the owner of the Clearbrook Terminal (or Terminal) located in Clearwater County, Minnesota. It is an existing above-ground storage tank terminal that is currently comprised of eleven (11) crude oil tanks and support equipment. The Clearbrook Terminal is operated by Koch Pipeline Company, L.P (KPL) (the Proposer). KPL, as operator of the MPL Clearbrook Terminal, proposes to expand the existing Terminal by constructing four (4) field-erected 300,000 barrel (50,400,000 gallons total) external floating roof crude oil tanks (the Project). The new tanks will be 196 feet in diameter and 56 feet high, and will have foundations that extend below the ground surface. In addition to the tanks and their associated containment areas, the Project will require new infrastructure that will include a new 1,500 foot access road, two small buildings to house power zone centers as well as necessary pumps and piping. Pipelines from North Dakota and Canadian oil fields supply the Terminal. A MPL pipeline called Line 4 transports crude oil from the Terminal to the Twin Cities’ refineries. MPL is planning to upgrade Line 4 in a separate project described in Paragraph 6b. The existing tanks and proposed new tanks at the Terminal are used for temporary storage, segregation, and blending of crude oil delivered through existing pipelines. The oil stored in tanks is then transported from the Terminal via existing pipelines.

To Submit Written Comments on the EAW Written comments on the EAW must be received by the MPCA EAW contact person within the comment period listed above.

NOTE: All comment letters are public documents and will be part of the official public record for this project.

Need for an EIS (1) A final decision on the need for an EIS will be made after the end of the comment period. (2) If a request for an EIS is received during the comment period, or if the MPCA Commissioner (Commissioner) recommends

the preparation of an EIS, the MPCA Citizens’ Board (Board) will make the final decision. (3) If a request for an EIS is not received, the final decision will be made by the Commissioner.

The Board meets once a month, usually the fourth Tuesday of each month, at the MPCA office in St. Paul. Meetings are open to the public and interested persons may offer testimony on Board agenda items. Information on the Board is available at: http://www.pca.state.mn.us/nwqh406.

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July 2013 version

ENVIRONMENTAL ASSESSMENT WORKSHEET This Environmental Assessment Worksheet (EAW) form and EAW Guidelines are available at the Environmental Quality Board’s website at: http://www.eqb.state.mn.us/EnvRevGuidanceDocuments.htm. The EAW form provides information about a project that may have the potential for significant environmental effects. The EAW Guidelines provide additional detail and resources for completing the EAW form. Cumulative potential effects can either be addressed under each applicable EAW Item, or can be addresses collectively under EAW Item 19. Note to reviewers: Comments must be submitted to the RGU during the 30-day comment period following notice of the EAW in the EQB Monitor. Comments should address the accuracy and completeness of information, potential impacts that warrant further investigation and the need for an EIS. 1. Project title: Clearbrook Tanks Project 2. Proposer: Koch Pipeline Company, L.P. 3. RGU: Minnesota Pollution Control Agency

Contact person: Natalie Schoonover Contact person: Patrice Jensen Title: Environmental Manager Title: Principal Planner Address: PO Box 64596 Address: 520 Lafayette Road North City, State, ZIP: St. Paul, MN 55164 City, State, ZIP: St. Paul, MN 55155 Phone: 651-438-1564 Phone: 651-757-2465 Fax: 651-480-3827 Fax: 651-297-8683 Email: [email protected] Email: [email protected]

4. Reason for EAW Preparation: (check one)

Required: Discretionary: oEIS Scoping o Citizen Petition X Mandatory EAW o RGU Discretion o Proposer Initiated If EAW or EIS is mandatory give EQB rule category subpart number(s) and name(s):

5. Project Location:

County: Clearwater City/Township: Leon PLS Location (¼, ¼, Section, Township, Range): The majority of the project area is in the northeast quarter of the northwest quarter, Section 32, Township 149 Range 37

Watershed (81 major watershed scale): Clearwater River GPS Coordinates: 47.6854505°, -095.4207631° (Degrees Lat Long) Tax Parcel Number: R12.032.0100

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Printed on recycled paper containing 30% fibers from paper recycled by consumers

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Tables, Figures, and Appendices attached to the EAW: Figures

· Figure 1 Site Location Map · Figure 2 Site Plan Aerial Imagery · Figure 3 Site Plan USGS Topographic Map · Figure 4 Site Map Land Cover · Figure 5 Site Map Soils · Figure 6 Site Map Water Resources

Appendices

· Appendix 1 – County Well Index Well Logs · Appendix 2 – Water Appropriation Permit · Appendix 3 – MN DNR Correspondence · Appendix 4 – Process Flow Diagram · Appendix 5 – MPCA Air Emission Option A Registration Permit

At a minimum attach each of the following to the EAW: · County map showing the general location of the project; · U.S. Geological Survey 7.5 minute, 1:24,000 scale map indicating project boundaries (photocopy

acceptable); and · Site plans showing all significant project and natural features. Pre-construction site plan and

post-construction site plan. 6. Project Description:

a. Provide the brief project summary to be published in the EQB Monitor, (approximately 50 words). The Minnesota Pipe Line Company, LLC (MPL) is the owner of the Clearbrook Terminal (or Terminal) located south of County Road 74 in Clearwater County, Minnesota. It is an existing above-ground storage tank terminal that is currently comprised of 11 crude oil tanks and support equipment. The Clearbrook Terminal is operated by Koch Pipeline Company, L.P (KPL) (the Proposer). KPL, as operator of the MPL Clearbrook Terminal, proposes to expand the existing Terminal by constructing four field-erected 300,000 barrel (50,400,000 gallons total) external floating roof crude oil tanks (the Project). The existing tanks and proposed new tanks at the Terminal are used for temporary storage, segregation, and blending of crude oil delivered through existing pipelines. In addition to the tanks and their associated containment areas, the Project will require new infrastructure that will include a new 1,500 foot access road, two small buildings to house power zone centers as well as necessary pumps and piping. Pipelines from North Dakota and Canadian oil fields supply the Terminal, and the oil stored in the tanks is then transported from the Terminal via existing pipelines (including MPL Line 4) to the Twin Cities’ refineries. MPL is planning to increase the capacity of Line 4 in a separate project.

Clearbrook Tanks Project Environmental Assessment Leon Township, Clearwater County, Minnesota 2 Worksheet

b. Give a complete description of the proposed project and related new construction, including infrastructure needs. If the project is an expansion include a description of the existing facility. Emphasize: 1) construction, operation methods and features that will cause physical manipulation of the environment or will produce wastes, 2) modifications to existing equipment or industrial processes, 3) significant demolition, removal or remodeling of existing structures, and 4) timing and duration of construction activities. The existing above-ground storage tanks located at the Clearbrook Terminal allow for the temporary storage, segregation, and blending of crude oil; crude oil is not dispensed at the Terminal. The proposed new tanks would add additional capacity for temporary storage, segregation, and blending. The existing footprint of the Terminal is approximately 65 acres within a 235 acre property. The remaining 170 acres forms a buffer zone along the south side of the Terminal. The Terminal is located in Section 32, Township 149 North, Range 37 West. It is bordered on the north by County Road 74 and another crude oil terminal owned by Enbridge. To the west, south, and east it is bordered by cropland, wooded areas, brush/grassland, and wetland. Site location is shown on Figure 1 for reference. A site plan and aerial photograph showing all relevant Project features is provided on Figure 2. As shown on Figure 2, the proposed new tanks will be located on the west side of the property. Figure 3 shows the Project site features overlain on United States Geological Survey (USGS) 7.5 minute quadrangle map. The total area within the Terminal perimeter where construction activities will take place is anticipated to be approximately 18 acres located in the north-west portion of the property. Approximately one half of the Project area would require grading or excavation. No significant demolition, removal or remodeling of existing structures is planned. There are currently 11 aboveground storage tanks located at the Clearbrook Terminal. Tank numbers 1-4 have a capacity of 100,000 barrels each (16,800,000 gallons total); tanks 5-9 have a capacity of 150,000 barrels each (31,500,000 gallons total); and, tanks 10-11 have a capacity of 300,000 barrels each (25,200,000 gallons total). All of these tanks are break-out tanks that are directly connected to pipelines coming into and exiting the Terminal in order to provide segregation of crude grades and contain crude oil. None of these tanks receive hazardous materials via truck or rail. Generally, the proposed work at the Clearbrook Terminal will include limited grading and resurfacing, constructing the new tanks and associated secondary containment, erecting two small buildings, constructing new roads, installing ancillary piping, and fencing of the site. New secondary containment berms will be constructed around the new tanks (see response to Item 12 c). Pending permit approvals, construction could begin as early as winter 2014-2015, and is estimated to be completed within 14 to 17 months after all required permits and authorizations are received, although the timeline may be extended depending on the date construction begins in relation to the winter months. The MPL pipeline system and Enbridge’s pipeline system interconnect at Clearbrook, Minnesota. The oil being shipped into the Clearbrook Terminal is supplied by Enbridge pipelines. While the Enbridge pipelines feeds the MPL system, the purpose of the Project is to more efficiently handle feedstock for the Minnesota refineries, better accommodate tank inspections, allow for unscheduled “spot” shipments and better manage and segregate crude varieties. The Project is independent of the Enbridge projects discussed in Section 19 of the EAW and would proceed without these unrelated projects.


In addition to the proposed Project, MPL has proposed a separate project (which MPL has named the MPL “Reliability Project”). MPL’s pipeline system is the primary pipeline system supplying crude oil to the Twin Cities’ refineries. MPL will request an increase in its capacity on MPL Line 4 from the Minnesota Public Utilities Commission (MPUC) to ensure the overall reliability of its pipeline system. This project consists of the addition of six pump stations to MPL Line 4 and other upgrades at existing stations. MPL indicates that the project will enable it to shift capacity to MPL 4, its newest pipeline, in the event of an outage on other segments of the pipeline system. In addition, MPL indicates the Line 4 project will allow MPL to conduct preventative maintenance on other segments of the pipeline system as needed without disrupting crude supplies to the Twin Cities’ refineries. When MPL added Line 4 to its system in 2008, it was designed to allow for a future increase in capacity. The MPL Reliability Project will allow the pipeline to operate at its original design capacity when needed to meet demand. Initial engineering indicates that three 10,750 gallons-per-minute pumps will be required per station. The work related to the new pump stations will occur solely on six small parcels of land located in the counties of Hubbard, Wadena, Morrison, Meeker, McLeod, and Scott. The parcels (each approximately 5-7 acres) are already owned by MPL or will be purchased by MPL. The parcels are located along the pipeline and will not require any change to the pipeline itself or acquisition of new pipeline right-of-way. In addition, two existing pump stations (located at Clearbrook and Albany) will require upgrading. One of the pump stations to be upgraded is located on the same site as the Clearbrook Terminal. The upgrade to the existing pump station will require minimal physical modification of the Clearbrook Terminal. Therefore, relevant impacts associated with the MPL Reliability Project are primarily associated with a minor increase in air emissions. KPL has applied for a capped air permit for the existing Terminal and the proposed expansion. The estimated project emissions from pump station upgrades at Clearbrook Terminal are 0.17 tons of volatile organic compounds (VOCs) per year, which is less than one percent of the VOC emissions allowed at the Terminal under the proposed capped permit. KPL has provided a separate pre-change analysis in Section 16 below, to evaluate the new pump stations and the relevant portions of the MPL Reliability Project. That analysis indicates that emissions at the Terminal from both the Clearbrook Terminal Project and the MPC Reliability Project pump station upgrade at Clearbrook can be accommodated under the proposed capped air emissions permit. Emissions from the pump station at the Clearbrook Terminal have been included in the future emissions estimates in KPL’s application for a capped air permit, and cumulative potential effects from the additional tank installations have already been accounted for as part of that permit action. The air permit application includes an analysis of both the Clearbrook Terminal tanks addition and the MPL Reliability Project in the capped permit pre-change analysis. The pre-change analysis demonstrates that the estimated future actual station emissions, incorporating the combined effect of both projects, allow the Terminal to maintain its status as a minor source of air emissions under the capped emissions permit. Further, any potential environmental impacts resulting from the MPL Reliability Project will be subject to separate review of the Certificate of Need (Docket # Pl-5/CN-14-320). Following are transmission lines which will be used to provide power to the pump stations associated with either the Terminal or Line 4. All of these projects are either in the process or will undergo environmental review related to approval processes of the MPUC.


