### 1 Background Information for Lead Infrastructure SIP and
Lead Nonattainment SIP for Ea gan, Dakota Coun ty, Minnesota

Introduction

This document provides background information for the State Implementation Plan (SIP) revision developed by the Minnesota Pollution Control Agency (MPCA) to address the National Ambient Air Quality Standard (NAAQS) for lead promulgated in 2008. This SIP revision includes both the infrastructure SIP to meet the requ irements of sections 110(a)(1) and 110(a)(2) of the Clean Air Act (CAA) and the SIP requirements for nonattainment areas.

Infrastructure/110(a) Requirements for Lead NAAQS

This portion of the SIP revision addresses the infras tructure requirements of section 110(a)(1) and (2) of the Clean Air Act in regards to the National Ambient Air Quality Standard (NAAQS) for lead promulgated

in 2008.

Section 110(a)(1): A Plan Which Provides for Implementation, Maintena nce, and Enforcement

The Minnesota Pollution Control Agency (MPCA) has, in prior submittals, documented its authority and
ability to provide for the implementation, mainte nance and enforcement of primary and secondary standards, as well as to adopt enforceable emissi on limitations and control measures to meet the primary and secondary standards, and to update both state rules and the SIP as necessary.

The Minnesota statute that lays out the powers and duties of the MPCA (Minn. Stat. 116.07) states,

“The agency shall also adopt standards of air quality[.]”

It goes on to give the agency the authority to:

“[A]dopt, amend, and rescind rules and standards having the force of law relating to any purpose...for the prevention, abatement, or control of air pollution.”

This statute also gives the agency the authority to enter into or enforce orders, schedules of compliance
and stipulation agreements, to require owners or oper ators of emission facilities to install and operate
monitoring equipment and to conduct tests, and to conduct investigations, issue notices and order hearings as it deems necessary to discharge its duties.

Minn. Stat. 116.072, authorizes the agency to issue or ders and assess administrati ve penalties to correct violations of the agency’s statutes, rules and permits. The statute authorizes administrative penalties up to a maximum of $10,000 for all violations identified during an inspection or compliance review.

Minn. Stat. 115.071, subd. 1 provides that violations of the agency’s statutes, rules, standards, orders, stipulation agreements, schedules of compliance and permits may be remedied with criminal prosecution, action to recover civil penalties, injunction, action to compel performance or other appropriate action or any combination of the above. Civil penalties may be recovered up to a maximum of $10,000 per day of violation, except that for violat ions related to hazardous waste, the daily maximum is $25,000 per day of violation.

Minnesota’s SIP-approved air quality rules are implemented through these statutory authorities and broadly cover the criteria pollutants: “sulfur diox ide, particulate matter, nitrogen oxides, carbon monoxide, ozone, lead, and any other pollutants for which national ambient ai r quality standards have been established” and prohibit emissions that caus e or contribute to a violation of any ambient air
quality standard.

### 2 The remainder of this section lays out the requir ements of Section 110(a)(2) and how Minnesota’s SIP
meets those requirements.

Section 110(a)(2)(A): Emission Li mits and Other Control Measures

Minn. Stat. 116.07, subd. 4 gives the MPCA the authority to “[A]dopt, amend, and rescind rules and standards having the force of law relating to any purpose for the prevention, abatement, or control of air pollution.” Minn. Stat. 116.07, subd. 4a gives th e MPCA authority to “issue permits, under such conditions as it may prescribe for the prevention of po llution, for the emission of air contaminants, or for the installation or operation of any emission fac ility, air contaminant treatment facility, treatment facility, potential air contaminant stor age facility, or storage facility”.

Minnesota’s SIP already includes a pe rmit issued to Gopher Resource which contains emission limitations to meet the original 1.5 μg/m 3 

### standard set for lead. Also included in this submittal is Minnesota’s

nonattainment SIP for the 2008 sta ndard, which includes enforceabl e emission limitations which demonstrate modeled compliance with the 0.15 μg/m 3 

### standard. These emission limits apply at all times, even during periods of startup, shutdown and malfunction, and no variance provisions are included.

Section 110(a)(2)(B): Ambient Air Quality Monitoring/Data System

Minnesota has a network of ambient air quality monitors that operate to meet the requirements of 40 CFR pt. 58. Data from the monitors is submitted to EP A’s Air Quality System (AQS) in a timely manner. All

air toxics sites where TSP metals are me asured are also analyzed for lead.

The MPCA completes an annual monitoring plan desc ribing the existing ambient monitoring network and any proposed changes, and notifies EPA Region 5 of any proposed changes. The MPCA’s recent Annual Air Monitoring Network Plans can be found at: http://www.pca.state.mn.us/mvri439 . MPCA’s 2011 Source Oriented Lead monitoring plan can be found at: http://www.pca.state.mn.us/index.php/viewdocument.html?gid=394

. Section 110(a)(2)(C): Programs for Enforcement, PSD, and NSR

Minn. R. Ch. 7007 contains the requirements of th e MPCA’s permitting program, through which enforceable emission limitations are placed on fac ilities. Any NAAQS is an applicable requirement for
stationary sources. Minnesota is under a Federal Im plementation Plan (FIP) for the PSD permitting program, and so permits PSD sources under 40 CFR 52.21, under a delegation of authority from EPA.

As noted in EPA’s guidance for the lead infrastructure SIP, PSD programs should include provisions that address greenhouse gas (GHG) emissions consistent with EPA’s Tailoring Rule. Because the MPCA
administers the Federal PSD regulations under 40 CFR 52.21, including the regulations that contain the appropriate Federal threshold for the permitting of applicable GHG emitting sources, GHG emissions are being appropriate addressed.

Although EPA does not evaluated plans for nonattainment areas as part of infrastructure SIPs, Minnesota
has an approved nonattainment NSR program, which was approved by EPA in the Federal Register on February 23, 2004. Minn. R. 7007.4000 through 7007.4030 incorporate by reference the new source review requirements specified in 40 CFR 51, Appendix S.

In addition, the MPCA has the authority to issue enfo rceable orders to ensure attainment of the NAAQS,
as demonstrated in previous SIP revisions. Minn. R. 7009.0030 and 7009.0040 provide for enforcement
measures. Minnesota State chapter 116.07 provides MPCA with the authority to enforce any provisions of the chapter related to air contamination. These prov isions include: entering into orders; schedules of

### 3 compliance; stipulation agreements; requiring owners or operations of emissions facilities to install and operate monitoring equipment; and conducting investigations.

Section 110(a)(2)(D)(i): Inters tate Transport Provisions

EPA’s guidance for the 2008 lead NAAQS infrastructure SI P recognizes that, due to its physical properties, lead does not experience the same formation or tr ansport phenomenon seen with particulate matter or ozone. Significant impacts from lead emissions on ei ther nonattainment, maintenance, or visibility are expected to be limited to short distances from the so urce. This makes it very unlikely that a source would

emit lead in an amount that would contribute si gnificantly to nonattainment or interfere with

maintenance of the 2008 lead NAAQS in another state.

As demonstrated in Minnesota’s designation letter for the lead NAAQS, all of Minnesota’s monitors current show very low ambient lead levels. (With th e exception of the monito rs in the nonattainment area, which are discussed in the nonattainment SIP.) As shown in the source-oriented lead monitoring report, referenced above, the sources in Minnesota that have higher levels of lead emissions are not located close to any borders with other states. Disp ersion modeling shows that concentrations of lead are located very close to the sources. Therefore, sources in Minnesota are not shown to cause or contribute to nonattainment or maintenance problems in other states, or to interfere with visibility at

Minnesota’s Class I areas.

As mentioned above, Minnesota is already under a FIP for PSD, and operates an approved NA NSR permitting program.

Most of Minnesota’s larger lead sources are not lo cated close enough to Minnesota’s Class I areas to have an impact on visibility. The closest large sour ce is U.S. Steel Minntac. On December 30, 2011, EPA approved the MPCA’s request to waive ambient le ad monitoring at Minntac, based on modeling and analysis that showed few impacts. The MPCA ha s submitted a Regional Haze SIP for Minnesota.

Section 110(a)(2)(D)(ii): Interstate an d International Transport Provisions

Minnesota’s air management program contains adequate provisions to ensure compliance with Section 126 of the CAA relating to interstate pollution abatem ent. Neighboring states and/ or tribes are notified regarding new or modified sources. MPCA notes that section 115 of the CAA relates to international pollution abatement. Minnesota has no pending obligations under section 115.

Section 110(a)(2)(E): Adequate Pers onnel, Funding, and Authority

The Minnesota Pollution Control Agency is the agency responsible for developing, implementing, and enforcing the SIP. The MPCA’s Performance Partners hip Grant (PPG) Agreement with the EPA provides the MPCA’s assurances of resources to carry out cert ain air programs. Information on MPCA’s authorized spending by program, along with program priorities, can be found at http://www.pca.state.mn.us/ jsri3d6 . A brief overview of MPCA’s budget can be found at http://www.pca.stat e.mn.us/sbiz3d7

. The MPCA’s authority to enforce the NAAQS has been documented above.

In compliance with Section 128 of the Clean Air Ac t, Minn. R. 7000.9000 requi res any member of the MPCA Citizens’ Board to disclose any conflict of interest.

Section 110(a)(2)(F): Stationary So urce Monitoring and Reporting

Minn. R. 7007.0800, Subp. 4 lays ou t the monitoring requirements that are included in each permit for major stationary sources. Minnesot a Rules Chapter 7017 sets forth moni toring and testing requirements. Minnesota Rules Chapter 7019 contains the requirement for sources to annually submit an emission

### 4 inventory report to the MPCA. The report must cont ain information on all pollutants for which a NAAQS has been established, including lead.

Section 110(a)(2)(G): Emergency Episodes

Based on the inventory of lead sources and historic ambient monitoring data, the MPCA does not believe that specific contingency measures are generally n eeded for lead. Minn. Stat. 116.11 provides the MPCA with emergency powers, which is furt her elaborated in Minn. R. 7000.5000.

116.11 EMERGENCY POWERS.

If there is imminent and substantial danger to the health and welfare of the people of the state, or of any of them, as a result of the po llution of air, land, or water, the agency may by emergency order direct the immediate discontinuance or abatement of the pollution without notice and without a hearing or at the request of the agency, the attorney general may bring an action in the name of the state in the appropriate district court for a temporary restraining order to immediately abate or prevent the pollution. The agency order or temporary restraining order shall remain effective until notice, hearing, and determination pursuant to other provisions of law, or, in the interim, as otherwise ordered. A final order of the agency in these cases shall be appealable in accordance with chapter 14.

The Administrative Order issued to Gopher Resource does include contingency measures, as required.

Section 110(a)(2)(H): Fu ture SIP Revisions
The MPCA has submitted many updates to the existi ng SIP in the last several years, and intends to continue to submit updates as needed in order to ensure changes at ex isting facilities will not jeopardize the NAAQS, to comply with new or revised NAAQS, or as requested by EPA. The ability to adopt or rescind rules and standards related to air pollution is found in Minn. Stat. 116.07, subd. 4; the authority to issue permits to regulate air pollution can be found in subd. 4a.

Section 110(a)(2)(I): Nonattainment area plan or plan revision Under Part D

This SIP revision includes a nonattainment area plan for Minnesota’s lead nonattainment area, including an Administrative Order issued to Gopher Resource containing enforceable emission limitations.

Section 110(a)(2)(J): Consultation with government officials, public notification, PSD and visibility protection

The MPCA’s procedural rules are in Minnesota Rules Chapter 7000. Minn. R. 7007.0850 lists the public notice and comment procedures for the issuance of air quality permits. The public may petition for meetings and hearings, including contested case hearing (Mi nn. R. 7000.1800). Minn. R. 7007.0900 provides for review of part 70 permits by affected states. The MPCA regularly works with Federal Land Managers to discuss issues impacting Minnesota’s Cl ass I areas. Minnesota is under a FIP for the PSD

program.

The MPCA provides a public notice of all SIP revisions and offers the public to request a public meeting. A meeting is held when one is requested. In addition, the public may petition to have items placed on the agenda for the MPCA Citizens’ Board, as shown in Minn. R. 7000.0650.

Minnesota’s fulfillment of the requirements related to PSD and visibility have been discussed in other

sections.

### 5 Section 110(a)(2)(K): Air Quality Modeling Data

Under Minn. R. 7007.0500, Subp. 1E, the MPCA may no tify an applicant that it is required to

demonstrate that its emissions do not cause a viol ation of ambient air quality standards. The MPCA routinely requires such modeling and information on air modeling can be found at http://www.pca.state.mn.us/nwqh421

. Section 110(a)(2)(L): Permitting Fees

Minn. R. 7002.0005 through 7002.0085 lay out the air quality permitting fees.

Section 110(a)(2)(M): Consultation/parti cipation by affected local entities

The MPCA is the main agency that development, impl ements, and enforces the st ate air quality program. Under Minn. Stat. 116.05, other departments and agenci es are directed to cooperate with the MPCA and

the MPCA is authorized to work with them.

The Minnesota Administrative Procedures Act (Minn. Stat. Ch. 14) provides general notice and comment
procedures that are followed during SIP development. The MPCA provides a public notice of all SIP revisions and offers the public to request a public meeting. A meeting is held when one is requested. In addition, the public may petition to have items placed on the agenda for the MPCA Citizens’ Board, as

shown in Minn. R. 7000.0650.

### 6 Nonattainment SIP for Eagan, Dakota County, Minnesota

This portion of the SIP revision addresses the no nattainment requirements for the area of Dakota
County, Minnesota that has been designated as nonattainment with the National Ambient Air Quality Standard (NAAQS) for lead promulgated in 2008. Gopher Resource, LLC (formerly known as Gopher Smelting and Refining Company, and then Gopher Resources Corp), located at 685 Yankee Doodle Road 1



### in Eagan, is the only significant source in the nonattainment area.

Gopher Resource (GR) is a lead-acid battery recycling facility that began operation in 1946. GR owns and
operates a secondary lead smelter that includes scra p pretreatment, smelting, refining, and casting. Lead is recovered from lead-acid batteries, scrap from battery manufacturing plants, and miscellaneous lead bearing materials. The recovered lead is refined in to alloys and sold to a variety of customers.

Today GR takes in 40-50,000 batteries a day, processing and recycling more than 10 million lead-acid batteries each year from Chicago to the Rocky Moun tains and into central Canada. In 2011, GR shipped137,000 tons of lead, much of it going to new battery production. GR also recycles the plastic from leadacid battery casings, selling more than 18 millio n pounds of polypropylene pellets to plastic manufacturers each year.

Regulatory History

In 1978, the U.S. Environmental Protection Agency (EPA) set a NAAQS for lead of 1.5 μ g/m 3 

### . The area around Gopher Resource has been monitored for ambient lead levels since 1983. Based on the monitoring data, the area surrounding GR was designat ed by the EPA as violating this lead NAAQS on
January 6, 1992. EPA approved a SIP revision and re designation request for the area on October 18, 1994 (50 FR 52531). The revision included an Administra tive Order (Order) with emission limits and other
requirements for GR, which ensured attainment with the NAAQS.

On November 18, 2002, the MPCA submitted a SIP revi sion including a maintenance plan update for the area and a request for a change in enforceable docu ment for GR, from the Order to the facility’s Air Emission Permit, which serves as a joint Title I/Titl e V document. EPA did not act on this submittal. On November 19, 2007, the MPCA formally withdrew th e request to replace the Order with the joint
document, but asked that EPA cons ider the maintenance plan update. On June 3, 2008, EPA published a direct final approval of the maintenance plan (73 FR 31614).

On July 29, 2010, the MPCA again submitted a SIP revi sion to include the joint Title I/Title V document

and the SIP enforceable document. This Air Emissi on Permit (No. 03700016-003) replaced the previous
Order for the facility. EPA approved this SIP document in a direct final rule effective March 14, 2011 (76 FR 2263).

2008 NAAQS

The lead NAAQS was revised in October 2008 from a quarterly average of 1.5 μ g/m 3 

### to a 3-month rolling average of 0.15 μ g/m 3 

### (73 FR 66964). Monitoring data for the area near GR over the period of 2006-2008

showed an exceedance of this new NAAQS.

The MPCA submitted a designation recommendation to EPA in Oc tober 2009, recommending that the area around GR be designated as a nonattainment area. The supporting data, maps, rationale, and conclusions for the recommended designation areas were provided as a technical support document (TSD) with the designation letter. EPA approved Minnesota’s submittal and recommendations and

1 

### The facility previously had an addre ss of 3385 South Highway 149, Eagan; the facility has not moved, but the address was changed by the city to provid e greater clarity for emergency vehicles.

### 7 designated a nonattainment ar ea surrounding GR in Dakota County on November 16, 2010. 2 

### This is the only lead nonattainment area in Minnesota.

This SIP revision addresses the nonattainment area surrounding GR. As discussed above, this area was previously in nonattainment with the prior lead NAAQ S, and GR is already subject to SIP conditions to

control lead emissions. This SIP revision includes new and additional emission limits in an Administrative

Order for GR to ensure that the nonattainment ar ea comes into attainment with the new NAAQS.

The MPCA is requesting that the Order be incorporated into Minnesota’s SIP as an additional enforceable
document. The current SIP conditions, which were submitted in 2010 in a joint Title I /Title V document,
should also continue to apply, though in some cases they may be superseded by more stringent

conditions in the Order.

Facility Description and New Requirements

GR is a secondary lead smelter an d battery recycler, which conducts the following four major operations and miscellaneous sources: scrap pretreatment, smelting, refining and casting. Lead is recovered from lead-acid batteries, scrap from battery manufacturing plants, and miscellaneous lead bearing materials.

The recovered lead is refined into alloys that are sold to a variety of customers.

The Emission Units at the Facility that discharg e lead emissions to the atmosphere are: two reverberatory furnaces, a blast furnace, nine refi ning kettles, a hammermill, three desulfurization reactors, a drier for the lead oxide paste from desu lfurization, and fugitive emissions from the raw material handling and blast and reverberatory furnace areas. Further information on the sources of
emissions is provided in the Mo deling section of this document.

The lead emissions from the Emissi on Units are controlled by four systems of dust collectors (scrubbers, baghouses,or cartridge filters). The lead emissions then exit through the Sc rubber Stack (SV001) two Torit Stacks (SV002 and SV008) and the Main Stack (SV003). Nine refinery kettles with stacks SV009 through SV017 constitute a smaller source of emission s. Figure 1, below, provides a process diagram of the facility.

GR has been proactive in investigating and mitiga ting possible causes for high emissions. After promulgation of the new lead standard in 2008, GR contracted a study of fugitive lead emissions escaping leaks, vents and ports, and also the deposition of lead particles on hard surfaces. In response to the study, GR installed two new Torit ventilation/filtrati on units to control fugitive lead emissions in the Material Transfer Room (MTR), the Battery Receivi ng Dock Area (RMPC), and the afterburner tower. The

inclusion of these units and the se cond Torit stack (SV008), which was a dded to the SIP in 2010, has been a key component in reducing emissions from the facility. GR also added additional negative pressure above the blast and reverberatory furnace area enclosure.

2012 Secondary Lead Smelting NESHAP

It should be noted that GR is a secondary lead smelte r and, as such, is subject to the requirements of the

rule for National Emissions Standards for Hazard ous Air Pollutants (NESHAP) from Secondary Lead

Smelting. The NESHAP applies to bl ast, reverberatory, rotary, and el ectric furnaces; refining kettles;

agglomerating furnaces; dryers; process fugitive emissions sources; buildings containing lead bearing

materials; and fugitive dust sources at secondary lead smelters.

2 

### Documents relating to the designation can be viewed at http://www.epa.gov/leaddesignations/ 2008standards/rec/region5R.html

### 8 The NESHAP requires that sources maintain the conc entration of lead compou nds in any process vent

gas at or below 1.0 milligrams of lead per dry standard cubic meter (0.00043 grains of lead per dry

standard cubic foot) and the flow-weighted average conc entration of lead compounds in vent gases at or

below 0.20 milligrams of lead per dr y standard cubic meter (0.000087 grains of lead per dry standard

cubic foot). It also requires operation of sources of fugitive lead under negative pressure and some

specific work practices for reducing fugitive lead.

Compliance with the standard is required by January 6, 2014, which is prior to the attainment date for

the 2008 lead NAAQS.

New Stack Emission Limits

In this SIP revision, new, lower emission limits are be ing applied to the key stacks, as shown in the table

below.

Table 1: New Stack Emission Limits

Stack Current SIP Limit (lbs/hour) 3 

### New SIP Limit (lbs/hour) Converted SIP Limit (gr/dscf) 4



### Scrubber Stack

SV001 0.078 0.0388 0.00021

Torit Stack

SV002 1.2 0.877 0.00069

Main Stack

SV003 0.71 0.17 0.00019

Torit Stack

SV008 0.97 0.0529 0.00005

The new stack limits and stack parameters reflect an improved wet scrubber and new stack parameters (taller stack height and narrower stack diameter) for the scrubber stack and adjustments to the Torit

banks to ensure maximum filtration.

3 

### Current SIP limits are not necessarily expressed in lb s/hour, but the limits were converted to lbs/hour for
comparison to the new limits that are bein g imposed in the Administrative Order.

4 

### Conversion was made using modeled parameters as follows:

Source Exit Temperature (oF) Exit Ve locity (ft/sec) Stack Diameter (ft,
assumed round)

SV001 86 52.41 3

SV002 119 54.31 8

SV003 150 70.64 6

SV008 76 57.79 7

### 9 Figure 1: Gopher Resource Process Diagram

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### 10 Fugitive Emissions – Roads

Controlling fugitive emissions is a focus for this fac ility. The existing SIP contains many requirements designed to reduce fugitive emissions, including use of negative pressure in the buildings, sweeping,
traffic limitations, and ventilation.

The facility has undertaken work to minimize the ambient impacts of fugitive dust. This includes major changes in traffic patterns at the facility. For instan ce, GR is constructing a ne w driveway entrance and a new truck staging area, including a new load scale, for incoming scrap trucks and materials trucks. These changes generally serve to redirect truck traffic, redu cing traffic in the areas of the highest dust loading in order to reduce the re-entrainment of fugitive du st mostly likely to contain lead particles. These changes will be completed in the summer and fall of 2012 and are included in the modeling

demonstration.

The modeling demonstration relies on modeled emission rates for the lead in the fugitive dust based on sampling of certain traffic areas around the facility. The SIP already includes control of this source through scheduled sweeping and associated work practices. This SIP revision adds a condition for additional silt sampling of sections of the roads and driveways associated with the new and existing truck traffic configuration. If the sampling shows that the lead concentrations in the silt are much higher than modeled, GR must either propose actions to re duce lead loading or provide additional modeling to

demonstrate that the concentrations do not jeopardize attainment.

Fugitive Emissions – Inside

GR has begun work on additional controls inside the buildings to prevent fugitive dust emissions, and
these controls are being required in the Administrative Order. These include installing additional pressure gauges on the penthouses in the main process building, which enclose the blast furnace and afterburner tower, to monitor negative pressure and en sure it is maintained. GR is also being required to install and operate pressure gauge units on the exte rior walls of the containment, material transfer, battery breaking, and refinery rooms in the main processing building. These units will be monitored through GR’s process and operations management software, “Wonderware”, which includes a data

archive.

Another key component of the Administrative Order is requirements for additional inspection and monitoring. This includes inspection of the thickne ss of the “A” pipes between the blast furnace and the afterburner and the afterburner and the baghouse, and additional monitoring near the blast furnace through use of an infrared camera, thermocoupl e, and low-draft alarm. These should prevent malfunctions such as those which caused high ambi ent lead concentrations in August 2010, which are discussed further in the context of the monitoring data. Increased monitoring is also being required on the Torit filter cartridge cleaning cycles, to ensure th at the appropriate reverse air flow pulsing occurs as required for proper operation.

Finally, the Order also requires installation and operation of a negative pressure booth in the maintenance shop to capture lead fumes and particles that may result from tasks that require torching or welding on lead bearing materials. The fugitive so urces that are inside the buildings of the facility are
controlled by negative pressure and dust collectors that are vented to control devices and stacks (emission sources). There are also fugitive sour ces identified by modeling outside the buildings.

### 11 Refinery Stacks and Other Emission Sources

In addition to the large stack and fugitive emi ssions, GR included in the modeling demonstration emissions from the refinery stacks and the roof of the nearby plastics building (where plastic is recycled). The gases from the combustion of natural gas fuel us ed to melt the scrap lead in the refinery kettles have been vented individually to the roof. The modeled emissions for these sources were based on grab
samples. The modeling showed that these sources ha d a very low culpability when looking at a 24-hour averaging period. Therefore, the Administrative Orde r does not require additional controls on these

sources.

