Northern Metals Application for Major Permit Amendment EAW

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ENVIRONMENTAL ASSESSMENT WORKSHEET

Note to reviewers: The Environmental Assessment Worksheet (EAW) provides information about a project that may have the potential for significant environmental effects. This EAW was prepared by the Minnesota Pollution Control Agency (MPCA), acting as the Responsible Governmental Unit (RGU), to determine whether an Environmental Impact Statement (EIS) should be prepared. The project proposer supplied reasonably accessible data for, but did not complete the final worksheet. Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) EQB Monitor. Comments on the EAW should address the accuracy and completeness of information, potential impacts that are reasonably expected to occur that warrant further investigation, and the need for an EIS. A copy of the EAW may be obtained from the MPCA by calling 651-757-2101. An electronic version of the completed EAW is available at the MPCA website at http://www.pca.state.mn.us/news/eaw/index.html#open-eaw. 1. Project Title: Northern Metals Application for Major Permit Amendment 2. Proposer: Northern Metals, LLC 3. RGU: Minnesota Pollution Control Agency Contact Person Stephen Ettinger Contact Person William Lynott and Title President and Title Planner Principal Address 2800 Pacific Street North Address 520 Lafayette Road North Minneapolis, Minnesota 55411 St. Paul, Minnesota 55155-4194 Phone 612-529-9221 Phone 651-757-2542 Fax 612-529-5863 Fax 651-297-2343 E-mail [email protected] E-mail [email protected] 4. Reason for EAW Preparation:

EIS Scoping

Mandatory EAW

Citizen Petition

RGU Discretion

Proposer Volunteered

X

If EAW or EIS is mandatory give EQB rule category subpart number and name: NA 5. Project Location: County Hennepin City/Twp Minneapolis SE 1/4 1/4 Section 10 Township 29 North Range 24 West GPS Coordinates: N 45.010 W 93.276 Tax Parcel Number

p-ear2-27a TDD (for hearing and speech impaired only): 651-282-5332

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

mailto:[email protected]

mailto:[email protected]

Northern Metals Application for Major Permit Amendment Environmental Assessment Minneapolis, Minnesota 2 Worksheet

Tables, Figures, and Appendices attached to the EAW: Attachment 1: Site Location Map Attachment 2: U.S. Geological Survey Map Attachment 3: Facility Plan View Attachment 4: Stormwater Management Attachment 5: Shredder Process Flow Diagram Attachment 6: Nearby Sources Attachment 7: Inventory of Petroleum Storage Tanks Attachment 8: Minnesota Department of Natural Resources (DNR) Correspondence Attachment 9: Historical Society Correspondence Attachment 10: Air Emission Risk Assessment

6. Description:

a. Provide a project summary of 50 words or less to be published in the EQB Monitor. Northern Metals, LLC proposes a major modification of its 1998 Air Emission Permit to: 1) include additions to pollution control equipment; 2) eliminate obsolete permit requirements; 3) modify other permit requirements to reflect actual emission rates achieved in practice; and 4) eliminate feedstock restrictions. The proposal includes only permit changes, no new construction.

b. Give a complete description of the proposed project and related new construction. Attach additional sheets as necessary. Emphasize construction, operation methods and features that will cause physical manipulation of the environment or will produce wastes. Include modifications to existing equipment or industrial processes and significant demolition, removal or remodeling of existing structures. Indicate the timing and duration of construction activities. Northern Metals, LLC, which owns a metal scrap recycling facility located in Minneapolis (Attachments 1 and 2), is proposing several amendments to its Air Emission Permit. The proposed project consists of amendments to Air Emission Permit No. 05300480-002 (Air Emission Permit) as proposed in the Application For A Major Permit Amendment, August 2010 (2010 Application), submitted by Northern Metals (Permit Amendment Project). No new construction is proposed as part of this project. In summary, the proposed changes to the permit: • Describe additions to the permitted pollution control equipment (see Section 6.b.2) • Substitute a new facility description for the description in the current Air Emission Permit (see

Section 6.b.3) • Increase the particulate emissions limits (see Section 6.b.4) • Modify the format of the mercury emissions limit (see Section 6.b.5) • Eliminate several feedstock restrictions and increase emissions limits on metals (see Section 6.b.6) • Eliminate the requirement to record the weight of all residue and materials collected by pollution

control equipment (see Section 6.b.7) • Replace the opacity limit for fugitive dust from the outdoor storage piles with the requirement to

comply with a more comprehensive fugitive dust control plan (see Section 6.b.8) • Eliminate the requirement to pave facility roads as obsolete (see Section 6.b.9) • Set test frequencies for subsequent performance testing (see Section 6.b.11)


1) Air Permit and Minneapolis Shredder Installation History The basis for the amendments being requested by the proposer is described in this brief history of the Air Emission Permit and the metal shredder installation. In 1995, a Northern Metals predecessor, American Iron and Supply Company (American Iron), proposed to install and operate a Kondiratortm hammermill metal shredder at American Iron’s Pacific Street Yard at 2800 Pacific Street North, Minneapolis, Minnesota (Pacific Street Yard). As directed by legislative action, the MPCA subsequently prepared the American Iron & Supply Company Metal Recycling Mill (Kondirator) Installation Environmental Assessment Worksheet dated October 9, 1995 (1995 EAW), as well as a Screening Level Human Health Risk Assessment For The Proposed Kondirator Metal Shredder/Recycler In Minneapolis, Minnesota dated June 30, 1995 (1995 Risk Assessment).

The 1995 Risk Assessment assumed that the pollution control equipment to be installed comprised a cyclone and scrubber for the shredder and a cyclone for the downstream cascade cleaning system. This combination of control devices produced a calculated filterable-particulate emission rate of 9.98 pounds per hour. For the risk analysis, the health and ecological risks were calculated based on Material Safety Data Sheets for the expected shredder feedstock. The 1995 Risk Assessment concluded that, at this emission rate, the potential human health risk for cancer exceeded the Minnesota Department of Health (MDH) risk threshold. The chemicals of concern that drove this result were the estimated particulate emissions of arsenic, beryllium, and hexavalent chromium. In the 1995 EAW, the MPCA calculated that, to meet the MDH cancer risk threshold, the particulate emissions must be limited to about 0.49 pounds per hour. In response, American Iron proposed additional mitigation – a fabric filter that would reduce the filterable particulate emission rate to 0.43 pounds per hour. This emission rate was based on vendor certification of the fabric filter. In this configuration, the scrubber would be eliminated from the pollution control equipment attached to the shredder. Instead, the shredder and the cascade cleaning system had separate cyclones, and the air streams from both cyclones were directed to the fabric filter. Upon agreement to these limitations, the MPCA’s Citizens’ Board (Board) determined that preparation of an Environmental Impact Statement (EIS) was not required. After the Board’s negative declaration on the need for an EIS, American Iron applied for an air emission permit. The application proposed the following control equipment: CE001 High Efficiency Cyclone on the hammermill shredder; CE002 High Efficiency Cyclone on the Cascade Cleaning system; and CE003 Common Fabric Filter (Baghouse) following both cyclones. But before the MPCA could act on American Iron’s application, the city of Minneapolis (City) brought litigation challenging the negative declaration on the need for an EIS. After the litigation concluded in early 1998, the MPCA resumed work on American Iron’s air emission permit application. In writing the Air Emission Permit, the MPCA incorporated the pollution control equipment proposed in the application and incorporated the 0.43 pounds per hour particulate emission rate as a permit condition for particulate matter (PM) and particulate matter less than 10 microns (PM10) emissions. The MPCA issued the Air Emission Permit to American Iron for installation and operation of a hammermill metal shredder, on December 8, 1998. The Air Emission Permit is a State, True Minor Permit with no expiration date.


In the 1998 permit, the MPCA added “organic condensables” as part of the Total PM and PM10 emission limits because of regulatory activity at the federal level that occurred between the negative declaration on the need for an EIS and the resumption of work on American Iron’s permit application. During that time period, the U.S. Environmental Protection Agency (EPA) completed revisions to the PM10 National Ambient Air Quality Standards (NAAQS) and the ambient air measurement protocols that made it clear that condensable matter at ambient conditions must be included in the calculation of particulate matter. However, during the 1995 Risk Assessment and EAW process, these federal regulations had not been promulgated. For this reason, both documents were based on filterable particulate matter and did not include condensable particulate matter. After the MPCA issued the Air Emission Permit in 1998, further litigation between American Iron and the City delayed the shredder installation until a settlement was agreed to in late 2002. Minor preparatory activities related to the stormwater management system commenced, but the shredder installation was further delayed by the project proposer. In early 2006, American Iron completed an important step in the shredder installation process by submitting to the MPCA the 2005 Voluntary Response Action Plan, 2800 Pacific Street North, Minneapolis, Minnesota dated January 25, 2006 (VRAP). The purpose was the cleanup of contaminated conditions at the site that had existed for many years. The MPCA approved the VRAP on February 10, 2006, and soil remediation work began in June 2006. In early 2007, Northern Metals purchased American Iron. Soil remediation work continued and planning for the shredder installation was accelerated. Construction of the shredder building and shredder installation began in August of 2008. Soil remediation work was completed in the same year. The shredder commenced operation on June 18, 2009. Because the control equipment design is the first of its kind in the nation, it required startup tuning and modifications that extended over several months. The initial configuration caused excessive build up of particulate matter in the ductwork and on the filter bags, requiring considerable ongoing maintenance. Actions taken included: hiring outside experts to analyze problems with air flow through the pollution control equipment; reworking duct connections to the shredder to optimize capture efficiency; installing a new fan blade configuration in the cyclones to maintain air flow over a wide range of operating conditions; and, adjusting the pollution control equipment to balance the various components for maximum efficiency. The stack testing required by the Air Emission Permit was conducted November 30 through December 4, 2009. Because the filter bags had been changed the day before the test and had not been conditioned to provide typical removal, a re-test for particulate matter emissions was conducted on December 22, 2009. Additional stack testing for mercury emissions was conducted on June 22, 23, and 29, 2010, in accordance with the Air Emissions Compliance Plan for the Hammermill Metal Shredder at the Pacific Street Yard in Minneapolis, Minnesota (Compliance Plan) submitted April 16, 2010. In September 2010, the MPCA requested that Northern Metals prepare a voluntary EAW in anticipation of public interest in the Permit Amendment Project. Northern Metals agreed to this request and submitted a draft EAW on November 22, 2010. This EAW has been revised based on the proposer’s responses to comments provided by the MPCA.