Clearbrook-Clearbrook West 115 kV Transmission Line, Minnkota Power Cooperative, Inc. Minnkota Power Cooperative, Inc. (Minnkota Power) is applying for a route permit for its Clearbrook-Clearbrook West Project pursuant to the alternative permitting procedures in Minn. R. 7850.2800 – 7850.3900. This project includes construction of a new 5.3-mile 115 kilovolt (kV) transmission line and a new 115/41.6 kV substation. The proposed project will start in Leon Township by tapping an existing 115 kV line and end in Pine Lake Township at the new Clearbrook West Substation. The proposed project is intended to serve a single industrial user in the Clearbrook area. Maps indicate this proposed transmission line ties into the Clearbrook Terminal. On August 5, 2014, Minnkota Power notified the MPUC of its intent to submit an application for a route permit. Menahga Area 115 kV Transmission Line Project Great River Energy and Minnesota Power filed a request for a Certificate of Need for a 22.5 mile 115 kilovolt (kV) high voltage transmission line in Hubbard, Wadena, and Becker counties. The project is primarily driven by Great River Energy’s load-serving needs and the need to serve a proposed new MPL pumping station to be built by MPL as part of the MPL Reliability Project. The MPUC approved the proposed notice plan on December 8, 2014. Motley 115 kV Transmission Line Project A transmission line is proposed to be constructed that is associated with some of the pump stations that require permitting through the Power Plant Siting Act; it is expected to be filed with the MPUC in 2015.

c. Project magnitude:

Total Project Acreage 18.27 acres (area within site boundary, Figure 2)

Linear project length new access road, 1,500 feet; access roads on tops of dike, 2,600 feet; roads inside containment area, 1,300 feet.

Number and type of residential units N/A Commercial building area (in square feet) N/A Industrial building area (in square feet) 121,968 square feet (2.8 acres area within

tank footprint) Institutional building area (in square feet) N/A Other uses – specify (in square feet) N/A Structure height(s) 56 feet

d. Explain the project purpose; if the project will be carried out by a governmental unit, explain

the need for the project and identify its beneficiaries.

The proposed additional tanks at the Clearbrook Terminal will allow more efficient transport and storage of crude oil feedstock for Minnesota refineries. Crude oil is not homogeneous, and is typically shipped in batches. The quality of crude oil can vary between batches. The interface (mixing zone) between batches shipped in a pipeline can be lower quality than the rest of the batch, and can have a deleterious effect on the refineries the pipeline serves. Large batches help


to reduce the potential for negative effects. To obtain larger batches, more storage is required. Of the tanks currently at the Clearbrook Terminal, only two have a capacity similar to that of the proposed tanks (300,000 barrels).

Also, the existing tanks operated by KPL are inspected and repaired pursuant to American Petroleum Institute (API) Standard 653. To meet the standard requirements, a tank must be inspected by a certified inspector internally and externally. This means the tank undergoing inspection must be emptied and thoroughly cleaned beforehand, inspected, and upon approval, put back in service. This process typically takes several months to complete. Having tanks temporarily out of service can affect KPL’s ability to serve the needs of Minnesota’s refineries by limiting the ability to segregate varying grades of crude oil at the Clearbrook Terminal.

Finally, KPL is regularly asked by shippers to accommodate unscheduled or “spot” shipments of crude oil feedstock. Because of current storage limitations at the Clearbrook Terminal, and the variability of crude oil available today, it is increasingly difficult for KPL to accommodate these customers’ needs. The additional proposed tanks will allow KPL greater flexibility in managing and segregating the different crude varieties, and thereby meet customer expectations.

e. Are future stages of this development including development on any other property planned

or likely to happen? 糎Yes X No

f. Is this project a subsequent stage of an earlier project? 糎Yes X No

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

after development: The table below summarizes cover types within the site boundary shown on Figure 4.

Before After Before After

Wetlands 0 0 Lawn/landscaping 0 0 Deep water/streams 0 0 Impervious surface 0.67 18.27 Wooded/forest 1.30 0 Stormwater Pond 0 0 Brush/Grassland 3.55 0 Existing Terminal 0 0 Cropland 12.75 0 TOTAL 18.27 18.27


8. Permits and approvals required: List all known local, state and federal permits, approvals, certifications 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.

Cumulative potential effects may be considered and addressed in response to individual EAW Item Nos. 9-18, or the RGU can address all cumulative potential effects in response to EAW Item No. 19. If addressing cumulative effect under individual items, make sure to include information requested in EAW Item No. 19 9. Land use:

a. Describe: i. Existing land use of the site as well as areas adjacent to and near the site, including parks,

trails, prime or unique farmlands. The Clearbrook Terminal is located within Leon Township in Clearwater County. The Terminal currently occupies approximately 65 acres within a 235 acre property. The Terminal is bordered on the north by County State Aid Highway (CSAH) 74 and an Enbridge Energy terminal. It is bordered on the west by land that is rotated between row-crop agriculture and hay production. To the south and east the Project area is bordered by mixed deciduous-coniferous forested areas (Figure 4). The city of Clearbrook is located approximately 1,000 feet northwest of the Terminal; a single-family residential housing area is northwest of the Project area, north of CSAH 74, along with parks, schools, and churches. There are no parks or trails adjacent to the Clearbrook Terminal, and all of the Project area is classified by the U.S. Department of Agriculture (USDA) as “prime farmland” or “prime farmland if drained” (Figure 5).

Unit of Government Type of Application Status MPCA Air Emission Option A Registration Permit # 02900002-

002 Existing

MPCA Capped Emissions Permit – Option 2 - Pending Application was received 5/23/14

MPCA Spill Prevention Control and Countermeasures (SPCC) Plan

Existing

MPCA NPDES Permit #MN0056472 Industrial Wastewater Existing MPCA NPDES/SDS General Construction Storm Water (CSW)

Permit. A Storm Water Pollution Prevention Plan (SWPPP) will be submitted to the MPCA prior to submitting the CSW permit application. CSW’s will also be required for construction of the pump stations.

Application to be submitted following completion of environmental review

MN DNR Water Appropriation Permit #1990-1207 Existing


ii. Plans. Describe planned land use as identified in comprehensive plan (if available) and any other applicable plan for land use, water, or resources management by a local, regional, state, or federal agency. Clearwater County has adopted a Resource Management Plan1 that provides a vision of the future condition of the land resources in Clearwater County, identifies strategies to achieve this vision, and addresses the most strategic resource management issues faced by the county. The plan focuses mainly on a strong vision for a more diverse forest in Clearwater County that can accommodate multiple uses. The Clearwater County Resource Management Plan identifies three main objectives for the Hardwood Hills portion of the county [Minnesota Department of Natural Resources (MDNR) and U.S. Forest Service Ecological Classification System (ECS)2], which includes Leon Township.

· Enhance wildlife habitat in two to four selected areas of the planning unit; · Improve access to high priority county land parcels that are now without

adequate access; and, · Increase the presence of the jackpine in the unit over the next 20 years by

identifying 1-3 sites over the next five years to convert conifer.

Clearwater County has also developed a Comprehensive Local Water Management Plan3 to address soil and water issues throughout the county including surface water quality protection and enhancement, drinking water source protection, exotic and invasive species management, and management of land use impacts on water quality. The plan primarily targets three major watersheds: Wild Rice River, Upper Mississippi River, and Clearwater River. The proposed Project is located within the Clearwater River watershed, the largest watershed in Clearwater County. The plan identifies Clearwater watershed as a priority area as the majority of the human activity in the county is concentrated within this watershed, including 100,000 acres of agricultural land and three municipalities with urban stormwater systems and municipal wells. The plan’s recommendations for water management in the Clearwater watershed and for the impaired waterbodies within the watershed focuses on forestry stewardship, agricultural best management practices (BMPs), soil conservation practices, proper septic system maintenance, and use of the County Shoreland Ordinance.

iii. Zoning, including special districts or overlays such as shoreland, floodplain, wild and scenic rivers, critical area, agricultural preserves, etc. The Clearbrook Terminal property is not subject to any zoning restrictions and the Project is not located in a special district or overlay such as shore land, floodplain, wild and scenic rivers, critical area, or agricultural preserves. An unnamed tributary to Silver Creek is located west of the Project area (Figure 6). This segment of stream is identified in Section 201.8 of Clearwater County’s Shoreland Management Ordinance4 as a Tributary

1 Clearwater County, 2008. Clearwater County Resource Management Plan. 2 Minnesota Department of Natural Resources (MNDNR). 2005. Field Guide to the Native Plant Communities of Minnesota: the Eastern Broadleaf Forest Province. Ecological land Classification Program, Minnesota County Biological Survey, and Natural Heritage and Nongame Research Program. MDNR St. Paul, MN. 3 Clearwater County, 2010. 2010 – 2020 Clearwater County Comprehensive Local Water Management Plan 4 Clearwater County, 2010. Clearwater County Shoreland Management Ordinance Clearbrook Tanks Project Environmental Assessment Leon Township, Clearwater County, Minnesota 8 Worksheet

Management District. All Project features, however, are located outside of the 300-foot shore land buffer of this stream and beyond the shoreland zoning restriction.

b. Discuss the project’s compatibility with nearby land uses, zoning, and plans listed in Item 9a

above, concentrating on implications for environmental effects. The proposed Project is compatible with established land use patterns in the area. The Clearbrook Terminal adjacent to the Project area has been in service since 1954. The proposed Project involves extending this land use slightly further west. The extension of an existing land use is not anticipated to introduce any conflict with adjacent and nearby land uses. Construction of the proposed Project on USDA prime farmlands would have a negligible effect on prime farmland in Clearwater County. The USDA classifies over 244,000 acres of farmland in Clearwater County as “prime” or “prime if drained”5. The farmland classified within the Project area represent less than 0.01 percent of the total prime and prime if drained farmland in Clearwater County. The land within the proposed Project footprint is not actively farmed at this time. Implementation of the proposed Project is compatible with Clearwater County’s Resource Management Plan. The proposed Project is not located within an area targeted for wildlife habitat enhancement or jackpine development, and will not impact county land parcels. Implementation of the proposed Project is also compatible with Clearwater County’s Comprehensive Local Water Management Plan as the proposed Project will comply with the plan and include provision to install appropriate soil erosion and stormwater BMPs. The proposed Project is compatible with Clearwater County’s Shoreland Management Ordinance. All Project features are located outside of the 300-foot shore land buffer along the unnamed tributary to Silver Creek that passes northwest of the Project area. Clearwater County does not have a general zoning ordinance.

c. Identify measures incorporated into the proposed project to mitigate any potential incompatibility as discussed in Item 9b above. No potential incompatibilities were noted in Item 9b above.

10. Geology, soils and topography/land forms:

a. Geology - Describe the geology underlying the project area and identify and map any susceptible geologic features such as sinkholes, shallow limestone formations, unconfined/shallow aquifers, or karst conditions. Discuss any limitations of these features for the project and any effects the project could have on these features. Identify any project designs or mitigation measures to address effects to geologic features. Per the Minnesota Geological Survey Map M-1776 (Quaternary Geology of the Fosston 30x60 Quadrangle, Northwest Minnesota, Kenneth L. Harris, 2007), the site is underlain by:

5 Soil Survey Staff, Natural Resources Conservation Service, United States Department of Agriculture. Soil Survey Geographic (SSURGO) Database for Clearwater County, MN. Available online at http://www.arcgis.com/apps/OnePane/basicviewer/index.html?appid=a23eb436f6ec4ad6982000dbaddea5ea. Accessed February 27, 2014. 6 Kenneth L. Harris, 2007. Quaternary Geology of the Fosston 30x60 Quadrangle, Northwest Minnesota. Clearbrook Tanks Project Environmental Assessment Leon Township, Clearwater County, Minnesota 9 Worksheet

http://www.arcgis.com/apps/OnePane/basicviewer/index.html?appid=a23eb436f6ec4ad6982000dbaddea5ea

· Modern deposits, primarily peat in old lake beds (generally a few feet thick); · Glacial till and outwash of Wisconsinan age (85,000 to 11,000 years before present) and

possibly older at depth (300 to 500 feet thick); and, · Precambrian bedrock, likely granitic.