Reasonably Available Co ntrol Measures (RACM)

On March 19, 2012, EPA issued guidance for control measures to be included in nona ttainment SIPs. 5



### This guidance is meant to help states meet the requirements of Section 172(c)(1) of the CAA that
nonattainment SIPs “provide for the implementati on of all reasonably available control measures as expeditiously as practicable (including such reductions in emissions from existing sources in the area as
may be obtained through the adoption, at a minimu m, of reasonably available control technology) and
shall provide for the attainment of the NAAQS.”

EPA’s guidance indicates that the following controls measures are likely to be considered RACM for sources in the secondary lead smelting category: fabr ic filters, enclosure hoods and partial enclosures, negative pressure total enclosures, paving of roads a nd cleaning or wet suppression of roads and storage piles. EPA also indicates that fabric filters with downstream add-on controls and replacement of old fabric filters may be RACM.

The MPCA believes that the extensive controls at GR, which include the Torit filtration and extensive use of negative pressure and enclosure, exceed the requirements for RACM.

Contingency Measures

The Administrative Order includes four contingency me asures that can be implem ented if the area fails
to maintain the standard by De cember 2015, or if a violation of the standard happens after the

attainment date. The measures included in the Order replace the contingency measures in the existing

SIP.

The four options are: seal coating of the roadway, procuring of better sweeping equipment to remove fugitive dust, use of additional air monitors to identi fy sources of emissions, and routing of the flue gases from the nine refining kettles through a new stack and baghouse. This final option would prevent the

release of uncontrolled emissions in the event of a leak in a kettle.

GR may choose which option or options to implement. If GR chooses to implem ent one of the first three measures, they must do so within 30 days of notifi cation by the MPCA. If GR chooses to implement the more extensive option – routing of the stack gases through a new stack –a plan for implementation must
be provided within 30 days.

5 

### Implementation of the 2008 Lead National Ambient Air Quality Standards (NAAQS): Guide to Developing Reasonably Available Control Measures (RACM) for Controlling Lead Emissions http://epa.gov/air/lead/pdfs/2012ImplementationGuide.pdf

### 12 Air Monitoring Data

The area around GR has several monitors, including two monitors operated by the MPCA (at the 465 site) 6 

### and two monitors operated by GR (referred to as GRS-1 and GRS-2). The GRS-1 monitor is colocated with the two MPCA monitors to the southeast of the facility, while the GRS-2 monitor is located on the north boundary of the property. The GRS monito rs are TSP monitors, but they are non-regulatory, as the analytical method does not conform to the federal reference method or federal equivalent
method. These monitors are used by GR to moni tor fugitive emissions and to identify possible
breakdowns in the stack emissions controls. Despite the non-regulatory nature of these monitors, they can provide additional validation of the monitori ng results and address the issue of emissions
measurement where there is no regulatory monitoring data.

The table below shows the maximum rolling three-month average concentrations for the last three years
at the MPCA monitor. Based on this data, the de sign value for the area surrounding GR is 0.259 μg/m 3



### for the years 2009 – 2011. This is a significant drop from the design value for 2006 – 2008, the years of data used for the designation, which was 0.697μg/m 3



### . Table 2: Eagan (465) - Gopher Resource Maximum Rolling 3-Month Average Co ncentrations by Year (μg/m 3 

### ) 2009-2011

Nov –

Jan Dec –

Feb Jan –

Mar Feb –
Apr Mar –
May Apr –

Jun May –

Jul Jun –
Aug Jul -
Sep Aug -

Oct Sep -

Nov Oct -

Dec

2009* 0.139 0.221 0.253 0.232 0.189 0.143 0.250 0.226 0.219 0.116 0.095 0.117

2010 0.101 0.094 0.103 0.097 0.114 0.075 0.071 0.220 0.240 0.259 0.104 0.091

2011 0.068 0.108 0.096 0.104 0.053 0.068 0.077 0.080 0.073 0.068 0.070 0.058

*Data prior to 2010 utilizes a non-FEM analytic method



### This data demonstrates that the installation of th e additional Torit ventilation and filtration system (August 2009) represented a key step towards attain ing the new NAAQS and clearly showed a decrease

in airborne lead measured at the monitor.

Although the monitoring data shows that the area does not currently meet the NAAQS, the three-month rolling average concentrations from the most recent year, 2011, are all below the NAAQS. Therefore, the
area is likely to be able to a ttain the NAAQS by the end of 2013.

The graph below shows daily lead concentrations for 2011 from the MPCA 465 monitor, which have
generally all been below the NAAQS. As the graph show s, only four days have had concentrations above

the standard.

6 

### The EPA ID for th is site is 27-037-0465

### 13 Figure 2: Daily Lead Concentrations for 2011

The 2011 data is incomplete. No data was collected at the primary or co-located monitor in July 2011 (July 2, 8, 14, 20 and 26) due to a state government shutdown. Due to a malfunction, there was also a

loss of data from these monitors on September 24, 2011. Therefore, the data for the quarter does not
meet the 75% completeness criterio n. However, information from the GRS-1 monitor indicates that
ambient lead concentrations at the missing days were well below the standard. The recorded values at the GRS-1 monitor were: 0.057 (July 2), 0.045 (July 8) , 0.040 (July 20), and 0.040 (July 26). The value for Sept 24 was 0.021 μg/m 3 

### . The monitor did not collect data on July 14.

Data from the GRS-2 monitor at the north of the facility further supports the demonstration that

ambient concentrations have decreased and the most recently quarterly averages are below the standard. The design value of the GRS-2 monitor for 2009 to 2011 would be 0.222 μg/m 3



### Table 3: GRS-2 Maximum Rolling 3-Month Av erage Concentrations by Year (μg/m 3 

### ) 2009-2011

NovJan DecFeb JanMar FebApr MarMay AprJun MayJul JunAug Jul-Sep AugOct SeptNov OctDec

2009 0.056 0.105 0.113 0.117 0.080 0.085 0.086 0.066 0.052 0.047 0.080 0.053

2010 0.055 0.033 0.050 0.083 0.081 0.073 0.066 0.077 0.092 0.153 0.148 0.123

2011 0.034 0.012 0.037 0.080 0.147 0.222 0.203 0.170 0.084 0.094 0.084 0.069 

### 0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9Lead Concentration (μg/m3)

No samples due to State

of Minnesota government shutdown

### 14 High ambient lead values recorded at MPCA 465 in August 2010 and October 2010 impacted the resulting quarterly averages and will prevent the areas from demonstrating attainment until the end of 2013 at the earliest. An investigation of these exceed ances uncovered issues th at have been corrected and are addressed in the Administrative Order. For example, a value of 2.72 μg/m 3 

### was recorded at the MPCA’s monitor on August 24, 2010. GR identified the cause of this exceedance as a hole in the exterior “A pipe” that connects the afterburner and the west baghouse. This pipe is normally maintained under negative pressure, but there was a coincident loss of negative pressure. Several corrective measures are included in the Order to prevent a reoccurrence, including regular inspection of the A pipe and more monitoring near the blast furnace.

With the exception of the identified events, monitoring has indicated compliance with the NAAQS. Therefore, with the addition of more stringent emission limits and the work practices required by the
Administrative Order, the MPCA believes the area will attain the NAAQS by the December 2015

attainment date. The Administrative Order does include contingency measures to be implemented
should the area fail to attain the NAAQS.

Air Dispersion Modeling

Emissions from GR were modeled to estimate am bient concentrations. Modeling was conducted by ENVIRON International Corporation and reviewed by the MPCA. Modeling determined that the area of
maximum impact is below the 0.15 μ g/m 3 

### level of the standard, calculated as a 3-month rolling average.

Model Options

Modeling was conducted using the U.S. EPA’s A MS/E PA R egulatory Mod el (AERMOD), version 11353,
which is the EPA’s recommended air dispersion model as set forth in Appendix W of 40 CFR Part 51 (Guideline on Air Quality Models ). AERMOD’s pre-processors, AE RMET (version 11059) and AERMAP (version 11103), were also used in the modeling analysis. AERSURFACE (version 08009), EPA’s nonregulatory surface characteristics pr eprocessor, was used to determine the surface characteristics of the meteorological tower. BPIPPRM (Building Profile In put Program for PRIME) version 04274 was used to
calculate building downwash values.

Model options selected for this analysis were CONC, RURAL, and BETA. The BETA option was selected to represent one of the refinery stacks, RSTACK08, by selecting the source pathway keyword POINTCAP. There are no other capped stacks at this facility. The monthly average concentr ation was chosen for the
averaging time, as AERMOD currently does not suppo rt calculating the design value for lead. Instead EPA’s post-processing tool, LEADPOST (version 11237), wa s used to calculate the design value from the monthly AERMOD output.

Modeling utilized the Universal Transverse Mercator (UTM) coordinate system, with Zone 15 of the North American Datum of 1983 (NAD83) in the UTM coor dinate system. The units of the coordinates are

in meters.

Emissions and Source Parameters

The modeling of Gopher Resource emissions was based on actual and estimated actual emissions
provides by GR and their consultants at ENVIRON, and were approved by MP CA staff. A total of 116 sources of lead were modeled from the facility. There were 15 point sources and 101 volume sources. The point sources consisted of the main stack, two To rit stacks, a scrubber stack, nine refinery stacks, and two exhaust fans on the plastic recycling building on the north side of the facility. The nine stacks for the nine refinery kettles conduct the combustion gases from heating the kettles to individual roof vents

### 15 (SV 009 - SV017). The emission estimates for these emi ssion units in the operating permit are based not on stack testing, but on emission factors for natural gas combustion.

The two exhaust fans on the plastics building were removed from the Order because the plastics building
is owned by another company, Resource Plastics, and not by GR. These two vents were not included in the operating permit as emission sources. The st ack test numbers were very small and a culpability analysis of these two sources pr oduced a contribution of 0.01%.

The volume sources are traffic-related dust emission s and slag bins emissions. The modeling assumed

that emissions from volume sour ces were emitted between 7am and 11pm, with no emissions occurring between 11pm and 7am. All other sources were assu med to be emitting lead 8,760 hours a year. Silt load sampling was conducted on October 25, 2011 to determine the lead content of the fugitive dust on Gopher Resource’s facility roads. The results were th en incorporated into the emission calculations for

the road sources.

ENVIRON used the most recent compliance stack testi ng to determine the source release parameters for each point source for the facility. For the main stack, the two Torit st acks and the scrubber stack, the release parameters represented the average of three te st runs from the stack te st reports. The refinery
stack vents were based on a single test value.

The volume sources and their release parameters were included in the final modeling exercise in the
AERMOD Model. These volume sources mainly consist of fugitive road emissions from Gopher’s facility which were represented as a series of separated volume sources in the model. The individual volume sources for each road segment were combined into source groups for the model output files. The volume source input values were quantified acco rding to the USEPA’s recommended methodologies in

the AERMOD User’s Guide.

Meteorology

The meteorological data set sele cted for this analysis consists of the surface station at the Minneapolis/St. Paul International Airport, MN (MSP ) and of the upper air station at the Twin Cities National Weather Service (NWS) office in Chanhasse n, MN (MPX). The five year period of 2006 – 2010 was processed with AERMET and AERMINUTE (versi ons 11059), as well as AERSURFACE (version 08009).
1-minute ASOS data was available for this station during the 2006 – 2010 time frame, and was processed with AERMINUTE. This helped to reduce the amount of missing and calm hours, though these were within acceptable ranges to begin with. Surface ch aracteristics were determ ined using AERSURFACE version 08009 with National Land Cover Data 1992 (NL CD92) from the USGS Land Cover Institute.
Comparisons of recent aerial images and NLCD92 da ta reveal that surface characteristics around the meteorological surface station have had minimal cha nges. For more information regarding processing of meteorological data, please refer to th e MPCA’s Meteorological Data webpage ( http://www.pca.state.mn.us/wfhy422 ).

Background Concentration

Background concentrations were determined us ing data taken from the EPA’s AirData website ( http://www.epa.gov/airdata/ ) for Minnesota. A value of 0.01 μ g/m 3 

### was selected as the representative background concentration for the area. This value was used in the lead monitoring siting analysis conducted in 2009. Though quarterly and monthly values were not availabl e via the AirData page (as it was during the time of 2009 analysis), 24-hour monitored values ranged from 0.01 to 0.04 μ g/m 3 

### at nonsource oriented monitors. This s uggested that background lead levels had not changed significantly, and

### 16 it was decided to continue to use 0.01 μ g/m 3 

### , to remain consistent with the previous analysis. This value was then input into AERMOD and included in the source group ALL.

Receptors and Terrain

Terrain elevations were incorpor ated into the modeling by usin g AERMAP (version 11103). 1/3 arc
second National Elevation Dataset (NED) data was obta ined from the U.S. Geological Survey’s (USGS)

Seamless Data Server. AERMAP then assigned elevations to all sources, buildings, and receptors within the modeling domain. The city of Eagan is nest led between the Minnesota River and the Minnesota Valley National Wildlife/Recreation Area to the west of the facility, and the Mississippi River further to

the east.

Receptors were placed around the property line of Gopher Resource as access to the general public is limited by fencing around the facility. Receptors were placed at a spacing of 10 meters around the
property line. A nested Cartesian grid was used to ex tend the receptor grid from the facility itself to a distance of 5,000 meters, thus resulting in a 10 k ilometer by 10 kilometer grid centered on Gopher Resource. Receptor spacing is provided in the table below.

Table 4: Receptor Spacing

Receptor Spacing Distance from Center of Facility

10 meters Property line

25 meters 0 – 500 meters

50 meters 500 – 2,500 meters

250 meters 2,500 – 5,000 meters

Model Results

Table 5: Model Results

Source Max. 3-Month Rolling Average ( μ g/m 3 

### ) Background

Concentration ( μ g/m 3 

### ) Total NAAQS
Impact ( μ g/m 3 

### ) Pb NAAQS ( μ g/m 3 

### ) % of NAAQS

Gopher

Resource 0.118097 0.01 0.13 0.15 86.7%

As shown in Table 5 above, air dispersion modeling indicates compliance will be achieved with the lead NAAQS. The maximum 3-month rolling average concentrations at the property line show attainment

with a total concentration 0.128 μ g/m 3 

### . This supports the monitoring data from the facility that has measured compliance with the lead standard with the exception of malfunction in cidents. Therefore, the MPCA is confident that the SIP revision provided by this Administrative Order will assist the Facility to

attain the NAAQS.

### 17 Maps

Figure 3: Maximum Three-Month Average Concentrations at each Receptor

Figure 4: MPCA air dispersion modeling results

### 18 Figure 5: MPCA modeling overlaid on Google Earth map on area of maximum impact

Conclusion

Based on the monitoring and modeling information, the MPCA believes that the additional controls

being required at Gopher Resource will be sufficient for the surrounding nonattainment area to return to

attainment by the December 2015 deadline.

### 19 Attachments

Attachment 1: Administrative Order

Attachment 2: Emission Calculations

Attachment 3: Air Quality Dispersion Modeling Protocol

Attachment 4: Public notice

Attachment 5: Completeness Review

### 20 Attachment 1: Administrative Order

### 1 STATE OF MINNESOTA

Minnesota Pollution Control Agency

In the Matter of:

GOPHER RESOURCE, LLC. FINDINGS AND ORDER

Proceeding to Develop and Implemen t a State Implementation Plan

for Minnesota’s Lead Nonattainment Area to Demonstrate, Attain, and Maintain Compliance with the National Ambient Air Quality

Standards for Lead

The Commissioner of the Minnesota Pollution Control Agency (MPCA) and Gopher Resource, LLC (Gopher) enter into this Administrative Order by Co nsent for the Gopher Resource lead recycling facility (Facility), Eagan, Dakota Co unty, Minnesota, pursuant to Mi nn. Stat. 116.07, subd. 9 (2010).

FINDINGS

BACKGROUND

1. Section 109 of the Clean Air Act (CAA), 42 U.S.C. 7409, requires the U.S. En vironmental Protection Agency (EPA) to promulgate national ambient air quality standards (NAAQS). The EPA has promulgated NAAQS to protect the public health (primary standards) and the public welfare (secondary standards). 40 CFR 50.2 (2011).

2. Among other pollutants, the EPA has promulgate d primary and secondary NAAQS for lead. The primary and secondary NAAQS for lead, promulgate d in 2008, are 0.15 micrograms per cubic meter,

maximum arithmetic 3-month me an concentration for a 3-year period. 40 CFR 50.16 (2011).

3. Each state is obligated by Section 110(a) of th e CAA, 42 U.S.C. 7410, to develop a plan which provides for “implementation, maintenance and enforcement” of the NAAQS.

4. The EPA has promulgated requirements for implementation plans titled “Requirements for Preparation, Adoption and Submittal of Im plementation Plans.” 40 CFR pt. 51 (2011).

5. The MPCA is a statutory agency of the state of Minnesota, charged with the responsibility to administer and enforce laws and promulgate ru les to prevent water, air and land pollution throughout the state of Minnesota. Minn. Stat. Chs. 115, 115B and 116 (2011).

6. The MPCA is empowered to promulgate standards and rules “for the prevention, abatement, or control air pollution...Without limitation, rules or st andards may relate to source or emissions of air contamination or air pollution, to the quality or compos ition of such emissions, or to the quality of or composition of the ambient air or outdoor atmo sphere or to any other matter relevant to the prevention, abatement, or control of air po llution.” Minn. Stat. § 116.07, subd. 4 (2011). See also Minn. Stat. § 116.07, subd. 2 (2011).

7. The MPCA has the authority to enforce any statute or rule related to air pollution by, among other things, adopting, issuing, entering into or enforc ing “reasonable orders, schedules of compliance and stipulation agreements.” Minn. Stat. § 116.07, s ubd. 9 (2011). Specifically, the MPCA has the authority to enforce Minn. Rules 7009.0020 (2011) wh ich states that “No person shall emit any pollutant in such an amount or in such a manner as to cause or contribute to a violation of any ambient air quality standard beyond such person’s property line, provided however, that in the event the general public has access to the person’s property or portion thereof, the ambient air

### 2 quality standards shall apply in those locations.”

8. Based on monitored violations of the lead standa rd, the MPCA staff performed a computer modeling analysis of the major contributor of lead emissions in the state to determine the extent of the nonattainment area for the primary and secondary NAAQS for lead. This modeling was conducted in

accordance with the EPA Guideline on Air Qual ity Models, 40 CFR pt. 51, Appendix W (2011), and was developed using the AERMOD dispersion mo del version 09292. The MPCA submitted proposed

lead nonattainment area boundaries to the EPA on October 15, 2009.

9. The EPA has designated the area in Dakota County bounded by Lone Oak Road (County Road 26) to the north, County Road 63 to the east, Westcott Road to the south, and Lexington Avenue (County Road 43) to the west, as a nona ttainment area for the primary and secondary NAAQS for lead. 40 CFR 81.324 (2011).

10. This area was previously designa ted as nonattainment with the 1978 NAAQS for lead on January 6, 1992, but was redesignated to atta inment on October 18, 1994 (50 FR 52531). The area continues to attain the 1978 standard. 40 CFR 81.324 (2011).

11. The major contributor of lead emissions in the designated lead nonattainment area is the Gopher Resource, LLC, lead recycling facility located at 3385 South Highw ay 149 in Eagan, in Dakota County, Minnesota. Lead emissions from the Facility have contributed to a violation of the primary and secondary NAAQS for lead.

12. The MPCA staff reviewed and approved a comp uter modeling analysis of the Facility that

demonstrates that the nonattainme nt area will attain and maintain compliance with the lead NAAQS if the Facility is operated in compliance with the requirements of this Order. The modeling was

conducted in accordance with the EPA Guidelines on Air Quality Models, 40 CFR pt. 51, Appendix W (2011) and was developed using the AE RMOD dispersion model version 11353.

13. The Facility emits pollutants into the ambient air in sufficient quantities to require an air emission permit pursuant to Minn. Stat. § 116.081 (2011) and Minn. Rules pts. 7007.0100 through 7007.1850 (2011).

14. On June 29, 2010, the MPCA issued Air Em ission Permit No. 03700016-003 to Gopher Resource authorizing the operation of its facility under specif ied terms and conditions. Air Emission Permit No. 03700016-003 contains conditions, cited as “Title I Condition: State Implementation Plan (SIP) for Lead NAAQS” which are included in Minnesota’s SIP for lead to ensure compliance with the 1978 lead NAAQS. These SIP conditions do not expire.

15. These Title I SIP conditions remain in effect toda y, except where specifically superseded by the

issuance of this Order.

16. This Order imposes additional requirements for the Fa cility as specified in Pa rts I through VI below,

to assure that the state will achieve and ma intain compliance with the 2008 NAAQS for lead.

### 3 ORDER

NOW, THEREFORE, IT IS ORDERED AND AGREED:

17. For the purpose of demonstrating reasonable prog ress and attaining, demonstrating and maintaining compliance with the NAAQS for lead as set forth in 40 CFR 50.16 (2011), Gopher shall operate its secondary smelting facility (Facility) located in th e city of Eagan, Dakota County, Minnesota in compliance with the following requirements and limitations:

I. General Operating and Maintenance Requirements

a. “A” Pipe Inspection. Gopher shall inspect the “A” Pipes, which are the interior and exterior pipes between the blast furnace and the afterburner and the afterburner and the baghouse, by conducting metal thickness me asurements of each pipe each time the reverberatory furnace is rebricked. It is th e parties’ expectation that the reverberatory furnace will be rebricked every six to eight months.

i. Gopher shall record the date of each measurement and the metal thickness.

b. Negative Pressure Booth. Gopher shall insta ll and operate a negative pressure booth in the maintenance shop for tasks that requir e torching or welding on lead bearing

materials.

i. Negative pressure shall be checked visually, ensuring that the sliding canvas on the open side of the booth is pulling inward, indicating negative pressure.

c. Air Flow Units. Gopher shall install and op erate at all times pressure gauges on the penthouses in the main processing building to monitor and maintain negative pressure. Gopher shall also install and operate at all times pressure gauge units on the exterior walls of the containment, material transfer, battery breaking, and refinery rooms in the main processing building to maintain negative pressure.

i. These units shall be installed and operational by December 31, 2012.

ii. To ensure negative pressure is mainta ined, Gopher shall monitor these units through the use of process/operations management software, with alarms to alert operators of malfunction. Any malfunction shall be corrected immediately or as soon as possible after detection.

d. Infrared Camera. Gopher shall install and oper ate at all times a remote infrared camera

above the blast furnace and add a thermo couple and low-draft alarm to monitor temperature and air flow in the blast furnace.

i. The camera shall be visually moni tored in the blast furnace office.

ii. The thermocouple and low draft alarm in formation shall be monitored through the process/operations management software.

iii. Any malfunction shall be corrected immediately or as soon as possible after

detection.

e. Torit Cartridge Cleaning Cycles. Gopher shall monitor the frequency of reverse air flow cycles of all the Torit cartridge banks through the use of process/operations management software, magnehelic gauges and alarms to alert operators of malfunction. Any malfunction shall be corrected immediatel y or as soon as possible after detection.

### 4 II. Emission Limitations and Dispersion

a. Emissions of lead compounds from the scrubber stack, main stack, and Torit stacks shall not exceed the levels identified below (Tab le 1) as the emission limit in lb/hr.

Table 1: Emission Limits and Stack Parameters

Name Stack Vent

ID Emission Limit (lb/hr) Stack Height (ft) Stack

Diameter (ft) Stack Temperature (°F) Stack Exit Velocity (ft/s)

SCRUBBER STACK SV001 0.0388 58.40 2.33 86 52.41

TORIT STACK 01 SV002 0.877 80.05 8.01 119 54.31

MAIN STACK SV003 0.17 199.15 6.00 150 70.64

TORIT STACK 02 SV008 0.0529 80.05 6.99 76 57.79

b. The stack parameters for each stack (height, diameter, temperature, and exit velocity) listed in Table 1 represent the minimum lead dispersion characteristics that Gopher must

meet.

i. If a performance test conducted under Part III shows a stack temperature or exit velocity that is more than 10% lower than the values shown in Table 1, Gopher shall notify the MPCA of that result in the performance test report required

under Minn. R. 7017.2035.

ii. Gopher shall, within 60 days of the submission of a performance test report indicating low flow or temperature as described in Part II.b.i, provide a demonstration that the conditions of the performance test demonstrated equivalent or better dispersion to that provided by the parameters in Table 1, or provide a demonstration that the change in dispersion will not jeopardize the

area’s return to and maintenance of attainment status.