2) Additions to Air Permit Pollution Control Equipment

As noted above, the pollution control equipment listed in the 1998 Air Emission Permit comprised three units – CE001 High Efficiency Cyclone on the hammermill shredder, CE002 High Efficiency Cyclone on the cascade cleaning system, and CE003 Common Fabric Filter (Baghouse) following both cyclones. Northern Metals has since installed additional control equipment to control particulate matter and related metal emissions. This control equipment is not included in the current Air Emission Permit. The shredder now has duplicate pollution control equipment on the two exhaust streams, one from the shredder and one from the cascade cleaning system. For the shredder, the emission control equipment now includes CE001 High Efficiency Cyclone, CE004 Venturi Scrubber, and CE006 Fabric Filter. For the cascade cleaning system, the equipment includes CE002 High Efficiency Cyclone, CE005 Venturi Scrubber, and CE007 Fabric Filter. The controlled emissions from the two exhaust streams then vent through a common stack numbered SV001.

In the Air Emission Permit, the cyclone on the cascade cleaning system (CE 002) is considered, for purposes of emissions calculations and permit program applicability, to be inherent process equipment because it is part of the system that separates desired scrap product from the residuals. The current configuration of the cascade cleaning system uses the same model cyclone as used for the shredder. The primary purpose of cyclone CE002 is to clean the metal product and further separate product from the unprocessed shredder residue. (“Unprocessed shredder residue” means the mixture of metals and waste materials left after shredding and separation in the shredder building but before processing in the Metal Recovery Plant located in the Pacific Street Yard’s North Warehouse.) Because in the 2010 Application Northern Metals has replaced the single fabric filter (CE003) with two fabric filters numbered CE006 and CE007, CE003 is now obsolete. Forms GI-02, GI-03, GI-04, GI-05a, and GI-05b are provided in the 2010 Application to clarify changes in equipment from the Air Permit as issued in 1998.

3) Facility Description

The Facility Description in the current Air Emission Permit was written in 1996 and is obsolete. The following up-to-date facility description replaces the existing description. Northern Metals is a metal recycling company whose wholly-owned subsidiary, American Iron & Supply Company, operates the Pacific Street Yard at 2800 Pacific Street North in Minneapolis, Minnesota. The property is bounded by 28th Avenue North on the south, Pacific Street North on the west, 31st Avenue North on the north, and the Mississippi River on the east. The Yard includes 12 acres of property and five buildings: the Office Building, the South Warehouse (attached to the Office Building); the Shredder Building, the North Warehouse and Metal Recovery Plant Building (which includes an attached Rain and Snow Shed), and the Scale Building. The Metal Recovery Plant is where residuals from the shredder are sent for final metal separation from the waste materials. See Attachment 3. The Rain and Snow Shed was added to the south side of the North Warehouse as part of modifications to the North Warehouse needed to house the Metal Recovery Plant. The Rain and Snow Shed has four functions related to this Plant.


a) The Rain and Snow Shed covers the bay where unprocessed shredder residue is placed after it leaves the shredder building. Protecting the unprocessed shredder residue is important because, if it becomes too wet, this seriously impairs the efficiency of the metal recovery process in the Metal Recovery Plant. The shed also prevents stormwater from leaching any contaminants from the residue.

b) In the bay with the unprocessed shredder residue are the trommel that initially sizes the

shredder residue and the conveyor leading to the rest of the metal recovery line inside the North Warehouse. This equipment must also be protected from rain and snow to prevent the unprocessed shredder residue from absorbing excessive moisture.

c) The Rain and Snow Shed protects recovered aluminum, which is stored in a bay in the shed,

from the effects of oxidation produced by contact with rainwater. This oxidation makes it harder to recycle the aluminum and reduces its value.

d) The Rain and Snow Shed also covers the storage bay for the processed shredder waste after it

leaves the Metal Recovery Plant. (“Processed shredder waste” means the mixture of wastes remaining after residual metal recovery in the Plant.) The processed shredder waste is sent to landfills for use as daily cover. The wetter the waste, the higher the transport and removal costs, so the Rain and Snow Shed minimizes this cost. The shed also prevents stormwater from leaching any contaminants from the processed shredder waste.

The Rain and Snow Shed also provides a large carbon footprint reduction that is unrelated to processing the shredder residue in the Metal Recycling Plant. Because the Shed extends over the Pacific Street Yard’s metal turnings holding pad, it prevents rain and snow from reaching the pad. Prior to adding the Rain and Snow Shed, the metal turnings pad was uncovered, and all rain and snow falling onto it was directed to the pad’s holding tank where the runoff mixed with turnings oils. This mixture was boiled to evaporate the water, and the recovered oil was reused as heating fuel for the North and South Warehouses. The Rain and Snow Shed reduced the oil and water mixture that had to be boiled to a tiny fraction of the 300,000 to 350,000 gallons previously processed. After purchasing American Iron and Steel Company, Northern Metals made significant investments in the Pacific Street Yard.

• Completion of Soil Remediation Including Paving. Northern Metals completed the soil

remediation activities required by the MPCA VRAP. This included paving all unpaved portions of the Pacific Street Yard except a small area behind the North Warehouse and Metal Recycling Plant Building as specified in the VRAP.

• Replacement of Rail Tracks. Northern Metals replaced the internal rail system at the Pacific Street Yard with a new system at new grades and a new rail scale. This work included paving around and between the new tracks with six inches of asphalt to meet the paving requirement in the VRAP.

• Stormwater Management System. Northern Metals installed an underground stormwater management system that directs flow from all paved areas of the Pacific Street Yard to the stormwater storage and treatment system, which was previously permitted by the MPCA. See American Iron and Steel Company NPDES/SDS Permit No. MN0063380 (NPDES Permit) and Attachment 4.


• Barge Dock Replacement. Northern Metals replaced the two barge docks on the Mississippi River with a modern, single dock. Unlike the two old docks, all stormwater from the new dock is directed to the stormwater management system (Attachments 3 and 4).

• Minneapolis Shredder Installation. Northern Metals constructed a Leadership in Energy and Environmental Design (LEED)-designed Shredder Building and installed a Metso Texas hammermill metal shredder inside the building as it was being built. The shredder installation included the in-feed conveyor system, the shredder itself, size separation equipment, cleaning equipment (referred to collectively as the cascade cleaning system), initial magnetic separation equipment, manual separation stations, finished product conveyor system, and the associated air pollution control equipment. The current control equipment design uses two exhaust streams, one from the shredder and one from the cascade cleaning system. Each exhaust stream is controlled by a high efficiency cyclone, a wet scrubber, and a fabric filtration system. The controlled emissions from the two exhaust streams vent through a single stack. See Attachment 5.

• New Metal Recycling Plant. The North Warehouse was modified to accommodate a new Metal Recycling Plant that further separates and recovers ferrous and non-ferrous metals from the shredding process residuals (Attachment 3).

• New Entrance, Truck Scale, and Scale House. Northern Metals reorganized the flow of materials through the Pacific Street Yard by opening a new entrance on Pacific Street North at 30th Avenue North, installing a new truck scale at this entrance, building a new scale house to serve the new truck and rail scales, and changing the old entrance/exit at Pacific Street North and 28th Avenue North to an exit only (Attachment 3).

The small area behind the North Warehouse remains unpaved as specified in the VRAP. This area must slope up from the entry gate on 31st Avenue North to the truck docks at the rear of the North Warehouse, so vehicles can access the Warehouse. Consequently, this area could not be sloped south into the stormwater management system. Stormwater from this area flows to 31st Avenue North and immediately to the Mississippi River via the City storm drain system. The MPCA Voluntary Investigation and Compliance Program staff decided this area should remain unpaved because: (a) the amount of stormwater runoff would be reduced by soil absorption; and (b) if a petroleum product spill occurred from vehicles accessing the North Warehouse (the most likely spill type in this part of the Pacific Street Yard), most of the spill would be absorbed in the soil rather than flowing immediately to the River. The Pacific Street Yard accepts most grades of bulk quantity commercial, industrial, and demolition scrap metal and processes it for sale to customers such as steel mills, foundries, smelting plants, or primary aluminum plants.

Proposed Permit Amendment

4) Particulate Matter Emissions Limits

Northern Metals seeks a modification of the Total PM and PM10 particulate matter emission limits for the shredder.


Particulate matter is a complex pollutant, but it can be generally grouped into two different types: filterable and condensable. Filterable particulate matter is made up of particles that are directly emitted as liquid or solid, whereas condensable particulate matter is directly emitted from the source as a gas or vapor and condenses and/or reacts with other compounds in the atmosphere after it is emitted to form solid or liquid particles. In the original permit for construction, the MPCA had sufficient information on the performance of fabric filters to capture filterable particulate matter, but lacked data on the fraction of PM that would condense downstream of the fabric filter. The stack testing results show that the combination of the filterable and condensable PM emissions is higher than the current emission limits. Because the initial permitting process did not account for the presence of condensable particulate matter, Northern Metals is proposing a modification to the permit’s particulate matter limits, to account for the fact that actual PM emissions are higher than was known when the 1998 permit was issued. Computer modeling of the new higher emissions rate demonstrates continued compliance with both the NAAQS and Minnesota State Ambient Air Quality Standards (MAAQS) for PM10 and PM2.5.

5) Mercury Emissions

Since Northern Metals is proposing to be allowed to shred auto hulks, and the occasional mercury switch may get through the required pre-processing removal process, the company initially proposed raising the current hourly mercury emission limit. Rather than raise the hourly limit, the permit proposes to modify the mercury emission limit for the shredder from an hourly emissions limit to an annual emission limit of three pounds per year. This change does not allow increased mercury emissions from Northern Metals, but instead changes the method for determining compliance with the limit. Mercury is a toxic air pollutant that is persistent and bioaccumulative. The primary route of exposure for most people and wildlife is by eating contaminated fish. Concentrations of mercury in the air are very low, but once deposited in aquatic systems the concentrations can be millions of times greater in fish and wildlife due to bioaccumulation. The process of bioaccumulating mercury, and, accordingly, the recovery of ecosystems after the reduction in atmospheric mercury deposition, is slow. Minnesota’s mercury Total Maximum Daily Load study defines the period of recovery in terms of years or potentially decades. Because the concern is a long-term concern, an annual mercury limit is appropriate. Mercury compliance testing at Northern Metals has demonstrated that, while mercury emissions are present in the flue gas stream, emissions are quite variable, but low overall.

o Mercury emissions are variable.

