flint hills resources - marshall tank farm expansion

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ENVIRONMENTAL ASSESSMENT WORKSHEET Note to reviewers: The Environmental Assessment Worksheet (EAW) provides information about a project that may have the potential for significant environmental effects. This EAW was prepared by the Minnesota Pollution Control Agency (MPCA), acting as the Responsible Governmental Unit (RGU), to determine whether an Environmental Impact Statement (EIS) should be prepared. The project proposer supplied reasonably accessible data for, but did not complete the final worksheet. Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) Monitor. Comments on the EAW should address the accuracy and completeness of information, potential impacts that are reasonably expected to occur that warrant further investigation, and the need for an EIS. A copy of the EAW may be obtained from the MPCA by calling 651-297-8510. An electronic version of the completed EAW is available at the MPCA Web site http://www.pca.state.mn.us/news/eaw/index.html#open-eaw. 1. Project Title: Flint Hills Resources, LP – Marshall Tank Farm Expansion 2. Proposer: Flint Hills Resources, LP 3. RGU: Minnesota Pollution Control Agency Contact Person Camie Pederson, P.E. Contact Person Jim Sullivan and Title Sr. Environmental Engineer and Title Project Manager Address P.O. Box 64596 Address 520 Lafayette Road North St. Paul, Minnesota 55164 St. Paul, Minnesota 55155-4194 Phone 651-480-3966 Phone 651-297-1788 Fax 651-480-3874 Fax 651-297-2343 4. Reason for EAW Preparation:

EIS Scoping

Mandatory EAW

X

Citizen Petition

RGU Discretion

Proposer Volunteered

If EAW or EIS is mandatory give EQB rule category subpart number and

name: 4410.4300(10)(b) – Storage Facilities

5. Project Location: County Lyon City/Twp Marshall 1/4 SW 1/4 Section 33 Township T112N Range R41W

Flint Hills Resources, LLP - Environmental Assessment Marshall Tank Farm Expansion Worksheet Marshall, Minnesota 2

Attachments to the EAW: Attachment 1 – County map showing the general location of the project Attachment 3 – Site plan showing all significant project and natural features Attachment 2 – U.S. Geological Survey 7.5 minute, 1:24,000 scale map indicating project boundaries Attachment 4 – MPCA Option D Air Quality Permit Attachment 5 – Aerial photograph of the project site and surrounding land use Attachment 6 – Minnesota Department of Natural Resources (DNR) Natural Heritage and Nongame

Research program correspondence Attachment 7 – City of Marshall Wastewater Facility Correspondence Attachment 8 – Depth to bedrock map – well locations Attachment 9 – Depth to ground water map – well locations Attachment 10 – Soil map of the project site and surrounding area Attachment 11 – Material Safety Data Sheet – Asphalt Binder Attachment 12 – Minnesota Historical Society correspondence

6. Description:

a. Provide a project summary of 50 words or less to be published in the EQB Monitor. Flint Hills Resources, LP (FHR), proposes to construct two new storage tanks at its facility in Marshall, Minnesota. Tank #73 would have a capacity of 3,700,000 gallons and Tank #74 would have a capacity of 9,100,000 gallons. Both would be used to store asphalt cement. The tanks to be constructed are located within the footprint of the existing facility.

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. FHR plans to construct two new asphalt cement storage tanks, install a new 24-million British thermal unit heater, and associated piping and loading racks at its existing facility in Marshall, Minnesota. Tank #73 would have a capacity of 3,700,000 gallons and would be used to store asphalt cement. Tank #74 would have a capacity of 9,100,000 gallons and would be used to store asphalt cement. The existing FHR Marshall facility encompasses 10.4 acres. The new tanks will be built within the existing FHR Marshall property. The construction area will be approximately 1.0 acres, 0.25 of which will end up being the tank footprint for Tank #73 and 0.6 acres will end up being the tank footprint for Tank #74. These tanks are being constructed to provide asphalt cement storage capacity over the winter months. No additional process capacity or capabilities are being added to the facility. The tanks will be constructed in the area shown in Attachment 3. No significant demolition of existing structures is planned. One emulsion unloading dock will be demolished. The ten-day notification will be sent to the MPCA prior to the project. The dock is constructed of concrete with a metal railing; there is no insulation on the unload dock, therefore, there are no asbestos-containing materials (ACM) or presumed ACM on or near the unloading dock. Construction will involve excavation for the placement of the tank foundations, construction of the tanks, and installation of ancillary piping and pumps for the transfer of the asphalt cement to and from tanks. Construction activities will be contained within the boundaries of the existing facility and will generate minimal, if any, waste. No hazardous waste will be generated. Location and site maps for the proposed project are found in Attachments 1-3.