III. Compliance Demonstration. Gopher shall demons trate compliance at the subject stacks by conducting annual stack tests using the applicable test methods for lead compounds described in

40 CFR 63.547.

a. Annual Compliance Tests. Each calendar year, Gopher shall conduct a performance test to demonstrate compliance with the emission limits in Table 1. Performance testing shall

be conducted a minimum of six months and a maximum of 18 months between tests.

b. Performance tests shall be conducted in compliance with Minn. R. 7017.2001 through 7017.2060, and using methodology and under such conditions as the Commissioner specifies in the Commissioner’s test plan approval.

IV. Fugitive Dust Measurement. Gopher shall conduct sampling to determine the level of lead compounds present in the dust on the paved surfaces at the Facility, in order to ensure that the air dispersion modeling accurately represents this fugitive lead source.

### 5 a. The facility shall conduct on-site lead load testing for each identified road segment shown in the map in Appendix 1. Each road segment shall be tested once. This testing is a one-time requirement.

i. Prior to beginning the testing, Gopher shall provide to the MPCA a performance test plan in accordance with Minn. R. 7017.2030.

1. The test plan shall provide a schedule for testing each identified road segment such that all road segments have been tested by December 31,

2013.

ii. The testing shall be conducted using the s ilt load test method in Appendix C.1 and C.2 of AP-42, EPA’s Compilation of Air Pollutant Emission Factors to determine the silt loading in g/m 2 

### , the lead content of that silt, and the subsequent load of lead in silt in g/m 2



### .

iii. The Company shall keep records of all si lt load testing and lead concentration

values.

b. If the tested load values of le ad in silt expressed in g/m 2 

### are found to be more than 10% greater than the values shown in the column labeled “Pb surface loading in silt” of the table in Appendix 1, Gopher shall notify the MPCA of that result in the performance test report required under Minn. R. 7017.2035 and sh all, within 60 days of the submission of the performance test report, propose subsequent actions to either reduce the loading of lead compounds in the silt on the roadway or provide a demonstration that the lead concentrations will not jeopardize the area’s return to and maintenance of attainment

status.

i. A copy of the performance test report and any necessary proposed subsequent actions shall be sent to the Supervisor of the Air Policy Unit at the MPCA.

V. Contingency Measures.

a. In the event that the nonattainment area in which Gopher is located fails to attain compliance with the 2008 lead NAAQS by December 2015, or if a violation of the lead
NAAQS occurs after December 2015, one or mo re of the following contingency measures shall be implemented.

i. Gopher shall conduct seal coating of existing asphalt roadway surfaces;

ii. Gopher shall procure and operate an impr oved efficiency ‘air sweeper’ truck to improve the removal of fugitive lead particles from hard surfaces;

iii. Gopher shall conduct additional air monitoring at the Facility with fixed or mobile monitors to identify possible sour ces of fugitive lead emissions that may

cause or contribute to the monitored exceedance of th e NAAQS. Within 90 days of completion of the monitoring, Gopher shall provide to the MPCA the results of the monitoring, including an identification of the likely sources of fugitive lead emissions and plans for controlling those emissions;

iv. Gopher shall route the flue gases from the refining kettles through a particulate

matter control device.

### 6 b. If Gopher chooses to implement one of contingency measures i. through iii., Gopher shall implement the chosen measure within 30 days following formal determination and notification of a violation by the MPCA or EPA.

c. If Gopher chooses to implement contingency measure iv, Gopher shall, within 30 days following formal determination and notification of a violation, provide to MPCA a plan and schedule for implementation.

d. Gopher shall notify MPCA of the chosen co ntingency measure and keep records of all contingency measures undertaken.

e. These contingency measures supersede and re place the contingency plan requirements cited as “Title I Condition: State Implementation Plan (SIP) for Lead NAAQS” in Air

Emission Permit No. 03700016-003.

VI. Recordkeeping

a. Gopher shall maintain electronic files of all in formation required by this Order in a form suitable for determination of Gopher’s compliance with this Order by EPA or MPCA staff and readily available for EPA or MPCA insp ection and review. Gopher shall retain the records for a minimum of five years follo wing the date on which the record was generated. The most recent two years of information must be kept on site.

General.

18. This Order does not relieve the Company of the oblig ation, in undertaking all actions required by this Order, to comply with applicable local, state, and federal laws and regulations, including, but not limited to, federal new source performance sta ndards, and laws and regulations related to occupational safety and health.

19. Nothing in this Order shall relieve Gopher of its obligation to meet permitting requirements for any physical or operational ch ange at its facility.

20. This Order shall be binding upon the Company and it s respective officers, employees, successors and assigns. The Company shall provide a copy of this Or der to any successor in interest prior to transfer of that interest, and shall simultaneously inform th e MPCA that this notice has been given. Should the Company sell or otherwise convey or assign any of its right, title or interest in the Facility, such conveyance shall not release the Company from any obligation imposed by this Order, unless the party to whom the right, title or interest has been transferred or assigned agrees in writing to fulfill the obligations of this Order and the MPCA approv es such transfer or a ssignment. The MPCA may disapprove a transfer or assignment if information demonstrates that the new owner lacks the ability or intent to fulfill the obligation of this Order.

21. This Order mandates actions and establishes limits necessary for the Company to attain, maintain and verify the state’s compliance with the lead NA AQS. To the extent that any federal or state statute, rule, permit, order, stipulation agreemen t, consent decree or schedule of compliance now in force or subsequently issued imposes limits and requ ires actions additional to those required in this Order, the Company shall comply wi th the additional requirements of the federal or state statute, rule, permit, order, stipulation agreement, consent decree or schedule of compliance.

22. This Order by Consent is effective upon the date th at it is signed by the MPCA Commissioner or his designee.

### 23. By their signatures below, the signatories to this Order represent that they have authority to enter

into and bind their respective parties.



### RESERVATION OF AUTHORITY

Nothing in this Order shall prevent the MPCA from taking action to enforce the requirements of this

Order, or from requiring additional action by the Regulated Party if necessary to ensure compliance with

the National Ambient Air Quality Standards and other MPCA rules and statutes.



### IT IS SO ORDERED AND AGREED.



### Gopher Resource, LLC Minnesota Pollution Control Agency



### J Line Stme

Chief Operating Officer Commissioner

Dated :

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_ 1

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____ _



### 7

### 8 Appendix 1: Road Sources

Segment Length (ft) Modeled Emission

Rate/Volume Source (g Pb/sec) Modeled Emission Rate/Segment

(g Pb/sec) Silt Loading (g/m 2 

### silt) Pb surface loading in silt

(g/m 2 

### Pb)

AB 337 1.46E-05 1.46E-04 1.46 1.56E-02

BC 345 1.41E-05 1.41E-04 1.46 1.56E-02

CD 264 3.68E-06 2.94E-05 1.03 2.48E-02

DE 402 4.67E-07 5.60E-06 1.03 2.48E-02

BF 216 5.16E-06 3.10E-05 4.42 9.50E-02

CG 363 1.84E-05 2.02E-04 1.03 2.48E-02

DH 161 3.13E-06 1.57E-05 1.03 2.48E-02

AI 356 1.80E-06 1.80E-05 1.46 1.56E-02

IJ 84 1.32E-07 3.96E-07 1.46 1.56E-02

IK 350 6.84E-06 6.84E-05 1.46 1.56E-02

KL 156 8.87E-06 4.44E-05 1.09 2.21E-02

### Attachment 2: Emission Calculations

### Name X Y RelHt Syinit Szinit

SLGBIN01 490509.000 4964685.810 1.5 0.710 0.700

LOADER01 490584.610 4964596.790 2.822 12.093 2.625

LOADER02 490566.170 4964589.080 2.822 12.093 2.625

LOADER03 490546.610 4964585.390 2.822 12.093 2.625

SLGLDR01 490581.040 4964606.090 2.822 12.093 2.625

SLGLDR02 490562.180 4964612.430 2.822 12.093 2.625

SLGLDR03 490547.030 4964624.910 2.822 12.093 2.625

SLGLDR04 490534.270 4964640.280 2.822 12.093 2.625

SLGLDR05 490525.830 4964658.420 2.822 12.093 2.625

SLGLDR06 490517.330 4964676.520 2.822 12.093 2.625

SLGLDR07 490506.370 4964692.920 2.822 12.093 2.625

AB01 490455.975 4964499.575 3.498 7.571 3.254

AB02 490454.362 4964509.725 3.498 7.571 3.254

AB03 490452.750 4964519.875 3.498 7.571 3.254

AB04 490451.137 4964530.025 3.498 7.571 3.254

AB05 490449.525 4964540.175 3.498 7.571 3.254

AB06 490447.912 4964550.325 3.498 7.571 3.254

AB07 490446.300 4964560.475 3.498 7.571 3.254

AB08 490444.687 4964570.625 3.498 7.571 3.254

AB09 490443.075 4964580.775 3.498 7.571 3.254

AB10 490441.462 4964590.925 3.498 7.571 3.254

BC01 490443.104 4964600.650 3.498 7.679 3.254

BC02 490448.001 4964609.950 3.498 7.679 3.254

BC03 490452.898 4964619.250 3.498 7.679 3.254

BC04 490457.795 4964628.550 3.498 7.679 3.254

BC05 490462.692 4964637.850 3.498 7.679 3.254

BC06 490467.589 4964647.150 3.498 7.679 3.254

BC07 490472.486 4964656.450 3.498 7.679 3.254

BC08 490477.383 4964665.750 3.498 7.679 3.254

BC09 490482.280 4964675.050 3.498 7.679 3.254

BC10 490487.177 4964684.350 3.498 7.679 3.254

CD01 490489.859 4964694.031 3.498 7.476 3.254

CD02 490490.328 4964704.094 3.498 7.476 3.254

CD03 490490.797 4964714.156 3.498 7.476 3.254

CD04 490491.266 4964724.219 3.498 7.476 3.254

CD05 490491.734 4964734.281 3.498 7.476 3.254

CD06 490492.203 4964744.344 3.498 7.476 3.254

CD07 490492.672 4964754.406 3.498 7.476 3.254

CD08 490493.141 4964764.469 3.498 7.476 3.254

DE01 490492.452 4964774.521 3.498 7.540 3.254

DE02 490490.606 4964784.563 3.498 7.540 3.254

DE03 490488.759 4964794.604 3.498 7.540 3.254

DE04 490486.913 4964804.646 3.498 7.540 3.254

DE05 490485.067 4964814.688 3.498 7.540 3.254

DE06 490483.220 4964824.729 3.498 7.540 3.254

DE07 490481.374 4964834.771 3.498 7.540 3.254

### DE08 490479.528 4964844.813 3.498 7.540 3.254

DE09 490477.681 4964854.854 3.498 7.540 3.254

DE10 490475.835 4964864.896 3.498 7.540 3.254

DE11 490473.989 4964874.938 3.498 7.540 3.254

DE12 490472.142 4964884.979 3.498 7.540 3.254

BF01 490444.982 4964599.375 3.498 7.894 3.254

BF02 490453.633 4964606.125 3.498 7.894 3.254

BF03 490462.284 4964612.875 3.498 7.894 3.254

BF04 490470.935 4964619.625 3.498 7.894 3.254

BF05 490479.586 4964626.375 3.498 7.894 3.254

BF06 490488.237 4964633.125 3.498 7.894 3.254

CG01 490494.233 4964691.000 3.498 7.464 3.254

CG02 490503.449 4964695.000 3.498 7.464 3.254

CG03 490512.665 4964699.000 3.498 7.464 3.254

CG04 490521.881 4964703.000 3.498 7.464 3.254

CG05 490531.097 4964707.000 3.498 7.464 3.254

CG06 490540.313 4964711.000 3.498 7.464 3.254

CG07 490549.528 4964715.000 3.498 7.464 3.254

CG08 490558.744 4964719.000 3.498 7.464 3.254

CG09 490567.960 4964723.000 3.498 7.464 3.254

CG10 490577.176 4964727.000 3.498 7.464 3.254

CG11 490586.392 4964731.000 3.498 7.464 3.254

DH01 490491.450 4964774.000 3.498 7.344 3.254

DH02 490487.600 4964783.000 3.498 7.344 3.254

DH03 490483.750 4964792.000 3.498 7.344 3.254

DH04 490479.900 4964801.000 3.498 7.344 3.254

DH05 490476.050 4964810.000 3.498 7.344 3.254

AI01 490462.209 4964494.525 3.498 7.840 3.254

AI02 490473.065 4964494.575 3.498 7.840 3.254

AI03 490483.922 4964494.625 3.498 7.840 3.254

AI04 490494.778 4964494.675 3.498 7.840 3.254

AI05 490505.634 4964494.725 3.498 7.840 3.254

AI06 490516.491 4964494.775 3.498 7.840 3.254

AI07 490527.347 4964494.825 3.498 7.840 3.254

AI08 490538.203 4964494.875 3.498 7.840 3.254

AI09 490549.060 4964494.925 3.498 7.840 3.254

AI10 490559.916 4964494.975 3.498 7.840 3.254

IJ01 490565.245 4964499.250 3.498 6.745 3.254

IJ02 490565.047 4964507.750 3.498 6.745 3.254

IJ03 490564.849 4964516.250 3.498 6.745 3.254

IK01 490570.680 4964495.075 3.498 7.755 3.254

IK02 490581.352 4964495.225 3.498 7.755 3.254

IK03 490592.024 4964495.375 3.498 7.755 3.254

IK04 490602.696 4964495.525 3.498 7.755 3.254

IK05 490613.368 4964495.675 3.498 7.755 3.254

IK06 490624.039 4964495.825 3.498 7.755 3.254

IK07 490634.711 4964495.975 3.498 7.755 3.254

### IK08 490645.383 4964496.125 3.498 7.755 3.254

IK09 490656.055 4964496.275 3.498 7.755 3.254

IK10 490666.727 4964496.425 3.498 7.755 3.254

KL01 490675.444 4964499.850 3.498 7.218 3.254

KL02 490682.207 4964506.550 3.498 7.218 3.254

KL03 490688.969 4964513.250 3.498 7.218 3.254

KL04 490695.731 4964519.950 3.498 7.218 3.254

KL05 490702.494 4964526.650 3.498 7.218 3.254

### Name X Y Ht(m) T(K) V(m/s) D(m)

MSTACK01 490648.08 4964581.07 60.7 339 21.53 1.83

TSTACK01 490624.75 4964566.34 24.4 321 16.55 2.44

TSTACK02 490604.38 4964589.55 24.4 298 17.62 2.13

RSTACK01 490677.85 4964583.00 8.4 501 5.61 0.49

RSTACK02 490676.27 4964586.41 8.4 540 2.50 0.49

RSTACK03 490675.71 4964587.51 8.4 682 3.82 0.49

RSTACK04 490674.68 4964589.73 8.4 520 2.54 0.49

RSTACK05 490670.72 4964597.65 8.4 445 2.36 0.49

RSTACK06 490668.58 4964597.89 8.4 461 2.40 0.49

RSTACK07 490668.27 4964598.84 8.4 662 4.98 0.49

RSTACK09 490673.97 4964604.78 8.4 470 3.33 0.49

SSTACK01 490585.81 4964667.44 17.8 303 1 5.97 0.71

PLSFAN01 490428.36 4964938.33 11.3 293 8.20 1.47

PLSFAN02 490450.57 4964952.55 11.3 293 8.20 1.47

### Name X Y Ht(m) T(K) V(m/s) D(m)

RSTACK08 490669.85 4964599.63 8.4 758 4.36 0.49

### Name HOURLY EMISSION RATE (g/s) ANNUAL EMISSION RATE (g/s)

MSTACK01 2.14E-02 N/A

TSTACK01 1.11E-01 N/A

TSTACK02 6.66E-03 N/A

RSTACK01 1.31E-04 N/A

RSTACK02 4.75E-05 N/A

RSTACK03 3.47E-05 N/A

RSTACK04 5.94E-05 N/A

RSTACK05 1.24E-04 N/A

RSTACK06 7.99E-05 N/A

RSTACK07 3.25E-05 N/A

RSTACK08 2.14E-05 N/A

RSTACK09 6.00E-05 N/A

SSTACK01 4.89E-03 N/A

PLSFAN01 2.09E-04 N/A

PLSFAN02 2.09E-04 N/A

SLGBIN01 3.78E-05 N/A

LOADER01 5.89E-06 N/A

LOADER02 5.89E-06 N/A

LOADER03 5.89E-06 N/A

SLGLDR01 2.05E-06 N/A

SLGLDR02 2.05E-06 N/A

SLGLDR03 2.05E-06 N/A

SLGLDR04 2.05E-06 N/A

SLGLDR05 2.05E-06 N/A

SLGLDR06 2.05E-06 N/A

SLGLDR07 2.05E-06 N/A

AB01 1.46E-05 N/A

AB02 1.46E-05 N/A

AB03 1.46E-05 N/A

AB04 1.46E-05 N/A

AB05 1.46E-05 N/A

AB06 1.46E-05 N/A

AB07 1.46E-05 N/A

AB08 1.46E-05 N/A

AB09 1.46E-05 N/A

AB10 1.46E-05 N/A

BC01 1.41E-05 N/A

BC02 1.41E-05 N/A

BC03 1.41E-05 N/A

BC04 1.41E-05 N/A

BC05 1.41E-05 N/A

BC06 1.41E-05 N/A

BC07 1.41E-05 N/A

BC08 1.41E-05 N/A

### BC09 1.41E-05 N/A

BC10 1.41E-05 N/A

CD01 3.68E-06 N/A

CD02 3.68E-06 N/A

CD03 3.68E-06 N/A

CD04 3.68E-06 N/A

CD05 3.68E-06 N/A

CD06 3.68E-06 N/A

CD07 3.68E-06 N/A

CD08 3.68E-06 N/A

DE01 4.67E-07 N/A

DE02 4.67E-07 N/A

DE03 4.67E-07 N/A

DE04 4.67E-07 N/A

DE05 4.67E-07 N/A

DE06 4.67E-07 N/A

DE07 4.67E-07 N/A

DE08 4.67E-07 N/A

DE09 4.67E-07 N/A

DE10 4.67E-07 N/A

DE11 4.67E-07 N/A

DE12 4.67E-07 N/A

BF01 5.16E-06 N/A

BF02 5.16E-06 N/A

BF03 5.16E-06 N/A

BF04 5.16E-06 N/A

BF05 5.16E-06 N/A

BF06 5.16E-06 N/A

CG01 1.84E-05 N/A

CG02 1.84E-05 N/A

CG03 1.84E-05 N/A

CG04 1.84E-05 N/A

CG05 1.84E-05 N/A

CG06 1.84E-05 N/A

CG07 1.84E-05 N/A

CG08 1.84E-05 N/A

CG09 1.84E-05 N/A

CG10 1.84E-05 N/A

CG11 1.84E-05 N/A

DH01 3.13E-06 N/A

DH02 3.13E-06 N/A

DH03 3.13E-06 N/A

DH04 3.13E-06 N/A

DH05 3.13E-06 N/A

AI01 1.80E-06 N/A

AI02 1.80E-06 N/A

AI03 1.80E-06 N/A

### AI04 1.80E-06 N/A

AI05 1.80E-06 N/A

AI06 1.80E-06 N/A

AI07 1.80E-06 N/A

AI08 1.80E-06 N/A

AI09 1.80E-06 N/A

AI10 1.80E-06 N/A

IJ01 1.32E-07 N/A

IJ02 1.32E-07 N/A

IJ03 1.32E-07 N/A

IK01 6.84E-06 N/A

IK02 6.84E-06 N/A

IK03 6.84E-06 N/A

IK04 6.84E-06 N/A

IK05 6.84E-06 N/A

IK06 6.84E-06 N/A

IK07 6.84E-06 N/A

IK08 6.84E-06 N/A

IK09 6.84E-06 N/A

IK10 6.84E-06 N/A

KL01 8.87E-06 N/A

KL02 8.87E-06 N/A

KL03 8.87E-06 N/A

KL04 8.87E-06 N/A

KL05 8.87E-06 N/ANameDescriptionACTUAL TESTED(mg/dscm)FLOW RATE (dscfm)CALCULATED EMISSION RATE(lbs/hr)CALCULATED EMISSION RATE(g/s)SCALEFACTORMODELLED EMISSION RATE(lbs/hr) ***MODELLED EMISSION RATE (g/s)***MSTACK01Main stack0.069940002.43E-023.06E-0371.70E-012.14E-02TSTACK01Torit stack0.2341430001.25E-011.58E-0278.77E-011.11E-01TSTACK02Torit stack0.0161260007.55E-039.51E-0475.29E-026.66E-03RSTACK01 Refinery stack 10.23012101.04E-031.31E-0411.04E-031.31E-04RSTACK02 Refinery stack 20.1905303.77E-044.75E-0513.77E-044.75E-05RSTACK03 Refinery stack 30.1305652.75E-043.47E-0512.75E-043.47E-05RSTACK04 Refinery stack 40.2405244.71E-045.94E-0514.71E-045.94E-05RSTACK05 Refinery stack 50.4805489.85E-041.24E-0419.85E-041.24E-04RSTACK06 Refinery stack 60.3205296.34E-047.99E-0516.34E-047.99E-05RSTACK07 Refinery stack 70.0907652.58E-043.25E-0512.58E-043.25E-05RSTACK08 Refinery stack 8 (w/ deflector) 0.0805661.70E-042.14E-0511.70E-042.14E-05RSTACK09 Refinery stack 90.1906694.76E-046.00E-0514.76E-046.00E-05SSTACK01Scrubber stack0.129134006.47E-038.16E-0463.88E-024.89E-03PLSFAN01 Plastic bldg exhaust 10.015295001.66E-032.0884E-0411.66E-032.09E-04PLSFAN02 Plastic bldg exhaust 20.015295001.66E-032.0884E-0411.66E-032.09E-04*** The modelled emission rates for the demonstration of SIP attainmentare higher than calculated values based on test history and indicateconservatism in the analysis of ambient impacts. ***Name XY Ht(m) D(m) radius (ft) acfm src velocity (ft/min) velocity (m/s) T (F) T (K)ft to mMSTACK01 490648.080 4964581.070 60.7 1.83 3.0019685 120000 pdf 4238.57 21.53 150 3390.3048TSTACK01 490624.750 4964566.34024.42.44 4.00262467 164000 pdf 3258.40 16.55 119 321TSTACK02 490604.380 4964589.55024.42.13 3.49409449 133000 pdf 3467.63 17.62 76 298RSTACK01 490677.850 4964583.0008.40.49 0.80380577 2240 pdf 1103.56 5.61 442 501RSTACK02 490676.270 4964586.4108.40.49 0.80380577 1000 pdf 492.662.50 512 540RSTACK03 490675.710 4964587.5108.40.49 0.80380577 1525 pdf 751.313.82 768 682RSTACK04 490674.680 4964589.7308.40.49 0.80380577 1013 pdf 499.072.54 477 520RSTACK05 490670.720 4964597.6508.40.49 0.80380577 944 pdf 465.072.36 342 445RSTACK06 490668.580 4964597.8908.40.49 0.80380577 957 pdf 471.482.40 371 461RSTACK07 490668.270 4964598.8408.40.49 0.80380577 1991 pdf 980.894.98 732 662RSTACK08 490669.850 4964599.6308.40.49 0.80380577 1741 pdf 857.724.36 904 758pointcapRSTACK09 490673.970 4964604.7808.40.49 0.80380577 1330 pdf 655.243.33 387 470SSTACK01 490585.810 4964667.44017.80.71 1.16469816 15000 pdf 3519.77 15.97 86 303PLSFAN01 490428.360 4964938.33011.31.47 2.41141732 29500 xl 1614.83 8.20 68 293PLSFAN02 490450.570 4964952.550 11.3 1.47 2.41141732 29500 xl 1614.83 8.20 68 293LINKED LINKEDLINKEDLINKEDPaved RoadsAP-42 Section 13.2.1E = [k(sL)0.91x (W)1.02] (1 - P/4N)where:E = emission factor (lb/VMT)k = particle size multiplier (lb/VMT, 0.0022 for PM10, 0.00054 for PM2.5, 0.011 for PM30(TSP))sL = road surface silt loading (g/m2)Surface Silt Loading (sL) from direct measurements conducted at Gopher Resource Corporation, Eagan, Minnesota, October 2011W = average weight of vehicles traveling the road (tons)VMT = vehicle miles traveledP = number of "wet" days with at least 0.254 mm (0.01") of precipitation during the averaging period (110 days for GOPHER)N = number of days in the averaging period (365 for annual period corresponding to above)NOTE: Shipping occurs between hours of 6 a.m. and 10 p.m.. Emissions assumed to occur over this 16 hour period dailySegmentDistance (ft) Distance (yards)4.1148 Truck height (m)AB3371123.32 Loader Height (m)BC345115CD26488DE402134BF21672CG363121DH16154AI356119IJ8428IK350117KL15652LOADER11940SLGLDR4013Vehicle TrafficShipping DailyEmptyLoad LoadedTotal Trucks Days TrucksWeight Weight WeightIncoming junk batteries to warehouse bldg D25553657162036Incoming junk batteries to RMPC1460036540162036NamesL (g/m2)Name%PbLead shipping out839536523162036SAMPLE A sLa 1.46 PbA 1.07%Loader trips1825365512315SAMPLE B sLb 4.42 PbB 2.15%Loader trips to slag bins54753651512315SAMPLE C sLc 6.08 PbC 1.99%Slag trucks14603654102030SAMPLE D sLd 1.03 PbD 2.41%UPS trucks1095365355SAMPLE E sLe 0.58 PbE 5.02%Plastic shipments out3653651162036SAMPLE F sLf1.09 PbF 2.03%Lead Sample Silt Loadings and Lead Percentages