The potential for mercury to enter a metal shredder stems largely from mercury switches in auto hulks and appliances. Minnesota law requires the removal of switches from automobiles before they are shredded for recycling, but that requirement does not extend to other devices using mercury switches, such as appliances. Northern Metals has a feedstock control plan to address mercury in scrap, which describes the company’s efforts to remove mercury switches before scrap enters the shredder. In particular, the Feedstock Control Plan requires suppliers to process

vehicles to meet or exceed the standards of the National Vehicle Mercury Switch Recovery Program (NVMSRP, a program developed by EPA and auto manufacturers to recover mercury switches from automobiles (see http://www.elvsolutions.org/minnesota.html). Northern Metals routinely audits suppliers’ participation in the NVMSRP, including physical audits of their operations. And, Northern Metals routinely inspects materials brought directly to the Pacific Street Yard by non-NVMSRP suppliers, including appliances and other scrap that may contain mercury devices, even though there is no federal or state requirement to do so. Further, Northern Metals continues to offer bounties for mercury switches, even though federal and state funds for such bounty programs are limited. Finally, Northern Metals will spot check processed vehicles to determine whether mercury switches and other hazardous materials have been removed. Nine measurements of mercury in Northern Metals’ stack emissions were made during three different periods in accordance with permit requirements and Minnesota rules. Mercury was detected in six of nine measurements, with one measurement an order of magnitude greater than the others. These results show that overall mercury emissions are low, but that high concentrations may occur. The measurements are shown in the table below.

o Mercury emissions on average are very low.

To determine compliance with an air emissions limit, state and federal sampling and analysis methods require taking three samples of the flue gases, and averaging the samples. Thus, the first three measurements in the table below represent the initial mercury emissions test for Northern Metals. Two additional stack tests have also been conducted providing the next six samples. The average emission rate as represented by the arithmetic average of all samples is 0.00053 lb/hr, about two-thirds of the permitted emission rate. Assuming the facility was to operate every hour allowed, annual emissions would be 2.01 pounds per year. The testing demonstrates that while an occasional high value might occur, overall emissions are low, and the intended facility limit of three pounds per year can be met.


http://www.elvsolutions.org/minnesota.html


The MPCA has evaluated both the short term and long term mercury emissions from this facility in the Air Emissions Risk Analysis (AERA), and has determined that no significant human health risks occur at the current permit limit of 0.00079 lbs/hr, or at the proposed equivalent annual emissions limit of three pounds per year. See Item 23 for a discussion of the air emissions risk analysis and its findings.

6) Feedstock Restrictions

Northern Metals proposes the removal of the restrictions that prohibit shredding auto hulks, aluminum scrap, brass scrap, copper scrap, stainless steel scrap, and used oil filters. Auto Hulks. The shredder currently shreds auto parts, including engine blocks, frames, frame parts, and body parts such as body panels, bumpers, hoods, fenders, roofs, and trunk lids, all as allowed in the Air Permit. However, the shredding of auto hulks is prohibited by the current permit.1 Northern Metals proposes eliminating this prohibition. The Northern Metals proposal is to shred “processed vehicles.” “Processed vehicles” are auto hulks that meet the standards established in the Feedstock Control Plan for the removal of batteries, gasoline, oil, and other fluids, gasoline tanks, mercury switches, tires, and other items. Pursuant to the proposed permit, Northern Metals will only accept and shred auto hulks (1) purchased from certified suppliers who are required to remove batteries, mercury switches, and other hazardous materials before reselling the scrap metal, or (2) processed at other Northern Metals facilities following the same requirements. Aluminum, Brass, Copper, and Stainless Steel Scrap. The original Air Emission Permit allows the shredder feedstock to include incidental amounts of aluminum, brass, copper, and stainless steel scrap. The restrictions on shredding these metals in other than incidental amounts were included because of assumptions about the feedstock composition used in 1995 Risk Assessment and 1995 EAW. These assumptions were incorporated into the permit requirements to limit filterable particulate emissions of arsenic, beryllium, and hexavalent chromium and, thereby, keep the potential human health risk for cancer below the MDH risk threshold. Specific emission limits for arsenic, beryllium and chromium were added as well. Northern Metals is now proposing new emission limits for arsenic, beryllium and chromium based on facility stack testing results and a worst case scenario of shredding an input volume of 95 percent of any one of aluminum, brass, copper and stainless steel scrap. According to Northern Metals, aluminum, brass, copper, and stainless steel will actually never comprise a significant fraction of scrap metal sent to the shredder. However, it is not possible to measure incoming scrap metal for the weight percentages of various metals, so the AERA was revised assuming the

1 In the scrap industry, “auto hulk” refers to an assembled vehicle that is ready for processing as scrap metal. Typically, the battery, fuels and other fluids, and the gas tank have been removed. Depending on local regulations, the expected end use, the scrap metal company’s preferences, and the scrapping method to be used, mercury switches and other parts may be removed before the auto hulk is baled, crushed, logged, shredded, or otherwise processed. Currently, the Minneapolis Shredder does not shred auto hulks, but it does shred vehicle parts, all as dictated by the Air Emission Permit.


emission limits proposed by Northern Metals (see Item 23). The AERA analysis shows that they do not exceed any health risk benchmarks. Thus, with the pollutant specific limits, the restrictions on how much of these feedstock metals can be shredded is redundant. Used Oil Filters. It is the policy of Northern Metals to not accept used oil filters. Used oil filters are included on the “Unacceptable Materials List” in the Northern Metals Feedstock Control Plan. In addition, the Pacific Street Yard does not accept unprocessed vehicles. All vehicle hulks must be processed by a certified ELV (End of Life Vehicle) supplier or by Northern Metals’ trained employees in conformance with Minn. R. 7045.0990, or Northern Metals will not shred them.

7) Recordkeeping

Northern Metals proposes to eliminate the requirement to record the weight of all residue and materials collected by pollution control equipment. According to the company, it is not possible to accurately record the weight of particulate material collected by the baghouses, which follow the wet scrubber and contain considerable moisture. The third set of bags is comprised of “smoke filters,” which are not designed to have a filter cake that could be collected or removed. Northern Metals believes the recordkeeping requirement was put in the Air Emission Permit because the original risk assessment was based on mass balance calculations for the shredder and cascade cleaning system. The current AERA is based on stack testing results from December 2009 and revised permit limits; therefore, weighing the amount of material collected by the pollution control equipment does not provide any additional useful information for air emissions control purposes.

8) FS 001 Product Storage Piles

The proposed permit replaces the zero percent opacity limit with the requirement to comply with a comprehensive fugitive dust control plan. The plan must be submitted and approved by the MPCA, and, among other things, will outline the measures that Northern Metals will take to ensure that the storage piles are managed in a way to minimize fugitive particulate matter emissions. Fugitive dust has not been demonstrated to be a concern during operation of the shredder, and fugitive sources were not included in the initial analysis. However, subsequent remodeling by MPCA staff included fugitive sources. Since the current Air Emission Permit was issued, key facility infrastructure has been changed to reduce fugitive emissions. That permit was issued for a shredder built outdoors and required paving only around the shredder and on roads within the Pacific Street Yard. As constructed, the shredder is housed inside the Shredder Building and all but a small fraction of the Pacific Street Yard has been paved. Finished Product Pile. Shredded metal in the finished product storage piles is not expected to contain any entrained dust because the cascade cleaning system uses a 45,000 cubic foot per minute air stream to clean dust and debris from the shredded metal. This removes any dust that would cause fugitive dust from wind erosion of storage piles. A visible emissions test was conducted on transfer of shredded metal to the product storage piles during initial performance testing on December 1, 2009. Zero percent opacity was reported during the one-hour test period when the shredder was operated at full load. The estimated routine fugitive emissions from the product storage piles are zero.


9) FS 002 Paved Roads

Northern Metals proposes to remove the requirement that facility roads be paved. When the Air Emission Permit was issued, most of the Pacific Street Yard was unpaved, including some of the internal roads. As noted in the new Facility Description, the entire Pacific Street Yard, with the exception of a small area behind the North Warehouse was paved to meet the VRAP requirements. The requirement to pave the roads is, therefore, obsolete.

10) FS 002 Cleaning Roads

Northern Metals has proposed to change the requirement to clean all primary roads, entrances, internal roads, and exits once per day to a requirement to clean these areas “when necessary to prevent particulate matter from becoming airborne.” Instead, the Air Emission Permit will still require daily road sweeping and cleaning, but allows for exceptions when the roads are snow- or ice-covered, or if 0.1 inches of liquid precipitation fell in the last 24 hours.

11) Performance Test Frequency Plans

Northern Metals proposes that the Air Emission Permit include the following performance test frequencies: • For Total PM, PM10, and PM2.5 emissions – every 60 months • For mercury emissions – every 36 months • For arsenic, beryllium, cadmium, hexavalent chromium, lead, manganese, and nickel

emissions– no further testing • For PCBs, dioxins, asbestos, antimony, barium, boron, calcium, chromium, cobalt, copper, iron,

lithium, magnesium, molybdenum, niobium, selenium, silver, tin, titanium, tungsten, vanadium, zinc, and zirconium emissions – no further testing

• Opacity for stack SV001 – every 60 months • Opacity for fugitive emissions from storage piles – no further testing Total PM and PM10 and PM2.5. The stack testing results for Total PM and PM10 emissions were less than 60 percent of the proposed particulate matter emissions limit. Therefore, based on the MPCA’s policy for setting performance test frequencies, the proposed stack test frequencies for Total PM, and PM10, and PM2.5 are every 60 months. Mercury. Although Northern Metals has proposed a flat three-year interval for mercury testing, the draft permit requires annual stack tests until three consecutive years of compliance with the mercury limit have been demonstrated. After that point, the proposed permit requires testing every 36 months. It is expected that mercury switches in recycled automobiles and appliances will continue to decrease. Several national mercury reduction programs have been implemented since the original air permit was issued in 1998. Mercury switches have been eliminated in automobiles since model year 2003. Based on this projected decrease in switches in the feedstock, it is reasonable to allow the Permittee to conduct performance tests no less than once every three years after they have demonstrated compliance with the mercury limit for three consecutive years. This approach is consistent with how test frequencies are established for units with variable feedstock through federal regulations.