The uppermost glacial deposits in the Project area are of the Lower Red Lake River member of the Red Lake River Group. The Lower Red Lake River member was deposited during the Wisconsin Glacial Episode by a late re-advance of the glacier flowing out of the Red River lowlands. The Lower Red Lake River member is present at the ground surface as a pebbly loam till, unsorted and unlayered, with gravel, cobbles and boulders. The till is massive, brownish-gray to olive gray, and calcareous. There is also a deposit of outwash sand and silt on the west side of the Project site, moderately to poorly sorted, up to 10 feet thick. Peat deposits have been mapped in the Project area north and east of the proposed tank site. Well logs in the Minnesota County Well Index (CWI)7 indicate groundwater is shallow, generally within 10 to 30 feet of the ground surface in the Project area. However, soil borings were made at the Project site during the geotechnical investigation for the Project. One boring had indications of groundwater at a depth of 40 feet. The other borings showed no groundwater at a depth of 42 feet. There are no limestone formations underlying the site, nor any other subgrade subject to karstification. There are no sinkholes in or near the site. Other than sand and gravel and peat, there are no known geologic resources in the Project area. These resources are abundant in the region. Site preparation, construction, and operation of four additional tanks at the existing Terminal will not alter geologic conditions in the Project area. Site conditions, including local geology were considered during initial design and layout of the proposed locations and will be further addressed as needed during detailed design.

b. Soils and topography - Describe the soils on the site, giving NRCS (SCS) classifications and descriptions, including limitations of soils. Describe topography, any special site conditions relating to erosion potential, soil stability or other soils limitations, such as steep slopes, highly permeable soils. Provide estimated volume and acreage of soil excavation and/or grading. Discuss impacts from project activities (distinguish between construction and operational activities) related to soils and topography. Identify measures during and after project construction to address soil limitations including stabilization, soil corrections or other measures. Erosion/sedimentation control related to stormwater runoff should be addressed in response to Item 11.b.ii. According to the US Department of Agriculture Natural Resource Conservation Service (NRCS) Soil Survey Geographic (SSURGO) database8, the soils on the Project site consist of Gonvick loam (180), Smiley loam (765), Linveldt fine sandy loam (713), Kratka fine sandy loam (481), and Waukon loam, 2 to 6 percent slopes (38B) (Figure 5).

7 http://mdh-agua.health.state.mn.us/cwi/cwiWellList.asp?township=&range=&section=&welllist= ('0000128544','0000462903','0000636509') 8 http://websoilsurvey.sc.egov.usda.gov Clearbrook Tanks Project Environmental Assessment Leon Township, Clearwater County, Minnesota 10 Worksheet

http://mdh-agua.health.state.mn.us/cwi/cwiWellList.asp?township=&range=&section=&welllist

General descriptions of these site soil types are as follows:

· The Gonvick series consists of very deep, moderately well drained soils that formed in calcareous loamy glacial till on glacial moraines. These soils have moderate or moderately slow permeability. Slopes range from one to four percent.

· The Smiley series consists of very deep, poorly drained soils formed in loamy glacial till on lake plains, till plains and moraines. These soils have moderate or moderately slow permeability. Slopes range from zero to two percent.

· The Linveldt series consists of very deep, moderately well drained soils that formed in a mantle of water worked sediments over calcareous loamy glacial till. These soils primarily are on glacial lake plains. Permeability is moderately rapid or rapid in the upper part and moderate in the underlying till. These soils have slopes of zero to three percent.

· The Kratka series consists of very deep poorly and very poorly drained soils that formed in a mantle of sandy glacial lacustrine or outwash sediments over lacustrine sediments or loamy glacial till on glacial lake plains, glacial deltas of former glacial lakes, stream terraces, and moraines. These soils have moderately rapid or rapid permeability in the upper part and moderately rapid to moderately slow permeability in the lower part. Slopes range from zero to two percent.

· The Waukon series consists of very deep well drained soils that formed in glacial till on glacial moraines. Permeability is moderate.

Operation of the Project is not expected to cause erosion or sedimentation and no control measures are anticipated to be necessary. Potential impacts to erosion and sedimentation evaluated below are associated with Project construction and stormwater management. No steep slopes or highly erodible soils exist at the Project site and the proposed construction area is relatively flat. Current elevation at the new tank locations varies from 1,348 to 1,357 feet above mean sea level (msl). The finished grade adjacent to each tank will be an elevation of approximately 1,345 feet msl. Site preparation will require grading of approximately 18 acres and excavation of approximately 120,000 cubic yards of soil. During site preparation and construction, standard erosion prevention and sediment control measures BMPs such as ditches, dikes and siltation fences that will be used to reduce the potential for pollutants to reach water bodies during construction of the tanks will be used to manage erosion and sedimentation. Post-construction, gravel and/or vegetation will be used to permanently stabilize surfaces disturbed during construction activities. Most of the soil excavated from the construction area will be used as engineered backfill, or for secondary containment upgrades. No offsite soil will be needed for construction.

11. Water resources:

a. Describe surface water and groundwater features on or near the site in a.i. and a.ii. below. i. Surface water - lakes, streams, wetlands, intermittent channels, and county/judicial

ditches. Include any special designations such as public waters, trout stream/lake, wildlife lakes, migratory waterfowl feeding/resting lake, and outstanding resource value water. Include water quality impairments or special designations listed on the current MPCA 303d Impaired Waters List that are within 1 mile of the project. Include DNR Public Waters Inventory number(s), if any.


There is an unnamed tributary to Silver Creek near the west side of the Project area (Figure 6). The unnamed tributary is on the MDNR list of Protected Public Waters. This unnamed tributary to Silver Creek will not be impacted by the Project, as it is outside the geographic scope of construction activities. There are no impaired waters (lakes, streams or wetlands) on or adjacent to the Project area. There are no trout streams, wildlife lakes, migratory waterfowl feeding/resting lakes, or outstanding resource value waters on or adjacent to the Project area.

Wetlands within the property boundary and in the vicinity of the Project area are shown on Figure 6. Most of these wetlands are classified as palustrine emergent (PEM) wetlands under the Cowardin classification system9 (Type 3 under Circular 3910, Shallow Marsh under Eggers & Reed11 classification). Several palustrine forested/scrub-shrub (PFO/PSS under Cowardin) wetlands are also present within and adjacent to the property boundary. These are classified as Type 6 under Circular 39, and shrub carr under Eggers & Reed. These wetlands will not be affected by the Project.

ii. Groundwater – aquifers, springs, seeps. Include: 1) depth to groundwater; 2) if project is within a MDH wellhead protection area; 3) identification of any onsite and/or nearby wells, including unique numbers and well logs if available. If there are no wells known on site or nearby, explain the methodology used to determine this. Well logs in the Minnesota CWI12 indicate groundwater in the Project area is shallow, generally within 10 to 30 feet of the ground surface. However, as noted in response to Item 10a, soil borings made at the Project site during the geotechnical investigation for the Project indicated groundwater depth of 40 feet or greater. Three active wells are located within the property boundary and are shown on Figure 6.

Two of these wells are production wells located immediately southeast of Tank 6 (CWI well

ID 636509 and 462903). Well 636509 is an inactive industrial well and well 462903 is an active (non-potable water) domestic well. Industrial wells may be used for hydrostatic testing depending on the availability of water from other sources, and as a non-potable water source for construction activities such as dust control, mixing grout products, cleaning, etc.

The third well is a domestic well (not used for drinking water purposes) located southeast of

Tank 4 (CWI well ID 128504). One additional well located within the property boundary has been sealed and abandoned (CWI well ID 667943). CWI well logs for these wells are provided in Appendix 1. There are no monitoring wells located within the proposed Project site.

9 Cowardin, L.M., V. Carter, F.C. Golet and E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. Office of Biological Services. U.S. Fish and Wildlife Service. U.S. Department of Interior. Washington, D.C. 20240. 10 U.S. Fish and Wildlife Service (USFWS). 1971. Circular 39: Wetlands of the United States. U.S. Department of the Interior. 11 Eggers, S.D. and D.M. Reed. 1997. Wetland Plants and Plant Communities of Minnesota & Wisconsin. U.S. Army Corps of Engineers, St. Paul District. 12 http://mdh-agua.health.state.mn.us/cwi/cwiWellList.asp?township=&range=&section=&welllist= ('0000128544','0000462903','0000636509') Clearbrook Tanks Project Environmental Assessment Leon Township, Clearwater County, Minnesota 12 Worksheet

http://mdh-agua.health.state.mn.us/cwi/cwiWellList.asp?township=&range=&section=&welllist

No impacts to groundwater are anticipated from the construction or operation of the proposed Project. Thus the Project is not expected to have any effect on any of these wells.

The Project is not within a Minnesota Department of Health (MDH) wellhead protection

area.

b. Describe effects from project activities on water resources and measures to minimize or mitigate the effects in Item b.i. through Item b.iv. below.

i. Wastewater - For each of the following, describe the sources, quantities and composition

of all sanitary, municipal/domestic and industrial wastewater produced or treated at the site. 1) If the wastewater discharge is to a publicly owned treatment facility, identify any

pretreatment measures and the ability of the facility to handle the added water and waste loadings, including any effects on, or required expansion of, municipal wastewater infrastructure. The existing Terminal does not discharge to a publicly owned treatment works (POTW) nor does it use municipal wastewater infrastructure. The Project will not require the Terminal to connect to a POTW and there will be no impacts to any municipal wastewater infrastructure.

2) If the wastewater discharge is to a subsurface sewage treatment systems (SSTS),

describe the system used, the design flow, and suitability of site conditions for such a system. The existing Terminal operates a sanitary septic system with drain field that services the office/facility restrooms. The septic system is regulated by a county permit. The Project will not increase the permanent number of workers at the Terminal. Therefore, the existing septic system will not need to be expanded. Portable toilets will be used during the construction process and will be serviced on a regular basis.

3) If the wastewater discharge is to surface water, identify the wastewater treatment

methods and identify discharge points and proposed effluent limitations to mitigate impacts. Discuss any effects to surface or groundwater from wastewater discharges. The normal operation of the tanks does not generate wastewater. Therefore, the projects will not result in a wastewater discharged to surface waters as part of normal Terminal operations. During construction, water used for the hydrostatic testing will be discharged in compliance with Minnesota Pollution Control Agency’s (MPCA’s) State Disposal System (SDS) permit MN0056472 and the effluent limits located in Chapter 2.4 “hydrotest discharges”. The tanks are inspected on a 10-20 year inspection cycle (response to Item 12 c). Prior to cleaning and inspection, product is pumped from the tanks to the pipeline. Liquid heel and any sludge remaining after normal pump-out are vacuumed out and the tank is degassed by forced ventilation before a final sludge removal and rinse-out. If necessary, diesel fuel is used as a diluent/cutter stock to loosen sludge. Final tank rinse is water and possibly some detergent to remove final residue or staining. Wastewater from the final tank rinse is not discharged; rather, it is hauled offsite to a licensed facility for oil/water separation and oil recycling.


ii. Stormwater - Describe the quantity and quality of stormwater runoff at the site prior to and post construction. Include the routes and receiving water bodies for runoff from the site (major downstream water bodies as well as the immediate receiving waters). Discuss any environmental effects from stormwater discharges. Describe stormwater pollution prevention plans including temporary and permanent runoff controls and potential BMP site locations to manage or treat stormwater runoff. Identify specific erosion control, sedimentation control or stabilization measures to address soil limitations during and after project construction. The area where the tanks are proposed to be constructed is an undeveloped field. Runoff from this field, as well as from the post construction tank farm, will be collected in a small drainage ditch within the Terminal property. This ditch flows to the northern edge of the property and discharges under CSAH 49 to the north. The Terminal is located in the Clearwater watershed. However, the area between the Terminal and Lower Red Lake is fairly flat with many wetlands and small unnamed lakes and streams. Therefore, it is difficult to identify the exact route storm water will flow once it is discharged off site. Construction of the new tanks, secondary containment and new internal roads will increase the impervious area of the site by approximately 18 acres and therefore requires a National Pollutant Discharge Elimination System (NPDES)/SDS Construction Stormwater General permit. Most of the runoff from the new impervious surfaces will be collected and retained in the secondary containment system. As a result, the new impervious surfaces will not significantly increase the rate at which water is discharged from the site to the surrounding watershed area. Accumulated stormwater will be inspected prior to discharge and will be discharged in a manner that prevents erosion or scouring in the conveyance ditch.

However, per current regulatory requirements, all dike discharge water will be checked for sheen. In the case of detection of contact with significant materials (visible sheen) BMPs are implemented based on an assessment of source and extent of significant material. The Terminal’s existing MPCA NPDES/SDS Industrial Stormwater permit (MN 0056472) incorporates some stormwater discharge requirements. In addition to the existing NPDES/SDS permit requirements, the Terminal will prepare a construction stormwater pollution prevention plan (SWPPP) for the Project as described in the MPCA’s general permit MNR 1000001 for construction stormwater. The SWPPP will describe the BMPs such as ditches, dikes and siltation fences that will be used to reduce the potential for pollutants to reach water bodies during construction of the tanks. As noted in the response to Item 10b, silt fencing and other BMPs will also be employed, as necessary, to prevent erosion and sedimentation discharges associated with the Project. Gravel and/or vegetation will be used to stabilize surfaces disturbed during construction activities. Most of the soil excavated from the construction area will be used as engineered backfill or for secondary containment structures.

iii. Water appropriation - Describe if the project proposes to appropriate surface or

groundwater (including dewatering). Describe the source, quantity, duration, use and purpose of the water use and if a DNR water appropriation permit is required. Describe any well abandonment. If connecting to an existing municipal water supply, identify the wells to be used as a water source and any effects on, or required expansion of, municipal water infrastructure. Discuss environmental effects from water appropriation, including


an assessment of the water resources available for appropriation. Identify any measures to avoid, minimize, or mitigate environmental effects from the water appropriation. The Project will require a one-time appropriation of approximately 12.6 million gallons (MG) of surface water to obtain the necessary hydrostatic test water for the new tanks. The Terminal will either use their existing water appropriations permit No. 1990-1207 or obtain a one-time water appropriation under the MDNR’s General Permit No. 1997-0005. The Terminal’s existing appropriations permit allows KPL to withdraw water from Steenerson Lake at a rate of 2,500 gallons per minute or 13.1 million gallons per year with a maximum daily volume of 600,000 gallons. Water use records for 2000-201213 indicate that no water has been appropriated under this permit since 2000. With no other water appropriations occurring under the permit at this time, there appears to be ample capacity to accommodate the water needs of the proposed Project within the existing appropriation limits. The existing water appropriation permit is included in Appendix 2 for reference.