### Name X Y RelHt Syinit Szinit Emission Rate (g/s)

SLGBIN01 490509.000 4964685.810 1.5 0.71 0.7 3.78E-05

Name X Y RelHt Syinit Szinit

LOADER01 490584.61 4964596.79 2.822 12.09302 2.625116

LOADER02 490566.17 4964589.08 2.822 12.09302 2.625116

LOADER03 490546.61 4964585.39 2.822 12.09302 2.625116

Name X Y RelHt Syinit Szinit

SLGLDR01 490581.040 4964606.090 2.822 12.09302 2.625116

SLGLDR02 490562.180 4964612.430 2.822 12.09302 2.625116

SLGLDR03 490547.030 4964624.910 2.822 12.09302 2.625116

SLGLDR04 490534.270 4964640.280 2.822 12.09302 2.625116

SLGLDR05 490525.830 4964658.420 2.822 12.09302 2.625116

SLGLDR06 490517.330 4964676.520 2.822 12.09302 2.625116

SLGLDR07 490506.370 4964692.920 2.822 12.09302 2.625116DescriptionDistance (ft) Segment(s) Trips/Year W (tons)sL VMT (miles) E (PM10) E (TSP) E (Pb)TSP(tons)Pb(tons)SEGMENT ABLOADED JUNK BATTERY TRUCK TO BUILDING D337AB255536.01.46163 1.1E-01 5.6E-01 5.9E-03 4.53E-02 4.85E-04UNLOADED JUNK BATTERY TRUCK FROM BUILDING D337AB255516.01.46163 4.9E-02 2.4E-01 2.6E-03 1.98E-02 2.12E-04LOADED JUNK BATTERY TRUCK TO RMPC337AB1460036.01.46932 1.1E-01 5.6E-01 5.9E-03 2.59E-01 2.77E-03UNLOADED JUNK BATTERY TRUCK FROM RMPC337AB1460016.01.46932 4.9E-02 2.4E-01 2.6E-03 1.13E-01 1.21E-03UNLOADED SLAG TRUCK IN337AB146010.01.4693 3.0E-02 1.5E-01 1.6E-03 7.01E-03 7.50E-05LOADED SLAG TRUCK OUT337AB146030.01.4693 9.2E-02 4.6E-01 4.9E-03 2.15E-02 2.30E-04UNLOADED PLASTICS TRUCK IN337AB36516.01.4623 4.9E-02 2.4E-01 2.6E-03 2.83E-03 3.03E-05LOADED PLASTICS TRUCK OUT337AB36536.01.4623 1.1E-01 5.6E-01 5.9E-03 6.47E-03 6.92E-05 g/s g/s per cellTOTAL5.08E-03 1.46E-04 1.463E-05SEGMENT BCLOADED JUNK BATTERY TRUCK TO BUILDING D345BC255536.01.46167 1.1E-01 5.6E-01 5.9E-03 4.63E-02 4.96E-04UNLOADED JUNK BATTERY TRUCK FROM BUILDING D345BC255516.01.46167 4.9E-02 2.4E-01 2.6E-03 2.03E-02 2.17E-04LOADED JUNK BATTERY TRUCK TO RMPC345BC1460036.01.46954 1.1E-01 5.6E-01 5.9E-03 2.65E-01 2.83E-03UNLOADED JUNK BATTERY TRUCK FROM RMPC345BC1460016.01.46954 4.9E-02 2.4E-01 2.6E-03 1.16E-01 1.24E-03UNLOADED PLASTICS TRUCK IN345BC36516.01.4624 4.9E-02 2.4E-01 2.6E-03 2.89E-03 3.10E-05LOADED PLASTICS TRUCK OUT345BC36536.01.4624 1.1E-01 5.6E-01 5.9E-03 6.62E-03 7.08E-05 g/s g/s per cellTOTAL4.88E-03 1.41E-04 1.406E-05SEGMENT CDLOADED JUNK BATTERY TRUCK TO BUILDING D264CD255536.01.03128 8.1E-02 4.0E-01 9.7E-03 2.59E-02 6.23E-04UNLOADED JUNK BATTERY TRUCK FROM BUILDING D264CD255516.01.03128 3.5E-02 1.8E-01 4.3E-03 1.13E-02 2.72E-04UNLOADED PLASTICS TRUCK IN264CD36516.01.0318 3.5E-02 1.8E-01 4.3E-03 1.61E-03 3.89E-05LOADED PLASTICS TRUCK OUT264CD36536.01.0318 8.1E-02 4.0E-01 9.7E-03 3.69E-03 8.90E-05 g/s g/s per cellTOTAL1.02E-03 2.95E-05 3.683E-06SEGMENT DEUNLOADED PLASTICS TRUCK IN402DE36516.01.0328 3.5E-02 1.8E-01 4.3E-03 2.46E-03 5.92E-05LOADED PLASTICS TRUCK OUT402DE36536.01.0328 8.1E-02 4.0E-01 9.7E-03 5.61E-03 1.35E-04 g/s g/s per cellTOTAL1.94E-04 5.60E-06 4.666E-07SEGMENT BFUNLOADED SLAG TRUCK IN216BF146010.04.4260 8.2E-02 4.1E-01 8.9E-03 1.23E-02 2.64E-04LOADED SLAG TRUCK OUT216BF146030.04.4260 2.5E-01 1.3E+00 2.7E-02 3.77E-02 8.11E-04 g/s g/s per cellTOTAL1.08E-03 3.10E-05 5.16E-06SEGMENT CGLOADED JUNK BATTERY TRUCK TO RMPC363CG1460036.01.031,003 8.1E-02 4.0E-01 9.7E-03 2.03E-01 4.88E-03UNLOADED JUNK BATTERY TRUCK FROM RMPC363CG1460016.01.031,003 3.5E-02 1.8E-01 4.3E-03 8.86E-02 2.13E-03 g/s g/s per cellTOTAL7.02E-03 2.02E-04 1.837E-05SEGMENT DHLOADED JUNK BATTERY TRUCK TO BUILDING D161DH255536.01.0378 8.1E-02 4.0E-01 9.7E-03 1.57E-02 3.78E-04UNLOADED JUNK BATTERY TRUCK FROM BUILDING D161DH255516.01.0378 3.5E-02 1.8E-01 4.3E-03 6.87E-03 1.65E-04 g/s g/s per cellTOTAL5.44E-04 1.57E-05 3.132E-06SEGMENT AIUPS TRUCK IN356AI10955.01.4674 1.5E-02 7.4E-02 7.9E-04 2.74E-03 2.93E-05UPS TRUCK OUT356AI10955.01.4674 1.5E-02 7.4E-02 7.9E-04 2.74E-03 2.93E-05UNLOADED TRUCK IN84AI839516.01.46133 4.9E-02 2.4E-01 2.6E-03 1.61E-02 1.73E-04LOADED LEAD SHIPMENT OUT84AI839536.01.46133 1.1E-01 5.6E-01 5.9E-03 3.69E-02 3.95E-04 g/s g/s per cellTOTAL6.27E-04 1.80E-05 1.804E-06SEGMENT IJUPS TRUCK IN84IJ10955.01.4617 1.5E-02 7.4E-02 7.9E-04 6.43E-04 6.88E-06UPS TRUCK OUT84IJ10955.01.4617 1.5E-02 7.4E-02 7.9E-04 6.43E-04 6.88E-06 g/s g/s per cellTOTAL1.38E-05 3.96E-07 1.321E-07SEGMENT IKUNLOADED TRUCK IN350IK839516.01.46557 4.9E-02 2.4E-01 2.6E-03 6.76E-02 7.23E-04LOADED LEAD SHIPMENT OUT350IK839536.01.46557 1.1E-01 5.6E-01 5.9E-03 1.55E-01 1.65E-03 g/s g/s per cellTOTAL2.38E-03 6.84E-05 6.842E-06SEGMENT KLUNLOADED TRUCK IN156KL839516.01.09248 3.7E-02 1.9E-01 3.8E-03 2.31E-02 4.69E-04LOADED LEAD SHIPMENT OUT156KL839536.01.09248 8.5E-02 4.3E-01 8.6E-03 5.28E-02 1.07E-03 g/s g/s per cellTOTAL1.54E-03 4.44E-05 8.874E-06LOADERLOADER TRIPS - LOADED119LOADER182515.06.0841 1.7E-01 8.3E-01 1.7E-02 1.72E-02 3.41E-04LOADER TRIPS - UNLOADED119LOADER182512.06.0841 1.3E-01 6.6E-01 1.3E-02 1.37E-02 2.72E-04 g/s g/s per cellTOTAL6.13E-04 1.77E-05 5.885E-06SLGLDRSLAG LOADER TRIPS - LOADED40SLGLDR547515.04.4241 1.2E-01 6.2E-01 1.3E-02 1.29E-02 2.77E-04SLAG LOADER TRIPS - UNLOADED40SLGLDR547512.04.4241 9.9E-02 5.0E-01 1.1E-02 1.03E-02 2.21E-04 g/s g/s per cellTOTAL4.97E-04 1.43E-05 2.046E-062.55E-02 7.34E-04XYx0y0x1y1N Length(m) DX(m) DY(m) Segment (m) Segment (ft)Plastics 490456.7814964494.5001 A1-2 A-B 490456.7814964494.500490440.6564964596.0001110.28 -1.61 10.15 102.77 337.18490440.6564964596.0002 B2-3 B-C 490440.6564964596.000490489.6254964689.0001110.51 4.90 9.30 105.10344.83490489.6254964689.0003 C3-4 C-D 490489.6254964689.000490493.3754964769.500910.07 0.47 10.06 80.59 264.39490493.3754964769.5004 D4-5 D-E 490493.3754964769.500490471.2194964890.0001310.21 -1.85 10.04122.52 401.97490471.2194964890.0005 E2-6 B-F 490440.6564964596.000490492.5634964636.500710.97 8.65 6.75 65.84216.00XY3-7 C-G 490489.6254964689.000490591.0004964733.0001210.05 9.22 4.00 110.51 362.57Slag490456.7814964494.5001 A4-8 D-H 490493.3754964769.500490474.1254964814.50069.79 -3.85 9.00 48.94160.58490440.6564964596.0002 B1-9 A-I 490456.7814964494.500490565.3444964495.0001110.86 10.86 0.05 108.56 356.18490492.5634964636.5006 F9-10 I-J 490565.3444964495.000490564.7504964520.50048.50 -0.20 8.50 25.51 83.68XY9-11 I-K 490565.3444964495.000490672.0634964496.5001110.67 10.67 0.15 106.73 350.16RMPC 490456.7814964494.5001 A11-12 K-L 490672.0634964496.500490705.8754964530.00069.52 6.76 6.70 47.60 156.16490440.6564964596.0002 B490489.6254964689.0003 C490591.0004964733.0007 GX YWRHSD 490456.7814964494.5001 A490440.6564964596.0002 BVERTEX X (UTM) Y (UTM) ZONE LONG LAT490489.6254964689.0003 CA 490456.7814964494.5001593.1207350000 44.8337951672490493.3754964769.5004 DB 490440.6564964596.0001593.1209410000 44.8347084974490474.1254964814.5008 HC 490489.6254964689.0001593.1203210932 44.8355441516XYD 490493.3754964769.5001593.1202770000 44.8362693278UPS490456.7814964494.5001 AE 490471.2194964890.0001593.1205570000 44.8373550420490565.3444964495.0009 IF 490492.5634964636.5001593.1202850000 44.8350769012490564.7504964520.50010 JG 490591.0004964733.0001593.1190410000 44.8359396742XYH 490474.1254964814.5001593.1205180000 44.8366750000PbShip 490456.7814964494.5001 AI 490565.3444964495.0001593.1193650000 44.8338014178490565.3444964495.0009 IJ 490564.7504964520.5001593.1193660000 44.8340249346490672.0634964496.50011 KK 490672.0634964496.5001593.1180110000 44.8338116305490705.8754964530.00012 LL 490705.8754964530.0001593.1175836622 44.8341129166VERTEX LINK

### Attachment 3: Modeling Protocol

# Air Quality Dispersion Modeling Protocol
for Demonstration of SIP Attainment (Supplement)

Prepared for: Minnesota Pollution Control Agency

Prepared on Behalf of: Gopher Resource Eagan, Minnesota

Prepared by: ENVIRON International Corporation Atlanta, Georgia

Date:
November 2011

Project Number:
07-21907AAir Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

Contents i



# Contents

Page

1 Introduction 1

1.1 Description of Current Operations 1

1.2 Facility Location 1

1.3 Document Organization 1

1.4 Contact Information 2

2 Modeling Methodologies, Settings, and Input 3

2.1 Model Selection and Settings 3

2.2 Modeled Pollutants and Averaging Periods 4

2.3 Modeled Sources and Their Release Parameters 4

2.4 Terrain Data 7

2.5 Building Downwash 7

2.6 Meteorological Data Set 9

2.6.1 Surface and Upper Air Meteorological Data 9

2.7 Receptors 9

3 Model Input, Output, and Results Submittal 10

4 References 10

List of Tables

Table 1: Lead Emitting Point Sources Included in Dispersion Modeling Analysis
Table 2: Buildings Incorporated into AERMOD
Table 3: Proposed Minimum Discrete Receptor Spacing

List of Figures

Figure 1-1: Site Location Map for Gopher Reso urce Facility
Figure 2-1: Location of Lead Sources, Buildings, and Facility Boundary
Figure 2-2: Elevation Data Domain Imported into AERMAP
Figure 2-3: Receptor Placement Used in Modeling Analysis
Figure 3-1: Maximum Three-Month Averag e Concentrations at each ReceptorAir Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

ii Contents 

### List of Acronyms

AAQ Ambient Air Quality

AERMET The meteorological preprocessor to AERMOD

AERMOD American Meteorological Society/Environmental Protection Agency Regulatory Model

BPIP Building Profile Input Program

CFR Code of Federal Regulations

ENVIRON ENVIRON Inter national Corporation Gopher Gopher Resource

HAP Hazardous Air Pollutant

ISCST3 Industrial Source Complex-Short Term

ISO International Standards Organization

MACT Maximum Achievable Control Technology

MPCA Minnesota Pollution Control Agency

NAAQS National Ambient Air Quality Standard

NED National Elevation Dataset

NLCD National Land Cover Database

NSPS New Source Performance Standards

NWS National Weather Service

Pb Lead

PMI Point of Maximum Impact

PRIME Plume RIse Model Enhancements

REL Reference Exposure Levels

USEPA United States Environmental Protection Agency

USGS United States Geological Survey

Yuasa Yuasa Battery, Inc.



### List of Units

g gram g/s grams per second kg kilogram

km kilometer

L liter

m meter

m 3 cubic meter

mg milligram

s second

yr year

μ g microgramAir Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

Introduction 1 

# 1 Introduction

Gopher Resource LLC (Gopher Resource) operates a lead recycling facility in Eagan, Dakota County, Minnesota that reclaims lead and plastic from spent automobile batteries.



## 1.1 Description of Current Operations

The Gopher property is approximately 55 acres in size and is located about 7.5 kilometers southeast of the Minneapolis – Saint Paul International Airport in Dakota County. Figure 1-1 provides an illustration of the location of the facility.

Gopher’s Eagan facility recycles spent lead-acid batteries. The recycling operations at this facility consist of battery crushing, smelting, and refining.



## 1.2 Facility Location

The Gopher property is located in Dakota County, Minnesota. The following locational information is for the approximate center of the modeling domain:

Gopher Resources, 3385 South Highway 149. Eagan, MN. 55121

UTM Coordinates (NAD83); Zone = 15; Easting = 490,535 meters; Northing = 4,964,720 meters

Base Elevation = 271 meters above Mean Sea Level (MSL)



## 1.3 Document Organization

This Modeling Protocol is divided into five sections as follows:

Section 1.0 – Introduction: describes the purpose and scope of the Ambient Air Quality Modeling and outlines the report organization.

Section 2.0 – Modeling Methodologies, Settings, and Input: discusses the emissions estimate to be used for dispersion modeling, the selection of the dispersion model, the data used in the dispersion model (terrain, meteorology, source characterization) and the identification of receptors evaluated in this analysis.

Section 3.0 – Model Input, Output, and Results Submittal: discusses the documentation that will be provided with the final application for MPCA review.

Section 4.0 – References: includes all references cited in this report.Air Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

2 Introduction 

## 1.4 Contact Information

Gopher Resource has contracted with ENVIRON International Corporation to perfor m the air quality analyses for this project. The ENVIRON contact for this project is:

Mr. Russell S. Kemp, PE ENVIRON International Corporation

1600 Parkwood Circle

Suite 310
Atlanta, GA 30339 Tel: (678) 388-1654 Email: rkemp@environcorp.comAir Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

Modeling Methodologies, Settings, and Input 3



# 2 Modeling Methodologies, Settings, and Input

This section summarizes our selection of the dispersion model that will be used in this analysis along with its operational settings and input.



## 2.1 Model Selection and Settings

The ambient air lead concentrations in the vicinity of the Gopher facility will be estimated using dispersion modeling techniques. To estimate off-property ambient air concentrations, ENVIRON will employ version 11103 of AERMOD, the USEPA’s recommended air dispersion model (USEPA 2004a and USEPA 2009c). AERMOD was developed as a replacement for USEPA’s Industrial Source Complex Short Term (ISCST3) air dispersion model to improve the accuracy of air dispersion model results for routine regulatory applications and to incorporate the progress in scientific knowledge of atmospheric turbulence and dispersion. This change was made in November 2005 (USEPA 2005b). After a one-year transition period for the change in model (i.e., as of November 9, 2006), ISCST3 is no longer considered a USEPA-approved model for certain regulatory applications. For these and the following reasons, ENVIRON proposes using AERMOD to determine ambient lead concentrations for this analysis.

AERMOD is appropriate for use in estimating ground-level short-term ambient air concentrations resulting from non-reactive buoyant emissions from sources located in simple and complex terrain. This analysis will be cond ucted using AERMOD in the regulatory default mode, which includes the following modeling control options:

• 

### adjusting stack heights for stack-tip downwash,

• 

### using upper-bound concentration estimates for sources influenced by building downwash from super-squat buildings,

• 

### incorporating the effects of elevated terrain,

• 

### employing the calms processing routine, and

• 

### employing the missing data processing routine.

Air modeling concentrations will be estimated us ing AERMOD in conjunction with information about the site, the locations of the lead emitting stacks, nearby land uses, representative meteorological data, and receptors.

This dispersion modeling project will utilize the Universal Transverse Mercator (UTM) Coordinate System which includes the inherent benefit of not using negative numbers or east/west designations. In addition, the UTM coordinate system provides a constant distance relationship anywhere on the map or domain. This project will utilize Zone 15 of the North American Datum of 1983 (NAD83) in the UTM coordinate system. The units of the coordinates

will be meters.Air Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

4 Modeling Methodologies, Settings, and Input 

## 2.2 Modeled Pollutants and Averaging Periods

The only pollutant that will be modeled is lead (Pb). Calculation of chemical concentrations for use in demonstrating Lead attainment relative to the 2008 Lead NAAQS (USEPA 2008b) requires the selection of appropriate concentration averaging times. To demonstrate agreement with the 2008 Lead NAAQS, ENVIRON will execute the AERMOD model and generate POST files using a monthly averaging period. These POST files will be processed through the USEPA’s LEADPOST Fortran-based computer program to generate consecutive three-month averages for comparison against the lead NAAQS.



## 2.3 Modeled Sources and Their Release Parameters

We propose this modeling analysis includes the lead emitting sources and roadways located at the Gopher facility

Table 1 includes a listing of the point sources that will be included in this modeling exercise and their release parameters in the AERMOD Model. We propose the final modeling will utilize

emission rates from these sources.Air Quality Dispersion Modeling ProtocolSIP Attainment DemonstrationModeling Methodologies, Settings, and Input5Table 1: Lead Emitting Point Sources Included in Dispersion Modeling AnalysisName Source DescriptionUTM Zone15 Easting(m)UTM Zone15 Northing(m)Elevation(m)PbEmissionRate (g/s)StackHeight(m)StackTemperature(K)ExitVelocity(m/s)StackDiameter (m)MSTACK01 Main stack 490648.1 4964581.1 272.72.20E-0260.733921.53 1.83TSTACK01 Torit stack 490624.8 4964566.3 272.21.09E-0224.432116.55 2.44TSTACK02 Torit stack 490604.4 4964589.6 271.66.79E-0324.429817.62 2.13RSTACK01 Refinery stack 1 490677.9 4964583.0 273.21.39E-048.45015.610.49RSTACK02 Refinery stack 2 490676.3 4964586.4 273.25.04E-058.45402.500.49RSTACK03 Refinery stack 3 490675.7 4964587.5 273.23.78E-058.46823.820.49RSTACK04 Refinery stack 4 490674.7 4964589.7 273.26.30E-058.45202.540.49RSTACK05 Refinery stack 5 490670.7 4964597.7 273.11.26E-048.44452.360.49RSTACK06 Refinery stack 6 490668.6 4964597.9 273.17.56E-058.44612.400.49RSTACK07 Refinery stack 7 490668.3 4964598.8 273.13.78E-058.46624.980.49RSTACK08Refinery stack 8(w/ deflector)490669.9 4964599.6 273.12.52E-058.47584.360.49RSTACK09 Refinery stack 9 490674.0 4964604.8 273.26.30E-058.44703.330.49SSTACK01 Scrubber stack 490585.8 4964667.4 271.14.84E-0317.830315.97 0.71PLSFAN01 Plastic bldg exhaust 1 490428.4 4964938.3 274.62.09E-0411.32938.201.47PLSFAN02 Plastic bldg exhaust 2 490450.6 4964952.6 272.92.09E-0411.32938.201.47Air Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

6 References 

### The data for Gopher’s point sources were obtained from previous modeling and geolocation of aerial photographs.

Point source release parameters for each source were taken from the most recent compliance stack testing for the facility. For the main stack, the two Torit stacks and the scrubber stack, the release parameters represent the average of three test runs from the stack test reports. The refinery stack vents were based on a single test value.

The final modeling report will include a table listing the volume sources in this modeling exercise and their release parameters in the AERMOD Model. These volume sources will mainly consist of fugitive road emissions from Gopher’s facility which will be represented as a series of separated volume sources in the model. The individual volume sources for each road segment will be combined into source groups for the model output files. The volume source input values will be quantified according to the USEPA’s recommended methodologies in the AERMOD

User’s Guide.

The emission factors for the fugitive road sources will be quantified using Equation (2) from section 13.2.1 (Paved Roads) in the USEPA’s Compilation of Air Pollutant Emission Factors (a.k.a., AP-42). The number of days with measureable precipitation (> 0.01 inches) was estimated from AP-42Figure 13.2.1-2 as 110 days. Vehicle weights, loaded and loaded, supplied by Gopher will be used in calculating the emission factors. Gopher will also collect sitespecific silt content samples from its facility roads as specified in the procedures for measuring surface dust found in Appendix C1 of AP-42. Gopher will also analyze these silt samples for lead content which will be used to ratio the particulate emission rate calculated using the AP-42 paved roads equations. The roads on Gopher’s property are all paved and regularly cleaned as required by federal NESHAP regulations.