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. Asphalt cement is produced year round as a by-product of refining crude oil into gasoline, diesel fuel, and fuel oil. Very little road construction is conducted during the winter months in Minnesota or in other states in this region. The demand, therefore, for asphalt cement during the winter months is much less than the demand during the summer months. Since asphalt cement is produced year round, the price of asphalt cement during the winter months is lower due to a seasonal reduction in market demand. Construction of the new tanks will allow FHR to take advantage of the market situation. The new tanks will enable FHR to purchase and store asphalt cement during the winter months when prices are low, and to sell during the summer months when demand is higher.

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

e. Is this project a subsequent stage of an earlier project? Yes No If yes, briefly describe the past development, timeline and any past environmental review.

7. Project Magnitude Data Total Project Area (acres) 1.0 acre or Length (miles) Number of Residential

Units: Unattached

NA

Attached

NA

maximum units per building

NA

Commercial/Industrial/Institutional Building Area (gross floor space): total square feet NA Indicate area of specific uses (in square feet): Office Manufacturing Retail Other Industrial Storage Tanks – 0.25 and 0.6 acres Warehouse Institutional Light Industrial Agricultural Other Commercial (specify) Building height If over 2 stories, compare to heights of nearby buildings See Item 26 8. Permits and approvals required. List all known local, state and federal permits, approvals and

financial assistance for the project. Include modifications of any existing permits, governmental review of plans, and all direct and indirect forms of public financial assistance, including bond guarantees, Tax Increment Financing, and infrastructure.

Unit of Government Type of Application Status Marshall Fire Department Fire Plan Pending MPCA Option D Air Permit Existing (see Attachment 4) MPCA AST Permit modification Application to be submitted MPCA Construction Storm Water Permit Application to be submitted Marshall Municipal Utilities Water Discharge from Hydrostatic testing Application to be submitted


9. Land use. Describe current and recent past land use and development on the site and on adjacent

lands. Discuss project compatibility with adjacent and nearby land uses. Indicate whether any potential conflicts involve environmental matters. Identify any potential environmental hazards due to past site uses, such as soil contamination or abandoned storage tanks, or proximity to nearby hazardous liquid or gas pipelines. The site is completely developed and in use as a transfer, storage, and tank farm facility for asphalt products. Past land use has been as a transfer and asphalt storage facility for FHR. The majority of the area around the FHR Marshall facility is industrial and commercial, mixed with some agricultural areas (see Attachment 5). North side: McLaughlin & Schulz, Inc., sand, gravel, and hot mix cement facility; agricultural fields;

Archer Daniels Midland Ethanol production facility; Schwans Corporation production facility.

East side: Agricultural fields; one residence. South side: Rhinehart Food Service grain elevators; Becker Iron and Steel; True Value lumber yards;

Midco Supply Material and Distribution, Inc. West side: Railroad tracks; agricultural fields; John Deere farm implement dealer; Doug’s Auto Parts

(auto salvage yard).