Arsenic, Beryllium, etc. The stack testing results for arsenic, beryllium, cadmium, hexavalent chromium, lead, manganese, and nickel were less than 60 percent of their respective limits in the Air Emission Permit. The emission rates based on the company’s proposed limits were analyzed in the AERA and were found to be well below respective health risk benchmarks. Although proposed testing frequency suggested by the Air Performance Test Form is every 60 months, Northern Metals proposes that no further testing be required for these pollutants based on the results of stack testing and the AERA. No further stack testing is necessary because compliance with these limits are ensured through the Feedstock Control Plan, shredder output limit and pollution control operation requirement. PCBs, Dioxins, Asbestos, etc. Northern Metals conducted initial performance testing for PCBs, dioxins, asbestos, antimony, barium, boron, calcium, chromium, cobalt, copper, iron, lithium, magnesium, molybdenum, niobium, selenium, silver, tin, titanium, tungsten, vanadium, zinc, and zirconium as required in the Air Emission Permit. There are no limits in the permit for these pollutants. The emission rates from the stack testing results, adjusted for proposed changes in feedstock requirements, were analyzed in the AERA and with refinements were found to be below respective health risk benchmarks. Based on the results of the stack testing and the AERA, no further performance testing will be required for these pollutants. Stack Opacity. The stack testing result for opacity from stack SV001 was less than 60 percent of the 20 percent limit. Therefore, the permit’s stack test frequency for opacity is every 60 months. Fugitives Opacity. The testing result for fugitive opacity emissions from the product storage piles was zero percent. Based on these results, Northern Metals requests that no further opacity testing from product storage piles be required. This requirement will be replaced by a fugitive dust control plan.

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

need for the project and identify its beneficiaries. The purpose of the Permit Amendment Project is to change the current Air Emission Permit following installation and startup of the shredder. Northern Metals’ current Air Emission Permit was issued in 1998, but the shredder and associated equipment were not installed until 2009. After startup of the shredder, stack testing was conducted on the shredder, according to requirements in the Air Emission Permit, and the results indicated the need to revise the initial permit terms and conditions. The proposed permit changes described above meet all federal and state air quality regulations, as demonstrated in the 2010-2011 Application, the AERA, and the NAAQS Modeling Report. The Permit Amendment Project will allow the shredder to operate as designed, with state-of-the-art pollution control equipment, and remain competitive with other metal shredding facilities in the state of Minnesota.

d. Are future stages of this development including development on any other property planned or likely to happen? Yes No

e. Is this project a subsequent stage of an earlier project? Yes No

If yes, briefly describe the past development, timeline and any past environmental review. This information is given in section 6.b.1.


7. Project Magnitude Data Total Project Area (acres) 11.7 or Length (miles)

Number of Residential Units:

Unattached

0

Attached

0

Maximum Units Per Building:

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

total square feet

117, 304

Indicate area of specific uses (in square feet):

Office and South Warehouse 30,000 Manufacturing 0 Retail 0 Other Industrial (Shredder Building) 23,944 North Warehouse 39,360 Rain and Snow Shed 24,000 Light Industrial 0 Institutional 0 Other Commercial (specify) 0 Agricultural 0 Shredder Building height 57.5 feet If over 2 stories, compare to heights of nearby buildings

All of the values above are existing. The Permit Amendment Project will not modify the total facility acreage, add any buildings or equipment, modify the square footage of any buildings, or change any building heights. This project includes no new construction.

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

assistance for the project. Include modifications of any existing permits, governmental review of plans, and all direct and indirect forms of public financial assistance including bond guarantees, Tax Increment Financing and infrastructure. All of these final decisions are prohibited until all appropriate environmental review has been completed. See Minn. R. 4410.3100.

Unit of Government Type of Application Status MPCA Major Air Permit Amendment Proposed Permit on Notice currently with

the EAW

9. Land use. Describe current and recent past land use and development on the site and on adjacent lands. Discuss project compatibility with adjacent and nearby land uses. Indicate whether any potential conflicts involve environmental matters. Identify any potential environmental hazards due to past site uses, such as soil contamination or abandoned storage tanks, or proximity to nearby hazardous liquid or gas pipelines. The Northern Metals property is located on the west bank of the Mississippi River in an area designated by the City as the North Washington Industrial Park. The property is surrounded by other heavy industrial uses. The area is home to manufacturers, metal recyclers, sand and gravel aggregate suppliers, and a cement plant (Attachment 6). Cranes, conveyor belts, electrical transmission lines, open storage, storage piles, heavy trucks, loud noises, and odors are dominant features in the area. The entire area is zoned I-3, the City’s heaviest industrial use designation. The Northern Metals operation is compatible with these surrounding uses. Scrap metal recycling operations started in 1951 and continued to the present on some or all of the property. From the 1950s to the present, the entire area east of Washington Avenue and south of the Lowry Avenue Bridge has been an industrial district. The area across the river from the Northern Metals


property is currently zoned for a mix of residential, commercial, and medium industrial areas. The project is consistent with the existing industrial existing land uses to the north, west, and south. In late 2002, the City approved installation of the shredder by granting a variance and issuing Conditional Use Permits (CUPs) for the project. As discussed in Section 6.b.3. above, the Pacific Street Yard has undergone extensive soil remediation. In early 2006, American Iron submitted the VRAP to the MPCA. Soil remediation work began at the Pacific Street Yard in June 2006. Northern Metals purchased American Iron in early 2007. Soil remediation work continued and was completed under the new owner. Construction of the Shredder Building and shredder began in August 2008. As part of this work, Northern Metals also installed a stormwater collection and treatment system, constructed a new barge dock on the Mississippi River, and paved nearly all of the Pacific Street Yard not covered by buildings. Any potential environmental hazards due to past site uses were remediated as part of the VRAP remediation project conducted under MPCA supervision. The Permit Amendment Project will not cause any environmental land use conflicts.

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

development: Before After Before After Types 1-8 wetlands 0 0 Lawn/landscaping 0 0 Wooded/forest 0 0 Impervious Surfaces 11.53 11.53 Brush/grassland 0 0 Stormwater pond 0 0

Cropland

0

0 Other (describe) Unpaved yard area

.17

.17

TOTAL 11.7 11.7

The Permit Amendment Project will not lead to any modification of current cover types. 11. Fish, Wildlife, and Ecologically Sensitive Resources. a. Identify fish and wildlife resources and habitats on or near the site and describe how they would be

affected by the project. Describe any measures to be taken to minimize or avoid impacts. The Pacific Street Yard does not provide habitat for wildlife species. Land within the Pacific Street Yard is primarily covered with buildings, scrap metal, pavement, or machinery. The industrial nature of the Pacific Street Yard and continued activity within the facility discourage use of the area by wildlife species. The Mississippi River is located along the eastern boundary of the Northern Metals property. Fish and wildlife species associated with the river community are expected to inhabit the river near the Northern Metals property without interference by this project. The Permit Amendment Project is not anticipated to have any adverse impacts on fish and wildlife resources in the Mississippi River. Water quality and the quantity of surface runoff from the site will not change as a result of the proposed modifications. Stormwater runoff is controlled and treated on site prior to discharging to the river as required in the existing NPDES Permit.


The Mississippi River corridor is used by waterfowl in their continental migration, according to the DNR. The proposed Permit Amendment Project will not affect the migration of these species or their use of the river. There is no construction associated with the proposed Permit Amendment Project.

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

If yes, describe the resource and how it would be affected by the project. Describe any measures that will be taken to minimize or avoid adverse impacts. Provide the license

agreement number (LA-___________) and/or Division of Ecological Resources contact number (ERDB 20110163) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources. Indicate if any additional survey work has been conducted within the site and describe the results. The DNR Natural Heritage Program was contacted on October 14, 2010, for information regarding known locations of rare and endangered species or resources in or near the project site. Copies of the response letter and database index report are provided in Attachment 8. The database query identified rare feature occurrences of the black sandshell mussel and peregrine falcon near the Pacific Street Yard. However, because the Permit Amendment Project is not a construction project, the DNR has indicated that it does not expect any negative effects to these features from the Permit Amendment Project.

12. Physical Impacts on Water Resources. Will the project involve the physical or hydrologic alteration

(dredging, filling, stream diversion, outfall structure, diking, and impoundment) of any surface waters such as a lake, pond, wetland, stream or drainage ditch? Yes No

13. Water Use. Will the project involve installation or abandonment of any water wells, connection to or

changes in any public water supply or appropriation of any ground or surface water (including dewatering)? Yes No

14. Water-related land use management districts. Does any part of the project involve a shoreland zoning district, a delineated 100-year flood plain, or a state or federally designated wild or scenic river land use district? Yes No If yes, identify the district and discuss project compatibility with district land use restrictions. The Pacific Street Yard is located within the FP Floodplain Overlay District, the SH Shoreland Overlay District, and the MR Mississippi River Critical Area Overlay District as designated in the City’s zoning regulations. As noted earlier, the City granted CUPs for construction of the shredder within these Overlay Districts, and a Variance was also granted for development in the SH and MR Overlay Districts within 50 feet of the Ordinary High Water Mark of the Mississippi River. The Permit Amendment Project will not require any additional construction or change to the approved CUPs or Variance.


15. Water Surface Use. Will the project change the number or type of watercraft on any water body?

Yes No If yes, indicate the current and projected watercraft usage and discuss any potential overcrowding or conflicts with other uses. The process output of the shredder is limited to 377,800 tons of processed scrap per year in the Air Emission Permit. The proposed modification does not change the process output; therefore, the amount of barge traffic from the Pacific Street Yard will not change.

16. Erosion and Sedimentation. Give the acreage to be graded or excavated and the cubic yards of soil to be moved: 0 acres; 0 cubic yards. Describe any steep slopes or highly erodible soils and identify them on the site map. Describe any erosion and sedimentation control

measures to be used during and after project construction. There is no construction associated with the proposed Permit Amendment Project. Nearly all of the Pacific Street Yard outside of the buildings has been paved with high-strength concrete.