The volume source release parameters for the roadways will be calculated according to guidance from the Haul Road Workgroup Recommendations provided by Dennis Becker of the MPCA. The basis for these recommendations is presented in in Gillies et al., 2005. For this modeling procedure the following parameters will be used:

i. Top of plume height = 1.7 x vehicle height (assumed heights of 4.11 m for semi-trucks and 3.32 m for loaders). ii. Release height = top of plume height / 2 iii. Initial sigma y = (road width + 6m) / 2.15 (road widths were approximately 10 m and loader route widths 20 m) iv. Initial sigma z = top of plume height / 2.15

Although the recommendations apply to unpaved roads, other documents available on the MPCA web-site suggested the dispersion parameters would apply equally for paved roads. The silt loading values and lead content sampled are specific to the paved roads of the Gopher facility. Roadway segments and loader routes will use silt loading values taken from the nearest sample location.Air Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

References 7



## 2.4 Terrain Data

Terrain elevations will be incorporated into the model using version 11103 of AERMAP, AERMOD’s terrain preprocessor, as per USEPA guidance (2009). Terrain elevation data for the entire modeling domain will be extracted from 1/3-arc second National Elevation Data (NED) files with a resolution of approximately 10 meters. These NED files will be obtained from the U.S. Geological Survey’s Seamless Data Serv er (http://seamless.usgs.gov). Please see Figure 2-2 for a graphical depiction of the terrain data to be used in this analysis. AERMAP will be configured to assign elevations for all sources, buildings, and receptors in the modeling domain.

Because there is no distinction in AERMOD between elevated terrain below release height (simple terrain) and terrain above release height (c omplex terrain), as with earlier regulatory

models that distinguished between simple terrain and complex terrain (USEPA 2004 a), we have not included in this protocol a description of complex terrain within 50 kilometers of the Gopher site. AERMAP will be configured to automatically calculate and assign Hill Height Scale values for all receptors.



## 2.5 Building Downwash

Building downwash algorithms incorporated into AERMOD account for the plume dispersion effects of the aerodynamic wakes and eddies produced by buildings and structures. The Plume Rise Model Enhancements (PRIME) model (incor porated into AERMOD) is used to determine the direction-specific building downwash parameters. Wind tunnel and field data have shown improved performance of PRIME as compared to the Building Profile Input Program (BPIP), the downwash model currently approved by USEPA for use with the ISCST3 dispersion model (Schulman et al. 2000). PRIME calculates fields of turbulence intensity, wind speed, and slopes of the mean streamlines as a function of projected building shape. Using a numerical plume rise model, PRIME determines the change in plume centerline location and the rate of plume dispersion with downwind distance. Concentrations are predicted in both the near and far wake regions, with the plume mass captured by the near wake treated separately from the uncaptured primary plume, and re-emitted to the far wake as a volume source.

ENVIRON evaluated onsite buildings from Gopher-owned structures for downwash analysis. These buildings will be placed into the model then the BPIP program will be executed on the point sources. Table 2 shows the heights of each building that will be incorporated into the

model.Air Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

8 References 

### Table 2: Buildings Being Incorporated into AERMOD

AERMOD Building ID Building Base Elevation (meters) Building Height (feet) Building Height (meters)



### bldg1 275.3 22.0 6.7

bldg2 275.4 22.0 6.7

bldg3 271.1 32.5 9.9

bldg4 270.4 37.4 11.4

bldg5 271.2 26.2 8.0

bldg6 271.9 26.9 8.2

bldg7 272.2 26.9 8.2

bldg8 272.4 26.6 8.1

bldg9 272.2 26.6 8.1

bldg11 272.8 44.6 13.6

bldg13 274.5 21.7 6.6

bldg14 273.4 18.0 5.5

bldg15 272.9 22.3 6.8

bldg18 271.9 10.8 3.3

bldg19 270.9 24.6 7.5

bldg20 272.9 20.7 6.3

bldg21 272.9 20.7 6.3

bldg22 275.8 33.1 10.1

bldg23 272.2 26.2 8.0

bldg24 272.2 43.6 13.3

bldg25 272.3 19.4 5.9

bldg26 272.5 9.8 3.0

bldg27 273.9 34.1 10.4

bldg28 273.3 28.9 8.8Air Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

References 9



## 2.6 Meteorological Data Set

AERMOD requires a meteorological input file to characterize the transport and dispersion of pollutants in the atmosphere. Surface and upper air meteorological data inputs as well as surface parameter data describing the land use and surface characteristics near the site are first processed using AERMET, the meteorological preprocessor to AERMOD. The output file generated by AERMET is the meteorological input file required by AERMOD. Details of AERMET and AERMOD meteorological data needs are described in USEPA guidance documents (USEPA 2004a, 2004b). Section 2.6.1 describes the surface and upper air meteorological data that will be used for the modeling.



## 2.6.1 Surface and Upper Air Meteorological Data

The 2006 – 2010 surface data files (*.SFC) for Minneapolis-Saint Paul International Airport (KMSP) and the upper air data files (*.PFL) for Chanhassen, MN (KMPX) were supplied by the MPCA. The Gopher facility is located approximately 7.5 km south-east of the airport. The coordinates and elevation for this location (KMSP) are 44° 52' 59" N and 93° 13' 44" W at 266 meters above sea level according to information from the National Climatic Data Centers. The corresponding data for the Chanhassen upper air station (KMPX) are 44° 50' 56" N and 93° 33'

55" W at 288 meters above sea level



## 2.7 Receptors

Ground-level lead concentrations located inside the facility boundary will be excluded from the impact assessment because the general public does not have ready access to the Gopher property. Consistent with EPA Guidance for Dispersion Modeling, we propose to place ground level receptors along the property line of each facility at 10 meter spacing intervals.

In addition to the property line receptors, we propose to utilize nested Cartesian grids of receptors at various spacings. Outside the property line receptors a grid of receptors with spacing of 25 meters will extend out to 500 meters from the center of the Gopher facility (1 km x 1 km grid). Beyond this grid, receptors spaced at 50 and 250 meters will extend to distances of 2500 meters (5 km x 5 km grid) and 5000 meters (10 km x 10 km grid), respectively (see Figure 2-3)

Table 3: Proposed Minimum Discrete Receptor Spacing

Receptor Spacing Distance from Center of Facility

10 meters Along Property Line

25 meters 0 – 500 meters

50 meters 500 – 2500 meters

250 meters 2500-5000 metersAir Quality Dispersion Modeling Protocol
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10 References 

# 3 Model Input, Output, and Results Submittal

The dispersion modeling results will be subm itted to MPCA documenting the modeling methodology and results. A report will be prepared and will include all appropriate modeling input and output files in electronic format. The presentation will be sufficient to demonstrate compliance with this modeling protocol and will include a proposed attainment plan for review and consideration by MPCA staff. Meteorological and BPIP input files will be included in the

submittal as well.

Deliverables will also include tables of the maximum three-month average concentrations for the modeled time period and figures depicting source and facility layout (see Figure 2-1), receptor placement (see Figure 2-3), and a figure depicting contours of the maximum three-month average concentrations at each receptor (see Figure 3-1).



# 4 References

AERMOD; Version 11103 ed.; American Meteorological Society/ Environmental Protection Agency, version 11103.

Gillies, J.A., Etyemezian, V. Kuhns, H. Nikolic, D. and Gillette, D.A. 2005. Effect of vehicle characteristics on unpaved road dust emissions. Atmospheric Environment, 39(13):2341-
2347

Schulman, LL; D.G. Strimaitis; J.S. Scire. 2000. Development and Evaluation of the PRIME Plume Rise and Building Downwash Model. Journal of the Air and Waste Management Association, 50(3)

United States Environmental Protection A gency (USEPA). 2004a. User's Guide for the AMS/EPA Regulatory Model - AERMOD. Offi ce of Air Quality Planning and Standards. Emissions Monitoring and Analysis Division. Re search Triangle Park, North Carolina. EPA454/B-03-001. September.

United States Environmental Protection A gency (USEPA). 2004b. User's Guide for the AERMOD Meteorological Preprocessor (AERMET). Office of Air Quality Planning and Standards. Emissions Monitoring and Analysis Division. Research Triangle Park, North Carolina. EPA-454/B-03-002. 5-9, 4-49. November

United States Environmental Protection Agency (USEPA). 2005a. AERMOD Implementation
Guide. Research Triangle Park, North Carolina. September.

United States Environmental Protection Agency (USEPA). 2005b. Revision to the Guideline on

Air Quality Models: Adoption of a Preferred General Purpose (Flat and Complex Terrain) Dispersion Model and Other Revisions; Final Rule. 40 CFR Part 51, Appendix W (Federal Register) 70216.Air Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

References 11



### United States Environmental Protection Agenc y (USEPA). 2008a. AERSurface User’s Guide. Air Quality Assessment Division. Research Triangle Park, North Carolina. EPA-454/B-08- 001. January.

United States Environmental Protection Agency (USEPA). 2008b. Revision to the National Ambient Air Quality Standards for Lead. Final Rule. Federal Register Volume 73, Page 66964 et seq. November 12.

United States Environmental Protection Agency (USEPA). 2009a. NAAQS from 40 Code of Federal Regulations (CFR) Part 52 (relating to National Primary and Secondary Ambient Air Quality Standards).

United States Environmental Protection Agency (USEPA). 2009b. AERMOD Implementation Guide. Office of Air Quality Planning and Standards. Emissions Monitoring and Analysis Division. Research Triangle Park, North Carolina. March 19.

United States Environmental Protection A gency (USEPA). 2009c. User's Guide for the AMS/EPA Regulatory Model – AERMOD (Adde ndum for Version 09292). Office of Air Quality Planning and Standards. Emissions Monitoring and Analysis Division. Research Triangle Park, North Carolina. EPA-454/B-03-001. October.Air Quality Dispersion Modeling Protocol
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Figures 

# Figures

€NV I RONAir Quality Dispersion Modeling Protocol
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14 References 

### Figure 1-1: Site Location Map for Gopher Resource FacilityAir Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

Figures



### Figure 2-1: Location of Lead Sources, Buildings, and Facility BoundaryAir Quality Dispersion Modeling Protocol
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16 References 

### Figure 2-2: Elevation Data Domain Imported into AERMAP 

## E'

Cl c 

### :.c
t 0 

### z

L!)

<lJ c 0 N**~** 1- :J 

# ,.

485000 486000 487000 488000 489000 490000 491000 492000 493000 494000 495000 496000

UTM Zone 15 Easting (m )



## €NVI RONAir Quality Dispersion Modeling Protocol
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Figures



### Figure 2-3: Receptor Placement Used in Modeling AnalysisAir Quality Dispersion Modeling Protocol
SIP Attainment Demonstration

18 References 

### Figure 3-1: Maximum Three-Month Average Concentrations at each ReceptorAQ Facility ID No:03700016Facility Name:GopherResourceFacility Address:3385 SouthHighway 149Eagan, MNFacility Contact:Steve Yates (651) 405-2213Model Input KeyParameters Units DescriptionType =POINT, AREA, AREA_CIRC, AREA_POLY, VOLUME, OPEN_PIT e.g. a stack = POINT, parking lot = AREAID =Source ID up to 8 charactersBase_Elev =[m] Source base elevation above mean sea levelHeight =[m] Release height above groundDiam =[m] Stack/Area diameter (POINT and AREA_CIRC only)Exit_Vel =[m/s] Exit velocity (POINT only)Exit_Temp =[K] Exit temperature (POINT only)Release Type =VERTICAL, HORIZONTAL, CAPPED (POINT only) - HORIZONTAL and CAPPED are non-default beta optionsEmission_Rate = [g/s or g/s/m2] Emission rate (g/s for POINT and VOLUME, g/s/m2 for all AREA and OPENPIT)X and Y[m] Stack Coordinates in UTM NAD83Desc =Stack description (boiler, furnace, etc)LOCATIONAQDMPS-01Air Quality Dispersion Modeling (AQDM) Protocol SpreadsheetProtocol Form for Criteria Pollutant ModelingDoc Type: Air Dispersion ModelingSRCPARAMEasting NorthingStack Vent PollutantBase_Elev Height Diam Exit_Vel Exit_Temp Release_Type Emission_Rate Emission_Rate X1Y1DESCID[m][m][m] [m/s] [K](g/sec)(lb/hr)[m][m]SV001NO2450.31 48.77 5.77 15.31 327.6 VERTICAL 1491182.56 495489.98 5251009.25Hood ExhaustSV001PM2.5450.31 47.57 5.47 15.31 327.35 VERTICAL 0.0050.04495494.98 5251011.25 Emergency power generatorSV003PM2.5450.31 46.37 5.17 15.31 327.1 VERTICAL1079.37 495499.98 5251013.25 Emergency power generatorStack Parameter Input TableEasting NorthingStack Vent PollutantBase_Elev Height Diam Exit_Vel Exit_Temp Release_Type Emission_Rate Emission_Rate X1Y1DESCID[m][m][m] [m/s] [K](g/sec)(lb/hr)[m][m]MSTACK01Pb272.7360.7 1.83 21.53 338.7 VERTICAL 2.20E-02 1.75E-01 490648.08 4964581.07Main stackTSTACK01Pb272.204 24.4 2.44 16.55 321.5 VERTICAL 1.09E-02 8.65E-02 490624.75 4964566.34Existing Torit stackTSTACK02Pb271.572 24.4 2.13 17.62 297.6 VERTICAL 6.79E-03 5.39E-02 490604.38 4964589.55New Torit stackRSTACK01Pb273.2118.4 0.49 5.61 500.9 VERTICAL 1.39E-04 1.10E-03 490677.85 4964583.00Refinery stack 1RSTACK02Pb273.1948.4 0.49 2.50 539.8 VERTICAL 5.04E-05 4.00E-04 490676.27 4964586.41Refinery stack 2RSTACK03Pb273.1888.4 0.49 3.82 682.0 VERTICAL 3.78E-05 3.00E-04 490675.71 4964587.51Refinery stack 3RSTACK04Pb273.1768.4 0.49 2.54 520.4 VERTICAL 6.30E-05 5.00E-04 490674.68 4964589.73Refinery stack 4RSTACK05Pb273.1328.4 0.49 2.36 445.4 VERTICAL 1.26E-04 1.00E-03 490670.72 4964597.65Refinery stack 5RSTACK06Pb273.1088.4 0.49 2.40 461.5 VERTICAL 7.56E-05 6.00E-04 490668.58 4964597.89Refinery stack 6RSTACK07Pb273.1058.4 0.49 4.98 662.0 VERTICAL 3.78E-05 3.00E-04 490668.27 4964598.84Refinery stack 7RSTACK08Pb273.1238.4 0.49 4.36 757.6 POINTCAP 2.52E-05 2.00E-04 490669.85 4964599.63Refinery stack 8RSTACK09Pb273.1688.4 0.49 3.33 470.4 VERTICAL 6.30E-05 5.00E-04 490673.97 4964604.78Refinery stack 9aq2-41 • 7/28/11•www.pca.state.mn.us • Available in alternative formats • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864Page 1 of 7Stack Parameter Input TableEasting NorthingStack Vent PollutantBase_Elev Height Diam Exit_Vel Exit_Temp Release_Type Emission_Rate Emission_Rate X1Y1DESCID[m][m][m] [m/s] [K](g/sec)(lb/hr)[m][m]SSTACK01Pb271.079 17.8 0.71 15.97 303.2 VERTICAL 4.84E-03 3.84E-02 490585.81 4964667.44Scrubber stackPLSFAN01Pb274.556 11.3 1.47 8.20 293.0 VERTICAL 2.09E-04 1.66E-03 490428.36 4964938.33 Plastic building exhaust fan vent 1PLSFAN02Pb272.921 11.3 1.47 8.20 293.0 VERTICAL 2.09E-04 1.66E-03 490450.57 4964952.55 Plastic building exhaust fan vent 2aq2-41 • 7/28/11•www.pca.state.mn.us • Available in alternative formats • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864Page 2 of 7IIIIIIIIAQ Facility ID No:03700016Facility Name:GopherRFacility Address:3385 SouthHi h 149Eagan, MNFacility Contact:Steve Yates (651) 405-2213Model Input KeyParameters Units DescriptionID =Source ID up to 8 charactersDesc =Optional descriptionBase_Elev =[m] Source base elevation above mean sea levelHeight =[m] Release height above groundSigmaY =[m] Initial sigma Y (VOLUME only)SigmaZ =[m] Initial sigma Z (all AREA and VOLUME only, optional for all AREA)Length_X =[m] X side length (OPEN PIT, AREA and VOLUME only, optional for VOLUME, will be used to calculate SigmaY)Emission_Rate = [g/s or g/s/m2] Emission rate (g/s for POINT and VOLUME, g/s/m2 for all AREA and OPENPIT)Num_Coords =Number of coordinate pairs (POINT = 1, VOLUME = 1, OPENPIT = 1, AREA = 1, AREA_CIRC = 1, AREA_POLY >= 3)X1 =[m] X coordinate of source location [m]Y1 =[m] Y coordinate of source location [m]AQDMPS-01Air Quality Dispersion Modeling (AQDM) Protocol SpreadsheetProtocol Form for Criteria Pollutant ModelingDoc Type: Air Dispersion ModelingLateral Dimension Vertical DimensionEastingNorthingIDPollutant Base_Elev Height SigmaYSigmaZLength_X Emission_Rate Emission_RateX1Y1[m][m][m][m][m](g/sec)(lb/hr)[m][m]DescCONCWE PM2.5469.2450.20.47483070.73 5247239.03haul roadSPACEHTNO2469.24515.24.65483070.73 5247239.03space heatersLateral Dimension Vertical DimensionEastingNorthingIDPollutant Base_Elev Height SigmaYSigmaZLength_X Emission_Rate Emission_RateX1Y1[m][m][m][m][m](g/sec)(lb/hr)[m][m]DescSLGBIN01Pb274.04 1.500.710.703.78E-053.00E-04490509.00 4964685.81Slag binLOADER ROUTE40.00Loader on paved surfaceLOADER01Pb270.99 2.8212.092.635.89E-064.67E-05490584.61 4964596.79LOADER02Pb270.73 2.8212.092.635.89E-064.67E-05490566.17 4964589.08LOADER03Pb271.41 2.8212.092.635.89E-064.67E-05490546.61 4964585.39SLGLDR ROUTE120.00Slag loader on paved surfaceSLGLDR01Pb270.80 2.8212.092.632.05E-061.62E-05490581.04 4964606.09SLGLDR02Pb270.66 2.8212.092.632.05E-061.62E-05490562.18 4964612.43SLGLDR03Pb271.27 2.8212.092.632.05E-061.62E-05490547.03 4964624.91SLGLDR04Pb271.90 2.8212.092.632.05E-061.62E-05490534.27 4964640.28SLGLDR05Pb272.64 2.8212.092.632.05E-061.62E-05490525.83 4964658.42SLGLDR06Pb273.46 2.8212.092.632.05E-061.62E-05490517.33 4964676.52SLGLDR07Pb274.29 2.8212.092.632.05E-061.62E-05490506.37 4964692.92SEGMENT AB102.77Semi-trucks on paved roadwayAB01Pb277.85 3.507.573.251.46E-051.16E-04490455.98 4964499.58AB02Pb276.66 3.507.573.251.46E-051.16E-04490454.36 4964509.73aq2-41 • 7/28/11•www.pca.state.mn.us • Available in alternative formats • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864Page 3 of 7Lateral Dimension Vertical DimensionEastingNorthingIDPollutant Base_Elev Height SigmaYSigmaZLength_X Emission_Rate Emission_RateX1Y1[m][m][m][m][m](g/sec)(lb/hr)[m][m]DescAB03Pb275.44 3.507.573.251.46E-051.16E-04490452.75 4964519.88AB04Pb274.21 3.507.573.251.46E-051.16E-04490451.14 4964530.03AB05Pb272.97 3.507.573.251.46E-051.16E-04490449.53 4964540.18AB06Pb271.71 3.507.573.251.46E-051.16E-04490447.91 4964550.33AB07Pb270.93 3.507.573.251.46E-051.16E-04490446.30 4964560.48AB08Pb271.04 3.507.573.251.46E-051.16E-04490444.69 4964570.63AB09Pb271.16 3.507.573.251.46E-051.16E-04490443.08 4964580.78AB10Pb271.28 3.507.573.251.46E-051.16E-04490441.46 4964590.93SEGMENT BC105.10Semi-trucks on paved roadwayBC01Pb271.61 3.507.683.251.41E-051.12E-04490443.10 4964600.65BC02Pb272.14 3.507.683.251.41E-051.12E-04490448.00 4964609.95BC03Pb272.67 3.507.683.251.41E-051.12E-04490452.90 4964619.25BC04Pb273.20 3.507.683.251.41E-051.12E-04490457.80 4964628.55BC05Pb273.74 3.507.683.251.41E-051.12E-04490462.69 4964637.85BC06Pb274.27 3.507.683.251.41E-051.12E-04490467.59 4964647.15BC07Pb274.72 3.507.683.251.41E-051.12E-04490472.49 4964656.45BC08Pb275.14 3.507.683.251.41E-051.12E-04490477.38 4964665.75BC09Pb275.14 3.507.683.251.41E-051.12E-04490482.28 4964675.05BC10Pb275.02 3.507.683.251.41E-051.12E-04490487.18 4964684.35SEGMENT CD80.59Semi-trucks on paved roadwayCD01Pb275.03 3.507.483.253.68E-062.92E-05490489.86 4964694.03CD02Pb275.15 3.507.483.253.68E-062.92E-05490490.33 4964704.09CD03Pb275.27 3.507.483.253.68E-062.92E-05490490.80 4964714.16CD04Pb275.40 3.507.483.253.68E-062.92E-05490491.27 4964724.22CD05Pb275.53 3.507.483.253.68E-062.92E-05490491.73 4964734.28CD06Pb275.61 3.507.483.253.68E-062.92E-05490492.20 4964744.34CD07Pb275.67 3.507.483.253.68E-062.92E-05490492.67 4964754.41CD08Pb275.72 3.507.483.253.68E-062.92E-05490493.14 4964764.47SEGMENT DE122.52Semi-trucks on paved roadwayDE01Pb275.83 3.507.543.254.67E-073.70E-06490492.45 4964774.52DE02Pb275.99 3.507.543.254.67E-073.70E-06490490.61 4964784.56DE03Pb276.16 3.507.543.254.67E-073.70E-06490488.76 4964794.60DE04Pb276.34 3.507.543.254.67E-073.70E-06490486.91 4964804.65DE05Pb276.53 3.507.543.254.67E-073.70E-06490485.07 4964814.69DE06Pb276.72 3.507.543.254.67E-073.70E-06490483.22 4964824.73DE07Pb276.51 3.507.543.254.67E-073.70E-06490481.37 4964834.77DE08Pb276.17 3.507.543.254.67E-073.70E-06490479.53 4964844.81DE09Pb275.75 3.507.543.254.67E-073.70E-06490477.68 4964854.85DE10Pb275.28 3.507.543.254.67E-073.70E-06490475.84 4964864.90DE11Pb274.87 3.507.543.254.67E-073.70E-06490473.99 4964874.94DE12Pb274.49 3.507.543.254.67E-073.70E-06490472.14 4964884.98SEGMENT BF65.84Semi-trucks on paved roadwayBF01Pb271.70 3.507.893.255.16E-064.10E-05490444.98 4964599.38BF02Pb272.43 3.507.893.255.16E-064.10E-05490453.63 4964606.13BF03Pb273.15 3.507.893.255.16E-064.10E-05490462.28 4964612.88BF04Pb273.88 3.507.893.255.16E-064.10E-05490470.94 4964619.63BF05Pb274.50 3.507.893.255.16E-064.10E-05490479.59 4964626.38BF06Pb274.21 3.507.893.255.16E-064.10E-05490488.24 4964633.13SEGMENT CG110.51Semi-trucks on paved roadwayCG01Pb274.79 3.507.463.251.84E-051.46E-04490494.23 4964691.00CG02Pb274.45 3.507.463.251.84E-051.46E-04490503.45 4964695.00CG03Pb274.13 3.507.463.251.84E-051.46E-04490512.67 4964699.00CG04Pb273.82 3.507.463.251.84E-051.46E-04490521.88 4964703.00CG05Pb273.53 3.507.463.251.84E-051.46E-04490531.10 4964707.00aq2-41 • 7/28/11•www.pca.state.mn.us • Available in alternative formats • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864Page 4 of 7Lateral Dimension Vertical DimensionEastingNorthingIDPollutant Base_Elev Height SigmaYSigmaZLength_X Emission_Rate Emission_RateX1Y1[m][m][m][m][m](g/sec)(lb/hr)[m][m]DescCG06Pb273.26 3.507.463.251.84E-051.46E-04490540.31 4964711.00CG07Pb273.01 3.507.463.251.84E-051.46E-04490549.53 4964715.00CG08Pb272.78 3.507.463.251.84E-051.46E-04490558.74 4964719.00CG09Pb272.56 3.507.463.251.84E-051.46E-04490567.96 4964723.00CG10Pb272.61 3.507.463.251.84E-051.46E-04490577.18 4964727.00CG11Pb272.66 3.507.463.251.84E-051.46E-04490586.39 4964731.00SEGMENT DH48.94Semi-trucks on paved roadwayDH01Pb275.87 3.507.343.253.13E-062.49E-05490491.45 4964774.00DH02Pb276.11 3.507.343.253.13E-062.49E-05490487.60 4964783.00DH03Pb276.37 3.507.343.253.13E-062.49E-05490483.75 4964792.00DH04Pb276.65 3.507.343.253.13E-062.49E-05490479.90 4964801.00DH05Pb276.68 3.507.343.253.13E-062.49E-05490476.05 4964810.00SEGMENT AI108.56Semi-trucks on paved roadwayAI01Pb278.64 3.507.843.251.80E-061.43E-05490462.21 4964494.53AI02Pb279.02 3.507.843.251.80E-061.43E-05490473.07 4964494.58AI03Pb279.14 3.507.843.251.80E-061.43E-05490483.92 4964494.63AI04Pb278.98 3.507.843.251.80E-061.43E-05490494.78 4964494.68AI05Pb278.82 3.507.843.251.80E-061.43E-05490505.63 4964494.73AI06Pb278.65 3.507.843.251.80E-061.43E-05490516.49 4964494.78AI07Pb278.49 3.507.843.251.80E-061.43E-05490527.35 4964494.83AI08Pb278.33 3.507.843.251.80E-061.43E-05490538.20 4964494.88AI09Pb278.16 3.507.843.251.80E-061.43E-05490549.06 4964494.93AI10Pb278.00 3.507.843.251.80E-061.43E-05490559.92 4964494.98SEGMENT IJ25.51Semi-trucks on paved roadwayIJ01Pb277.45 3.506.753.251.32E-071.05E-06490565.25 4964499.25IJ02Pb276.51 3.506.753.251.32E-071.05E-06490565.05 4964507.75IJ03Pb275.58 3.506.753.251.32E-071.05E-06490564.85 4964516.25SEGMENT IK106.73Semi-trucks on paved roadwayIK01Pb277.89 3.507.753.256.84E-065.43E-05490570.68 4964495.08IK02Pb278.03 3.507.753.256.84E-065.43E-05490581.35 4964495.23IK03Pb278.17 3.507.753.256.84E-065.43E-05490592.02 4964495.38IK04Pb278.31 3.507.753.256.84E-065.43E-05490602.70 4964495.53IK05Pb278.45 3.507.753.256.84E-065.43E-05490613.37 4964495.68IK06Pb278.59 3.507.753.256.84E-065.43E-05490624.04 4964495.83IK07Pb278.73 3.507.753.256.84E-065.43E-05490634.71 4964495.98IK08Pb278.87 3.507.753.256.84E-065.43E-05490645.38 4964496.13IK09Pb279.01 3.507.753.256.84E-065.43E-05490656.06 4964496.28IK10Pb278.65 3.507.753.256.84E-065.43E-05490666.73 4964496.43SEGMENT KL47.60Semi-trucks on paved roadwayKL01Pb277.95 3.507.223.258.87E-067.04E-05490675.44 4964499.85KL02Pb277.13 3.507.223.258.87E-067.04E-05490682.21 4964506.55KL03Pb276.40 3.507.223.258.87E-067.04E-05490688.97 4964513.25KL04Pb275.75 3.507.223.258.87E-067.04E-05490695.73 4964519.95KL05Pb275.20 3.507.223.258.87E-067.04E-05490702.49 4964526.65aq2-41 • 7/28/11•www.pca.state.mn.us • Available in alternative formats • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864Page 5 of 7AQ Facility ID No:03700016Facility Name:Gopher ResourceFacility Address:3385 SouthHighway 149Eagan, MNFacility Contact:Steve Yates (651) 405-2213Stack Vent Emission PollutantDescriptionEmission Factor Emission Factors References/Assumptions/EquationsIDUnitUsed to generate short - term emission rateSV001EU001NO2Emergency Power Generator Concentrator-Diesel0.011,200 kW capacity provided by vendor x 1.341 hp/kW =1,609 hp lb/hp-hr emission factors from AP-42 'LargeStationary Diesel And All Stationary Dual-fuel Engines'(10/96)T bl 3 4 1SO2 0 00809Emission Calculations TableStack Vent Emission PollutantDescriptionEmission Factor Emission Factors References/Assumptions/EquationsIDUnitUsed to generate short - term emission rateROADWAYSPbRoadway emission factors for TSP VARIABLEE = [k(sL)0.91 x (W)1.02] (1 - P/4N)ÕE = emission factor (lb/VMT)Formula from AP-42 Section 13.2.1k = particle size multiplier (lb/VMT, 0.0022 for PM10, 0.00054 for PM2.5, 0.011 for PMsL = road surface silt loading (g/m2)SLAG BINPbTSP emission factor for slag transfer0.00154% Pb content; 60 tons/day slag movedW = average weight of vehicles traveling the road (tons)Emission factor from AP-42 Table 11.19.2-1VMT = vehicle miles traveledP = number of "wet" days with at least 0.254 mm (0.01") of precipitation during the avN = number of days in the averaging period (365 for annual period corresponding toaAQDMPS-01Air Quality Dispersion Modeling (AQDM) Protocol SpreadsheetProtocol Form for Criteria Pollutant ModelingDoc Type: Air Dispersion Modelingaq2-41 • 7/28/11•www.pca.state.mn.us • Available in alternative formats •651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864Page 6 of 7M30(TSP))veraging period (110 days for GOPHER)above)aq2-41 • 7/28/11•www.pca.state.mn.us • Available in alternative formats •651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864Page 7 of 7www.pca.state.mn.us • 651