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

Before After Before After Types 1-8 wetlands 0 0 Lawn/landscaping 2.3 1.45 Wooded/forest 0 0 Impervious Surfaces 8.2 9.05 Brush/grassland 0 0 Other (describe) 0 0 Cropland 0 0 TOTAL 10.5 10.5 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 site currently offers only extremely limited habitat for birds and mammals. There is a windbreak consisting of Poplar (Populus sp.) trees along the south property boundary between the tank farm and the conveyance channel. The vegetation within the windbreak consists of Kentucky blue grass and rye grass. Based on information provided by the DNR, the most likely animal species to be found on or near the FHR property would be those associated with agricultural and windbreak edge habitat. These include common birds such as the field sparrow, chipping sparrow, song sparrow, blue jay, cardinals, black birds, and crows. Common mammals would include chipmunk, squirrels, mice, rabbits, and transitional species such as deer, skunk, fox and raccoon. A copy of the DNR correspondence is found in Attachment 6.


b. Are any state (endangered or threatened) species, rare plant communities or other sensitive

ecological resources such as native prairie habitat, colonial waterbird nesting colonies or regionally rare plant communities on or near the site? Yes No

If yes, describe the resource and how it would be affected by the project. Indicate if a site survey of the resources has been conducted and describe the results. If the DNR Natural Heritage and Nongame Research program has been contacted give the correspondence

reference number. ERDB 20011111 Describe measures to minimize or avoid adverse impacts.

In 2001, the DNR Natural Heritage and Nongame Research program performed a review of the Minnesota Natural Heritage Database (see Attachment 6). That review showed no occurrence of rare species or natural communities within a one-mile radius of the FHR’s Marshall Facility.

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

(dredging, filling, stream diversion, outfall structure, diking, and impoundment) of any surface waters such as a lake, pond, wetland, stream or drainage ditch? Yes No If yes, identify water resource affected. Describe alternatives considered and proposed mitigation measures to minimize impacts. Give the DNR Protected Waters Inventory (PWI) number(s) if the water resources affected are on the PWI.

13. Water Use. Will the project involve installation or abandonment of any water wells, connection to or changes in any public water supply or appropriation of any ground or surface water (including dewatering)? Yes No If yes, as applicable, give location and purpose of any new wells; public supply affected, changes to be made, and water quantities to be used; the source, duration, quantity and purpose of any appropriations; and unique well numbers and DNR appropriation permit numbers, if known. Identify any existing and new wells on the site map. If there are no wells known on site, explain methodology used to determine.

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 facility is located in a Zone X area where the 100-year flood is less then one foot in depth.1 This type of flood would not present a concern to the integrity of the storage tanks.

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.

1 May 30, 2001, correspondence from the DNR – Marshall Office to Mark Bailey, Koch Pavement Solutions, regarding flood plain elevations.


16. Erosion and Sedimentation. Give the acreage to be graded or excavated and the cubic yards of soil to be moved: 1.0 acres; 18,500 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.

The proposed construction area is relatively flat. Silt fencing and other best management practices (BMPs) will be employed, as necessary, to prevent erosion and sedimentation discharges associated with the project. Gravel and/or vegetation will be used to stabilize surfaces disturbed during construction activities. Most of the soil excavated from the construction area will be used as engineered backfill or for secondary containment upgrades.

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 storm-water pollution prevention plans.

Construction of the asphalt cement storage tanks on the site will not significantly increase the impermeable area of the site. The impermeable area within the site will increase by 0.85 acres. The facility is covered by the State General Stormwater Permit for Industrial Discharges (MNG611000). BMPs described in the facilities existing Stormwater Pollution Prevention Plan will be sufficient to control existing, along with any additional, runoff due to the construction of the new tanks. Construction of the new tanks will not impact the quality of the runoff from this site as all of the runoff from the site remains within the secondary containment area.

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.

The site drains to a culvert located in the southeast corner of the FHR property. The culvert is fitted with a gate valve and discharges to a city storm culvert, which, in turn, discharges to the Redwood River. Due to the small increase in impervious area, this project is not expected to significantly increase the quantity or change the quality of surface water runoff from the site into the Redwood River.