17. Water Quality – Surface-water Runoff. a. Compare the quantity and quality of site runoff before and after the project. Describe permanent

controls to manage or treat runoff. Describe any stormwater pollution prevention plans. There will be no change in the quantity or quality of site runoff after the Permit Amendment Project. Northern Metals holds National Pollutant Discharge Elimination System (NPDES)/State Disposal System (SDS) Permit MN0063380, November 1, 2009 (NPDES Permit). Pursuant to that permit, Northern Metals has adopted a number of source reduction best management practices in its Stormwater Pollution Prevention Plan. Northern Metals installed a stormwater collection and treatment system and paved almost all of the Pacific Street Yard when it installed the shredder, Metal Recycling Plant, and associated equipment. Most of the stormwater that falls on the site drains to the stormwater collection and treatment system. Currently, collected stormwater is either recycled for dust control or is treated and discharged to the Mississippi River. The stormwater collection system consists of 32 catch basins and manholes. These catch basins collect runoff before it has a chance to channelize and carry entrain sediments. Each catch basin includes a four-foot deep sump for capturing coarse sediment and metals. Catch basin sumps are relatively easy to inspect and clean out. Material removed from the sumps is processed on site to remove metals before disposal. Catch basins employ passive hydrocarbon collectors for holding back floating debris and oil in the sump. Seven-foot diameter underground pipes store stormwater runoff after it travels through the sump catch basins and skimmers. If a storm event exceeds the design capacity of the storage and treatment system, the incremental amount of stormwater overflows to the Pacific Street Yard outfall, which in turn discharges to the Mississippi River. Material removed from the underground storage pipes will be processed on site to remove available metals before disposal. The pipes act like an underground sedimentation pond, providing pretreatment of the stormwater before it goes through the filter system.


A pressurized sand filter system treats the collected stormwater following the underground storage pipes. The sand filter system is located in the Office/South Warehouse building, which allows for operation throughout the winter. The sand filters are designed to automatically backwash when a specified pressure drop through the filter is reached. The sediment laden backwash water discharges to a sediment containment system also located within the building. Backwash water is detained long enough to settle out the sediment from the filters. Excess water flows back into the stormwater collection system, upstream of the underground storage pipes. Sediments removed from the backwash containment system are analyzed for chemical characterization and disposed of off site at a regulated facility. The design of the existing stormwater system, approved by the MPCA at shredder startup, is capable of managing the stormwater runoff from the existing site. Northern Metals is not seeking to expand the area now managed by the existing stormwater system, so there will be no increase in hydraulic loading to the stormwater system. Northern Metals is not seeking to change any of the paved area or the very small unpaved area; therefore there will be no increase in hydraulic loading.

b. Identify routes and receiving water bodies for runoff from the site; include major downstream water bodies as well as the immediate receiving waters. Estimate impact runoff on the quality of receiving waters. Stormwater runoff from the Pacific Street Yard is discharged to the Mississippi River following on-site treatment. The Permit Amendment Project will not change the quality or quantity of runoff from the Pacific Street Yard.

18. Water Quality – Wastewater. a. Describe sources, composition and quantities of all sanitary, municipal and industrial wastewater

produced or treated at the site. The Pacific Street Yard generates and discharges only normal domestic sewage to the City’s sanitary sewer lines. The Permit Amendment Project will not affect sanitary or municipal wastewater produced. Wastewater is produced from the two Venturi scrubbers. The Permit Amendment Project will not change the process output in the Air Emission Permit for the shredder; therefore, the quantity of wastewater from the scrubbers is not expected to change. There are no non-stormwater discharges (other than for sanitary uses) from the Pacific Street Yard.

b. Describe waste treatment methods or pollution prevention efforts and give estimates of composition after treatment. Identify receiving waters, including major downstream water bodies (identifying any impaired waters), and estimate the discharge impact on the quality of receiving waters. If the project involves on-site sewage systems, discuss the suitability of site conditions for such systems. Wastewater from the two Venturi scrubbers is treated on site. The wastewater is evaporated in two evaporators located in the South Warehouse. The evaporators include oil/water separators to remove any oily waste prior to evaporation. Any waste oil from the oil/water separator would be shipped off site to a used oil recycler, although none has been generated to date. Any solid products that are collected in the bottom of the evaporators are put into 55-gallon drums, tested, and sent to an appropriate off-site treatment or disposal facility.


c. If wastes will be discharged into a publicly owned treatment facility, identify the facility, describe

any pretreatment provisions and discuss the facility’s ability to handle the volume and composition of wastes, identifying any improvements necessary. Not applicable.

19. Geologic hazards and soil conditions. a. Approximate depth (in feet) to Ground water: 10 minimum; 11 average. Bedrock: 50 minimum; 75 average.

Describe any of the following geologic site hazards to ground water and also identify them on the site map: sinkholes, shallow limestone formations or karst conditions. Describe measures to avoid or minimize environmental problems due to any of these hazards. Based on hydrogeologic investigations conducted for the Pacific Street Yard, approximately 50 to 100 feet of alluvial silt, sand, and gravel underlie the property. Nearly all of the Pacific Street Yard is paved with high-strength concrete to prevent infiltration to the subsurface. The area around and between the railroad tracks is paved with asphalt to prevent stormwater from penetrating to underlying soils.

b. Describe the soils on the site, giving Natural Resources Conservation Service classifications, if known. Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils. Discuss any mitigation measures to prevent such contamination. Not applicable.

20. Solid Wastes, Hazardous Wastes, Storage Tanks. a. Describe types, amounts and compositions of solid or hazardous wastes, including solid animal

manure, sludge and ash, produced during construction and operation. Identify method and location of disposal. For projects generating municipal solid waste, indicate if there is a source separation plan; describe how the project will be modified for recycling. If hazardous waste is generated, indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments. Processed shredder waste is stockpiled in the Rain and Snow Shed west of the barge dock (Attachment 3). Solid waste from metal processing is generally nonmetallic debris such as soil, plastics, rubber, cloth, paper, cardboard, and small pieces of wood. Solid waste collected from the two cyclones is included with the miscellaneous solid waste. Processed shredder waste is tested quarterly per state regulations and disposed of at a licensed landfill. Because of the higher proportion of waste materials in processed vehicles, processing vehicles may generate an estimated additional 1,250 tons per month of solid waste. The additional solid waste will be removed by three additional trucks per operating day. The composition of the solid waste is expected to be the same as waste material from shredding vehicle parts, which is currently allowed under the Air Emission Permit.


The 1,250 tons per month of additional solid waste is the estimated amount of waste material when shredding processed vehicles compared to vehicle parts. Processing vehicles produces upholstery and plastic waste because the entire vehicle is shredded. The estimated increase in solid waste was obtained from Northern Metals personnel with experience at other shredders that shred whole vehicles, and is consistent with other Minnesota and Michigan estimates of solid waste generation.2

b. Identify any toxic or hazardous materials to be used or present at the site and identify measures to be used to prevent them from contaminating ground water. If the use of toxic or hazardous materials will lead to a regulated waste, discharge or emission, discuss any alternatives considered to minimize or eliminate the waste, discharge or emission. Northern Metals prevents hazardous wastes, pollutants, and contaminants from entering the Pacific Street Yard through its Feedstock Control Plan, described in Item 23. Nearly the entire Pacific Street Yard is paved with high-strength concrete to prevent infiltration of materials to groundwater. The stormwater collection and treatment system controls runoff from the site. Although the facility currently shreds car parts and proposes to shred processed auto hulks, it does not accept used oil filters. As described in the Feedstock Control Plan, trained personnel remove any hazardous materials from scrap metals prior to processing in the shredder. Used circuit boards and other electronic components, mercury switches or devices, cathode ray tubes, and PCB ballasts and capacitors removed from scrap metal and scrap appliances are stored indoors prior to shipment. A small volume of used oil filters, used oil, lead acid batteries, and used antifreeze are generated by on-site maintenance of company equipment and vehicles. Table 20.b-1 provides a list of hazardous wastes and the estimated quantity generated annually.

Table 20.b-1

Hazardous Waste Materials

Waste Name Estimated Quantity Per Year

Cathode Ray Tubes 300 lb

Circuit Boards and Electronics Scrap 2000 lb

Machine Coolant 17350 gal

Mercury Switches & Probes Less than 1 lb

Parts Washing Solution 100 gal

Rags Contaminated with Chlorinated Solvent 400 lb

Used Antifreeze 200 gal

Used Fluorescent Lamps 30 lb

Used Lead Acid Batteries 500 lb

Used Oil 3000 gal

Used Oil Filters 200 lb

Used Oily Sorbent Material 1600 gal

Used PCB Ballasts and Capacitors Less than 20 lb

2 Conversation with Jon Spigel, Northern Metals, November 18, 2010.


Northern Metals also uses small quantities of hazardous materials for maintenance activities. These materials are listed in Table 20.b-2.

Table 20.b-2 Hazardous Materials Inventory List

Chemical/Product Name Location

Acetylene Gas Maintenance Building

Antifreeze Maintenance Building

Argoshield Gas Maintenance Building

Brake Cleaner Maintenance Building

Carbon Dioxide Gas Maintenance Building

Diesel Fuel Additive Maintenance Building

Gear & Chain Lube Fire Box in Maintenance Building

Glass Cleaner with ammonia Fire Box in Maintenance Building

Hydraulic Oil In shredder Equipment

Kerosene Maintenance Building/Shredder Building

Metal Degreaser & Carburetor Cleaner Fire Box in Maintenance Building

Metal Parts Cleaner Fire Box in Maintenance Building

Mineral Oil Electrical Transformers

New Motor/Hydraulic Oil in drums Maintenance Building/South Warehouse

Nitrogen Refrigerated Liquid Shredder Building

Oxygen Gas Maintenance Building

Propane Gas Maintenance Building

Repell Fire Box in Maintenance Building

Thrust Quick Starting Fluid Fire Box in Maintenance Building

Transmission Fluid Maintenance Building

Used Oily Floor Dry Maintenance Building

Used Oil Pads & Socks Maintenance Building

WD-40 Fire Box in Maintenance Building

50% Ethylene Glycol In shredder Equipment

0.2% Soda Ash Solution In shredder Equipment

c. Indicate the number, location, size and use of any above or below ground tanks to store petroleum products or other materials, except water. Describe any emergency response containment plans. Attachment 7 is a list of aboveground and underground storage tanks used to store petroleum products and other materials. The secondary containment method is indicated where applicable. Northern Metals has prepared and implemented a Spill Prevention, Control, and Countermeasures Plan for the Pacific Street Yard.


21. Traffic. Parking spaces added: 0 Existing spaces (if project involves expansion): NA Estimated total average daily traffic generated: Three trucks for shredder residue. Estimated maximum peak hour traffic generated and time of occurrence: NA

Indicate source of trip generation rates used in the estimates.