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# AQDMP

- 01

Air Quality Dispersion Modeling (AQDM) Protocol

Protocol Form for Criteria Pollutant Modeling

Doc Type: Air Dispersion Modeling



### Guidance Information on Page 12

Instructions: Permit applicants required to conduct air dispersion modeling should submit two paper copies of the completed Air Quality Dispersion Modeling Protocol form (AQDMP-01), the Air Quality Dispersion Modeling Protocol Spreadsheet (AQDMPS-01), and all accompanying files to:

Air Quality Permit Document Coordinator Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN 55155 -4194

Applicants may also submit an electronic version in addition to the two paper copies.

Electronic copies of the forms and accompanying files should be sent to: AirModeling.PCA@state.mn.us

.



## Facility Information

AQ file no.: AQ facility ID no.: 03700016 Today’s date (mm/dd/yyyy): 11/ 21 /2011

Three

- letter modeling facility ID (ex., ACE, XAK, MEC, NUP, etc.): GRC

Facility

name: Gopher Resource

Facility street
address: 3385 South Highway 149

City: Eagan State: MN Zip code: 55121

- 2317

Phone: ( 651 ) 454

- 3310 Fax: ( 651 ) 454

- 7926 E

- mail:

Facility contact: Steve Yates Protocol prepared by: ENVIRON International Corp.

Contact phone: (651) 405

- 2213 Contact e

- mail address: Steve.Yates@grcmn.com

County: Dakota Elevation at facility: 275 m

Latitude, Longitude of facility (Dec. degrees) : 44.835 N, 93.120 W and UTM coordinates, (NAD83, zone 15 extended): x= 490535 m, y= 4964720 m



### Files to accompany protocol Use the checkboxes to indicate that the following **required** files are included with the completed protocol form. Please do not use spaces or special characters in the file names or pathways.

1. Sample AERMOD input files for each modeled criteria pollutant (*.inp, *.adi, *.ami)

*Note: Input file should include receptor grid and building downwash (if applicable)

2. BPIPPRM input file (*.bpi)

3. Elevation files for input into AERMAP (*.tif (NED files), *.dem(s))

4. Background data files with concentratio ns for each applicable pollutant (annual, seasonal, monthly, daily, etc.)

5. AQDMPS

- 01 spreadsheet

6. Optional , but recommended, files and supporting documents (ex., SAM and/or SMS Spreadsheets, images, figures, SIL analysis modeling output files, etc.)

– Please list : Facility location, modelling domain, receptor array

...



## Section A. Purpose for Air Dispersion Modeling and Related Informationwww.pca.state.mn.us • 651

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aq2- 40 • 7/22/11 Page 2 of 12 1. What is the purpose for conducting the ambient air dispersion modeling (check all that apply)?

Permit requirement EAW EIS SIP PSD

Other

– pl ease explain:

2. What type of air emission permit does this facility currently hold?

N o current permit Federal (Title V/Part 70) State State Registration Capped General

Other :

3. Will you be applying for a permit or a permit amendment for the project? Yes No

4

. In 50 words or less, pl ease provide a description of the proposed project:
Demonstration of lead (Pb) NAAQS attainment

5

. Is the proposed project subject to PSD ? Yes No

a. If y es

, list pollutants:

b. Is this facility considered a major source for PSD: Yes No

6

. Has the PSD minor source baseline been set for : Dakota County ? Yes No

a. If yes, for which pollutant(s) and the year(s) it was set (check all that apply)?

NO 2 PM 10 PM 2.5 SO 2 PSD major source baseline (PM 2.5 trigger date will be on Oct. 20, 2011, 1 year after F.R. publication date.)

NO 2 1988 PM 10 1975 PM 2.5 2010 SO 2 1975

7

. What type of analysis will be conducted (check all that apply)?

NAAQS/MAAQS PSD Class II Increments PSD Class I Increments SIL Analysis Screening

Other:

8

. Was MPCA air dispersion modeling staff consulted while completing this form ? Yes No

a. If yes, please list consultation information:

MPCA
staff name: Dennis Becker DQ or tracking no: N/A Date of
consultation (mm/dd/yyyy): 11/08/2011

Topic of consultation:

Volume source parameters.

9

. Addition al information for this section (if not applicable, place N/A in field) :

N/A



## Section B. EPA Pre-Processors and EPA Post-Processors

1. Will AERMAP be used ? Yes No

If no, please explain:

2

. What version of AERMAP is proposed to be used : AERMAP version 11103

a. If other, please explain :

b. What type of elevation data will be used :

NED 1/3 arc second NED 1 arc second DEM 7.5 min DEM 1.0 degree

Other

- Please describe:
All UTM coordinates must be in NAD83, Zone 15 Extended ( **not** NAD27).

3. Will BPIP

- PR I M E version 04274 be used ? Yes No

If no , please explain :www.pca.state.mn.us • 651

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aq2- 40 • 7/22/11 Page 3 of 12 Tiering of buildings must follow MPCA’s modeling guidance from section 6 of the Oct. 2004 “MPCA Air Dispersion Modeling Guidance For Minnesota Title V Modeling Requirements And Federal Prevent ion of Significant Deterioration (PSD) Requirements (Version 2.2).”

4. Will MPCA pre

- processed AERMET data be used? Yes No If no, proceed to question 5.

Note

– MPCA’s pre

- processed meteorological data with AERMET incorporates the following details:

AERSURFACE version 08009 is used to determine surface chara cteristics using 1992 LULC data.

Yearly

- averaged moisture conditions (wet, dry, or average) based on historical ranks are accounted for in
AERSURFACE to aid in the determination of Bowen ratio values

. Default 1.0 km radius for surface roughness and 10 km b y 10 km domain for albedo and Bowen ratio used in
AERSURFACE

a. If no , will on

- site meteorological data be processed and used ? Yes No

* If no to question 4a, skip to question 5 and provide additional information in question 6.

b. If yes to question 4a, please answer the following questions. Otherwise, please move on to question 5.

i. Will AERSURFACE be used to determine surface characteristics around the meteorological tower ? (Default is “Yes”) Yes No

ii. What version of AERSURFACE is proposed to be used : (Select from list)

iii. What LULC data will be used? (Select from list)

If other, please explain:

iv. Will yearly

- averaged moisture conditions (wet, dry, or average) based on historical ranks be accounted for in AERSURFACE (for the Bowen Ratio)? (Default is “Yes”) Yes No

v. Will the default 1.0 km radius for surface roughness, and 10 km by 10 km domain for albedo and Bowen ratio be
used ? (Default is “Yes”) Yes No

If no , please explain:

5. Are any EPA post

- processors (such as LEADPOST) proposed to be used in the analysis? Yes No

a. If yes, what post

- processor(s) and version(s) :

LEADPOST v ersion 11237

6

. Addition al information for this section (if not applicable, place N/A in field) : AERMET v11059 (SFC & PFL) meteorological files from M SP

- MPX (SFC WBAN 14922 & UA ID 94983) for 2006

- 2010 were supplied by MPCA.



## Section C. Model Selection and Options (Key CO Pathway Inputs)

1

. Identify the air dispersion model and version proposed to be used in the analysis: AERMOD version 11103

a. If other, please list:

2. Will alternative air dispersion models and/or methods, as specified by Appendix W, be applied (e.g., parallel version(s) of model, PVMRM/OLM, secondary formation, etc.) ? Yes No
If yes, please explain:

a. If yes, will approval be required by MPCA and/or EPA Region V air modeling staff ? Yes No
If yes, please select: MPCA (State

- only action) EPA Region V (PSD/SIP action)

If no, please explain: N/A

3. What criteria pollutants are required to and will be modeled (check all that apply)?

CO NO 2 PM 2.5 PM 10 SO 2 Pb H 2 S Other:

Please refer to **table A.1 and A.2 in the appendix** for averaging times and form of standard for each criteria pollutant(s).
Refer to the most recent version of the EPA’s AERMOD User’s Guide fo r correct pollutant IDs to use. Use EPA’s most recent modeling guidance’ methods for PM 2.5

.

4. What model options are proposed to be used in the analysis for the source under review (check all that apply)?
Regulatory Default

- list pollutants : Non

- Regulatory Default

- List pollutants:

Concentration Rural Urban Other: BETA

a. If Urban, please specify population area, population, and surface roughness radius:www.pca.state.mn.us • 651

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Population area: Population: Surface roughness radius: 1.0 km

b. If Non

- Regulatory Default, please specify non

- default options: N/A

5. If NO 2 is required to be analyzed for the 1

- hour and annual NAAQS, what tier methodology(s) is proposed?

N/A, NO 2 not required (skip to question 6)
Tier 1 (100% NO x to NO 2 conversion, most conservative)
Tier 2 (Default ambient ratio of 0.80, or an appropriate ratio value)

Tier 3 (OLM, requires justification and approval by MPCA and/or EPA Region 5)
Tier 3 (PVMRM, requires justificatio n and approval by MPCA and/or EPA Region 5)

a. If Tier 2, please provide the ambient ratio proposed (default = 0.80): 0.80

b. If Tier 3 is anticipated to demonstrate compliance in the modeling analysis (OLM or PVMRM), please provide the following details now to expedite MPCA’s review:

In

- stack ratio of NO 2 /NO x (NO2STACK) (default=0.50): 0.50

Equilibrium ratio (NO2EQUIL) (default=0.90): 0.90

Ozone (Please select option(s)) : Monitored Value (OZONEVAL): Units (OZONUNIT): ug/m^3

MPCA

- generated Inverse

- Distance Weighted Hourly O 3 File (μg/m 3 ) (OZONEFIL)

File name: DMAX: km

MPCA

- generated Maximum Hourly Monitored O 3 File (μg/m 3 ) (OZONEFIL)

File name: DMAX: km

Other

- please explain:

c. Is EPA approval needed for the modeling protocol (e.g., Tier 3 NO 2 )? Tier 3 NO 2 methodologies that require approval by Region 5 modeling staff need to have said approval before submission of this form.

Yes

– PSD/SIP permit action No

– State

- only action

d. Are the following criteria from Appendix W, section 3.2.2, p aragraph (e) met in this protocol?

e. “Finally, for condition (3) in paragraph (b) of this subsection...an alternative refined model may be used provided that:

i. The model has received a scientific peer review;

ii. The model can be demonstrated to be applicable to the problem on a theoretical basis;

iii. The data bases which are necessary to perform the analysis are available and adequate;

iv. Appropriate performance evaluations of the model have shown that the model is not biased toward underestimates;
and

v. A protocol on methods and procedures to be followed has been established.” Yes No

If no , please explain:

6. Addition al information for this section (including justification for non

- default or additional values listed in 5a or 5b):

P b modeling only



## Section D. Emission Source Characterizations and Parameters (Key SO Pathway Inputs)

Include and list the facility’s modeling parameters for all source types in the MPCA’s Modeling Parameters Spreadsheet (Form AQDMPS-01). For background sources listed within SO Pathway, please see Section I.

1. Please indicate which of the following source characterizations are present at your facility and will be included for modelin g analysis (check all that apply ):

“Yes” = Source

- type present and will model; “N/A” = Source

- type not present; “No” = Source

- type present but will not model.

**Subsection I. Point sources** :

Yes N/A No please explain:

a. Are any of the point sources capped and/or horizontal stacks (see guidance in section 6.1, AERMOD Implementation Guide (03/19/2009)) and accounted for in the following?

No Yes

– e xit velocity(s) = 0.001 m/s Non

- Default POINTCAP/POINTHOR*
*Please provide justification for use of non

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b. Addition al information for this sub section (if not applicable, place N/A in field):
One stack has a deflector (cap).

**Subsection II. Volume sources:**

Yes N/A No please explain:

Please refer to figure A.1 in the appendix on calculating the lateral and vertical dimensions.

a. Will there be any volume source(s) overlapping or within 1.0 meters of any receptors?

No Yes *

* Volume source should be converted to an area source of commensurate size (per section 6.2 of the latest AERMOD Implementation Guide (03/19/2009)) or be further refined.

b. Addition al information for this subsection (if not applicable, place N/A in field):

N/A

**Subsection III. Area sources (includes AREACIRC and AREAPOLY):**

Yes N/A No please explain:

a

. Addition al information for this subsection (if not applicable, place N/A in field):

N/A

**Subsection IV. Open pit sources:**

Yes N/A No please explain:

a. Addition al information for this subsection (if not applicable, place N/A in field):

N/A

2. Are fugitive emissions emitted from the source and will they be accounted for in the modeling analysis?

(Examples of fugitive emissions include but are not limited to: traffic on paved and/or unpaved roads, stockpiles of various materials, wind erosion, loadout, unloading, etc.)

Yes N/A No please explain:

a. If yes, please list the facilities’ fugitive sources: Slag bin and roadways

Note: If modeling for paved road fugitive dust, please read and complete S ection E.

b. Will the Standardized Mobile Source (SMS) Spreadsheet be used to determine emissions due to paved and/or unpaved roads (unpaved spreadsheets under development)? Yes No

3. Will all insignificant activities emitted from the source for PM 10 , with emissions over 0.1 lb/hr and for PM 2.5 , with emissions over 0.02 lb/hr, be accounted for in the modeling?

Yes N/A No please explain:

* Please provide justification for excluding any fugitive and/or insignificant activities within the modeling.

Plea se scale for other pollutants. For example, (0.1 lb/hr)/(150 μg/m 3 ) = (X lb/hr)/(35 μg/m 3

), where X = 0.02 lb/hr.
Refer to guidance in section 10 of t he Oct. 2004 “MPCA Air Dispersion Modeling Guidance For Minnesota Title V Modeling Requirements And Federal Prevention of Significant Deterioration (PSD) Requirements (Version 2.2)”

4. Will all applicable PSD increment consuming and/or expanding sources be modeled for your source?

Yes N/A No please explain:

5. Will emission factors/scalars be used to demonstrate compliance in the air dispersion modeling analysis? Yes No
If yes to a., describe which sources and the types of emission factors/scalars that will be applied : Emission factors for paved roadways (AP

- 42 Section 13.2.1) & pulverized mineral processing (AP

- 42 Section 11.19.2)

6. Will NO 2 /NO x ratios be provided, source

- by

- source, for OLM/PVMRM options? N/A Yes No

7. Will “OLMGROUP ALL” be used for OLM option? N/A Yes No

8. Addition al information for this section (if not applicable, place N/A in field):www.pca.state.mn.us • 651

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## Section E. Paved Roads Fugitive Dust (Optional)

Current MPCA policy regarding modeling of paved road fugitive dust emissions, in support of air quality permitting or environmental review, recommends that:

New facilities or facilities undergoing physical expansions will not be required to model paved road fugitive dust emissions if a facilities’ predicted ambient impacts for PM 10 and PM 2.5 are less than a specified % of the NAAQS and/or PSD Class II Increment. This policy does not apply to modeling that supports permitting in maintenance areas or the development of State Implementation Plans. Exceptions to the policy can and will occur.

If paved road fugitive dust emissions are proposed to be included in your modeling analysis and you did not answer “No” to question 1b, MPCA guidance recommends that the source in question first model its’ facility without including paved road fugitive dust emissions. Results then can be recorded using Table E-01 below for PM 10 and PM 2.5 (NAAQS modeling must include background concentrations).

1. Does your facility have paved road fugitive dust emissions for PM 10 and PM 2.5 ?

Yes No

– Please continue to the next section (F)

a. Will your facility include paved road fugitive dust emissions for modeling? Yes No

b. Is your facility either a new source or an existing facility undergoing a physical expansion?

New source Existing w/ phys. expan. No *

* If no, please answer questions 2

– 4 only as necessary and then proceed to the next section.

c. If yes to question 1 and no to question 1a, please provide justification for not including paved road fugitives:

2. How many vehicles per day drive on and off your facility’s property?

Employee traffic and parking: Third

- party truck traffic:

3. Will you be using the most recent version of the MPCA’s Standardized Mobile Source (SMS) spreadsheet to determine paved road fugitive dust emissions and source parameters?

Yes* No *If yes, please submit SMS with this modeling protocol form and indicate on the cover page of this form.

4. Addition al information for this section (if not applicable, place N/A in field):

**Note:** Modeling and completing the tables below are optional for this form. However, results must be provided with the modeling analysis results in the permit application, to support or not support the inclusion paved road fugitive dust sources in the analysis.



### Table E- 01

Averaging
Period NAAQS (μg/m 3 ) Modeled NAAQS Impact
Concentrations (μg/m 3 ) % of NAAQS PSD Class II

Increments (μg/m 3 ) Modeled Class II

Increment Impact
Concentrations (μg/m 3 ) % of Class II

Increments

PM 10 24

- hour 150 0.0 30 0.0

Annual 50 0.0 17 0.0

PM 2.5 24

- hour 35 0.0 9 0.0

Annual 15 0.0 4 0.0

Table E-02 indicates the resultant category(s) for your facility, based on the % of the standard(s) for PM 10 and PM 2.5 (see results in columns “% of NAAQS” and “% of Class II Increments” in Table1F-01 above). This uses the highest % from all averaging periods for each pollutant and standard. The category descriptions are provided in Table E- 03 . Answers to question 2 above will help determine permit conditions if modeled concentrations result in a category 2 designation.



### Table E- 02

NAAQS PSD Class II Increments
**NAAQS Result(s) w/ Background**  Cat. 1 Cat. 2 Cat. 3 **PSD Class II Result(s)**  Cat. 1 Cat. 2 Cat. 3www.pca.state.mn.us • 651

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PM 2.5 0.00 # < 80% 80% < # < 95% 95% < # 0.00 # < 40% 40% < # < 80% 80% < #



### Table E- 03

Cat 1: Paved road fugitive emissions not required to be modeled, and no paved road fugitive dust permit conditions.

Cat 2: Paved road fugitive emissions not required to be modeled, with paved road fugitive dust permit conditions determined by

levels of traffic at the facility.

Cat 3: Paved road fugitive emissions are required to be modeled, with site

- specific paved road fu gitive dust permit conditions.

Re

- modeling and/ or addition of paved road fugitive emissions source group required.



## Section F. Receptors (RE Pathway)

Please refer to guidance from Table 4 and 5 of the October 2004 “ MPCA Air Dispersion Modeling Guidance For Minnesota Title V Modeling Requirements And Federal Prevention of Significant Deterioration (PSD) Requirements (Version 2.2)” , as well as federal guidance.