18. Water Quality – Wastewater.

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

The existing site has septic tanks for sanitary wastewater generated from the site office. Boiler blowdown and condensate is removed off site by a transporter and taken to the city of Marshall wastewater treatment facility. There are no other wastewater streams generated by a facility. The proposed project will not generate any new wastewater streams. There will be a one-time discharge of hydrostatic test water from the new tanks after they are pressure tested. The hydrostatic testing water will be supplied by Marshall Municipal Utilities. FHR has contacted Gene Soderbeck from the MPCA, and no permit is needed to discharge clean water from the hydrostatic testing of the


tanks into the Redwood River as long as there is no chlorine in the water. The MPCA recommended letting the water sit in the tank for three to five days until the chlorine dissipates. The water will be tested for chlorine prior to discharge.

b. Describe waste treatment methods or pollution prevention efforts and give estimates of composition after treatment. Identify receiving waters, including major downstream water bodies, and estimate the discharge impact on the quality of receiving waters. If the project involves on-site sewage systems, discuss the suitability of site conditions for such systems. Sanitary wastes are collected in on-site septic tanks, and then it is transported to the city of Marshall wastewater treatment facility. Wastewater generated from boiler blowdown and condensate is stored on site and then transported to the city of Marshall wastewater treatment facility. In some cases, some brine solution from the water softener may be stored and shipped to the city of Marshall wastewater treatment facility. Approximately 4,000 gallons per year would be treated by the city of Marshall wastewater treatment facility. The city of Marshall has acknowledged the practice illustrated above in a March 21, 2007, correspondence (see Attachment 7).

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.

Wastes are not discharged to a publicly owned treatment facility; however, sanitary wastes, boiler blowdown and condensate, and brine solution are transported to the city of Marshall wastewater treatment facility. The city of Marshall does not require any pretreatment of the wastes. Approximately 4,000 gallons per year would be treated by the city of Marshall wastewater treatment facility.

d. If the project requires disposal of liquid animal manure, describe disposal technique and

location and discuss capacity to handle the volume and composition of manure. Identify any improvements necessary. Describe any required setbacks for land disposal systems.

Not applicable.

19. Geologic hazards and soil conditions. a. Approximate depth (in feet) to Ground water: 15 minimum; 17 average. Bedrock: 40 minimum; 64 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.

Depth to ground water and depth to bedrock are taken from nearest wells for which there are data in the County Well Index.2 The depth to bedrock and depth to ground water maps are found in Attachments 8 and 9, respectively.

2 The depth to bedrock was calculated using well log data collected from the Minnesota Department of Health County Well Index. Depth to bedrock data was collected by locating wells in the surrounding area and then identifying them through the use of a six-digit unique well number in the County Well Index system. The following wells were identified as part of the depth to bedrock analysis: 212788, 222351, 222352, 222353, 222359, 222360, 222361, and 239792. A depth to ground water was calculated in a similar method using data from wells 222352, 222353, 222359, and 222360. There are no known or suspected geologic site hazards on the FHR property.


b. Describe the soils on the site, giving U.S. Department of Agriculture (USDA) Soil Conservation

Service (SCS) classifications, if known. Discuss soil granularity and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils. Discuss any mitigation measures to prevent such contamination.

According to the USDA SCS, Lyon County, Minnesota, Soil Survey, the soils on the FHR property consist of the Lamoure silty clay loam (418). The soils adjacent to the FHR property are Canisteo clay loam (86) and LaPrairie silty clay loam (51) (see Attachment 10).