The Project does not involve the installation or abandonment of any water wells or connection to or changes in any public water supply. While installation of water wells is not anticipated for this Project, in the unlikely event that adequate water for hydrotesting cannot be secured as anticipated from Steenerson Lake, one or more non-potable water wells may need to be installed. Any such wells would be installed only after appropriate regulatory approvals (MDNR appropriations) and in conformance with all the requirements of Minnesota water well codes.

iv. Surface Waters a) Wetlands - Describe any anticipated physical effects or alterations to wetland

features such as draining, filling, permanent inundation, dredging and vegetative removal. Discuss direct and indirect environmental effects from physical modification of wetlands, including the anticipated effects that any proposed wetland alterations may have to the host watershed. Identify measures to avoid (e.g., available alternatives that were considered), minimize, or mitigate environmental effects to wetlands. Discuss whether any required compensatory wetland mitigation for unavoidable wetland impacts will occur in the same minor or major watershed, and identify those probable locations. The Project will not involve the physical or hydrologic alteration (dredging, filling, stream diversion, outfall structure, diking, and/or impoundment) or modification of wetlands. The Project has been designed to avoid environmental effects to wetlands and compensatory wetland mitigation is not required. MPL will meet BMPs during construction, and will construct containment dikes designed to contain 110 percent of the volume of one tank or the tank volume plus sufficient freeboard to contain precipitation from the 25-year, 24-hour storm (about five inches), whichever was greater.

b) Other surface waters- Describe any anticipated physical effects or alterations to surface water features (lakes, streams, ponds, intermittent channels, county/judicial ditches) such as draining, filling, permanent inundation, dredging, diking, stream diversion, impoundment, aquatic plant removal and riparian alteration. Discuss direct and indirect environmental effects from physical

13 http://files.dnr.state.mn.us/waters/watermgmt_section/appropriations/index-number-active.pdf Clearbrook Tanks Project Environmental Assessment Leon Township, Clearwater County, Minnesota 15 Worksheet

modification of water features. Identify measures to avoid, minimize, or mitigate environmental effects to surface water features, including in-water Best Management Practices that are proposed to avoid or minimize turbidity/sedimentation while physically altering the water features. Discuss how the project will change the number or type of watercraft on any water body, including current and projected watercraft usage. The Project does not involve the physical or hydrologic alteration (dredging, filling, stream diversion, outfall structure, diking, and impoundment) of any surface waters. The unnamed tributary to Silver Creek to the west of the Project area will be protected during Project construction through the implementation of standard erosion control practices. In addition, as discussed in response to Item 12c, protection plans already in place including the Terminal’s Spill Prevention Control and Countermeasure Plan (SPCC) and Pipeline Hazardous Materials Safety Administration (PHMSA) Emergency Response Plan (ERP) will be updated to address this Project. There are no water bodies in the Project area; therefore, there is no current watercraft usage.

12. Contamination/Hazardous Materials/Wastes:

a. Pre-project site conditions - Describe existing contamination or potential environmental hazards on or in close proximity to the project site such as soil or ground water contamination, abandoned dumps, closed landfills, existing or abandoned storage tanks, and hazardous liquid or gas pipelines. Discuss any potential environmental effects from pre-project site conditions that would be caused or exacerbated by project construction and operation. Identify measures to avoid, minimize or mitigate adverse effects from existing contamination or potential environmental hazards. Include development of a Contingency Plan or Response Action Plan. The Clearbrook Terminal is subject to regulations issued by the United States Department of Transportation (DOT). The Terminal must comply with emergency response planning regulations found in 49 CFR 194. The planning requirements associated with the Terminal include worst case spill planning, contracting with spill response organizations, and providing plans/coordinating with local first responders. The Terminal also has prepared and must maintain a SPCC that meets the requirements of 40 CFR 112. The DOT response plan required by 49 CFR 194 contains spill planning requirements that parallel the MPCA spill planning requirements found in Minn. Stat. ch. 115E “Oil and Hazardous Substance Discharge Preparedness.” There are no known contamination issues associated with this site that would be exacerbated by this Project. The Terminal was constructed in 1954 and there have been releases within the existing footprint of the Terminal. However, these releases were remediated and determined not to pose a risk to receptors and have been closed with the MPCA. There are no known potential environmental hazards due to past site uses under or around the proposed new tank construction area. The Terminal has a Soils Management Plan which describes the response actions the Terminal will implement in the event impacted soils are discovered during construction. Should impacted soil be encountered, KPL will immediately notify the Minnesota State Duty Officer.


b. Project related generation/storage of solid wastes - Describe solid wastes generated/stored during construction and/or operation of the project. Indicate method of disposal. Discuss potential environmental effects from solid waste handling, storage and disposal. Identify measures to avoid, minimize or mitigate adverse effects from the generation/storage of solid waste including source reduction and recycling. Construction activities will generate some quantity of solid waste. This waste will include cardboard, plastic, and other packaging materials used to ship new equipment and supplies. Where possible, scrap steel, cardboard, and other materials will be recycled. It is expected that soils from site grading will be used in the construction of the new containment berm. All solid waste will be managed within the boundaries of the work site or existing Terminal until properly tested and characterized to determine the appropriate disposal method. Disposal methods for solid wastes that are determined to be not hazardous may include disposal at a local municipal solid waste land fill. Demolition debris or similar materials would be disposed of at a permitted industrial/demolition landfill. As indicated in response to Item 12d, any hazardous waste will be disposed of following MPCA hazardous waste regulations at a Resource Conservation and Recovery Act (RCRA) permitted hazardous waste Treatment, Storage, and Disposal Facility. Refer also to the response to Item 12d for a description of the wastes that could be generated in connection with the ongoing operation of the tanks.

c. Project related use/storage of hazardous materials - Describe chemicals/hazardous materials

used/stored during construction and/or operation of the project including method of storage. Indicate the number, location and size of any above or below ground tanks to store petroleum or other materials. Discuss potential environmental effects from accidental spill or release of hazardous materials. Identify measures to avoid, minimize or mitigate adverse effects from the use/storage of chemicals/hazardous materials including source reduction and recycling. Include development of a spill prevention plan. Primary measures to avoid, minimize, or mitigate adverse effects from the storage of chemicals/hazardous materials (i.e., crude oil) at the Terminal are described in detail in the PHMSA ERP written in accordance with 49 CFR 194. The PHMSA ERP is also intended to satisfy the requirements of the Oil Pollution Act of 1990 (OPA 90) and has been prepared in accordance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) as well as the U.S. Environmental Protection Agency (EPA) Region V Area Contingency Plan. In addition, the tanks will be designed and constructed to meet the same API standards as referenced in Minn. R. 7151.2100 “above ground storage of liquid substances” regulations. Specifically, the Terminal will provide:

· Secondary containment: New containment berms will be constructed for the new tanks, independent of the existing tank containment. The expected height of the new berms will range from approximately 10 feet to approximately 14.5 feet. Dikes will be designed to contain 110 percent of the volume of one tank or the tank volume plus sufficient freeboard to contain precipitation from the 25-year, 24-hour storm (about five inches), whichever was greater. Based on the geotechnical investigation, the clay materials at the bottom of the proposed containment area and extending more than 45 feet below the proposed grade excavation have very low permeability. These in-situ clay soils will be scarified and re-compacted to provide a low permeability liner. The soil will be covered with geotextile and four inches of aggregate surfacing. Percolation tests will be conducted after compaction to verify that the percolation rate meets 7151 permeability rates (1x10-7 centimeters/second) and the results will be certified by a


registered professional engineer. Minn. R. ch. 7151 establishes uniform performance standards and technical requirements for aboveground storage of liquid substances for the protection of the public health and the environment. Consistent with the intent to protect public health and the environment, the proposed secondary containment is aligned with the standards in Minn. R. ch. 7151 subpt. 5.

· Tank construction: The four field-erected tanks will be constructed to meet API Standards 620, 650, 651, 653. The tank floor will be designed with a release prevention barrier consistent with API 651 Appendix I, including a concrete ring wall with under tank leak detection and a geosynthetic clay liner (GCL).

· Labeling: Tanks will be labeled with the substance stored, capacity, and unique identification number.

· Corrosion protection: Corrosion protection will meet API Standard 651. · Overfill protection, monitoring (liquid levels in tanks): DOT 195.446 control room

management regulations and a Supervisory Control and Data Acquisition (SCADA) system will be used to prevent overfills and monitor tanks for leak detection.

· Maintenance: Maintenance will be conducted in accordance with API Standard 653 and maintenance program requirements of DOT 195 Subpart F. Generally, future API inspection will occur on a 10-20 year inspection cycle determined in accordance with inspector recommendations and API 653 Section 6.4.2.

During the earth moving phase of construction, it may be necessary for a contractor to stage a portable diesel fuel tank at the site. Such a tank would be limited to 1,000 gallons. Secondary containment will be permanently attached to the tank in the form of an integral dyke or a double-walled tank. Some temporary worksite heat may be provided using propane/liquefied petroleum. Propane will be stored in approved containers (limited to 1,000 gallons) in segregated areas with proper signage and fire prevention measures per Occupational Safety and Health Administration (OSHA) 1923.153. Similar methods will be applied to welding gasses. Any oils including fuels stored on site in support of construction activities will be covered by a SPCC plan. Contractors will be required to store any chemicals, paints, adhesives, welding supplies, etc., in trailers or other enclosed structures. All spills will be cleaned up immediately, properly packaged, and disposed in a MPCA approved permitted landfill. Releases to the environment will be reported to the state duty officer consistent with the measures in the Terminal’s SPCC Plan and PHMSA ERP. KPL will retain a qualified environmental professional for remediation of releases to the environment if such an event were ever to occur. Impacted soil will be properly tested and characterized to determine the appropriate disposal method. Disposal methods for soils and other solid wastes that are determined to be not hazardous may include disposal at a local municipal solid waste land fill. Any hazardous waste will be disposed of at a RCRA permitted hazardous waste Treatment, Storage, and Disposal Facility. Contractors will be required to recycle when appropriate and ensure all solid wastes are placed in dumpsters or other containers and properly disposed.

d. Project related generation/storage of hazardous wastes - Describe hazardous wastes

generated/stored during construction and/or operation of the project. Indicate method of disposal. Discuss potential environmental effects from hazardous waste handling, storage, and


disposal. Identify measures to avoid, minimize or mitigate adverse effects from the generation/storage of hazardous waste including source reduction and recycling. Hazardous wastes are not expected to be generated during construction. However, waste generated by the construction activities will be properly characterized prior to disposal. Any waste that is determined to be a hazardous waste will be packaged, accumulated, transported, and disposed of following MPCA hazardous waste regulations. Once the new tanks are operational, periodic waste streams will likely include tank bottoms and shell reconditioning blast media generated during API-653 tank inspection and maintenance. These wastes will also be properly characterized prior to disposal. Any waste that is determined to be a hazardous waste will be packaged, accumulated, transported, and disposed of following MPCA hazardous waste regulations.

13. Fish, wildlife, plant communities, and sensitive ecological resources (rare features): a. Describe fish and wildlife resources as well as habitats and vegetation on or in near the site.

Based on native plant community mapping from the MDNR/USGS ECS14, the proposed Project area lies within the Hardwood Hills Subsection of the Minnesota and Northeast Iowa Morainal Section (MIM).The Hardwood Hills subsection is generally typified by steep slopes, high hills and lakes formed in glacial end moraines and outwash plains. Presettlement vegetation within this subsection typically included maple-basswood forests interspersed with oak savannas, tallgrass prairies, and oak forests. However, much of this subsection is currently farmed or in pastured grasslands. The immediate Project area is currently dominated by cropland and grassland and bordered by narrow, deciduous shelterbelts.

