p-ear2-27a
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:
2.
Proposer:
Northern Metals Application for Major Permit Amendment
Northern Metals, LLC
Contact Person
Stephen Ettinger
RGU:
Minnesota Pollution Control Agency
Contact Person
William Lynott
and Title
President
and Title
Planner Principal
Address
2800 Pacific Street North
Minneapolis, Minnesota 55411
Address
520 Lafayette Road North
St. Paul, Minnesota 55155-4194
Phone
Fax
E-mail
4.
3.
612-529-9221
612-529-5863
[email protected]
Phone
Fax
E-mail
651-757-2542
651-297-2343
[email protected]
Reason for EAW Preparation:
EIS
Scoping
Mandatory
EAW
Citizen
Petition
RGU
Discretion
Proposer
Volunteered
If EAW or EIS is mandatory give EQB rule category subpart number and name:
5.
Project Location:
SE
1/4
GPS Coordinates:
County
1/4
N
Section
45.010
Hennepin
10
City/Twp
Township
W
29 North
93.276
Tax Parcel Number
p-ear2-27a
TDD (for hearing and speech impaired only): 651-282-5332
Printed on recycled paper containing 30% fibers from paper recycled by consumers
X
NA
Minneapolis
Range
24 West
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)
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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Environmental Assessment
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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.
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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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.
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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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.
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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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.
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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•
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.
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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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
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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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.
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Minneapolis, Minnesota
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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.
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Minneapolis, Minnesota
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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.
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Minneapolis, Minnesota
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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.
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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Environmental Assessment
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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.
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Minneapolis, Minnesota
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7.
Project Magnitude Data
Total Project Area (acres)
Number of Residential
Units:
11.7
Unattached
0
or Length (miles)
Attached
0
Commercial/Industrial/Institutional Building Area (gross floor space):
Maximum Units Per
Building:
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
MPCA
9.
Type of Application
Major Air Permit Amendment
Status
Proposed Permit on Notice currently with
the EAW
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
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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Environmental Assessment
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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:
Types 1-8 wetlands
Wooded/forest
Brush/grassland
Cropland
Before
0
0
0
After
0
0
0
0
0
Lawn/landscaping
Impervious Surfaces
Stormwater pond
Other (describe)
Unpaved yard area
TOTAL
Before
0
11.53
0
After
0
11.53
0
.17
11.7
.17
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.
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Minneapolis, Minnesota
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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.
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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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.
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Minneapolis, Minnesota
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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 onsite 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.
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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:
Bedrock:
10
50
minimum;
minimum;
11
75
average.
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.
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Minneapolis, Minnesota
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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
2
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
Conversation with Jon Spigel, Northern Metals, November 18, 2010.
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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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
c.
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
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.
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Minneapolis, Minnesota
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21.
Traffic. Parking spaces added:
0
Existing spaces (if project involves expansion):
Estimated total average daily traffic generated:
Three trucks for shredder residue.
Estimated maximum peak hour traffic generated and time of occurrence:
NA
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.
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Minneapolis, Minnesota
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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.
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Minneapolis, Minnesota
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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
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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Environmental Assessment
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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.
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Minneapolis, Minnesota
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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
Total
% of
NAAQS
Modeled Background
Predicted
Averaging
Value
NAAQS
(MAAQS)
Pollutant
Impacts
Impacts
Time
3
)
(μg/m3)
(MAAQS)
(μg/m
(μg/m3)
(μg/m3)
24-hour
12.07877
47
59.07877
150
39.39%
PM10
Annual
1.46389
27
28.46389
(50)
56.93%
24-hour
8.92410
26
34.92410
35
99.78%
PM2.5
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.
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Minneapolis, Minnesota
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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
Existing lb/hr 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.
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Minneapolis, Minnesota
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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.
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Minneapolis, Minnesota
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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.
b.
c.
d.
e.
Archaeological, historical, or architectural resources?
Yes
No
Prime or unique farmlands or land within an agricultural preserve?
Designated parks, recreation areas, or trails?
Yes
No
Scenic views and vistas?
Yes
No
Other unique resources?
Yes
No
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.
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Minneapolis, Minnesota
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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 shortterm 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
Northern Metals Application for Major Permit Amendment
Minneapolis, Minnesota
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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-andmonitoring/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.
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Minneapolis, Minnesota
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Table 29.1: Cumulative Inhalation Health Risk Estimates
Max Acute
Max Chronic
Respiratory Hazard
Respiratory Non-Cancer Max Inhalation
Index
Hazard Index
Cancer Risk
Risks from City of Lakes
0.53
1.09
4.4 in 100,000
monitoring data and averaged
nitrogen dioxide data
Hard Chrome Inc. screening
0.49
0.05
0.2 in 100,000
risk estimates
Maximum Northern Metals risk
0.10
0.09
0.4 in 100,000
estimates with the proposed
permit changes
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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Minneapolis, Minnesota
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§
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¨
694
Brooklyn Park
§
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694
Fridley
Brooklyn Center
New Brighton
Hilltop
Crystal
§
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¨
Columbia Heights
Barr Footer: ArcGIS 10.0, 2011-11-01 07:51:32.134000 File: I:\Projects\23\27\1076\MAPS\Report_Maps\EAW_Nov2011\Attachment01 Site Location Map.mxd User: JJL2
94
47
Robbinsdale
Saint Anthony
Roseville
Site
Location
100
§
¦
¨
35W
Minneapolis
Golden Valley
55 Wright
§
¦
¨
Anoka
County
55
£
¤
35W
County
Lauderdale
952A
§
¦
¨
394
§
¦
¨
280
94
§
¦
¨
394
Hennepin
County
§
¦
¨
§
¦
¨
Site
Ramsey
County
494
394
Saint Paul
55
§
¦
¨
35W
Saint Louis Park
§
¦ §
¨
¦
¨
§
¦
¨
94
35W
Carver
County
35E
Scott
Dakota
County
;
!