If the peak hour traffic generated exceeds 250 vehicles or the total daily trips exceeds 2,500, a traffic impact study must be prepared as part of the EAW. Using the format and procedures described in the Minnesota Department of Transportation’s Traffic Impact Study Guidance (available at http://www.oim.dot.state.mn.us/access/pdfs/Chapter%205.pdf) or a similar local guidance, provide an estimate of the impact on traffic congestion on affected roads and describe any traffic improvements necessary. The analysis must discuss the project’s impact on the regional transportation system. Because of the higher proportion of waste materials in processed vehicles, processing of vehicles may generate an estimated additional 1,250 tons per month of processed shredder waste. Up to three additional trucks per day may be utilized to haul the processed shredder waste to a licensed landfill. Because this is less than five percent of daily traffic from the Pacific Street Yard, there is no significant impact on traffic generated by the Permit Amendment Project. Although the Permit Amendment Project would allow Northern Metals to shred processed vehicles and aluminum, brass, copper, and stainless steel scrap in addition to the existing feedstocks, the removal of this restriction would not increase incoming deliveries of raw materials, or outgoing trucks with product shipments, because the process output limit of the shredder will be unchanged. The addition of these new feedstocks would replace part of the existing feedstock and therefore have no impact on traffic.

22. Vehicle-related Air Emissions. Estimate the effect of the project’s traffic generation on air quality, including carbon monoxide levels. Discuss the effect of traffic improvements or other mitigation measures on air quality impacts. Current loading and unloading operations produce vehicle related air emissions. The proposed Permit Amendment Project indicates an increase of up to three additional trucks per operating day to remove processed shredder waste. Because this is less than five percent of daily traffic from the Pacific Street Yard, this traffic will not cause a significant impact on air quality. As discussed above in Item 21, the process output tonnage of the shredder will be unchanged. The addition of new feedstocks would replace part of an existing feedstock and therefore have no impact on potential vehicle related air emissions. In summary, no significant change in vehicle related air emissions is expected from the Permit Amendment Project.

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


23. Stationary Source Air Emissions. Describe the type, sources, quantities and compositions of any

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

Northern Metals accepts limits on shredder emissions to avoid major source classification for the Title V Operating Permit program. The proposed permit does not change this classification. Stationary sources of air emissions at the Pacific Street Yard include the metal shredder and the cascade cleaning system. Insignificant sources include storage piles, paved roads, raw material handling, boilers, furnaces and space heaters for building heat, two evaporators to dispose of water from the Venturi scrubbers, collected metal turnings oil, and welding tools. All insignificant sources are listed in the appendix to the air permit, except the fugitive particulate sources (storage piles, paved roads, and raw material handling). These three activities are listed in the permit to ensure that they are managed according to the facility’s fugitive dust control plan. Fugitive dust emissions from raw material handling and paved roads are less than the originally proposed installation because the 1995 EAW studied and the Air Emission Permit was issued for a shredder built outdoors with paving only around the shredder and on roads within the Pacific Street Yard. However, as constructed, the shredder is housed inside the Shredder Building and all but a small fraction of the Pacific Street Yard has been paved. The Permit Amendment Project is not expected to increase the quantity or composition of fugitive dust emissions.

b. Air Pollution Control Devices

Pollution control equipment in the current Air Permit comprises three units – a high-efficiency cyclone on the hammermill shredder, a high-efficiency cyclone on the cascade cleaning system, and a common fabric filter following both cyclones. However, Northern Metals added additional control equipment after the current permit was issued. Therefore, as constructed and as described in the application to amend the permit, the shredder operates additional pollution control equipment that places duplicate control on two exhaust streams, one from the hammermill shredder and one from the cascade cleaning system. Each exhaust stream is controlled by a high-efficiency cyclone, Venturi scrubber, and a fabric filter. The controlled emissions from the two exhaust streams vent through a single stack.

c. Pollution Prevention Techniques

The Feedstock Control Plan describes how feedstock to the shredder is controlled. Northern Metals prevents hazardous wastes, pollutants, and contaminants from entering its Pacific Street Yard by its restrictions on incoming scrap material. For example, appliances that need further processing before shredding are not accepted at the Pacific Street Yard. Refrigerants used in certain appliances may include ozone-depleting chemicals. Appliances that contain refrigerants are not accepted until the refrigerants have been removed by a certified appliance recycler. Appliances that do not contain refrigerants and that have been further processed by Northern Metals’ trained employees are accepted at the Pacific Street Yard.


Northern Metals does not accept appliances that contain refrigerants at any of its facilities because it does not have the trained personnel or equipment necessary to remove refrigerants from appliances. At other Northern Metals facilities, except the Pacific Street Yard, Northern Metals will accept appliances with refrigerant removed but that need further processing to remove electronic components, such as capacitors and mercury switches, because Northern Metals has personnel trained to remove these components. At the Pacific Street Yard, Northern Metals will accept only fully processed appliances, either from suppliers or other Northern Metals facilities. This policy prevents accidental shredding of appliances that still contain electronic components. Northern Metals does not accept electronic waste or e-scrap at its facilities. Electronic or e-scrap includes any appliance or device used in the home or business that processes and displays information. Electronic appliances or devices are distinguished from other appliances by the presence of complex circuitry, circuit boards, or signal processing equipment. The Pacific Street Yard currently does not accept vehicles because they are prohibited under the terms of the current Air Emission Permit. The Permit Amendment Project includes a requested permit amendment to allow processed vehicles to be recycled in the shredder. Following the permit amendment, only vehicles processed by approved vehicle suppliers who have properly removed all refrigerants, fluids, and hazardous components (including mercury-containing devices) will be accepted for shredding at the Pacific Street Yard. Any vehicles accepted from other Northern Metals locations will be handled through its End of Life Vehicle (ELV) program which includes removal of all refrigerants, fluids, and hazardous components, including mercury containing devices. The Pacific Street Yard will not accept any vehicles with attached fuel tanks, pursuant to its Feedstock Control Plan. Northern Metals does not accept any radioactive materials at any of its facilities, including the Pacific Street Yard. The Yard operates a state-of-the-art radiation monitoring system to enforce this restriction. The truck scale and rail system are both equipped with the most advanced technology for detecting all types of radiation above background levels. Industrial smoke detectors, navigational equipment, spark gap indicators, thermostats, luminous signs, and ignition exciters are examples of scrap material that may contain radiation. To minimize explosions in the shredder and in other handling and processing equipment at its facilities, Northern Metals does not accept any explosive or flammable materials or containers that hold these materials. The Pacific Street Yard will accept containers that previously held explosive or flammable materials, but only if the container has been emptied and cut into two pieces. Compressed gas cylinders and oxygen bottles will only be accepted if the cylinder or bottle has been emptied and cut into two pieces, and the valves have been removed. Fuel tanks will only be accepted if the tanks have been separated from other materials, completely drained, and cut into two pieces. Northern Metals has a load inspection program that is described in its Feedstock Control Plan. All trucks entering and leaving the Pacific Street Yard are weighed on the incoming truck scale or the rail scale. The truck and rail scales are equipped with video cameras that feed to closed circuit televisions in the scale house that serves both scales. The scale operator visually inspects each load using the closed circuit televisions. When the scale operator sees materials in a load that does not meet Northern Metals specifications, the scale operator rejects the load, and it is returned to the supplier. After a load has been inspected and cleared by the scale operator, the scale operator then informs the load inspector and the crane operator by radio that a truck is coming to the crane area for unloading. The scale operator directs the driver to the appropriate unloading area. Generally, iron


and steel are unloaded in the yard’s open areas and nonferrous metals such as aluminum, brass, and copper are directed to one of the two nonferrous metals warehouses. The load inspector inspects every load when it is unloaded at the yard. The crane operator also continuously examines the material as it is unloaded with the overhead cranes. If the crane operator or any other yard personnel see materials that do not meet specifications, the material is immediately segregated. The load inspector performs an additional inspection on the segregated material. If the load inspector determines that material does not meet specifications, the yard supervisor or operations manager is notified, inspects the load, and notifies the environmental manager. The environmental manager pulls together the necessary information for documentation, and the rejection procedure is carried out. A third check of the materials is made by the shredder operator when the material is loaded into the shredder for processing. The shredder operator is stationed in a booth with a view of the material on the infeed conveyor. If the shredder operator sees material on the infeed conveyor that does not meet specifications, the shredder operator stops the conveyor until the material can be removed. The suppliers of any segregated materials are notified of the rejection and must pay for return transportation and any special handling costs.

d. Impacts on Air Quality--Criteria Pollutant Modeling (Particulates)

Northern Metals submitted a NAAQS Modeling Report with its major permit amendment application in August 2010. Modeling was conducted using the EPA’s AERMOD dispersion model (version 09292). The AERMOD modeling system includes a meteorological model (AERMET) and a terrain processing model (AERMAP). AERMOD also incorporates the PRIME building downwash algorithms for refined concentration calculations resulting from turbulent mixing due to building influences. The source, building, and receptor elevations were developed using AERMAP and a U.S. Geological Survey 10 meter National Elevation Dataset. MPCA pre-processed AERMET files were used, with surface meteorological data from the Minneapolis/St. Paul International Airport, Minnesota and concurrent upper air meteorological data from Chanhassen, Minnesota. The shredder has limits on its hours of operation, which were incorporated via AERMOD’s “hourly emission” option. This option allows the modeler to input a different emission rate for every hour in the period modeled (single year or five year combined) using a text file. A City CUP limits Northern Metals’ operating hours to 7:00 a.m. – 6:00 p.m. Mondays through Fridays and 9:00 a.m. – 6:00 p.m. on weekends and legal holidays. The hourly emission rate file had an emission rate of zero for the hours where the shredder was not allowed to operate. Emissions of PM10 and PM2.5 were modeled at the proposed emission rate of 4.2 pounds per hour. Hourly emission rates were modeled for comparison with both short-term PM10 and PM2.5 standards and the annual PM10 and PM2.5 standards. For the NAAQS modeling analysis, the shredder modeling results include the MPCA Option 1 background values for the Minneapolis/St. Paul Twin Cities area. The shredder building was determined to be the only influential building on the shredder stack and was included in the downwash analysis using the Building Profile Input Program. The location and dimensions were determined with the GIS tool ARCMAP and building design drawings.