There are no fisheries resources in the Project area. The MDNR Comprehensive Wildlife Conservation Strategy (CWCS) lists 85 Species of Greatest Conservation Need (SGCN) in the Hardwood Hills Subsection15. Nearly three-quarters of the SGCN species listed are birds. It is unlikely that most of the SGCN species listed for the subsection are present within the Project area on a regular basis. This is because approximately half of the listed SGCN species are wetland or aquatic habitat species, and would therefore not utilize the Project area. In addition, the Project area is immediately adjacent to a developed, industrial area. SGCN species tend to be sensitive to disturbance and habitat degradation16. Moreover, non-SGCN species (e.g., raccoons, opossums, brown-headed cowbirds and crows) are better able to utilize edge and disturbed habitats, and likely displace SGCN species in those areas. The vegetative cover within the proposed Project area may support some of the upland SGCN species, but most of the upland species would more likely utilize the wooded and open areas south of the Project site. SGCN species may utilize the wetland areas near the proposed

14 Minnesota Department of Natural Resources (MNDNR). 2005. Field Guide to the Native Plant Communities of Minnesota: the Eastern Broadleaf Forest Province. Ecological land Classification Program, Minnesota County Biological Survey, and Natural Heritage and Nongame Research Program. MDNR St. Paul, MN. 15 Minnesota Department of Natural Resources (MNDNR). 2006. Tomorrow’s Habitat for the Wild and Rare: An Action Plan for Minnesota Wildlife, Comprehensive Wildlife Conservation Strategy, Division of Ecological Services, Minnesota Department of Natural Resources. 16 Minnesota Department of Natural Resources (MNDNR). 2006. Tomorrow’s Habitat for the Wild and Rare: An Action Plan for Minnesota Wildlife, Comprehensive Wildlife Conservation Strategy, Division of Ecological Services, Minnesota Department of Natural Resources. Clearbrook Tanks Project Environmental Assessment Leon Township, Clearwater County, Minnesota 19 Worksheet

Project; however, the wetlands are also near human disturbance, which tends to reduce SGCN presence.

b. Describe rare features such as state-listed (endangered, threatened or special concern) species, native plant communities, Minnesota County Biological Survey Sites of Biodiversity Significance, and other sensitive ecological resources on or within close proximity to the site. Provide the license agreement number (LA-____) and/or correspondence number (ERDB _____________) from which the data were obtained and attach the Natural Heritage letter from the DNR. Indicate if any additional habitat or species survey work has been conducted within the site and describe the results. The MDNR Natural Heritage Information System (NHIS) was queried in April 2014 under MDNR license agreement number LA-501 to determine if known occurrences of rare, endangered, or special concern species or sensitive ecological habitats are present within or adjacent to the Clearbrook Terminal. Results of the NHIS query returned no records of known occurrences of threatened, endangered, or special concern species or sensitive ecological habitats within one mile of the proposed tank location. In addition to completing the NHIS, a consultation letter was sent to MDNR regarding rare features, including fens. Based on the NHIS review, it was determined that no rare features will be affected by the Project. The MDNR has indicated their concurrence with this assessment (Appendix 3). The U.S. Fish and Wildlife Service17 has documented records for two federally-protected species in Clearwater County. These are the federally-threatened Canada lynx (Lynx canadensis) and the proposed federally-endangered Northern long-eared bat (Myotis septentrionalis). Neither species would utilize the Project area as a primary habitat. Canada lynx has a large home range, and would likely avoid the industrialized areas immediately adjacent to the Project site. Northern long-eared bat would possibly utilize the forested areas south of the Project site in the summer; otherwise the Project area and immediate vicinity have no habitat value for Northern long-eared bat. Moreover, there are no documented records for either species within at least one mile of the Project area.

c. Discuss how the identified fish, wildlife, plant communities, rare features and ecosystems may be

affected by the project. Include a discussion on introduction and spread of invasive species from the project construction and operation. Separately discuss effects to known threatened and endangered species. The Project will be constructed on an area that is currently cropland and grassland. The Project will not result in loss of native wildlife habitat. No identified fish, wildlife, plant communities, rare features, or ecosystems will be affected by the Project. There will be no introduction and spread of invasive species from the Project construction and operation. No known threatened and endangered species reside within the Project site, or within at least one mile of the Project site.

d. Identify measures that will be taken to avoid, minimize, or mitigate adverse effects to fish,

wildlife, plant communities, and sensitive ecological resources. No direct adverse effects to fish, wildlife, plant communities, or sensitive ecological resources are anticipated. Aquatic habitat in the unnamed tributary to Silver Creek west of the Project

17 http://www.fws.gov/midwest/endangered/lists/minnesot-cty.html Clearbrook Tanks Project Environmental Assessment Leon Township, Clearwater County, Minnesota 20 Worksheet

area will be protected during Project construction through the implementation of standard erosion control practices.

14. Historic properties:

Describe any historic structures, archeological sites, and/or traditional cultural properties on or in close proximity to the site. Include: 1) historic designations, 2) known artifact areas, and 3) architectural features. Attach letter received from the State Historic Preservation Office (SHPO). Discuss any anticipated effects to historic properties during project construction and operation. Identify measures that will be taken to avoid, minimize, or mitigate adverse effects to historic properties. The Minnesota State Historic Preservation Office (SHPO) database was searched on April 4 2012, to generate a list of known archaeological sites and an inventory of known historic structures in the Project area and within a one-mile-buffer zone around the Project area. The outcomes of the Project area cultural resources search are summarized in Table 1, below. All of the sites were found outside the Project area, with the exception of site CE-LEN-003 (MN Pipeline Company Terminal historic property).The MPL Terminal historic property has no locational information in the Minnesota SHPO database and no file is available for this site at the Minnesota SHPO. It is possible the historic property is at the existing Clearbrook Terminal site. According to the SHPO database, the site has been inventoried but not nominated for inclusion in the National Register of Historic Places (NRHP). Based on this review of SHPO data, there are no indications that NRHP eligible historic properties are likely to be found in the Project area and no indication that known cultural resources will be affected by the proposed Project. If cultural resources are encountered during construction, KPL will cease construction and contact the SHPO for further evaluation.

Table 1. Archaeological and Historical Sites and Properties within One Mile of Project Area

Site Number/ Inventory Number

Type Cultural Affiliation

Component Stratigraphy

Current Use

Condition NRHP Notes

CE-CBC-001

House Historical 1910 – Northern MN Lumbering

Surface House in 1986

Good in 1986

Inventoried, and evaluated, not nominated

Local significance Report CE-86-1H*; not in Project area

CE-CBC-002

House Historical – Northern MN Lumbering


Good in 1986







Current Use


CE-CBC-003

House built by carpenter and mason Victor Shelquist and father and owned by VS

Historical 1921 – Northern MN Lumbering


Good in 1986



CE-CBC-004

House Historical 1910 – Northern MN Lumbering


Good in 1986



CE-CBC-005

Hotel Historical – Northern MN Lumbering

Surface Hotel-Café in 1986

Good in 1986



CE-CBC-006

Bank Historical – Northern MN Lumbering

Surface Bank in 1986

Good in 1986



CE-CBC-008

Warehouse Historical – Agricultural Development and Railroad Construction

Surface Storage in 1986

Fair in 1986 Inventoried, and evaluated, not nominated


CE-CBC-009

Clearbrook Co-op Elevator

Historical ca. 1916 – Agricultural Development and Railroad Construction

Surface Grain elevator in 1986

Fair in 1986 Inventoried, and evaluated, not nominated


CE-CBC-010

Clearbrook Train Station

Historical – Northern MN Lumbering

Surface Unknown in 1986

Fair in 1986 Considered Eligible


CE-CBC-011

Clearbrook Co-op Creamery

Historical – Agricultural Development and Railroad Construction

Surface Fertilizer plant in 1986

Good in 1986







Current Use


CE-CBC-012



Good in 1986



CE-CBC-013



Good in 1986



CE-CBC-014

House Historical Surface Unknown

Unknown Unknown No file at SHPO; in Clearbrook town and not in Project area

CE-CBC-015



CE-CBC-017



CE-CBC-018



CE-LEN-003

MN Pipeline Company Terminal (located south side of Co Rd 49

Historical Surface Unknown

Unknown Inventoried, not nominated

No file at SHPO, no legal location listed in SHPO database; possibly at the existing Clearbrook Terminal site

CE-LEN-005

Silver Creek Cemetery


Unknown Unknown No file at SHPO; not in Project area

CE-LEN-006

House and outbuilding


Unknown Unknown No file at SHPO; not in Project area

* Manuscript CE-86-1H: Barbara Hightower and Jeffery A. Hess, 1986. Clearwater County Historic Properties Survey

15. Visual: Describe any scenic views or vistas on or near the project site. Describe any project related visual effects such as vapor plumes or glare from intense lights. Discuss the potential visual effects from the project. Identify any measures to avoid, minimize, or mitigate visual effects.


The equipment for the proposed Project will have an industrial appearance consistent with the existing equipment at the Terminal. The new tanks will be 196 feet in diameter and 56 feet high, and will have foundations that extend below the ground surface. The tank heights and widths are commensurate with two of the tanks already in operation. The new tanks will be over 0.3 mile from the nearest residence, and ~200 feet closer to the nearest residence than the nearest existing tank. While the Project components will introduce new visual elements to the west of the existing Terminal, these Project components are visually consistent with the tanks and equipment currently located at the Terminal and therefore would not significantly alter the viewshed in the area.

There are no scenic vistas on or near the Terminal property which require special attention with regard to adverse visual impacts.

16. Air:

a. Stationary source emissions - Describe the type, sources, quantities and compositions of any emissions from stationary sources such as boilers or exhaust stacks. Include any hazardous air pollutants, criteria pollutants, and any greenhouse gases. Discuss effects to air quality including any sensitive receptors, human health or applicable regulatory criteria. Include a discussion of any methods used assess the project’s effect on air quality and the results of that assessment. Identify pollution control equipment and other measures that will be taken to avoid, minimize, or mitigate adverse effects from stationary source emissions. Air emissions from the operation of the Clearbrook Terminal are primarily comprised of VOC and hazardous air pollutants (HAP), and a nominal amount of greenhouse gas emissions (GHG) and particulate matter (PM) emissions from the unpaved roads. The emission sources are organized as follows:

· Tank standing and withdrawal emissions (VOC, HAP and GHG). · Tank roof landing and cleaning emissions (VOC and HAP). · Roadway emissions (PM).

Air emissions from the additional four tanks will be of the same type, source and composition as the existing air emissions sources at the Clearbrook Terminal, with emissions from the tanks primarily comprised of VOCs. Future actual VOC emissions after the Project is completed are estimated at the high end to be 61.89 tons per year, an increase relative to estimated annual average actual emissions of 36.97 tons of VOC per year for 2012-201318. The Clearbrook Terminal currently operates under an Option A Registration Permit, but because actual emissions of VOC and other pollutants will not exceed major source thresholds after construction of the new tanks, KPL has elected to apply for and operate in accordance with a Minnesota Capped Emissions Permit (Option 2). Although the Clearbrook Terminal actual emissions are expected to increase as a result of construction of the new tanks, the permit emission limits under which the entire Terminal will operate will become more restrictive under the new Capped Permit. Specifically, the Capped Emissions Permit shall limit station VOC emissions to 85 tons per year, which is less than the 100 tons per year limit in the Clearbrook Terminal’s current Option A Registration Permit.

18 For 2013 Actual VOC emissions were 20.91 tons per year. For 2012, actual VOC emissions were 53.02 tpy; the higher emissions level is primarily due to tank cleaning and inspection activities.


The estimated future actual emissions (61.89 tons per year) and the capped (limited) emissions (85 tons per year) are well below the major source permit threshold (100 tons per year) and the mandatory EAW trigger for air emissions generation (250 tons per year). Additionally, the Project is subject to the capped emissions permit approval process which, per Part 7007.1148 of the state rules, requires a facility to conduct an ambient air quality assessment when demonstrating initial eligibility for a capped permit. The Terminal emits only insignificant levels of PM10, NOx, and SO2, which are the pollutants subject to these ambient air quality assessment modeling requirements. There is no requirement to model VOC emissions because, as discussed in more detail below, individual source impacts cannot practically be modeled given the regional transport nature of potential ozone impacts related to those emissions. The potential to emit from the Terminal following the Project will be less than the current potential to emit due to installation of emissions controls at the new tanks and issuance of the capped permit. Appendix 4 provides a process flow diagram of site operations. Air Emission Permitting The Clearbrook Terminal is currently permitted as a minor source under state air quality regulations and operates under an Air Emissions Option A Registration Permit. Appendix 5 provides the current air permit for the site. As part of the Project, KPL proposes to add the following units shown in Table 2, each of which has an estimated potential to emit of less than 1.93 tons per year VOCs when storing crude oil year-round:

Table 2. Proposed New Air Emission Units, Potential VOC Emissions and Control Equipment

Emission Unit Potential VOC Emissions (tpy)

Control Equipment

Storage Tank 12 (300,000 bbl capacity)

1.93 External floating roof, with dual seals and guide-pole controls







The addition of these units would result in increased criteria pollutant emissions, mostly VOC emissions from the tanks themselves, as well as insignificant levels of fugitive emissions from additional piping components (e.g. valves, flanges and connectors), and pumps. Actual 2013 emissions from the Clearbrook Terminal are summarized in Tables 3 and 4 below. The estimated future actual Terminal emissions after the proposed Project are summarized in Tables 5 and 6 below. Actual emissions from the facility before and projected actual emissions after the Project are below major source thresholds.