1. What type of receptor grid will be used? Nested Cartesian

a. If other or a combination , please describe:

2. How many # receptors in total will be in the receptor grid? 12,834

3. What will be the grid dimensions ? (Ex., radius of 10 km, 5 km by 5 km, etc.) 10 km x 10 km

4. What is the proposed spacing of receptors for...?

a. Inside the property boundary(s): N/A meters

b. On the fenceline(s): 10 meters

c. On the property line(s): N/A meters

d. Beyond the property line(s): 25, 50 & 250 meters

5. Will FLAGPOLE receptors be included in the receptor grid?

Yes N/A No

– Please continue to the next section (F)

6

. Addition al information for this section (if not applicable, place N/A in field):

N/A



## Section G. Meteorological Data (ME Pathway)

1. What meteorological surface station is proposed for use? Please indicate the three letter call sign, station name and the
state the surface station is located in. (Ex.: MSP: Minneapolis/St. Paul, MN)

Pre

- processed AERMET version 06341 or earlier files: N/A

Pre

- processed AERMET version 11059, with or without AERMINUTE version 11059 processing, files: N/A
MSP, Minneapolis/St. Paul Int'l Arpt, MN

Other:

2. What meteorological upper air station was used? MPX: Twin Cities/Chanhassen, MN

3. What consecutive 5

- year period will be used? 2006 - 2010

a. If other, please specify:



### Subsection I: On-Site Meteorological Data

Note: If site-specific meteorological data will be collected and used, please follow the federal guidance (EPA’s), as specified in section 8.3 and section 8.3.3.2 (QA/QC) of 40 CFR Part 51 dated 11/09/2005 (Appendix W).

a. If site

- specific meteorological data will be collected and used, where will the location of the meteorological tower be set (city and state, coordinates, etc.)?

N/A

b. If site

- specific meteorological data will be collected and used, what year of data is proposed to be used?

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. What justification(s) applies for the proposed surface and upper air stations identified above? (Check all that apply)
Similar surface characteristics as meteorological tower Similar land use characteristics

Similar wind patterns/characteristics Proximity to surface and/or upper air station(s)

Other

– Please describe:

a. Please provide additional detail for your justifications:
The meteorological data was supplied by MPCA. The MSP Airport is on the edge of the modelling domain.

5. Will wind speed categories be used?

Yes No

– Skip to question 6.

a. If yes, please list the user

- specified wind speed categories for the ME WINDCATS pathway:

b. If yes, please list the user

- specified wind speed emission factors for the SO EMISFACT WSPEED pathway:

6

. Addition al information for this section (if not applicable, place N/A in field):

N/A



## Section H. SIL Analysis and Results

1. Will a SIL analysis be conducted in conjunction with this project, in order to determine if a cumulative analysis is required ?

N/A

– Proceed to the next section (I)

No

– Will not model against SILs and instead proceed directly to conducting a cumulative analysis

Yes

– List for w hich pollutants:

2. Extent of SIL receptor grid: km

3. If a preliminary SIL analysis has been conducted for this project, it is optional but recommended that results be provided (in the table below) including corresponding model output files.



### Class II Significant Impact Levels Modeling Results for :

Pollutant Averaging Time Modeled Impacts (H1H) (μg/m 3 ) SILs (μg/m 3 )

***As of**
**10/26/2010** % of SIL Exceed SIL? Radius of Impact (If exceeds SIL)

SO 2 1

- hr 7.83 0.0

(blank) km

3

- hr 25 0.0

24

- hr 5 0.0

Annual 1 0.0

PM 10 24

- hr 5 0.0 (blank) km

Annual 1 0.0

PM 2.5 24

- hr 1.2 0.0 (blank) km

Annual 0.3 0.0

NO x 1

- hr 7.52 0.0 (blank) km

Annual 1 0.0

CO 1

- hr 2000 0.0 (blank) km

8

- hr 500 0.0

4. Addition al information for this section (if not applicable, place N/A in field):

Demonstration of SIP attainment.



## Section I. Background Values

Please refer to pages 35-39 and Table B-4 of the “ AERMOD User’s Guide, Addendum for Version 11103 ” for guidance as well as the latest version of the MPCA’s Air Dispersion Modeling Guidance for Title V and PSD. *Contact MPCA air dispersion modeling staff for MPCA-generated products.www.pca.state.mn.us • 651

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aq2- 40 • 7/22/11 Page 9 of 12 1. Are background concentrations required for your analysis?

Yes

– List pollutants required for: Pb

No

– Please explain and proceed to question 3 (e.g., SIL analysis

- only, etc.):

a. Will MPCA

- generated background concentrations be used?

No Yes

– List pollutants required for:

If yes, check MPCA

- generated background concentrations option(s) to be used:

SO BACKGRND BGflag (BGflag can be defined as ANNUAL, SEASON, MONTH, etc. See Table B

- 4, Appendix B, of the AERMOD User’s Guide Addendum)

BGflag(s):

SO BACKGRND HOURLY
File name(s):
File creation date(s) & time(s):
Radius Maximum (RMAX): km

Uniform background concentration(s)

b

. Will user
- generated background concentrations be used?

No Yes

– List pollutants required for:

If yes, check user

- generated background concentrations option(s) to be used:

SO BACKGRND BGflag (BGflag can be defined as ANNUAL, SEASON, MONTH, etc. See Table B

- 4, Appendix B, of the AERMOD User’s Guide Addendum)

BGflag(s):

SO BACKGRND HOURLY
File name(s):
File creation date(s) & time(s):
Radius Maximum (RMAX): km
Uniform background concentration(s)

c

. If yes to question 1b above, please provide additional information regarding the development of user
generated background concentrations.

Background value(s) developed from: MPCA website EPA website

Other

– explain:

Examined monitors out to a distance of: km

Faci lity setting : Urban Suburban Rural

Facility land use (industrial, residential, agricultural, cropland, mixed, etc.):
Monitor setting : Urban Suburban Rural

Monitor land use (industrial, residential, agricultural, cropland, mixed, etc.):
Form of background value(s) (maximum, 98 th percentile, etc.): km

2. If “SO BACKGROUND BGflag ANNUAL” or user

- developed uniform background concentrations will be used, please input the background concentrations in the table below. (ANNUAL in this context means uniform value; it does not mean annual average.)

Uniform Background Concentrations

Pollutant Averaging Time Periods

**1⁄2**

**- Hour**  **1**

**- Hour**  **3**

**- Hour**  **8**

**- Hour**  **24**

**- Hour**  **Rolling 3**

**- month**  **Annual**

SO 2 - - -
PM 10 - - - - -
PM 2.5 - - - - - NO x - - - - - CO

- - - - -
Pb

- - - - - 0

-
H 2 S

- - - - - - Other

-

3. Addition al information for this section (if not applicable, place N/A in field):www.pca.state.mn.us • 651

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aq2- 40 • 7/22/11 Page 10 of 12 Pb SIL analysis



## Section J. Nearby Sources

*Contact MPCA air dispersion modeling staff for MPCA-generated products.

1. Will any nearby sources be modeled explicitly for the analysis?

N/A No Yes

– List pollutants required for:

a. Will MPCA

- generated nearby sources be used?

N/A No Yes

– List pollutants required for:

If yes, check MPCA

- generated near sources option(s) to be used:

Refined nearby source modeling Within km of subject facility

List nearby sources:

First

- approximation representative (FAR) data
File name(s):

Creation date: Creation time:

Distance (DMAX) 

### : Scalar (SMAX):

Significance level: Coef. * D test:

b

. Will user
- generated nearby sources be used?

N/A No Yes

– List pollutants required for:

If yes, check user

- generated near sources option(s) to be used:

Refined nearby source modeling Within km of subject facility

List nearby sources:

First

- approximation representative (FAR) data
File name(s):

Creation date: Creation time:

Distance (DMAX) 

### : Scalar (SMAX):

Significance level: Coef. * D test:

2. Addition al information for this section (if not applicable, place N/A in field):

N/A



## Appendix

Figure A.1www.pca.state.mn.us • 651

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aq2- 40 • 7/22/11 Page 11 of 12 Table A.1 – Modeled Form of the NAAQS/MAAQS for Averaging Periods

Pollutant 1

- hour 3

- hour 8

- hour 24

- hour Monthly Annual

CO H2H

- H2H

- - - NO 2 98 th percentile of the daily max. 1

- hour values

- - - - H1H

Pb

- - - - H1H

- PM 10 - - - H6H of the multiyear values

- H1H

PM 2.5 - - - 98 th percentile of daily max. 24

- hour values

- H1H
SO 2 99 th percentile of the daily max. 1

- hour values H2H

- H2H

- H1H

Table A.2 – Modeled Form of PSD Increment for Averaging Periods

Pollutant 1

- hour 3

- hour 24

- hour Annual

NO 2 - - - H1H

PM 10 - - H2H H1H

PM 2.5 - - H2H* H1H

SO 2 - H2H H2H H1H **Criteria pollutants modeled for SIL analyses should be modeled as H1H’s.**



## Helpful Webpages and Documents/Guidance

Please consult the following webpages and documents for the most current modeling guidance and recommendations when filling
out this form:
U.S. EPA’s Support Center for Regulatory Atmospheric Modeling: http://www.epa.gov/scram001/ Please check the SCRAM webpage regularly for the most recent updates to guidance, models, and standards; especially, for modeling guidance related to: 24-hour PM2.5, 1-hour NO2, and 1- ho ur SO2 NAAQS.
U.S. EPA’s 40 CFR Part 51 Appendix W: http://www.epa.gov/ttn/scram/guidance/guide/appw_05.pdf
U.S. EPA’s AERMOD Implementation Guide: http://www.epa.gov/ttn/scram/7thconf/aermod/aermod_implmtn_guide_19March2009.pdf

U.S. EPA’s AirData: http://www.epa.gov/air/data/index.html
MPCA’s Air Dispersion Modeling: http://www.pca.state.mn.us/nwqh421
MPCA’s Ambient Air Monitoring Network Plan: http://www.pca.state.mn.us/mvri439
USGS’ National Map Seamless Viewer (NED data) : http://seamless.usgs.gov/website/seamless/viewer.htm

For questions on this form, or data requests from MPCA air dispersion modeling staff, please send an e-mail to: AirModeling.PCA@state.mn.us . Please be sure to include with your questions or requests: the form ID (ADQMP-01), facility name and permit #, and contact information.

Questions can also be asked by calling one of the MPCA’s air dispersion modeler’s (phone numbers are listed on the MPCA’s Air Dispersion Modeling webpage, link above).

Note: Please be sure to use UTM Coordinates, NAD83, Zone 15 Extended for all locational data.www.pca.state.mn.us • 651

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aq2- 40 • 7/22/11 Page 12 of 12 Under-Development by MPCA Staff:

Procedures and data involving the following subject areas are under-development and therefore, MPCA air dispersion modeling staff should be contacted (via the email address above) to discuss data files, methods, and/or procedures for:
Standardized Air Modeling (SAM) Spreadsheet and/or Standardized Mobile Source (SMS) Spreadsheet Background concentration data Nearby sources

Pre -processed AERMET meteorological data files Ozone data generated for Tier 3 NO 2 modeling

Acronyms

AERMAP

AERMET
AERMOD
AERSURFACE Air Quality (AQ) Air Quality Dispersion Modeling Protocol form (AQDMP- 01) Air Quality Dispersion Modeling Protocol Spreadsheet (AQDMPS- 01)

BPIP- PR IME
C arbon Dioxide (CO) Digital Elevation Model (DEM) Environmental Assessment Worksheet (EAW) Environmental Impact Statement (EIS) U.S. Environmental Protection Agency (EPA) Hydrogen Sulfide (H 2 S) Kilometer ( km ) Minnesota State Ambient Air Quality Standard (MAAQS) Minnesota Pollution Control Agency (MPCA)

National Ambient Air Quality Standard (NAAQS) National Elevation Dataset (NED) Nitrogen Dioxide ( NO 2 ) Particulate Matter less than 10 um in size (PM 10 ) Particulate Matter less than 2.5 um in size (PM 2.5 ) Lead ( Pb )
POINTCAP
POINTHOR Prevention of Significant Deterioration Program (PS D) Plume Volume Molar Ratio Method/Ozone Limiting Method (PVMRM/OLM) Standardized Air Modeling (SAM) Significant Impact Level ( SIL ) Sulfur Dioxide (SO 2 ) State Implementation Plan (SIP) Standardized Mobile Source (SMS) Universal Transverse Mercator (UTM)www.pca.state.mn.us • 651

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aq2- 44 • 11/30/11 Page 1 of 2 

# AQDM PRF

- 01

AQDM Protocol Review Form
for Criteria Pollutant Modeling Air Quality Dispersion Modeling (AQDM)

Doc Type: Air Dispersion Modeling

Publication document #n/a

Instructions: This form is used for Minnesota Pollution Control Agency (MPCA) internal use by Air Dispersion Modeler and Air Permit Engineers to review for Criteria Pollutant Modeling.



## Protocol Information

Today’s date (mm/dd/yyyy): 1/23/2012 Today’s date (mm/dd/yyyy):

MPCA Air Dispersion Modeler: Melissa Sheffer MPCA Air Permit Engineer:

Air quality file number: Air quality ID number: 03700016

Three

- letter modeling facility ID (ex., ACE, XAK, MEC, NUP, etc.): GRC

Facility name: Gopher Resources

Date protocol was received at the MPCA (mm/dd/yyyy): 1/17/2012

Project name: Gopher Pb Attainment Demonstration , Re

- Model



## Approval of Modeling Protocol by Sections

– Completed by Air Dispersion Modeler

S ection and s ection name Acceptable/ Unacceptable Deficiencies and/or comments

Files to accompany Protocol Acceptable Re

- run of model, including a background concentration of 0.01 ug/m^3, resulted in a maximum rolling 3

- month concentration of 0.12 8097

.

Section A: Purpose for air dispersion modeling and related
information Acceptable No comments

Section B : EPA Pre

- processors and EPA Post

- processors Acceptable No comments

Section C : Model selection and options (Key CO pathway inputs) Acceptable Question C.4.b should not have been left as "N/A" and instead should
have mentioned non

- default option of BETA for POI NTCAP on stack
RSTACK08.

Section D : Emission source characterizations and parameters (Key SO pathway inputs) Acceptable No comments

Section E : Paved roads fugitive

dust Acceptable Section not filled out, but as policy is for PM10 and PM2.5, this is acceptable.

Section F : Receptors (RE pathway) Acceptable No comments

Section G : Meteorological data (ME pathway) Acceptable No comments

Section H : SIL analysis and re sults Acceptable No comments

Section I : Background values Acceptable Background value of 0.01; was approved via email on 01/12/2012.

Section J : Nearby sources Acceptable No comments

Section K : Anticipated outputs (OU pathway) Acceptable This version of the modeling protocol form did not have Section K.

AQDMPS

- 01 Form Acceptable Values in spreadsheet matched input file entries.www.pca.state.mn.us • 651

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aq2- 44 • 11/30/11 Page 2 of 2 Noted that point source emission rates were taken from most recent stack tests (as indicated in supplemental document). As explained in a phone
conversation with Darren Wilton

, the main stack, the two tor it stacks, and

the scrubber stack were all modeled at more con servative emission rates
than the stack tests resultant emissions.

Modeling Protocol is: Approved



## Approval of Modeling Protocol by Sections

– Completed by Air Permit Engineer

S ection and s ection name Acceptable/

U nacceptable Deficiencies and/or comments

Section D : Emission source characterizations and parameters (Key SO pathway inputs) [select from list]

Section E : Paved roads fugitive

dust [select from list]

AQDMPS

- 01 Form [select from list]

Comments on other sections:

Modeling Protocol is: [select from list]www.pca.state.mn.us • 651

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aq2- 43 • 9/23/11 Page 1 of 1 

# AQDM P AN

- 01

AQDM Protocol Approval Notification Form

Air Quality Dispersion Modeling (AQDM)

Doc Type: Air Dispersion Modeling

Instructions: This form is used for Minnesota Pollution Control Agency (MPCA) internal use by Air Dispersion Modeler and Air Permit Engineers to review for Criteria Pollutant Modeling.



## Facility Information

AQ file no.: AQ facility ID no.: 03700016 Submittal date (mm/dd/yyyy): 1/23/2012

Three

- letter modeling facility ID ( ex., ACE, XAK, MEC, NUP, etc.): GRC

Facility name: Gopher Resource

Facility street addr ess: 3385 South Highway 149

City: Eagan State: MN Zip code: 55121

Protocol prepared by: ENVIRON International Corp. Preparer p hone: 678

- 388

- 1654

Preparer e

- mail address: rkemp@environcorp.com



## Protocol Approval Notification

This is to notify you that the modeling protocol has been reviewed and is approved or denied as noted below for the project described in the protocol.

If approved, any minor changes to the project after this approval should be made in consultation with Minnesota Pollution Control Agency (MPCA) and documented in the modeling results report that is submitted with your permit application. Major changes from the protocol may result in a request for a re-submittal of the protocol.

Please be aware that federal and state standards and model versions can change over the life of a project, therefore the facility may be asked to update the modeling protocol and/or modeling report to reflect applicable changes.



## Reviewer Information

Protocol reviewed:

Modeler name: Melissa Sheffer Review date (mm/dd/yyyy): 1/5/2012

Permit engineer name: name: Review date (mm/dd/yyyy):

Areas reviewed: AQDMP

- 01, AQDMPS

- 01 (not emission calcs), and supplemental document.

Modeling information (Non

- emissions) Preliminary emissions



### Protocol is: Approved Conditionally approved Not approved

Reasons :

As indicated in the AQDMPRF

- 01, all sections were acceptable . Emission ca lculations have not been reviewed by a permit

e ngineer , as of y et.

### Attachment 4: Public Notice

### Minnesota Pollution Control Agency

Environmental Analysis and Outcomes Division

Public Notice on Draft State Implementation Plan Revision

NOTICE IS HEREBY GIVEN , that the Commissioner of the Minnesota Pollution Control Agency

(MPCA) has determined that a State Implementation Plan (SIP) revision must be submitted to meet

Minnesota’s requirements under Section 110(a) and Sect ion 172 of the Clean Air Act with regards to the

National Ambient Air Quality Standards (NAAQS) for le ad (40 CFR 50.16). The draft SIP Revision is now

available for public comment.

Background. The United States Environmental Prot ection Agency (EPA) has promulgated a

NAAQS for lead of 0.15 μg/m 3 

### . On November 22, 2010, the EPA designated a portion of Dakota County

bounded by: Lone Oak Rd. (County Rd. 26) to the nort h, County Rd. 63 to the east, Wescott Rd. to the

south, and Lexington Ave. (County Rd. 43) to the we st as being in nonattainment with the NAAQS for

lead (75 FR 71033). The main source of lead in this area is Gopher Resource, LLC.

Purpose of the SIP Revision. This SIP revision contains both the required infrastructure and

nonattainment plans for lead. The infrastructure port ion of the SIP demonstrates that the MPCA has the

ability to implement and enforce measures to ensure that the NAAQS is maintained in areas where air

quality already meets the standards. The nonattainmen t plan portion contains information showing how

the nonattainment area will be br ought into attainment with the standard. The nonattainment plan

includes new requirements for Gopher Resource, LLC, that are included in an Administrative Order

(Order) that will be issued to the facility, and mode ling to demonstrate that these conditions will allow

the area to attain the NAAQS. The MPCA will be formally requesting that the U.S. Environmental

Protection Agency (EPA) amend Minnesota’s SIP to include the new conditions in this Order.

### The MPCA will consider changing the contents of the proposed SIP revision based on comments

received during the comment peri od. Following the end of the comment period, the Commissioner will

decided whether to submit the proposed SIP revision to the EPA unless, as provided by Minn. Stat.

116.02, the MPCA Citizens’ Board makes this decision.

MPCA Contact Person. The MPCA contact person is Catherine Neuschler. Written comments,

requests and petitions should be mailed to: Catherin e Neuschler, Minnesota Po llution Control Agency,

Environmental Analysis and Outcomes Division, 520 Lafayette Road North, St. Paul, MN 55155-4194,

telephone number: 651-757-2607 Voice or toll fr ee 1-800-657-3864; facsimile number: 651-297-8324;

and email: catherine.neuschler@st ate.mn.us. TTY users may call the MPCA at TTY 651-292-5332 or 1-

800-657-3864.

Availability of SIP. A copy of the proposed SIP revision is available on the MPCA’s Web site at

http://www.pca.state.mn.us/udgxb61. A copy of the proposed SIP is also available upon request by

contacting Catherine Neuschler at 651-757-2607, or will be mailed to any interested person upon the

MPCA’s receipt of a written request. Materials relating to the SIP revision are available for inspection by

appointment at the MPCA St. Pa ul Office, 520 Lafayette Road North, St. Paul, Minnesota 55155,

between the hours of 8:00 a.m. and 4:30 p.m., Monday through Friday. To examine these materials in

St. Paul, or for more information, please contact Catherine Neuschler.

Public Comment Period and Potential Public Meeting. Your comments must be in writing and

received by the MPCA contact person by 4:30 p.m. on May 25, 2012. Written comments may be

submitted to the MPCA contact person at the address, facsimile number, or E-mail address listed above.

A public information meeting will only be held if one is requested by 4:30 p.m. on May 25, 2012.

If such a meeting is requested, it will be held fr om 3:00 p.m. to 4:00 p.m. on Wednesday, May 30, 2012,

at the MPCA St. Paul Office, 520 La fayette Road North, Mi nnesota. To find out if a public information

meeting will be held, please call Catherine Neusch ler at 651-757-2607, after May 25, 2012. The public

### information meeting, if one is requested, will prov ide information, receive public input, and answer

questions about the proposed SIP revision. If the pub lic information meeting is held, additional written

comments on the proposed document s will be accepted until 4:30 p.m. on June 8, 2012, following the

same guidelines described above.

Request to Have MPCA Citi zens’ Board Make Decision. You have the right to submit a petition

to the MPCA Commissioner asking that the MPCA Citizens’ Board make the decision on submitting the

proposed SIP revision to the EPA. Your petition must be in writing, and must be received by the MPCA

contact person by 4:30 p.m. on May 25, 2012. Whether the petition will be grante d or denied is at the

sole discretion of the MPCA Commissioner. The MPCA Citizens’ Board will only make the decision on the

proposed SIP revision if the MPCA Commissioner gran ts your petition or if an MPCA Citizens’ Board

member makes a timely request to have the decision made by the MPCA Citizens’ Board.

### State of Minnesota 

# State Register

Proposed, Adopted, & Expedited Rules; Executive Orders; Appointments; Commissioners’ Orders; Revenue Notices; Official Notices; State Grants & Loans; State Contracts; Non-State Public Bids, Contracts &Grants

Published every Monday (Tuesday when Monday is a holiday)



# Monday 23 April 2012 

# Volume 36, Number 40

Pages 1239 - 1284

# State Register

Judicial Notice Shall Be Taken of Material Published in the State Register

The State Register is the official publication of the State of Minnesota’s Executive Branch of government, published weekly to fulfill the
legislative mandate set forth in Minnesota Statutes , Chapter 14, and Minnesota Rules , Chapter 1400. The State Register contains:

• Proposed Rules • Adopted Rules • Exempt Rules • Expedited Rules • Withdrawn Rules • Vetoed Rules • Executive Orders of the Governor • Appointments • Proclamations

• Commissioners’ Orders • Revenue Notices • Official Notices • State Grants and Loans • Contracts for Professional, Technical and Consulting Services • Non-state Public Bids, Contracts and Grants



### Printing Schedule and Submission Deadlines

PUBLISH Deadline for: Emergency Rules, Executive and

Vol. 36 DATE Commissioner’s Orders, Revenue and Official Notices, Deadline for Proposed,

Issue ( BOLDFACE shows S tate Grants, Professional-Technical-Consulting Adopted and Exempt

Number altered publish date) Contracts, Non-State Bids and Public Contracts RULES



### # 41 Monday 30 April Noon Tuesday 24 April Noon Wednesday 18 April # 42 Monday 7 May Noon Tuesday 1 May Noon Wednesday 25 April # 43 Monday 14 May Noon Tuesday 8 May Noon Wednesday 2 May # 44 Monday 21 May Noon Tuesday 15 May Noon Wednesday 9 May

PUBLISHING NOTICES: We need to receive your submission ELECTRONICALLY in Micr osoft WORD format. Submit ONE COPY of your notice via e-mail to: robin.panlener@state.mn.us . State agency submissions must include a “ State Register Printing Order” form, and, with contracts, a “Certification/Internal Contract Negotiation” form. Non-State Agencies should submit ONE COPY, with a letter on your letterhead stationery requesting publication and date to be published. Costs are $10.20 per tenth of a page (columns are seven inches wide). One typwritten, double-spaced page = 4/10s of a page in the State Register , or $40.80. About 2-1/2 pages typed, double-spaced, on 8-1/2"x11" paper = one typeset page in the State Register. Contact editor if you have questions (651) 297-7963, or e-mail: robin.panlener@state.mn.us

.