Lamoure clay loam (418) – This nearly level, poorly drained, calcareous soil is commonly found in flood plains that are a few feet higher than the rivers, creeks, and drainageways that dissect them. Typically, the surface layer is silty clay loam about 25 inches thick. It is black in the upper part and very dark gray in the lower part. The subsoil is grayish brown, mottled, friable clay loam about nine inches thick. The underlying material is to a depth of about 60 inches is grayish brown and light olive gray, mottled loam glacial till. Canisteo clay loam (86) – This nearly level, poorly drained, calcareous soil is on the rims of depressions and in other low, wet areas on the floor of the lowland plain. Lime has accumulated in the surface layer, which is grayish when dry. Typically, the surface layer is clay loam about 22 inches thick. It is black in the upper part and black and mottled with grayish brown in the lower part. The subsoil is grayish brown, mottled, friable clay loam about nine inches thick. The underlying material to a depth of 60 inches is grayish brown and light olive gray, mottled loam glacial till. LaPrairie silty clay loam (51) – This nearly level, moderately well-drained soil is on bottomland that is subject to occasional overflow. It is on the highest parts of the bottomland, mostly adjacent to the stream. Individual areas range from 10 to more than 200 acres in size. Typically, the surface layer is 200 acres in size and is about 30 inches thick. It is black loam in the upper part and very dark gray, calcareous loam in the lower part. The subsoil is dark grayish brown and very dark gray, calcareous, friable loam about 10 inches thick. The underlying material to a depth of about 60 inches is very dark grayish brown, mottled, calcareous, stratified silt loam and fine sand. There have been no major spills at the facility. Over the past 8 years, there have been 24 small spills, and all of the spills have been contained on the property. Fifteen of these involved asphalt cement, with 12 less than 10 gallons each and 3 larger spills of 30, 70, and 100 gallons. There were 3 fuel oil spills, with quantities less then 2 gallons, and a total cumulative amount spilled of 4.1 gallons. Three hot oil spills occurred at the facility with a total cumulative amount spilled of 24 gallons. There were also two sulfur spills (3 total gallons) and a soap spill (15 gallons). All of the spills were cleaned up and the wastes disposed of properly. There have been no lasting soil impacts and no ground-water impacts as a result of these spills.

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.


Construction activities will be contained within the boundaries of the existing facility and would generate minimal waste, which will be appropriately disposed of in the facility’s existing solid waste trash dumpsters or dumpsters provided by the contractor. Soil excavated for the tank foundation is expected to be used to level other areas on site.

The new tanks are located in an area where these has not been any historical activity. If historical contamination is encountered during the project, the MPCA would be contacted to report the release, work would be stopped, appropriate personal from within the company would be contacted, and a consultant would be contacted to evaluate the situation and address the contamination as appropriate.

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.

FHR’s Marshall Terminal is currently a very small quantity generator of hazardous waste (MND 982 645 822). The site currently generates about five gallons per year of waste methanol from the laboratory at the facility. The addition of the two new tanks should not create any change in the amount of hazardous waste generated by the facility. Various grades and specification of asphalt cements are currently, and will continue to be, stored at the facility. These products are stored in above-ground storage tanks (ASTs) with properly designed and maintained dikes or berms. All tanks will be tested prior to filling with asphalt cement and will be subject to regular inspection and testing to verify their integrity, according to the Spill Prevention, Control and Countermeasures Plan (SPCC) Plan and AST permit. A copy of the Material Safety Data Sheet for asphalt is found in Attachment 11.

c. Indicate the number, location, size and use of any above or below ground tanks to store petroleum products or other materials, except water. Describe any emergency response containment plans.

There are 47 existing ASTs on the site. These tanks store finished product asphalt emulsions, emulsion chemicals, fuel oil (for production purposes), and asphalt cement. Two additional asphalt cement storage tanks will be constructed at the facility – tank #73 will be 3,700,000 gallons and tank #74 will be 9,100,000 gallons. The location of the storage tanks and the proposed tank are shown on Attachment 3. An SPCC Plan for the existing facility was revised in August 2005. The SPCC Plan is available at the facility. The SPCC Plan will be amended when the new tanks are built. The SPCC Plan includes a spill contingency plan, secondary containment including berms and dikes, drainage systems, procedures for managing above-ground tanks, maintenance of AST integrity, mechanical integrity of piping, pumps and valves, the facility transfer operations, site security, personnel training and maintenance of records.


21. Traffic. Parking spaces added: 0 Existing spaces (if project involves expansion): 30-40 Estimated total average daily traffic generated: 100-150 Estimated maximum peak hour traffic generated (if known) and its

timing: Up to 10 trucks per hour between 7:00 a.m. and 4:00 p.m.

Provide an estimate of the impact on traffic congestion affected roads and describe any traffic improvements necessary. If the project is within the Twin Cities metropolitan area, discuss its impact on the regional transportation system.