The ambient air boundary was defined as the fence line around the Pacific Street Yard. Using MPCA guidance, ten meter spacing was used along the fence line with 50 meter spacing of receptors extending beyond the fence line to the edge of the industrial area. The industrial area was defined as the area from the fence line to the nearest residential area. From the edge of the industrial area out to one kilometer, the receptor spacing is 100 meters. The proposed emission rate limits modeled demonstrate attainment with the NAAQS and MAAQS standards, which are intended to protect human health. Modeling results are shown in Table 23.1 below, which also include impacts from fugitive sources FS002 (paved roads) and FS003 (raw material handling).

Table 23.1 Air Dispersion Modeling Results for Northern Metals, LLC

NAAQS/MAAQS Analysis

Pollutant Averaging

Time

Modeled Impacts (μg/m3)

Background Value

(μg/m3)

Total Predicted Impacts (μg/m3)

NAAQS (MAAQS) (μg/m3)

% of NAAQS

(MAAQS)

PM10 24-hour 12.07877 47 59.07877 150 39.39% Annual 1.46389 27 28.46389 (50) 56.93%

PM2.5 24-hour 8.92410 26 34.92410 35 99.78% Annual 1.57711 10 11.57711 15 77.18%

e. Air Emissions Risk Analysis (AERA) of Non-Criteria Pollutant Modeling (Air Toxics)

The MPCA developed the AERA process to provide for: (1) a standardized health review of facility air emissions; and (2) a consistent format for presenting the quantitative risk estimates, along with qualitative information to provide context to these risk estimates. An AERA estimates cancer and non-cancer risks to human health from a proposed project and/or an existing facility. Facility risk guidelines have been developed by the MPCA, in consultation with the MDH, which are generally consistent with EPA guidance. The guidelines for cancer-related risks were established such that the increased risk of a person getting cancer over the course of their lifetime due to exposure to the carcinogenic chemicals emitted from a given facility should not exceed 1 in 100,000 (1E-05). The non-cancer risks (called hazard quotients) are calculated by dividing the modeled air concentrations by the health benchmarks from the MDH, EPA, and the California EPA. The facility guideline for non-carcinogenic chemicals is that the sum of the hazard quotients (called the hazard index) should not exceed 1. If emissions from a facility result in estimated risks in excess of these levels, MPCA staff evaluates whether further refinement of the analysis, further investigation, modifications to the facility, or stricter air emissions limits, are warranted. All quantitative risk estimates have uncertainty related to the following factors: air emission estimates, air dispersion modeling, exposure assumptions, and toxicity information. These uncertainties are considered qualitatively within the AERA process and assumptions are made to minimize the potential for understanding risks. Interested readers can find more detailed information on the air risk analysis process at http://www.pca.state.mn.us/air/aera.html.

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


Potential health risks were characterized in the AERA from the existing shredder, as well as the shredder after the proposed permit modifications, for the pollutants in table 23.2 below.

Table 23.2 Summary of Potential Changes in Emission Rates used in the AERA

Pollutant Existing lb/hr Existing tons/yr Note

Proposed lb/hr

Proposed tons/yr Note

Potential tons/yr Increase

Antimony compounds 0.000086 0.00016 3 0.0024 0.0045 5 0.0044

Arsenic compounds 0.00052 0.0010 1 0.0024 0.0012 2 0.00023

Barium compounds 0.00033 0.00062 6 0.0011 0.0020 7 0.0014

Beryllium compounds 0.00022 0.00042 1 0.0072 0.0038 2 0.0034

Boron 0.0013 0.0025 6 0.0042 0.0079 7 0.0055

Cadmium compounds 0.00034 0.00064 1 0.0072 0.0025 2 0.0018

Hexavalent chromium 0.00031 0.00059 1 0.0021 0.00070 2 0.00011

Copper compounds 0.0040 0.0076 4 0.23 0.43 5 0.42

Lead compounds 0.00093 0.0018 1 0.02 0.0076 2 0.0058

Manganese compounds 0.0088 0.017 1 0.012 0.017 2 0

Mercury compounds 0.00079 0.0015 1 0.00079 0.0015 1 0

Nickel compounds 0.0041 0.0077 1 0.086 0.030 2 0.022

Selenium compounds 0.000028 0.000053 6 0.000091 0.00017 7 0.00012 TCDD Equivalents (PCBs/dioxins/furans) 5.42E-09 1.02E-08 8 8.68E-09 1.64E-08 9 6.14E-09

Vanadium oxide 0.00043 0.00081 3 0.012 0.023 5 0.022

Zinc compounds 0.023 0.043 6 0.12 0.23 5 0.19

*Calculation Notes 1 Current permit limit (lb/hr). 2 Calculated from proposed potential to emit (lb/hr) at 4.2 lb/hr PM or permit limit (tons/yr). 3 2% throughput limit mass balance calculation assuming current PM permit limit. 4 1% throughput limit mass balance calculation assuming current PM permit limit. 5 Worst case scenario based on 100% throughput (lb/hr at 4.2 lb/hr PM limit) of alternative feed stocks assuming ~95% throughput is metal (as tested) at the proposed permit limit plus a safety factor, since there will always be some percent that is dirt and other non-metallic feedstock. 6 Highest stack test value. 7 Highest stack test value at 4.2 lb/hr PM. 8 Highest detected stack test values and average instrument detection limits (when the pollutant was not detected). 9 Highest detected values or average instrument detection limit (when the pollutant was not detected) and a scalar of 1.6 to represent the potential 60% increase in non-metallic feedstock from processing auto hulks.

The pollutants listed above were modeled for the AERA similarly to what was done for the criteria pollutants. Short-term (hourly) modeling for the AERA showed the maximum impacts to be in areas zoned for industrial use along the western property boundary of the facility. Long-term (annual) modeling for the AERA showed the maximum impacts to be in areas zoned for industrial use along the eastern property boundary.


In addition to estimating maximum short and long-term risks, refined long term (chronic) risk estimates at the potentially most impacted area zoned residential (across the river) were also calculated. The maximum facility risk estimates were below facility risk guidelines, except for the urban gardener cancer risk estimates. Maximum urban gardener cancer risk estimates were found to be above facility risk guidelines. This finding led to a more in-depth (i.e., refined) analysis of the data. This led in turn to the finding that the area of maximum impact was not a residential area, and thus the urban gardener scenario would not be relevant. The residential area most impacted by the emissions was then identified, and the refined facility urban gardener cancer risk estimates at that location equaled the risk guidelines. The urban gardener cancer risk estimates were dominated by PCBs and dioxins/furans. The urban gardener exposure was assessed assuming a 70-year residence with consumption of home-grown produce (1.4 lbs/week), incidental soil ingestion (0.7 grams/week) plus the consumption of seven home-grown eggs per week. An additional analysis based on asbestos stack testing at the facility was conducted and cancer risk estimates from asbestos were found to be below risk driver levels (10 percent of a health risk benchmark) when compared to the EPA IRIS Health Benchmark for asbestos. MPCA staff confirmed the conclusion of the 1996 Health Risk Assessment that emissions from the facility would not impact fish tissue concentrations substantially in the Mississippi River. As is standard MPCA practice, tail pipe emissions from truck traffic moving on the property and insignificant sources were not included in the AERA. Since Minneapolis has an idling prevention ordinance, the facility does not foresee having the equivalent of two or more trucks idling continuously for an hour or longer, so emissions from trucks idling on the property were not included in the AERA.

f. Greenhouse Gases

Greenhouse gas emissions of carbon dioxide, methane, or nitrous oxide are not expected from the stationary sources of emissions at the Pacific Street Yard except from insignificant activities. Insignificant activities include boilers, furnaces and space heaters for building heat, two evaporators to dispose of water from the venturi scrubbers and collected metal turnings oil, and a small quantity of carbon dioxide used in maintenance for welding. The proposed Permit Amendment Project will not cause an increase in greenhouse gas emissions.

24. Odors, noise and dust. Will the project generate odors, noise or dust during construction or during operation? Yes No

If yes, describe sources, characteristics, duration, quantities or intensity and any proposed measures to

mitigate adverse impacts. Also identify locations of nearby sensitive receptors and estimate impacts on them. Discuss potential impacts on human health or quality of life. (Note: fugitive dust generated by operations may be discussed at item 23 instead of here.) Odors have not been demonstrated to be a concern during operation of the shredder. The Permit Amendment Project will not cause a change in odors generated from the shredder or the Pacific Street Yard.


Noise levels were evaluated according to the requirements in the Air Emission Permit. Noise measurements were taken in December 2009 across the river close to the nearest residential area, which is along North Marshall Street. Both the L10 and L50 Adjusted Source Noise Levels were found to be below the Sound Level Limit for Noise Area Class I. The changes requested in the Permit Amendment Project are not expected to increase noise levels from current levels. The dominant noise source determined by the 2009 measurements is the fans on the shredder building with additional contributions from crane engines and handling of feedstock and product. Noise levels from unloading compressed auto hulks may decrease compared to unloading of other scrap metal materials as auto hulks are loaded into the shredder with a crane mounted electromagnet and not dropped. The Permit Amendment Project indicates an increase of up to three additional trucks per operating day to remove processed shredder waste. Because this is less than five percent of daily traffic from the Pacific Street Yard, three trucks per day will not cause a significant impact on noise levels. In summary, the Permit Amendment Project is not anticipated to change the level of noise generated at the Pacific Street Yard. Fugitive dust emissions are discussed in Item 23.

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

measures to minimize or avoid adverse impacts. Archaeological, Historical and Architectural Resources The proposed Permit Amendment Project is on an existing site within an existing industrial park. The proposed Permit Amendment Project is not anticipated to result in disturbance of previously undeveloped or disturbed areas, and no cultural resources are known to exist on the Pacific Street Yard. The Minnesota State Historical Preservation Office (SHPO) was contacted on October 13, 2010, and information was requested regarding whether any historic or archaeological resources were present adjacent to the Pacific Street Yard or nearby. The search of the SHPO database was conducted for Township 29 North, Range 24 West, Section 10. Based on the results of the SHPO query to the Minnesota Archaeological Inventory, there are no archaeological resources in the area. The SHPO query to the Historic Structures Inventory for the section in which the Pacific Street Yard is located shows a number of structures in the area including private homes, concrete block rowhouses, businesses, two local churches, and the Lowry Avenue Bridge (currently being replaced with a new bridge). The closest listed structures are in Gluek Riverside Park, a home on Marshall Street, a home on 2nd Street, Shorty and Swede’s, and Hildebrand Store and Flat. Since the project involves no new construction, no impacts to these structures are expected from the Permit Amendment Project. Direct impacts to historic or archaeological resources on or within proximity to the Pacific Street Yard are not anticipated from the Permit Amendment Project. See Attachment 9.