Table 3. Criteria Pollutant 2013 Actual Emission Summary

NOX SOX CO VOC PM(1) CO2e (tons) (tons) (tons) (tons) (tons) (tons) Storage Tanks - - - 20.91 - 343 Roof Landings(2) - - - - - - Tank Cleanings(2) - - - - - -

Roadways - - - - 18.29 - Total 0 0 0 20.91 18.29 343 1. All PM assumed to be PM10 and PM2.5. 2. There were no tank roof landings or tank cleanings in 2013. For 2012, actual VOC emissions were 53.02

tpy; the higher emissions level is primarily due to tank cleaning and inspection activities.

Table 4. HAP 2013 Actual Emission Summary Storage Tanks Roof Landings Tank Cleanings (tons) (tons) (tons) Benzene 0.13 - - Biphenyl 0.01 - - Cumene 0.02 - - Ethylbenzene 0.07 - - Hexane 0.64 - - Isooctane 0.02 - - Mercury 9.55E-05 - - Naphthalene 0.03 - - Phenol 0.05 - - Toluene 0.17 - - Xylenes 0.23 - - Max Single HAP(1) 0.64 Total HAP 1.43

1. Max single HAP = Hexane. 2. There were no tank roof landings or tank cleanings in 2013. Table 5. Future Actual Criteria Pollutant Emissions Summary

NOX SOX CO VOC PM(1) CO2e (tons) (tons) (tons) (tons) (tons) (tons) Storage Tanks - - - 22.57 - 346 Roof Landings - - - 5.04 - - Tank Cleanings - - - 34.28 - -

Roadways - - - - 18.29 - Total - - - 61.89 18.29 346 1. All PM assumed to be PM10 and PM2.5.


Table 6. Future Actual HAP Emissions Summary

Storage Tanks Roof Landings Tank Cleanings (tons) (tons) (tons) Benzene 0.14 0.03 0.22 Biphenyl 0.01 3.83E-07 2.60E-06 Cumene 0.02 1.83E-04 1.25E-03 Ethylbenzene 0.06 1.68E-03 1.14E-02 Hexane 0.72 0.23 1.56 Isooctane 0.02 2.73E-03 1.86E-02 Mercury 8.96E-05 2.69E-10 1.83E-09 Naphthalene 0.03 1.43E-05 9.72E-05 Phenol 0.05 2.41E-05 1.64E-04 Toluene 0.17 1.44E-02 0.10 Xylenes 0.22 5.14E-03 0.03 Max Single HAP(1) 2.51

Total HAP 3.67 1. Max single HAP = Hexane.

As noted above, the Clearbrook Terminal currently operates under an Option A Registration Permit. Because actual emissions of VOC and other pollutants will not exceed major source thresholds after construction of the new tanks, KPL has elected to apply for and operate in accordance with a Minnesota Capped Permit (Option 2). Tables 5 and 6 show that future actual emissions from operation of the Clearbrook Terminal with the additional units are within Capped Permit Option 2 emission thresholds. Because KPL has elected to operate in accordance with a Minnesota Capped Permit, the Terminal-wide potential to emit for VOC and other regulated pollutants are effectively restricted to levels less than those under the current air permit. Table 7 below compares the existing Registration Permit to the Capped Permit emission limits.

Table 7. Existing Registration Permit and Future Capped Permit Emission Limits

Pollutant Current Option A Registration Permit Limits (tpy)

Capped Permit Option 2 Permit Limits (tpy)

Hazardous Air Pollutants – Singe HAPs

10 8.0

Hazardous Air Pollutants – Total Combined HAP

25 20

PM 100 75 PM-10 100 75 VOC 100 85 SO2 100 90 NOx 100 85 CO 100 85 CO2e 100,000 85,000


Prevention of Significant Deterioration (PSD) The Terminal is a minor source under federal PSD regulations in 40 CFR 52.21 because its facility-wide limited PTE is and will remain less than 100 tons per year (TPY) for any criteria pollutants. New Source Performance Standards (NSPS) The proposed tanks are subject to NSPS, specifically 40 CFR Part 60, subpart Kb. As such, they will be equipped with controls as described in the paragraph marked “Tanks,” below. National Emission Standards for Hazardous Air Pollutants (NESHAPs) The Terminal is and will remain a minor source for HAPs. The proposed Project does not exceed any NESHAPs emissions thresholds and therefore no NESHAPS apply to the proposed Project. Tanks The tanks will be constructed with the controls which meet the emission control requirements specified in 40 CFR 60 Subpart Kb. These emission controls include an external floating roof equipped with dual rim-seals, guide-poles equipped “no-visible gap” controls, and gaskets and bolts on other appurtenances as required by the regulation. Fugitive Sources The Terminal is not subject to regulatory driven fugitive source monitoring requirements. Fugitive emissions from piping components will be controlled by KPLs preventative maintenance program which is designed to ensure that leaks are detected and repaired in a timely manner. Air Modeling The Project is subject to the capped emissions permit approval process which per Minn. R. 7007.1148 requires a facility to conduct an ambient air quality assessment when demonstrating initial eligibility for a capped permit. The Terminal does not operate any emission units that are subject to the ambient air quality assessment modeling requirements. As indicated above, actual emissions after the Project are below major source thresholds and any mandatory EAW triggers for air emissions. The capped emissions permit, Option 2, limits the actual emissions at the Terminal to 85 tons per year volatile organic compounds, 20 tons per year for HAPs, 75 tons per year PM, and 85,000 tons per year CO2e. The maximum amounts estimated for VOCs and HAPs are 69.53 tons per year and 4.18 tons per year, respectively. The Terminal is and will remain a minor source for HAPs. The Project will primarily result in increased VOC emissions and small amounts of HAPs from the tanks and associated piping equipment used to transfer the crude oil to and from pipelines. VOCs are regulated by the EPA as precursors to ozone formation. Ozone is a photochemical pollutant that is not generally emitted directly from sources, but is a secondary pollutant created through complex reactions, primarily from VOCs and oxides of nitrogen (NOx). This complex chemistry is well understood but has historically presented significant challenges to the designation of particular models for assessing the impacts of individual stationary sources for the formation of this pollutant. Since formation of ozone takes place over tens to hundreds of kilometers downwind from sources, regional models have been developed to simulate ozone levels over large areas. These models have worked well and have been used to develop


strategies for reducing VOCs and NOx in order to attain the ozone ambient air quality standards. Emissions from individual sources have not shown any impact in these regional models. As indicated above, actual emissions after the Project are well below major source thresholds and any mandatory EAW triggers for air emissions. The Capped Emissions Permit, Option 2, will allow for Terminal emissions that are higher than the 2013 actual emissions (85 tons per year VOC, 20 tons per year for combined HAPs, 75 tons per year PM, and 85,000 tons per year CO2e); however, KPL estimates the future actual VOC and HAPs to be 61.89 and 3.67 tons per year, respectively. The Terminal is and will remain an area source for HAPs. Based on the regulatory and policy judgment reflected in these thresholds, from an air standpoint, the proposed Project does not have the potential for significant environmental effects. The Project will primarily result in an incremental increase in VOC emissions with nominal emissions of GHG and PM and as a result, a criteria pollutant air assessment is not required for the project.

b. Vehicle emissions - Describe the effect of the project’s traffic generation on air emissions. Discuss the project’s vehicle-related emissions effect on air quality. Identify measures (e.g. traffic operational improvements, diesel idling minimization plan) that will be taken to minimize or mitigate vehicle-related emissions. Vehicle related air emissions are included in the analysis described in Item 16(a). Construction traffic related to the delivery of building supplies and the hauling offsite of excess soil will temporarily increase traffic during construction by approximately 80 vehicle trips per day on average. These trips will be spaced out through the day and are not expected to have an effect on peak hour traffic. To minimize vehicle emissions, KPL will encourage its contractors to adopt the following measures:

· Ensure that diesel-powered equipment is properly maintained and shut off when not in use;

· Prohibit engine tampering to increase horsepower; · Use ultra-low sulfur diesel fuel for their equipment if it is available for purchase within a

reasonable distance to the construction locations; · Minimize, to the extent practical, construction-related trips of workers and equipment;

and · Where practical, use newer model year equipment and vehicles.

c. Dust and odors - Describe sources, characteristics, duration, quantities, and intensity of dust

and odors generated during project construction and operation. (Fugitive dust may be discussed under item 16a). Discuss the effect of dust and odors in the vicinity of the project including nearby sensitive receptors and quality of life. Identify measures that will be taken to minimize or mitigate the effects of dust and odors. The proposed Project equipment and operations are consistent with current conditions at the Terminal, so no new odor impacts will be introduced by the Project. During normal operations the existing Terminal generates minimal odor. Existing tanks have a number of features (including mechanical seals, stilling wells and vapor seals) in place that minimize the potential for oil carryover (oil transfer to the sides of the tank and above the floating roof), thereby minimizing odor impacts. The proposed project will not noticeably change the existing odor profile at the Terminal.


No dust impacts are expected as a result of operations since the tanks themselves do not generate dust and no permanent traffic impacts are expected as a result of the Project. Construction of the Project will generate dust during site grading and preparation. However, no impacts to quality of life are anticipated as any fugitive dust emissions from construction activities would be minimized through control measures. These controls include watering or applying dust suppressants. These may be applied to exposed soil surfaces and unpaved roads.

17. Noise

Describe sources, characteristics, duration, quantities, and intensity of noise generated during project construction and operation. Discuss the effect of noise in the vicinity of the project including 1) existing noise levels/sources in the area, 2) nearby sensitive receptors, 3) conformance to state noise standards, and 4) quality of life. Identify measures that will be taken to minimize or mitigate the effects of noise. Existing noise levels at the site are typical for a pipeline terminal with breakout tanks. Noise is generated primarily by pumps at the site. Other notable noise sources in the area include traffic noise from Minnesota Highway 92. The nearest residential receptor is located west of the Terminal off of Minnesota Highway 92. Neither Leon Township nor Clearwater County has noise ordinances or permitting requirements. However, no existing issues with noise at nearby residential areas have been identified. The addition of tanks at the existing Terminal will have a negligible impact on the existing sound profile in the area. Construction of the Project will generate noise during site grading and preparation as well as tank construction. Any construction related effects on noise, however, will be short term, temporary effects and are expected to be minor. Construction will take place during daylight hours to minimize or mitigate the effects of construction noise. No impacts to quality of life in the area are anticipated.

18. Transportation

a. Describe traffic-related aspects of project construction and operation. Include: 1) existing and proposed additional parking spaces, 2) estimated total average daily traffic generated, 3) estimated maximum peak hour traffic generated and time of occurrence, 4) indicate source of trip generation rates used in the estimates, and 5) availability of transit and/or other alternative transportation modes. No additional permanent parking spaces will be added at the Terminal as a result of the proposed Project. Temporary staging space for contractors will be necessary during construction of the Project. Operation of the Project will not cause a change in existing traffic at the Terminal. Construction traffic related to the delivery of building supplies and the hauling of fill materials will temporarily increase traffic during construction by approximately 80 vehicle trips per day on average. These trips will be spaced out through the day and are not expected to have an effect on peak-hour traffic.


b. Discuss the effect 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. 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. Use the format and procedures described in the Minnesota Department of Transportation’s Access Management Manual, Chapter 5 (available at: http://www.dot.state.mn.us/accessmanagement/resources.html) or a similar local guidance, Operation of the proposed Project will not generate any new permanent traffic. Therefore, there will be no permanent impacts to traffic congestion or to the function of the regional transportation system. Construction activities discussed above are expected to contribute primarily to traffic on Minnesota Highway 92, located west of the Terminal and CSAH 49, located north of the Terminal. Average annual daily traffic volume information available for 2011 from the Minnesota Department of Transportation (MnDOT)19 indicates that the relevant sections of Minnesota Highway 92 and CSAH 49 have average daily traffic (AADT) volumes of 2,300 and 175, respectively. Relative to 2011 AADT volumes, construction impacts would represent a relatively minor increase in traffic on Minnesota Highway 92. While construction traffic would increase traffic on CSAH 49 by approximately 50 percent, the effects would be limited to the construction period. Because peak hour traffic generated does not exceed 250 vehicles and the total daily trips do not exceed 2,500, a traffic impact study is not required.

c. Identify measures that will be taken to minimize or mitigate project related transportation effects.