SUBSCRIPTION SERVICES: Copies are available at Minnesota’s Bookstore, 660 Olive Street, St. Paul, MN 55155. Order by phone: Metro area: (651) 297-3000 Toll free (800) 657-3757. TTY relay service phone number: (800) 627-3529. NO REFUNDS. E-mail subscriptions are available by contacting (651) 297-8777. Send address changes to Minnesota’s Bookstore, 660 Olive Street, St. Paul, Minnesota 55155.

SEE THE State Register free at website: http://www.minnesotasbookstore.com

• State Register: On-line subscription – $180, includes LINKS, INDEX, special section “CONTRACTS & GRANTS,” with
Sidebar Table of Contents, Early View after 4:30 pm Friday (instead of waiting for early Monday), and it’s sent to you via E-mail

.

• Single issues are available for a limited time: State Register $5.00.

• “Affidavit of Publication” includes a notarized “Affidavit” and a copy of the issue: $15.00.

Governor: Mark Dayton (651) 296-3391 Administration Commissioner: State Register editor: Robin PanLener

Lieutenant Governor: Yvonne Prettner Solon Spencer R. Cronk (651) 201-2555 (651) 297-7963 (651) 296-3391 Plant Management Division: Assistant editor: John Mikes Attorney General: Lori Swanson (651)296-6196 David Fielding (651) 201-2350 (651) 297-4616

Auditor: Rebecca Otto (651) 296-2551 Minnesota’s Bookstore: Subscriptions Manager: Loretta J. Diaz Secretary of State: Mark Ritchie (651) 296-2803 Mary Mikes (651) 297-3979 (651) 297-8777

Copyright © 2012 Plant Management Division, Department of Administration, State of Minnesota. USPS Publication Number: 326-630 (ISSN: 0146-7751)

THE STATE REGISTER IS PUBLISHED by Plant Management Division, Department of Administration, State of Minnesota, pursuant to Minnesota Statutes § 14.46 and is available at main branch county libraries in Minnesota and all “State Depository Libraries:” State University and Community College libraries; University of Minnesotalibraries; St. Paul, Minneapolis and Duluth Public Libraries; Legislative Reference Library; State Law Library; Minnesota Historical Society Library; and Library Development Service at the State Department of Education.



## Minnesota Legislative Information

Senate Public Information Office (651) 296-0504 House Public Information Services (651) 296-2146 State Capitol, Room 231, St. Paul, MN 55155 State Office Building, Room 175,

Website: www.senate.mn 100 Rev. Dr. Martin Luther King Jr Blvd., St. Paul, MN 55155

Website: www.house.leg.state.mn.us/hinfo/hinfo.htm 

## Minnesota State Court System

Court Information Office (651) 296-6043
MN Judicial Center, Rm. 135, 25 Rev. Dr. Martin Luther King Jr Blvd.,
St. Paul, MN 55155 Website: www.mncourts.gov 

## Federal Register

Office of the Federal Register (202) 512-1530; or (888) 293-6498 U.S. Government Printing Office – Fax: (202) 512-1262

Website: http://www.access.gpo.gov/su_docs/aces/aces140.html(Cite 36 SR 1241) State Register , Monday 23 April 2012 Page 1241 

# Contents

Contract information is available from the Materials Management (MMD) Helpline (651) 296-2600, or Web site: www.mmd.admin.state.mn.us

State Register information is available from Minnesota’s Bookstore (651) 297-3000, or (800) 657-3757, Web site: www.minnesotasbookstor e.com **Minnesota Rules: Amendments & Additions** 

Rules Index: Vol. 36, #37-40: 2 April - 23 April 2012..................................... 1242



### Adopted Rules
**Teaching Board**
Adopted Permanent Rules Relating to Special Education

Teacher Standards.......................................................................................................... 1243



### Exempt Rules
**Natural Resources Department (DNR)**
Adopted Exempt Permanent Game and Fish Rules: Designated Experimental and Special Management Waters: Northern Pike in Designated Waters...... 1247



### Expedited Emergency Rules
**Natural Resources Department (DNR)**
Adopted Expedited Emergency Game and Fish Rule: Waters with Restrictions on Taking Fish; Designated Special Management Waters - Mille Lacs Lake Fishing.................................................... 1252



### Official Notices

Bond Rates, Meetings, Notices and Announcements............................................ 1253

**Agriculture Department (MDA)**
Proposed Determinations Regarding the Occurrence of Chlorpyrifos in Surface Waters of Minnesota........................................................ 1254 Public Hearing on the Issuance of an Agricultural Development Revenue

Bond under Minnesota Statutes , Chapter 41C, on Behalf of Andrew and Ashley Frank in Posen Township, Yellow Medicine County.................. 1254

**Emergency Medical Services Regulatory Board (EMSRB)**
Completed Application for the License Application
of Reservation Ambulance Service, White Earth, Minnesota.......................... 1255

**Employment and Economic Development Department (DEED)** 
Request for Comments on Possible Amendment to Rules Governing Vending Stands and Business Enterprises- Services for the Blind................. 1256

**Human Services Department (DHS)**
Public Notices of the Disproportionate Population Adjustment and Proposed Payment Rates for State Operated Treatment Centers....................... 1257

**Investment Board**
Meeting Notice of the Administrative Committee on 3 May 2012..................... 1258

**Labor and Industry Department (DLI)**
Correction to Commercial Prevailing Wage Rates for Labor Code 728, Wiring Systems Installer, Winona County............................................................ 1258

**Natural Resources Department (DNR)**
Fish and Wildlife Habitat Stamp Art Contests........................................................ 1258

**Pollution Control Agency (MPCA)**
Public Notice on Draft State Implementation Plan Revision.............................. 1259 Availability of the Draft Greater Blue Earth River Basin Turbidity TMDL Report and Request for Comment............................................. 1260

**Transportation Department (Mn/DOT)**
Notices of Suspension and Debarment....................................................................... 1262



### State Grants & Loans

Available Grant Funds and Loans............................................................................... 1263

**Housing Finance Agency (MHFA)** Consolidated Request for Proposals for · 2012 Single Family Request for Proposals · 2012 Multifamily Request for Proposals · 2013 Housing Tax Credit Program Request for Proposals....... 1263

**Human Services Department (DHS)**
Request for Proposals to Operate the Minnesota Problem Gambling Helpline...................................................................................... 1271 **Bureau of Mediation Services (BMS)**
Applications Accepted for Funding Under the Minnesota Area Labor-Management Committee Program for Fiscal Year 2013 Grants............ 1272



### State Contracts

Vendors and Consultants............................................................................................... 1273

**Administration Department (Admin)**
Availability of Request for Qualifications for a Construction Manager at Risk for the Minnesota State Capitol Repair, Restoration and Preservation......... 1273

**Colleges and Universities, Minnesota State (MnSCU)**
Anoka Technical College: Request Proposals for Building and Developing a New College Website..... 1274 North Hennepin Community College - Information Technology Services (ITS): Availability of Request for Proposal (RFP) for North Hennepin Community College Web Site Re-Launch Builder/Implementer...................... 1274 Saint Paul College: Request for Proposal for Childcare Services and Lease of Early Education Center............................................................................................... 1275

**Human Services Department (DHS)**
State Operated Services (SOS): Availability of Contract for Psychiatric and Primary Care Services.................. 1275

**Labor and Industry Department (DLI)**
Availability of Contract to Provide Laboratory Analysis Services.................. 1276

**Military Affairs Department**
Facilities Management Office, Camp Ripley, Little Falls, MN: Request for Proposals for Commissioning Services for the Education Complex Addition, Camp Ripley, Little Falls, Minnesota (Project No. 11130)........... 1276

**Natural Resources Department (DNR)**
Availability of Contract for Adaptive Management Plan Writing Services.... 1277 Request for Proposals for State Park and Recreational Area Virtual Tours...... 1277

**Public Safety Department (DPS)**

Driver and Vehicle Services Division: Intent to Award for the Replacement of the State’s Driver’s License and Motor Vehicle Legacy Information Systems........................................................... 1278

**Transportation Department (Mn/DOT)**
Engineering Services Division: Contracting Opportunities for a Variety of Highway Related Technical Activities (“Consultant Pre-Qualification Program”).................... 1278 Engineering Services Division: Professional/Technical Contract Opportunities and Taxpayers’ Transportation Accountability Act Notices.................................... 1279 Office of Civil Rights: Request for Proposals for Targeted Group Business Outreach and Assistance...1279



### Non-State Bids, Contracts & Grants

Contracts with other Units of Government............................................................... 1280

**Metropolitan Airports Commission**
Request for Qualifications for MSP Airside Civil Engineering Services........ 1280 Minneapolis-St. Paul International Airport: Call for Bids for Fiber Infrastructure Upgrade 2012............................................... 1280 Minneapolis-Saint Paul International Airport:

Call for Bids for Campus Terminal Monumentation

............................................... 1281 Terminal 1-Lindbergh: Call for Bids for Terminal 1-Lindbergh Main Food Court Countertop Replacement............................................................................................................... ... 1282 Anoka County - Blaine Airport: Call for Bids for 2012 Pavement Rehabilitation - Runways................................ 1282 Minneapolis-St. Paul International Airport: Call for Bids for 2012 Perimeter Security Improvements....................................... 1283 Flying Cloud Airport: Call for Bids 2012 South Building Area Development......................................... 1283(Cite 36 SR 1259) State Register , Monday 23 April 2012 Page 1259 4. Year 2013 Walleye Habitat Stamp Contest . Entries will be accepted beginning Monday, October 8, 2012, and continuing
until 4:00 P.M. Friday, October 19, 2012, at the DNR Division of Fish and Wildlife, 500 Lafayette Road, Box 20, St. Paul, Minne sota, 55155-4020. The judging will take place Thursday, October 25, 2012 at the Minnesota DNR Office, 500 Lafayette Road, St. Paul,

Minnesota, 55155-4020.

5. Year 2014 Turkey Habitat Stamp Contest . Entries will be accepted beginning Monday, December 13, 2012, and continuing
until 4:00 P.M. Friday, December 28, 2012, at the Minnesota DNR, Division of Fish and Wildlife, 500 Lafayette Road, Box 20, St. Paul,
Minnesota, 55155-4020. The judging will take place Thursday, Jan 10, 2013 at the Minnesota DNR Office, 500 Lafayette Road, St. Paul,

Minnesota, 55155-4020. All entries for the contest must be accompanied by the appropriate application materials. Contest application
packages, which include all entry forms and specifications, are available by writing: Minnesota DNR Information Center, 500 Laf ayette Road, St. Paul, Minnesota, 55155-4020; or by calling the DNR at (651) 296-6157. The contest application and information are al so

available on the DNR website at http://www.dnr.state.mn.us/contests/stamps.html

.

Dated: 21 March 2012 Bill Penning

Division of Fish and Wildlife
Department of Natural Resources



# Minnesota Pollution Control Agency (MPCA)
**Environmental Analysis and Outcomes Division Public Notice on Draft State Implementation Plan Revision** 

NOTICE IS HEREBY GIVEN , that the Commissioner of the Minnesota Pollution Control Agency (MPCA) has determined that a
State Implementation Plan (SIP) revision must be submitted to meet Minnesota’s requirements under Section 110(a) and Section 17 2 of
the Clean Air Act with regards to the National Ambient Air Quality Standards (NAAQS) for lead (40 CFR 50.16). The draft SIP Rev ision
is now available for public comment.

Background. The United States Environmental Protection Agency (EPA) has promulgated a NAAQS for lead of 0.15 μg/m 3 . On
November 22, 2010, the EPA designated a portion of Dakota County bounded by: Lone Oak Rd. (County Rd. 26) to the north, County
Rd. 63 to the east, Wescott Rd. to the south, and Lexington Ave. (County Rd. 43) to the west as being in nonattainment with the NAAQS
for lead (75 FR 71033). The main source of lead in this area is Gopher Resource, LLC.

Purpose of the SIP Revision. This SIP revision contains both the required infrastructure and nonattainment plans for lead. The
infrastructure portion of the SIP demonstrates that the MPCA has the ability to implement and enforce measures to ensure that t he
NAAQS is maintained in areas where air quality already meets the standards. The nonattainment plan portion contains information
showing how the nonattainment area will be brought into attainment with the standard. The nonattainment plan includes new requi rements for Gopher Resource, LLC, that are included in an Administrative Order (Order) that will be issued to the facility, and modelin g to demonstrate that these conditions will allow the area to attain the NAAQS. The MPCA will be formally requesting that the U.S.
Environmental Protection Agency (EPA) amend Minnesota’s SIP to include the new conditions in this Order.

The MPCA will consider changing the contents of the proposed SIP revision based on comments received during the comment pe riod.
Following the end of the comment period, the Commissioner will decided whether to submit the proposed SIP revision to the EPA u nless,
as provided by Minnesota Statutes 116.02, the MPCA Citizens’ Board makes this decision.

MPCA Contact Person. The MPCA contact person is Catherine Neuschler. Written comments, requests and petitions should be
mailed to: Catherine Neuschler, Minnesota Pollution Control Agency, Environmental Analysis and Outcomes Division, 520 Lafayette

Road North, St. Paul, MN 55155-4194, telephone number: (651) 757-2607 Voice or toll free 1-800-657-3864; facsimile number:
(651) 297-8324; and e-mail: catherine.neuschler@state.mn.us

. TTY users may call the MPCA at TTY: (651) 292-5332 or 1-800-657-

3864.

Availability of SIP. A copy of the proposed SIP revision is available on the MPCA’s Web site at http://www.pca.state.mn.us/udgxb61

. A copy of the proposed SIP is also available upon request by contacting Catherine Neuschler at (651) 757-2607, or will be mailed to any 

# Official NoticesPage 1260 State Register, Monday 23 April 2012 (Cite 36 SR 1260) interested person upon the MPCA’s receipt of a written request. Materials relating to the SIP revision are available for inspec tion by
appointment at the MPCA St. Paul Office, 520 Lafayette Road North, St. Paul, Minnesota 55155, between the hours of 8:00 a.m. and 4:30
p.m., Monday through Friday. To examine these materials in St. Paul, or for more information, please contact Catherine Neuschle r.

Public Comment Period and Potential Public Meeting. Your comments must be in writing and received by the MPCA contact
person by 4:30 p.m. on May 25, 2012. Written comments may be submitted to the MPCA contact person at the address, facsimile

number, or E-mail address listed above.

A public information meeting will only be held if one is requested by 4:30 p.m. on May 25, 2012. If such a meeting is requ ested, it will
be held from 3:00 p.m. to 4:00 p.m. on Wednesday, May 30, 2012, at the MPCA St. Paul Office, 520 Lafayette Road North, Minnesot a. To find out if a public information meeting will be held, please call Catherine Neuschler at (651) 757-2607, after May 25, 2012 . The public
information meeting, if one is requested, will provide information, receive public input, and answer questions about the proposed SIP
revision. If the public information meeting is held, additional written comments on the proposed documents will be accepted until 4:30
p.m. on June 8, 2012, following the same guidelines described above.

Request to Have MPCA Citizens’ Board Make Decision. You have the right to submit a petition to the MPCA Commissioner asking
that the MPCA Citizens’ Board make the decision on submitting the proposed SIP revision to the EPA. Your petition must be in wr iting,
and must be received by the MPCA contact person by 4:30 p.m. on May 25, 2012. Whether the petition will be granted or denied is at the
sole discretion of the MPCA Commissioner. The MPCA Citizens’ Board will only make the decision on the proposed SIP revision if the
MPCA Commissioner grants your petition or if an MPCA Citizens’ Board member makes a timely request to have the decision made by

the MPCA Citizens’ Board.



# Minnesota Pollution Control Agency (MPCA)
**Regional Environmental Division Notice of Availability of the Draft Greater Blue Earth River Basin Turbidity TMDL**  **Report and Request for Comment**

**Public Notice Period Begins: April 23, 2012** 

**Public Notice Period Ends: May 29, 2012** 

The Minnesota Pollution Control Agency (MPCA) is requesting comments on the draft Greater Blue Earth River Basin Turbidity Total
Maximum Daily Load (TMDL). The draft Turbidity TMDL Report for the Greater Blue Earth River Basin is available for review at
http://www.pca.state.mn.us/water/tmdl.html#drafttmdl

.

Following the comments, the MPCA will revise the draft TMDL Report and submit it to the Environmental Protection Agency (EPA) f or approval. Comments must be sent to the MPCA contact person listed below by 4:30pm on May 29, 2012.

Required by the federal Clean Water Act, a TMDL is a scientific study that calculates the maximum amount of a pollutant th at a waterbody can receive and still meet water quality standards for that pollutant. It is a process that identifies sources of the pollutant
causing an impairment and allocates necessary reductions among them. This multi-year effort results in a pollution reduction plan and
engages stakeholders and the general public. An approved TMDL is followed by implementation activities for achieving the necess ary

reductions.

This TMDL study covers 39 reaches within the Greater Blue Earth River Basin area that are currently listed for aquatic life impairments due to turbidity. Turbidity is a measure of the water’s clarity and is caused by the amount of particles in the water, su ch as sediment.
Higher turbidity reduces the penetration of sunlight in the water and can harm aquatic life.

The Greater Blue Earth River Basin is comprised of three major watersheds; the Le Sueur, the Watonwan, and the Blue Earth, with a
total land area of 3,540 square miles. Contained within the watershed are approximately 3,384 miles of streams and rivers. The Greater
Blue Earth’s watersheds have been the subject of numerous studies, research efforts, and water quality improvement projects due to the
disproportionately high levels of sediment and nutrients they supply to the Minnesota River. 

# Official Notices

### Attachment 5: Completeness Review

A. Administrative Materials (40 CF R pt. 51, Appendix V, Part 2.1)

The EPA’s Criteria for Determining the Completeness of Plan Submittals, published at 40 CFR part 51,
Appendix V, requires states to provide the basic documents that show that the State has properly followed the administrative requirements called for by the CAA for the adoption of SIPs. The
requirements, and how this SIP revision complies with these requirements, are discussed here:

1) Formal Letter of Submittal:

“A formal letter of submittal from the Governor or his designee, requesting EPA approval of the plan or

revision thereof.”

Attached to this SIP revision request is a formal letter of submittal from the MPCA Commissioner, Paul
Aasen, to the EPA Region V Administrator, Susan He dman. The office of the Commissioner of the MPCA is statutorily created at Minnesota Statute § 116.03, subd. 1 (a). The Commissioner is appointed by the
Governor, and the duties of the position include ac ting as the state agent to “apply for, receive, and disburse federal funds made available to the state by federal law or rule and regulations promulgated thereunder for any purpose related to the power an d duties of the MPCA or the Commissioner. The
Commissioner shall comply with any and all require ments of such federal law or such rules and regulations promulgated thereunder to facilitate app lication for, receipt, and disbursement of such
funds.” Minn. Stat. § 116.03 subd. 3.

2) Evidence of State Adoption of Plan and Issuance of Orders in Final Form

“Evidence that the State has adopted the plan in the State code or body of regulations; or issued the permit, order, consent agreement (hereafter ‘documen t’) in final form. That evidence shall include the date of adoption or final issuance as well as the effective date of the plan, if different from the adoption/issuance date.”

Attachment 1 contains the Administrative Order by Consent between the MPCA and Gopher Resource. The Order became effective as soon as it was signed by the Commissioner or his designee.

3) Legal Authority Documentation:

“Evidence that the State has the necessary le gal authority under St ate law to adopt and implement the plan.”

This SIP revision request is an update to MPCA’s SIP for the former lead nonattainment area in the city of
Eagan, Dakota County. The MPCA submitted a SIP revision and redesignation request in June 1993, subsequently updated in September 1994. The EPA granted approval of the SIP revision and redesignation request on October 18, 1994 (59 FR 52431) . The revision included an Administrative Order (Order) containing emission limits and other requirements for Gopher, which ensured attainment with

the NAAQS.

On November 18, 2002, the MPCA submitted a SIP revi sion including a maintenance plan update for the

area. On June 3, 2008, EP A published a direct final approval of the maintenance plan (73 FR 31614).

### On July 29, 2010, the MPCA submitte d a SIP revision to include the join t Title I/Title V document and the

SIP enforceable document. This Air Emission Perm it (No. 03700016-003) replaced the previous Order for
the facility. EPA approved this SIP document in a direct final rule effective March 14, 2011 (76 FR 2263).

4) Compliance with State Procedures:

“Evidence that the state followed all of the procedural requirements of the State’s laws and constitution in conducting and completing the adoption/issuance of the plan.”

MPCA complied with all relevant state procedures fo r issuing the permit as well as the SIP revision.

5) Public Notice:

“Evidence that public notice was given of the propos ed change consistent with the procedures approved by the EPA, including the date of the publication of the notice.”

The public notice for the SIP revision was published in the State Register on April 23, 2012 with the public comment period commencing on April 23, 2012 a nd ending on May 25, 2012. During the public comment period, a copy of the SIP revision request wa s made available at the MPCA office located in St. Paul and on the MPCA’s website. A copy of th e public notice is attached. (Attachment 4).

6) Public Hearing Certification:

“Certification that public hearing(s) were held in ac cordance with the informatio n provided in the public

notice and the State’s laws and constitution, if applicable.”

The public notice states: “A public information meet ing will only be held if one is requested by 4:30 p.m. on May 25, 2012. If such a meeting is requeste d, it will be held from 3:00 p.m. to 4:00 p.m. on Wednesday, May 30, 2012, at the MPCA St. Paul Offi ce, 520 Lafayette Road North, Minnesota. To find out if a public information meeting will be held, please call Catherine Neuschler at 651-757-2607, after May 25, 2012. The public informatio n meeting, if one is requested, will provide information, receive public input, and answer questions about the proposed SIP revision. If the public information meeting is held, additional written comments on the proposed do cuments will be accepted until 4:30 p.m. on June 8, 2012, following the same gui delines described above.”

No public meeting was requested.

7) Public Comments and State Response:

“Compilation of the public comment s and State’s response thereto.”

EPA SIP staff made several comments on how to im prove both the infrastructure SIP and the lead

nonattainment SIP. This included adding a section addressing 110( a)(2)(D)(ii) to the infrastructure
portion, and more detailed references to EPA’s infrastructure SIP guidance. It also included the addition of a short discussion of the NESHAP for secondary lead smelters, which applies to Gopher Resources.

For the lead nonattainment SIP, EPA suggested describing the impacts of the new second lead smelt

### B. Technical Support:

1) Pollutants Regulated:

“Identification of all regulated pollutants affect by the plan.”

The regulated pollutant subject to th is SIP revision request is lead.

2) Source Identification

“Identification of the locations of affected so urces including the EPA attainment/nonattainment
designation of the locations and the state of the Attainment Plan for the affected area(s).”

The affected source within the Eagan, Dakota Co unty nonattainment area is Gopher Resource, LLC. 3) Emissions Quantification:

“Quantification of the changes in the plan; allowable emissions from the affected sources; estimates of changes in current actual emissions from affected sources or, where appropriate, quantification of the changes in actual emissions through calculations of the differences between certain baseline levels and allowable emissions anticipated as a result of the revision.”

This SIP revision reduces emissi ons of lead from the source.

4) NAAQS Protections:

“The State’s demonstration that the NAAQS, prev ention of significant deterioration increments, reasonable further progress demonstration, and visibi lity, as applicable, are pr otected if the plan is approved and implemented.”

The modeling demonstration shows that the area will attain the NAAQS.

5) Modeling Information

“Modeling information required to support the prop osed revision, including input data, output data, models used, justification of the model selections, ambient monitoring data used, meteorological data used, justification for use of off-site data (where used), modes of models used, assumptions, and other

information relevant to the determination of adequacy of the modeling analysis.”

The modeling information is summarized in the Back ground Document and included in Attachment 2.

6) Continuous Emission Reduction

“Evidence, where necessary, that emission limitatio ns are based on continuous emission reduction technology.”

These requirements are included in the Administrative Order issued to the source and the existing joint Title I/Title V document.

### 7) Emission Level Assurance

“Evidence that the plan contains emission limitat ions, work practice standards and recordkeeping/
requirements, where necessary, to ensure emissions levels.”

Again, the above requirements are addressed in the Order and joint Title I/Title V document.

8) Compliance/Enforcement

“Compliance and enforcement strategies, including ho w compliance will be determined in practice.”

The above requirements are addressed in the Order and joint Title I/Title V document.

9) Special Economic and Te chnological Justifications:

“Special economic and technological justifications required by any applicable EPA policies, or an explanation of why such justifications are not necessary.”

This requirement does not apply to this submittal.

Conclusion
The MPCA expects that the Eagan lead ar ea will attain the lead NAAQS of 0.15 μ g/m 3



### .