For the majority of the year, the expansion will have no impact on traffic. The frequency of truck traffic will increase during winterfill operation (potentially on a 24-hour basis). Essentially, the additional winterfill tanks would allow FHR to take advantage of off-season asphalt cement supply. On average, there is approximately 5,000 tank truck deliveries made to the facility per year. Following installation of the new tanks, truck traffic will not increase; however, it would shift the timing of the deliveries to between December and March. Therefore, the truck traffic would decrease throughout the remainder of the year (there would be fewer asphalt cement deliveries during the spring, summer, and autumn months as a result of the new storage capacity provided by the winterfill tanks). The facility is located near U.S. Highways 59, 23, and 19. Trucks entering and leaving the facility would use North 7th Street, and either County Road 33 or Fairview Road to enter or leave U.S. Highways 59, 23, and 19. All local roads and U.S. Highways 59, 23, and 19 would be able to easily accommodate the seasonal increase in truck traffic expected during winterfill operations.

22. Vehicle-related Air Emissions. Estimate the effect of the project’s traffic generation on air quality, including carbon monoxide levels. Discuss the effect of traffic improvements or other mitigation measures on air quality impacts. Note: If the project involves 500 or more parking spaces, consult EAW Guidelines about whether a detailed air quality analysis is needed.

The net effect of the project will be no increase in vehicle-related air emissions. The new tank(s) will be filled once per year. The truck traffic from this one-time fill (usually in winter) will be the same as the previous operations, which consisted of regular receipts of asphalt throughout the summer. The market demand and resulting throughput of the facility are independent of the amount of storage available.

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.

The facility has several existing stationary sources consistent with the operation of an asphalt terminal. These consist of ASTs, combustion units (2 heaters and 1 boiler), 9 loading racks, and 14 unloading spots. The facility has an Option D registration air permit for its existing air sources. The project will involve the addition of two large ASTs and a hot oil heater. The addition of this equipment will not change the status of the Option D registration permit.


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.)

Construction is expected to last for eight to ten months. Construction will involve the use of heavy equipment to grade the location of the new tank, and heavy equipment to install the tank. Although dust control measures, such as wetting of roadways, will be used, some dust will be generated during grading. Typical heavy equipment construction noise will be generated during grading and construction. There will be minor amounts of fugitive asphalt fume emissions from the new tanks during winterfill operation and during the normal operation season (approximately April–November). Asphalt cement tanks are maintained at atmospheric pressure and fugitive emissions typically result as the vapor space in the tank is exchanged due to the addition or removal of product. Fugitive emissions typically consist of small amounts of semi-volatile organic compounds (less than 100 pounds per year). There are faint odors associated with asphalt fumes. The addition of the new tank is not expected to increase the concentration or duration of asphalt odors associated with the facility.

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

measures to minimize or avoid adverse impacts.

The Minnesota Historical Society was consulted in 2001 and no archaeological sites or historic structures were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for the Marshall facility (see Attachment 13). Agricultural farmland is located to the north, east and west of the site. Construction of the new tanks will not impact any of the nearby farmland. Justice Park is located 200 yards southeast of FHR. The park consists of a baseball/softball field and picnic area along the banks of the Redwood River. The current facility has no impact on the park. Addition of the new storage tank is not expected to have any impact on the use of Justice Park.

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


If yes, explain. During construction, there will be heavy earth moving equipment and large cranes at the facility. When finished, tank #73 will be approximately 48 feet high and 115 feet wide and tank #74 will be approximately 48 feet high and 180 feet wide. Although the tanks will be visible off site, they will not be the highest structures near the site. The highest structure currently on the site is 48 feet high. A grain elevator near the site, which is 50–60 feet in height, is the tallest structure in the area. FHR is located within a Zone I-2, General Industrial District. City of Marshall land use regulations allow structures within an I-2 area to be built to heights up to 75 feet, without any special approval.