19. Cumulative potential effects: (Preparers can leave this item blank if cumulative potential effects

are addressed under the applicable EAW Items) a. Describe the geographic scales and timeframes of the project related environmental effects

that could combine with other environmental effects resulting in cumulative potential effects. Minn. R. pt. 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. Cumulative potential effects result when impacts associated with the proposed Project are combined with impacts associated with past, present, or reasonably foreseeable future projects within the area affected by the proposed Project. Analysis of cumulative potential effects accounts for the possibility that, added together, the minor impacts of many separate projects may be significant. This cumulative potential effects analysis considers resources that are expected to be impacted by the proposed Project and assesses past, present, and reasonably foreseeable projects to identify any geographic and temporal overlap in impacts. For past projects, Minn. R. 4410.0200, subp. 11a states that “it is sufficient to consider the current aggregate effects of past actions.” In most cases, the existing conditions in the environmentally relevant area provide an equivalent representation of the past actions.

19 http://www.dot.state.mn.us/traffic/data/maps/trunkhighway/2011/counties/clearwater2.pdf Clearbrook Tanks Project Environmental Assessment Leon Township, Clearwater County, Minnesota 31 Worksheet

This Project’s main potential environmental effect evaluated is an increase in permitted air emissions (primarily VOCs and HAPs). Other potential environmental effects from the Project include: minor impacts to stormwater, minor visual effects; risk associated with hazardous material storage; minor, temporary impacts to wastewater and water appropriations; and minor, short-term construction-related air, stormwater, and noise impacts. The environmentally relevant area for evaluating cumulative potential effects varies in size depending on the types of resources and potential impacts being considered. Air quality impacts associated with the Project, for example, may extend somewhat beyond the immediate Project area. Other potential impacts from the proposed Project have been identified and are more geographically concentrated in the immediate vicinity of the Project. The timeframe of potential impacts from the proposed Project ranges from short-term temporary construction related impacts to longer term potential impacts to air quality. The table below summarizes the relevant geographic and temporal scale of potential impacts from the Project as well as the expected magnitude and nature of these impacts.

Resource/Impact Timescale Geographic Area of Impact Nature/Extent of Project Impacts

Construction Noise Short term, temporary

Immediate Project vicinity Minor; no local residences or other receptors

Construction Stormwater

Short term, temporary

Immediate Project vicinity Minor; managed via implementation of BMPs

Wastewater Short term, temporary

Project vicinity/Clearwater River watershed

Minor; one time hydrostatic test water disposal

Water appropriation Short term temporary

Nearby waterbody Minor; one time appropriation managed under existing permit

Air Quality (construction related impacts)

Short term, temporary

Project vicinity/airshed conservatively estimated to include 1 mile radius around property

Minor fugitive dust; managed via implementation of BMPs

Air Quality (Project operation related impacts)

Long term/Project life

Project vicinity/airshed conservatively estimated to include 1 mile radius around property

Minor; after construction the Terminal will operate within Capped permit emissions limits

Stormwater Long term/Project life

Project vicinity/Clearwater River watershed

Minor, small increase in impervious area, managed under existing NPDES permit

Risk associated with hazardous material storage

Long term/Project life

Immediate Project vicinity Minor; managed under existing PHMSA ERP and SPCC plan

Visual effects Long term/Project life

Project vicinity Minor


Other projects There is an existing Enbridge terminal located adjacent north-northeast of the Project. Enbridge also stores crude oil at their facility, and has additional plans to field-erect (2) 150,000 barrel external floating roof crude oil tanks and a new pump station at their facility. There is a potential for cumulative effects in air quality with the additional crude oil tank construction.

b. Describe any reasonably foreseeable future projects (for which a basis of expectation has

been laid) that may interact with environmental effects of the proposed project within the geographic scales and timeframes identified above. To ensure a complete review of cumulative potential effects, KPL also has undertaken efforts to identify other potential future projects in the relevant geographic area by contacting the MPCA. Portions of the identified projects could be located within approximately 1.0 miles of the Clearbrook Terminal. These projects were evaluated based upon information in publicly available documents and information obtained from MPCA. No plans for future growth have been identified by the local units of government in the Project area. Other construction projects There are three additional projects proposed by Enbridge that could have some impact in the environmentally relevant area. These projects have been publicly announced. Enbridge Line 67 Project According to publicly available documents, the Enbridge Line 67 Upgrade involves increasing capacity on Line 67 (formally referred to as the 'Alberta Clipper project'). Phase I involves the addition of pumping horsepower and crude oil tanks at existing sites with no pipeline construction. New pumping units, including valves and appurtenances, will be installed at pump stations in Viking, Clearbrook and Deer River, Minnesota. Line 67 terminates at Enbridge's terminal in Superior, Wisconsin, where additional oil storage tanks will also be constructed. Phase II of the Line 67 project will involve the construction of pump stations and associated equipment adjacent to or near Enbridge facilities on property that is owned or acquired in fee by Enbridge. Enbridge submitted its application for the Phase I expansion project to the National Energy Board in October 2012 and received approval in February 2013. Construction began in June 2013, and anticipated construction completion and in-service timing is mid-2014. The Phase II project Certificate of Need is currently under review by the MPUC. Based on information available in Enbridge’s Line 67 project Certificate of Need application, Phase II of the Line 67 project will require minimal physical modification of Enbridge’s Clearbrook terminal, but will not require expansion of the existing footprint. Thus, potential impacts are anticipated to be primarily related to minor increases in air emissions associated with increased throughput. As with the projects described below, potential impacts to other media would be minor and highly localized. Potential impacts related to construction such as noise, stormwater, and traffic would be temporary. In addition, KPL has designed the Project to avoid any impact to wetlands; therefore, there is no need to consider the potential impacts the Enbridge project may have on wetlands Enbridge Sandpiper Project According to publicly available documents, Enbridge is proposing to build the Sandpiper Pipeline project – an approximately 610-mile interstate crude oil pipeline originating at its Beaver Lodge Station south of Tioga, North Dakota. The project is expected to bring North Dakota crude oil to Clearbrook, and from there, to another existing terminal owned by Enbridge in Superior,


Wisconsin. From Superior, the oil will be transported by Enbridge through other interconnected pipelines to refinery hubs in the United States and eastern Canada. The Sandpiper project is currently in the planning and permitting phase and the current proposed route includes Enbridge’s Clearbrook Terminal, where two additional above ground storage tanks will be constructed. Target construction timeframe for the project is late 2014 to 2016. Potential environmental impacts from the project are likely to be similar to any linear corridor construction project. In the vicinity of the Clearbrook Terminal these potential impacts could include short term temporary construction related impacts to noise, stormwater, and traffic. Longer term impacts may include minor increases in air emissions. Enbridge Line 3 Replacement Project Enbridge is proposing to replace its Line 3 pipeline which runs from Hardisty, Alberta to Superior, Wisconsin. Enbridge’s Clearbrook Terminal is located along this route. A new 36-inch pipeline will replace the existing 34-inch pipeline along most of the Line 3 route from Neche, North Dakota to Superior, Wisconsin. Segments of Line 3 from the Canadian border to Neche and near the Minnesota/Wisconsin border to the Superior terminal are being replaced under separate segment replacement projects. Enbridge is proposing to route Line 3 in the same corridor as the Sandpiper pipeline. Enbridge indicates that the Line 3 replacement project is intended to improve safety, reduce future maintenance activities, and restore delivery capacity. After the replacement pipeline is built, the existing Line 3 pipeline will be deactivated according to federal regulations. The Line 3 replacement project is currently in the planning and permitting phase, with a target construction start date of late 2015/early 2016. In the vicinity of MPL’s Clearbrook Terminal potential impacts from Enbridge’s Line 3 Replacement project could include short term temporary construction related impacts to noise, stormwater, and traffic. The three projects described above involve pipeline construction or upgrades. The primary impact from those projects on the Clearbrook Terminal Project include potential temporary increases in air emissions in the environmentally relevant area around the Clearbrook Terminal during construction and long-term increases in air emissions potentially related to the operation of tanks and pump stations. The potential environmental effects resulting from the addition of the four tanks and related equipment as described above are not significant. The Project's main potential environmental effects would be an increase in permitted air emissions (primarily VOCs and HAPs). KPL qualifies for a capped permit and will operate the Terminal, including the new tanks, within the limitations set forth in Section 16 above. Any impact from air emissions would be localized and limited to the Clearbrook Terminal and immediate surrounding area. As described above in Table 3, the 2013 actual VOC emissions for the Clearbrook Terminal were 20.91 tons. Enbridge operates a crude oil terminal just north of the Clearbrook Terminal. MPCA’s emission inventory website20 indicates that Enbridge’s 2012 VOC emissions were 46.23 tons. Understanding the regional transport nature of ozone generation due to VOC emissions, the cumulative emissions from both the KPL and Enbridge terminals are negligible in comparison to state-wide actual VOC emissions from stationary sources.

20 http://www.pca.state.mn.us/index.php/air/air-monitoring-and-reporting/air-emissions-modeling-and-monitoring/criteria-air-pollutant-emission-inventory/facility-actual-emissions-data.html Clearbrook Tanks Project Environmental Assessment Leon Township, Clearwater County, Minnesota 34 Worksheet

In addition, as part of the Sandpiper Pipeline project, Enbridge is proposing to construct a new pump station and tanks at a new terminal approximately 3.8 miles west of their existing Clearbrook terminal. Due to the distance separating the existing KPL Terminal from the proposed tank addition at the Enbridge terminal, the long-range transport nature of VOC emissions impacts, and the relatively small level of emissions from both sources, there will be no significant cumulative effect from the proposed projects. For non-air items, potential environmental impacts would primarily be related to short term construction impacts at the existing facility and a minor, one-time water appropriation under an existing permit. These temporary potential impacts are negligible. Also, there are no residences or other receptors in the immediate area that would be impacted by temporary construction activity. The character and type of stormwater would not change and any increase in volume would not be significant, since stormwater will be managed via a detention pond. The potential visual impact of the four new tanks would be insignificant given this is an existing Terminal with 11 above-ground tanks and there have been tanks at this location for over 50 years. Any potential risk associated with above-ground hazardous material storage would be addressed through procedures as outlined in the station’s Emergency Response Plan and SPCC plan. Therefore any potential long-term environmental impacts from the Project are not significant.

c. Discuss 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. The Project's main potential environmental effects would be an increase in permitted air emissions (primarily VOCs and HAPs). KPL qualifies for a capped permit and will operate the Terminal, including the new tanks, within the limitations set forth in Section 16 above. Any impact from air emissions would be localized and limited to the Clearbrook Terminal and immediate surrounding area. For non-air items, potential environmental impacts would primarily be related to short term construction impacts at the existing Terminal and a minor, one-time water appropriation under an existing permit. Also, there are no residences or other receptors in the immediate area that would be impacted by temporary construction activity. The character and type of stormwater would not change and any increase in volume would not be significant, since stormwater will be managed via a detention pond. The potential visual impact of the four new tanks would be insignificant given this is an existing Terminal with 11 above-ground tanks and there have been tanks at this location for over 50 years. Any potential risk associated with above-ground hazardous material storage would be addressed through procedures as outlined in the Terminal’s Emergency Response Plan and SPCC plan. Therefore any potential long-term environmental impacts from the Project are not significant.