Designated Parks, Recreation Areas, or Trails The current zoning of the Pacific Street Yard is I-3, heavy industrial, and there are no designated parks, recreation areas, or trails on the yard. At present, the closest parks to the Pacific Street Yard are Fairview Park to the west, on the other side of I-94, and Gluek Park to the east, on the other side of the Mississippi River. However, the Pacific Street Yard is in the area covered by the Above the Falls development plan, which is discussed in Item 27.

26. Visual impacts. Will the project create adverse visual impacts during construction or operation? Such as glare from intense lights, lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks? Yes No

27. Compatibility with plans and land use regulations. Is the project subject to an adopted local comprehensive plan, land use plan or regulation, or other applicable land use, water, or resource management plan of a local, regional, state or federal agency? Yes No

If yes, describe the plan, discuss its compatibility with the project and explain how any conflicts will be resolved. If no, explain. The following land use and development plans, that include the Upper River area of the Mississippi River, have been adopted by the City: • Above the Falls, 2000 • Industrial Land Use and Employment Policy Plan, November 2006 • The Minneapolis Plan for Sustainable Growth, October 2009 The Above the Falls land use management plan calls for a park corridor on both sides of the Mississippi River and anticipates a transition of the land use adjacent to the riverfront parks corridor to a mix of residential, office, light-industrial, and commercial uses and transition away from barging and heavy industry for the Upper River. The Minneapolis Plan for Sustainable Growth, Industrial Land Use and Employment Policy Plan, and the Above the Falls plans are guides for future development rather than prescriptive documents for short-term land uses. All proper land use permits have been obtained from the City for operation of the Pacific Street yard and the shredder. Therefore, Northern Metals may continue to operate the Pacific Street Yard and the shredder, even if the City changes the property’s zoning to prohibit industrial uses. At that point, the Pacific Street Yard and the shredder would become legal non-conforming uses, entitled to remain and even to be rebuilt if damaged or destroyed.

28. Impact on infrastructure and public services. Will new or expanded utilities, roads, other infrastructure or public services be required to serve the project? Yes No


29. Cumulative potential effects. Minn. R. 4410.1700, subp. 7, item B requires that the RGU consider the

“cumulative potential effects of related or anticipated future projects” when determining the need for an environmental impact statement. Identify any past, present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects. (Such future projects would be those that are actually planned or for which a basis of expectation has been laid.) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects. Air Quality Impacts Attachment 6 identifies 13 facilities within 1.5 kilometers and the Xcel Energy Riverside Plant at a distance of 2 kilometers as nearby point sources of air emissions. The majority of these facilities have registration permits, the exceptions being G & K Services, Diamond Vogel North Inc., GAF Materials Corp., Hard Chrome Inc., and the Xcel Energy Riverside Plant. Xcel Energy’s Riverside Plant was once a coal-fired electric generating facility, but is now natural gas-fired. G& K Services is a dry cleaner. Diamond Vogel North Inc. is a paint and urethane manufacturer. GAF Materials Corp manufactures asphalt roofing products. Hard Chrome Inc. is an electroplating facility. Air Toxics (Non-Criteria Pollutants) - To form a more complete picture of potential cumulative health risks from inhaling outside air pollution in the vicinity of Northern Metals, monitoring data from the nearest air toxics monitoring station and facility specific risk estimates from Hard Chrome, Inc. were considered along with potential risks from Northern Metals (Table 29.1). Of the facilities listed above, Hard Chrome Inc. has the most similar non-criteria pollutant emissions and is the only facility for which MPCA has air toxics modeling. The other facilities emit mostly volatile organic compounds, not metals. The City of Lakes monitor is approximately 3km south east of Northern Metals. It monitors pollutants from surrounding sources and distant emissions sources that contribute to a regional level of air pollution. Since there is no nearby nitrogen dioxide monitor, an average of risk estimates from Twin Cities nitrogen dioxide monitoring data was included. More information about the MPCA annual air monitoring network can be found in the air monitoring network plan at http://www.pca.state.mn.us/index.php/air/air-monitoring-and-reporting/air-emissions-and-monitoring/air-monitoring-network-plan.html. The cumulative inhalation risk estimates equaled facility risk guidelines (Hazard Index = 1) for respiratory effects and above facility risk guidelines for cancer. Inhalation cancer risk estimates from ambient air monitoring data are above facility risk guidelines (1 in 100,000 excess cancer risk) throughout the state but are within EPA’s excess cancer risk goal range of 1 in 1,000,000 to 1 in 10,000. The risk estimates from the incremental changes proposed were about four percent of the total summed cumulative inhalation cancer risk, five percent of chronic respiratory risk estimates, and nine percent of the total summed acute respiratory risk estimates. Overall risk estimates were similar to other facilities and areas in the state.

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

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


Table 29.1: Cumulative Inhalation Health Risk Estimates

Max Acute Respiratory Hazard Index

Max Chronic Respiratory Non-Cancer Hazard Index

Max Inhalation Cancer Risk

Risks from City of Lakes monitoring data and averaged nitrogen dioxide data

0.53 1.09 4.4 in 100,000

Hard Chrome Inc. screening risk estimates

0.49 0.05 0.2 in 100,000

Maximum Northern Metals risk estimates with the proposed permit changes

0.10 0.09 0.4 in 100,000

Total Cumulative Sum 1.12 1.23 5 in 100,000

Change in risks from proposal 0.10 0.06 0.2 in 100,000

% Contribution from proposal 9% 5% 4%

Criteria Pollutants – For criteria air pollutants PM10 and PM2.5 (see Table 23.1), background air concentrations were used pursuant to MPCA guidance. Those background air concentrations are intended to address cumulative impacts. The air dispersion modeling analysis determined that potential increases in air emissions from the proposed Project are expected to meet all ambient air quality standards (Table 23-1).

30. Other Potential Environmental Impacts. If the project may cause any adverse environmental impacts

not addressed by items 1 to 28, identify and discuss them here, along with any proposed mitigation. No other potential adverse environmental impacts were identified.

31. Summary of issues. List any impacts and issues identified above that may require further investigation before the project is begun. Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues, including those that have been or may be ordered as permit conditions.

No additional impacts or issues have been identified.

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SITE LOCATION MAPNorthern Metals, LLC

Minneapolis, Minnesota

Site Location

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USGS MAPNorthern Metals, LLC


Site Location

shredder buildingshredder stack

finished product

shredder intake conveyor

shredder feedstock

Mississippi River

new barge dock

stormwater outfall

rain and snowshed

north warehouse

truck exit

product conveyor

south warehouse

rail spur

shear material

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FACILITY PLAN VIEWNorthern Metals, LLC

Minneapolis, MN

Property Boundary

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Attachment 4

STORMWATERMANAGEMENT

Northern Metals, LLCMinneapolis, MN

+ Catch Basin

Stormwater Storage Pipe

Stormwater Outfall

Property Boundary

Attachment 5 Process Flow Diagram

Raw Material

Screening

Rejected Feedstock

Feedstock to Shredder

Shredder

Cascade Cleaning System

Processed Shredder Residue

Cyclone Scrubber* Baghouse

Cyclone

Scrubber*

Baghouse

Air Emissions (Limit: 4.2 lb PM/ PM10/ PM2.5/hr)

Evaporator (Approx. 1500 gal water/day)

Evaporator (Approx. 1500 gal water/day) MRP* (Unprocessed

Shredded Residue)

Separated Metal Products

(100 ton/hr Ferrous)

*Any solids removed from the scrubbers are sent to the Metal Recycling Plant (MRP) for further metallic extraction.

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Web Label

G&K Services

Graco Riverside

Hard Chrome Inc.

Cemstone Products

St. Olaf Residence

Marigold Foods Inc.

Moore NorthAmerica

GAF Materials Corp.

Northern Metals LLC

Pioneer Metal Finishing

Diamond Vogel North Inc.

Consolidated Container Co.

Xcel Energy - Riverside Generating Plant

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Attachment 6

NEARBY SOURCESNorthern Metals, LLC


Air Permit Type

!( Federal

!( Registration

!( Synthetic Minor (State)

^ Northern Metals LLC

Imagery: 2009 Aerials Express

Attachment 7

Inventory of Petroleum Storage Tanks

Tank ID

Type of Tank

Tank Location Tank Contents

Tank Capacity (gallons)

Secondary Containment

F1 AST Fueling Station No. 2 Diesel Fuel 500

Concrete containment 12’x26’x6”

F2 UST Fueling Station No. 2 Diesel Fuel 6,000 Steel, double walled

F3 UST Fueling Station Unleaded Gasoline 1,000 Steel, double walled

M1 AST North Warehouse Maintenance Area

SAE 10W30 Motor Oil 250 Containment 7’x3½’x6”


SAE 85W140 Lube Oil 250 Containment 18’x4’x2 ½’


HS 32 Hydraulic Oil 250 Containment 18’x4’x2 ½’


SAE 15W30 Motor Oil 250 Containment 18’x4’x2 ½’


SAE 30W Motor Oil 250 Containment 18’x4’x2 ½’

M7 AST North Warehouse Maintenance Area Used Motor Oil 265 Containment 6’x4’x1’

E1 AST Evaporator System and South Warehouse Oil/Water 2,600

Concrete Floor of Evaporator Room

E3 AST Evaporator System and South Warehouse Oil/Water 350


E4 AST Evaporator System and South Warehouse Oil/Water 350


E5 AST Evaporator System and South Warehouse Oil 200


E6 AST Evaporator System and South Warehouse Oil 1,500




Attachment 7 Inventory of Petroleum Storage Tanks Page 2

Tank ID

Type of Tank

Tank Location Tank Contents

Tank Capacity (gallons)

Secondary Containment





E10 AST Evaporator System and South Warehouse Hydraulic Oil 275


E11 AST Evaporator System and South Warehouse Hydraulic Oil 300


P10 UST Metal Turnings/ Borings Pad Oil/Water 5,500 Bermed Concrete Pad

P11 UST Metal Turnings/ Borings Pad Oil/Water 5,500 Bermed Concrete Pad

P12 AST Metal Turnings/ Borings Pad Oil/Water 1,000 Bermed Concrete Pad

ATTACHMENT 8

ATTACHMENT 9

ATTACHMENT 10

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Northern Metals Application for Major Permit Amendment EAW

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