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 FHR Marshall facility and the surrounding area are currently zoned as an I-2, General Industrial District. According to City of Marshall building officials, the use of the facility as an asphalt terminal is consistent with the I-2 zoning designation. In 1996, the City of Marshall published a Comprehensive Plan. In that plan the Marshall facility and surrounding areas are designated as industrial zones. There are not required building permits with the tank, only a revised Fire Plan to the Fire Department

28. Impact on infrastructure and public services. Will new or expanded utilities, roads, other infrastructure or public services be required to serve the project? Yes No If yes, describe the new or additional infrastructure or services needed. (Note: any infrastructure that is a connected action with respect to the project must be assessed in the EAW; see EAW Guidelines for details.)

A new transformer was requested for the site from Marshall Municipal Utility. More natural gas will be needed at the site to run the new heater, and it will be equipped with a fuel oil #2 backup.

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

“cumulative potential effects of related or anticipated future projects” when determining the need for an environmental impact statement. Identify any past, present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative impacts. Describe the nature of the cumulative impacts and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to cumulative impacts (or discuss each cumulative impact under appropriate item(s) elsewhere on this form). In order to assess the proposed project’s “cumulative potential effects of related or anticipated future projects,” the project proposers conducted an analysis that addressed other projects or operations in context to the potential direct or indirect impacts of the proposed Project that: (1) are already in existence or planned for the future; (2) are located in the surrounding area; and (3) might reasonably be expected to affect the same natural resources. FHR is not currently planning any actions in connection with the proposed project that have not been addressed in this evaluation. Because the impacts from this project are so minimal, we do not believe there is a potential for contribution to an adverse cumulative potential effect with other existing activities.


Further, as summarized below, FHR’s investigation has not identified any planned or likely projects that will occur in the same geographic area as the project. The following is a summary of the issues included in the overall cumulative effect analysis. Air Quality The project at the FHR Marshall facility will not change the status of the Option D Registration Permit (see item 23). There are two air emissions permits known to exist in the city of Marshall, based on a review of air permits issued by the MPCA – ADM Corn Processing and Marshall Sand and Gravel. ADM Corn Processing is located at 400 North Erie Road and is located approximately 0.5 miles northwest of the FHR facility. Marshall Sand and Gravel is located at 2191 County Road 74 and is located approximately 2.5 miles southwest of the FHR facility. The minimal emissions from the FHR project are not expected to contribute to or create an adverse cumulative potential effect with the other two facilities. There are no significant additional point sources of air emissions known to be proposed or planned in the vicinity of the proposed project. This information was gathered through the city of Marshall engineer, Glen Olson, and a review of the MPCA list of public notices. Water and Sewer The city of Marshall water service has a maximum daily capacity of 8 million gallons/day. According to Marshall Municipal Utilities the average total daily use is approximately 2.7 million gallons/day. There will be no change to the water appropriations at the facility because of the project; therefore, it is unlikely to cause or contribute to an adverse cumulative potential effect. (Please refer to items 16, 17, and 18 for additional information.) Sanitary waste is collected in on-site septic tanks, and then is transported to the city of Marshall wastewater treatment facility. Approximately 4,000 gallons per year would be treated by the city of Marshall wastewater treatment facility. There will be no change to the sanitary waste disposal system or the amount of wastes produced at the facility because of the project; therefore, it is unlikely to cause or contribute to any cumulative potential effects. Transportation Following installation of the new tanks, truck traffic will not increase; however, completion of the project would shift the timing of the deliveries to between December and March. Therefore, the truck traffic would decrease throughout the remainder of the year. (There would be fewer asphalt cement deliveries during the spring, summer, and autumn months as a result of the new storage capacity provided by the winter fill tanks. See also item 21.)

The facility is located near U.S. Highways 59, 23, and 19. Trucks entering and leaving the facility would use North 7th Street, and either County Road 33 or Fairview Road to enter or leave U.S. Highways 59, 23, and 19. All local roads and U.S. Highways 59, 23, and 19 would be able to easily accommodate the seasonal increase in truck traffic expected during winter fill operations.

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.

The project is not expected to cause any adverse environmental impacts.

flint hills resources - marshall tank farm expansion

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