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SITE MAPLAND COVERKoch Pipeline

Clearwater County, MN

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Land Cover TypeCropland

Existing Facility

Brush/Grassland

Impervious Surface

Deep Water/Streams

Wetland

Wooded/Forest

Property Boundary

Site Boundary

Imagery: NAIP 2010

Figure 5

SITE MAPSOILS


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Farmland ClassificationNot prime farmland

All areas are prime farmland

Prime farmland if drained

Farmland of statewide importance

Soil Map Unit NameBraham loamy fine sand, 2 to 8 percent slopes

Bullwinkle muck

Cathro muck

Eckvoll loamy fine sand

Fordum, Fairdale, and Lamoure soils, frequently flooded

Gonvick loam

Hamre muck

Hangaard sandy loam

Karlstad sandy loam

Kratka fine sandy loam

Linveldt fine sandy loam

Mooselake and Lupton soils

Naytahwaush loam, 15 to 30 percent slopes

Roliss loam

Smiley loam

Sugarbush loamy sand, 1 to 8 percent slopes

Water

Waukon loam, 12 to 20 percent slopes, eroded

Waukon loam, 2 to 6 percent slopes

Waukon loam, 6 to 12 percent slopes, eroded

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SITE MAPWATER RESOURCES


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!> Wells - County Well Index

Property Boundary

Site Boundary

Shoreland Management Area

Rivers and Streams

Delineated Wetland

Wetlands (National Wetlands Inventory)Freshwater Emergent Wetland

Freshwater Forested/Shrub Wetland

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Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS,AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community

Holm's Well Co. 15398 HOLM, D License Business Name Lic. Or Reg. No. Name of Driller

Geological Material Color Hardness From To CLAY RED SOFT 0 36 CLAY GRAY SOFT 36 47 SAND & GRAVEL BROWN HARD 47 51

Drilling Fluid --

Well Hydrofractured? Yes No From Ft. to Ft.

Use Domestic

Casing Type Joint No Information Drive Shoe? Yes No Above/Below 1 ft.

Casing Diameter Weight Hole Diameter

3 in. to 42 ft. 7.7 lbs./ft.

Open Hole from ft. to ft. Screen YES Make JOHNSON Type stainless steel

Diameter Slot/Gauze Length Set Between 2 4 47 ft. and 51 ft.

Static Water Level 31 ft. from Land surface Date Measured 07/21/1979 PUMPING LEVEL (below land surface) ft. after hrs. pumping g.p.m.

Well Head Completion Pitless adapter manufacturer Model

Casing Protection 12 in. above grade

At-grade (Environmental Wells and Borings ONLY) R E M A R K S

VILLAGE OF CLEARBROOK SLOT/GAUZE 10/60

Located by: Method: GPS SA On (averaged)

Unique Number Verification: Info/GPS from data source Input Date: 12/22/1999

System: UTM - Nad83, Zone15, Meters X: 318812 Y: 5283998

Grouting Information Well Grouted? Yes No

Nearest Known Source of Contamination feet direction type

Well disinfected upon completion? Yes No

Pump Not Installed Date Installed Manufacturer's name Model number HP Volts Length of drop Pipe ft. Capacity g.p.m Type Material

First Bedrock Last Strat

AquiferDepth to Bedrock ft.

Abandoned Wells Does property have any not in use and not sealed well(s)?

Yes No

Variance Was a variance granted from the MDH for this well? Yes No Well Contractor Certification

County Well Index Online Report 128544 Printed 2/25/2014HE-01205-07

Minnesota Unique Well No.

128544County ClearwaterQuad ClearbrookQuad ID 331B

MINNESOTA DEPARTMENT OF HEALTH

WELL AND BORING RECORD

Minnesota Statutes Chapter 103I

Entry Date 04/07/1988Update Date 02/14/2014Received Date

Well Name MINNESOTA PIPELINE Township Range Dir Section Subsections Elevation 1342 ft.

149 37 W 29 CDB Elevation MethodCalc from DEM (USGS 7.5 min or equiv.)

Well Depth Depth Completed Date Well Completed

51 ft. 51 ft. 07/21/1979

Drilling Method Jetted

Page 1 of 1Well Log Report - 00128544

2/25/2014http://mdh-agua.health.state.mn.us/cwi/well_log.asp?wellid=128544

APPENDIX 1

Renner E.H. Well 71015 COX, A License Business Name Lic. Or Reg. No. Name of Driller

Geological Material Color Hardness From To CLAY GRAY 0 22 CLAY GRAY 22 26 CLAY GRAY 26 45 GRAVEL GRAY 45 55 GRAVEL/COBBLES GRAY 55 58 SAND GRAY 58 63 SILTY SAND BROWN 63 75 SILTY SAND/CLAY BROWN 75

Drilling Fluid Water


Use Industrial

Casing Type Plastic Joint Welded Drive Shoe? Yes No Above/Below ft.


14 in. to 38 ft. 54.6 lbs./ft.

8 in. to 48 ft. 49.6 lbs./ft. Open Hole from ft. to ft. Screen YES Make JOHNSON Type stainless steel

Diameter Slot/Gauze Length Set Between 7.5 30 15 45 ft. and 60 ft.

Static Water Level 15 ft. from Land surface Date Measured 08/01/1990 PUMPING LEVEL (below land surface) 46 ft. after 180 hrs. pumping 90 g.p.m.



At-grade (Environmental Wells and Borings ONLY) R E M A R K S

HEIGHT ABOVE/BELOW: 14"-2, 3-8" WORK PERFORMED UNDER ENGINEERING OF E.HICKOK OF J.MONTGOMERY.

Located by: Method: GPS SA On (averaged)

Unique Number Verification: Info/GPS from data source Input Date: 12/22/1999

System: UTM - Nad83, Zone15, Meters X: 319094 Y: 5284301


Grout Material: Neat Cement from 0 to 43 ft. 25 bags

Nearest Known Source of Contamination feet direction type



First Bedrock Last Strat

AquiferDepth to Bedrock ft.


Yes No









Well Name MN PIPELINE COMPANY Township Range Dir Section Subsections Elevation 1350 ft.

149 37 W 29 Elevation MethodCalc from DEM (USGS 7.5 min or equiv.)


75 ft. 60 ft. 08/08/1990

Drilling Method Cable Tool









Well Name MN PIPELINE CO. Township Range Dir Section Subsections Elevation 1350 ft.

149 37 W 32 AAA Elevation MethodCalc from DEM (USGS 7.5 min or equiv.)


142 ft. 141 ft. 09/01/1999

Drilling Method Non-specified Rotary

Geological Material Color Hardness From To CLAY GRAY 0 44 SAND & GRAVEL BROWN 44 55 CLAY GRAY 55 57 SAND & GRAVEL BROWN 57 61 SILTY SAND BROWN 61 88 SAND & GRAVEL BROWN 88 134 CLAY GRAY 134 135 SAND BROWN 135 142

Drilling Fluid Bentonite


Use Industrial

Casing Type Steel (black or low carbon) Joint No Information Drive Shoe?

Yes No Above/Below ft.


12 in. to 111 ft. lbs./ft. 18 in. to 142 ft.


Diameter Slot/Gauze Length Set Between 12 65 30 111 ft. and 141 ft.

Static Water Level 10 ft. from Land surface Date Measured 09/01/1999 PUMPING LEVEL (below land surface) 141 ft. after 6 hrs. pumping 250 g.p.m.



At-grade (Environmental Wells and Borings ONLY)

N O R E M A R K S

Located by: Clearwater Cty. Soil & Water Cons. Dist.

Method: GPS SA On (averaged)

Unique Number Verification: Tag on well Input Date: 03/23/2001System: UTM - Nad83, Zone15, Meters X: 319121 Y: 5284319


Grout Material: Neat Cement from 0 to 30 ft. 2 yrds.

Grout Material: Bentonite from 30 to 40 ft. 30 bags

Nearest Known Source of Contaminationfeet direction type



First Bedrock

Last StratAquiferDepth to Bedrock ft.


Yes No


Traut M.J. Well Co. 71536License Business Name Lic. Or Reg. No. Name of Driller





667943County ClearwaterQuadQuad ID





Well Name MINNESOTA PIPELINE Township Range Dir Section Subsections Elevation ft.

149 37 W 32 AAA Elevation Method


45 ft. 38 ft. 10/04/2001

Drilling Method Non-specified Rotary

Geological Material Color Hardness From To CLAY GRAY MEDIUM 0 3 SAND & GRAVEL BROWN SOFT 3 10 CLAY GRAY MEDIUM 10 34 SAND & GRAVEL GRAY SOFT 34 38 SANDY CLAY GRAY SOFT 38 45

Drilling Fluid Bentonite


Use Domestic

Casing Type Plastic Joint Unknown Drive Shoe? Yes No Above/Below ft.


4 in. to 34 ft. lbs./ft. 8 in. to 45 ft.


Diameter Slot/Gauze Length Set Between 4 12 4 34 ft. and 38 ft.

Static Water Level-10 ft. from Land surface Date Measured 10/04/2001 PUMPING LEVEL (below land surface) 38 ft. after 3 hrs. pumping 20 g.p.m.



At-grade (Environmental Wells and Borings ONLY)

N O R E M A R K S Grouting Information Well Grouted? Yes No

Grout Material: Neat Cement from 0 to 25 ft. 8 bags

Nearest Known Source of Contamination55 feet W direction Septic tank/drain field type


Pump Not Installed Date Installed 02/05/2002 Manufacturer's name RED JACKET Model number 12G9 HP 0.5 Volts 230 Length of drop Pipe 20 ft. Capacity 12 g.p.m Type Submersible Material

First Bedrock

Last StratAquiferDepth to Bedrock ft.


Yes No


Traut M.J. Well Co. 71536License Business Name Lic. Or Reg. No. Name of Driller




APPENDIX 2

April 24, 2014

Lisa Joyal Natural Heritage Information System Data Distribution Coordinator and Endangered Species Environmental Review Coordinator Minnesota Dept. of Natural Resources 500 Lafayette Road St. Paul, MN 55155-4025

Re: Koch Pipeline Company, L.P. New Breakout Tanks, Clearwater County Twp 149 North, Range 37 West, Section 32

Lisa:

I am currently assisting Koch Pipeline Company, L.P. (KPL) with the preparation of an Environmental Assessment Worksheet (EAW) for constructing four new above-ground breakout tanks at the existing Minnesota Pipe Line Company’s (MPL’s) Clearbrook Station, located in Clearwater County, Minnesota (Section 32, Township 149 North, Range 37 West). This letter is a request for your concurrence and/or comment on the potential impacts of the project on local endangered, threatened or special concern (ETSC) species, based on my review of the NHIS database. I am providing you with my review of the proposed project’s proximity to documented ETSC species, and a determination for your concurrence that the project will have no impact on Minnesota listed species.

The MPL Clearbrook Station currently comprises 11 crude oil breakout tanks and ancillary support activities. A breakout tank is a type of oil storage tank for the temporary holding of crude oil. The new tanks would be built within the existing property boundaries at the Clearbrook Station within an expanded earthen containment berm. A site location map showing the relevant project is provided in Attachment 1.

Question 13 of the 2013 revised DNR EAW form asks whether there are any state-listed (endangered, threatened or special concern) species, rare plant communities or other sensitive ecological resources on or near the site. I have consulted the NHIS database, using Barr’s License Agreement (LA-674) to search for documented records of listed species in the area. Based on my search, it appears that there are no state endangered, threatened or special concern species within one mile of the proposed breakout tank construction. NHIS records near the project are 2.7 to 2.9 miles north of the proposed project, in Section 17. These NHIS records are for several vascular plant species associated with a calcareous fen, incudingsterile sedge (Carex sterilis), beaked spikerush (Eleocharis rostellata) and hairlike beakrush (Rhynchospora capillacea). The wetland complex in which these species have been recorded will not be affected by the proposed project. In addition, no component of the proposed project would alter groundwater hydrology in the Section 17 calcareous fen wetland complex.

APPENDIX 3

Lisa Joyal, MN DNR April 24, 2014 Page 2

KPL MPL Clearbrook DNR‐Joyal_ETSC letter_04242014dwj.docx

There is also a documented bald eagle (Haliaeetus leucocephalus) nest approximately 1.8 miles southeast of the proposed project. The project will not disturb eagle nesting activities at the NHIS-recorded eagle nesting site. Based on the review of the NHIS database, I have determined that the proposed project will have no adverse effects on state-listed species that are known or likely to occur in Clearwater County. Please review the NHIS database for the proposed project area and provide your concurrence with this determination and/or further guidance to avoid impacts to state-listed species. Thank you, Lisa. Please call me at (952) 832-2875 or e-mail me at [email protected] if you have any questions or comments. Sincerely,

Daniel W. Jones Senior Environmental Scientist Barr Engineering Company

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1

Louise I. Segroves

From: Bump, Samantha (DNR) <[email protected]>Sent: Tuesday, June 03, 2014 11:24 AMTo: Daniel W. JonesSubject: NHIS Response: Koch Pipeline

Hi Daniel, I have reviewed your assessment of the potential for the Koch Pipeline Breakout Tanks project to impact rare features, and concur with your assessment. Thank you for notifying us of this project, and for the opportunity to provide comments. Have a great day, Samantha Bump NHIS Review Specialist (651) 259‐5091 Division of Ecological and Water Resources Minnesota Department of Natural Resources 500 Lafayette Road, Box 25 St. Paul, MN 55155 [email protected] www.mndnr.gov/eco

FIGURE B-1Process Flow Diagram

#12, #13,#14, #15

APPENDIX 4

APPENDIX 5

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