Site Location
Attachment 1
N
1
Miles
0
1
SITE LOCATION MAP
Northern Metals, LLC
Minneapolis, Minnesota
Site Location
;
!
N
2,000
Feet
0
Attachment 2
2,000
USGS MAP
Northern Metals, LLC
Minneapolis, Minnesota
Barr Footer: ArcGIS 10.0, 2011-11-01 07:53:50.762000 File: I:\Projects\23\27\1076\MAPS\Report_Maps\EAW_Nov2011\Attachment02 USGS Map.mxd User: JJL2
Lowry Ave N
Mississippi River
31st Ave N
north
warehouse
site entrance
metal recovery
plant
shear material
rain and snow
shed
new barge dock
finished product
product conveyor
30th Ave N
shredder stack
shredder building
truck and railroad scales
shredder intake conveyor
N Pacific St
Barr Footer: ArcGIS 10.0, 2011-04-08 12:33:51.084000 File: I:\Projects\23\27\1076\MAPS\Report_Maps\EAW_Nov2011\Attachment03 Facility Plan View.mxd User: kac2
rail spur
shredder feedstock
truck exit
south
warehouse
office
stormwater outfall
28th Ave N
;
!
Property Boundary
Attachment 3
N
250
Feet
0
250
FACILITY PLAN VIEW
Northern Metals, LLC
Minneapolis, MN
Mississippi River
31st Ave N
Barr Footer: ArcGIS 10.0, 2011-11-01 09:20:07.917000 File: I:\Projects\23\27\1076\MAPS\Report_Maps\EAW_Nov2011\Attachment04 Stormwater Management.mxd User: JJL2
north
warehouse
metal recovery
plant
rain and snow
shed
+
+
+
+
30th Ave N
+
+
+
N Pacific St
+
+
+
+
+
+
south +
warehouse
+
stormwater outfall
28th Ave N
+
;
!
Catch Basin
Stormwater Storage Pipe
Stormwater Outfall
Property Boundary
Attachment 4
N
250
Feet
0
250
STORMWATER
MANAGEMENT
Northern Metals, LLC
Minneapolis, MN
Attachment 5
Process Flow Diagram
Raw Material
Rejected
Feedstock
Screening
Feedstock
to Shredder
Evaporator
(Approx. 1500 gal
water/day)
Shredder
Cyclone
Scrubber*
Baghouse
Air
Emissions
Cascade
Cleaning
System
MRP* (Unprocessed
Shredded Residue)
Separated Metal
Products
(100 ton/hr Ferrous)
Cyclone
Scrubber*
Evaporator
(Approx. 1500 gal
water/day)
Processed Shredder Residue
*Any solids removed from the scrubbers are sent to the Metal Recycling Plant (MRP) for further metallic extraction.
Baghouse
(Limit: 4.2 lb
PM/ PM10/
PM2.5/hr)
(
!
Xcel Energy - Riverside Generating Plant
1.5 KM Radius
Barr Footer: ArcGIS 10.0, 2011-11-01 08:21:41.266000 File: I:\Projects\23\27\1076\MAPS\Report_Maps\EAW_Nov2011\Attachment06 Nearby Sources.mxd User: JJL2
Consolidated Container Co.
(
!
(
!
(
!
(
!
GAF Materials Corp.
St. Olaf Residence
^
(
!
(
!
(
!
Cemstone Products
(
!
(
!
(
!
Northern Metals LLC
Web Label
G&K Services
Moore North
America
Hard Chrome Inc.
Marigold Foods Inc.
Diamond Vogel North Inc.
Pioneer Metal Finishing
(
!
(
!
Graco Riverside
Imagery: 2009 Aerials Express
;
!
Air Permit Type
(
!
Federal
(
!
Registration
(
!
Synthetic Minor (State)
^
1,500
Northern Metals LLC
Attachment 6
N
Feet
0
1,500
NEARBY SOURCES
Northern Metals, LLC
Minneapolis, Minnesota
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”
M3
AST
North Warehouse
Maintenance Area
SAE 85W140
Lube Oil
250
Containment 18’x4’x2 ½’
M4
AST
North Warehouse
Maintenance Area
HS 32
Hydraulic Oil
250
Containment 18’x4’x2 ½’
M5
AST
North Warehouse
Maintenance Area
SAE 15W30
Motor Oil
250
Containment 18’x4’x2 ½’
M6
AST
North Warehouse
Maintenance Area
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
Concrete Floor of
Evaporator Room
E4
AST
Evaporator System
and South Warehouse
Oil/Water
350
Concrete Floor of
Evaporator Room
E5
AST
Evaporator System
and South Warehouse
Oil
200
Concrete Floor of
Evaporator Room
E6
AST
Evaporator System
and South Warehouse
Oil
1,500
Concrete Floor of
Evaporator Room
E7
AST
Evaporator System
and South Warehouse
Oil
250
Concrete Floor of
Evaporator Room
Attachment 7
Inventory of Petroleum Storage Tanks
Page 2
Tank
ID
Type
of
Tank
E8
AST
E9
Tank Location
Tank
Contents
Tank
Capacity
(gallons)
Secondary Containment
Evaporator System
and South Warehouse
Oil
300
Concrete Floor of
Evaporator Room
AST
Evaporator System
and South Warehouse
Oil
400
Concrete Floor of
Evaporator Room
E10
AST
Evaporator System
and South Warehouse
Hydraulic Oil
275
Concrete Floor of
Evaporator Room
E11
AST
Evaporator System
and South Warehouse
Hydraulic Oil
300
Concrete Floor of
Evaporator Room
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