1 

Background Information for Lead Infrastructure SIP and 

Lead Nonattainment SIP for Eagan, Dakota County, 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 requirements 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 infrastructure 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, Maintenance, and Enforcement 

The Minnesota Pollution Control Agency (MPCA) has, in prior submittals, documented its authority and 

ability to provide for the implementation, maintenance and enforcement of primary and secondary 

standards, as well as to adopt enforceable emission 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 operators 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 orders and assess administrative 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 violations 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 dioxide, particulate matter, nitrogen oxides, carbon 

monoxide, ozone, lead, and any other pollutants for which national ambient air quality standards have 

been established” and prohibit emissions that cause or contribute to a violation of any ambient air 

quality standard. 
2 

The remainder of this section lays out the requirements of Section 110(a)(2) and how Minnesota’s SIP 

meets those requirements. 

Section 110(a)(2)(A): Emission Limits 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 the MPCA authority to “issue permits, under such 

conditions as it may prescribe for the prevention of pollution, for the emission of air contaminants, or for 

the installation or operation of any emission facility, air contaminant treatment facility, treatment 

facility, potential air contaminant storage facility, or storage facility”. 

Minnesota’s SIP already includes a permit issued to Gopher Resource which contains emission limitations 

to meet the original 1.5 μg/m3 standard set for lead. Also included in this submittal is Minnesota’s 

nonattainment SIP for the 2008 standard, which includes enforceable emission limitations which 

demonstrate modeled compliance with the 0.15 μg/m3 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 EPA’s Air Quality System (AQS) in a timely manner. All 

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

The MPCA completes an annual monitoring plan describing 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 the MPCA’s permitting program, through which 

enforceable emission limitations are placed on facilities. Any NAAQS is an applicable requirement for 

stationary sources. Minnesota is under a Federal Implementation 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 enforceable 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 provisions 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): Interstate Transport Provisions

EPA’s guidance for the 2008 lead NAAQS infrastructure SIP recognizes that, due to its physical properties, 

lead does not experience the same formation or transport phenomenon seen with particulate matter or 

ozone. Significant impacts from lead emissions on either nonattainment, maintenance, or visibility are 

expected to be limited to short distances from the source. This makes it very unlikely that a source would 

emit lead in an amount that would contribute significantly 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 the exception of the monitors 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. Dispersion 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 located close enough to Minnesota’s Class I areas to 

have an impact on visibility. The closest large source is U.S. Steel Minntac. On December 30, 2011, EPA 

approved the MPCA’s request to waive ambient lead monitoring at Minntac, based on modeling and 

analysis that showed few impacts. The MPCA has submitted a Regional Haze SIP for Minnesota. 

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

Minnesota’s air management program contains adequate provisions to ensure compliance with Section 

126 of the CAA relating to interstate pollution abatement. 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 Personnel, Funding, and Authority

The Minnesota Pollution Control Agency is the agency responsible for developing, implementing, and 

enforcing the SIP. The MPCA’s Performance Partnership Grant (PPG) Agreement with the EPA provides 

the MPCA’s assurances of resources to carry out certain 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.state.mn.us/sbiz3d7. 

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

In compliance with Section 128 of the Clean Air Act, Minn. R. 7000.9000 requires any member of the 

MPCA Citizens’ Board to disclose any conflict of interest. 

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

Minn. R. 7007.0800, Subp. 4 lays out the monitoring requirements that are included in each permit for 

major stationary sources. Minnesota Rules Chapter 7017 sets forth monitoring 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 contain 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 needed for lead. Minn. Stat. 116.11 provides the MPCA 

with emergency powers, which is further 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 pollution 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): Future SIP Revisions

The MPCA has submitted many updates to the existing SIP in the last several years, and intends to 

continue to submit updates as needed in order to ensure changes at existing 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 (Minn. 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 Class 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 notify an applicant that it is required to 

demonstrate that its emissions do not cause a violation 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/participation by affected local entities

The MPCA is the main agency that development, implements, and enforces the state air quality program. 

Under Minn. Stat. 116.05, other departments and agencies 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 nonattainment 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 Road1

 

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 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 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 Mountains and into central Canada. In 2011, GR shipped 

137,000 tons of lead, much of it going to new battery production. GR also recycles the plastic from leadacid battery casings, selling more than 18 million 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 μg/m3

. The area 

around Gopher Resource has been monitored for ambient lead levels since 1983. Based on the 

monitoring data, the area surrounding GR was designated by the EPA as violating this lead NAAQS on 

January 6, 1992. EPA approved a SIP revision and redesignation request for the area on October 18, 1994 

(50 FR 52531). The revision included an Administrative 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 revision including a maintenance plan update for the 

area and a request for a change in enforceable document for GR, from the Order to the facility’s Air 

Emission Permit, which serves as a joint Title I/Title V document. EPA did not act on this submittal. On 

November 19, 2007, the MPCA formally withdrew the request to replace the Order with the joint 

document, but asked that EPA consider 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 revision to include the joint Title I/Title V document 

and the SIP enforceable document. This Air Emission 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 μg/m3 to a 3-month rolling 

average of 0.15 μg/m3

 (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 October 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 address of 3385 South Highway 149, Eagan; the facility has not moved, but the 

address was changed by the city to provide greater clarity for emergency vehicles. 
7 

designated a nonattainment area 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 NAAQS, 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 area 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 and 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 discharge lead emissions to the atmosphere are: two 

reverberatory furnaces, a blast furnace, nine refining kettles, a hammermill, three desulfurization 

reactors, a drier for the lead oxide paste from desulfurization, 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 Modeling section of this document. 

The lead emissions from the Emission Units are controlled by four systems of dust collectors (scrubbers, 

baghouses,or cartridge filters). The lead emissions then exit through the Scrubber 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 emissions. Figure 1, below, provides a process diagram of 

the facility. 

GR has been proactive in investigating and mitigating 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/filtration units to control fugitive lead emissions in the 

Material Transfer Room (MTR), the Battery Receiving Dock Area (RMPC), and the afterburner tower. The 

inclusion of these units and the second Torit stack (SV008), which was added 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 smelter and, as such, is subject to the requirements of the 

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

Smelting. The NESHAP applies to blast, reverberatory, rotary, and electric 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 concentration of lead compounds 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 concentration of lead compounds in vent gases at or 

below 0.20 milligrams of lead per dry 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 being 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 lbs/hour, but the limits were converted to lbs/hour for 

comparison to the new limits that are being imposed in the Administrative Order. 

4

 Conversion was made using modeled parameters as follows: 

Source Exit Temperature (oF) Exit Velocity (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 facility. 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 instance, GR is constructing a new 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, reducing traffic in the areas of the highest dust loading 

in order to reduce the re-entrainment of fugitive dust 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 reduce 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 ensure it is maintained. GR is also being required to 

install and operate pressure gauge units on the exterior 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 thickness 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, thermocouple, and low-draft alarm. These should prevent 

malfunctions such as those which caused high ambient 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 that 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 sources 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 sources identified by modeling outside the buildings. 

 
11 

Refinery Stacks and Other Emission Sources

In addition to the large stack and fugitive emissions, 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 used 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 had a very low culpability when looking at a 24-hour 

averaging period. Therefore, the Administrative Order does not require additional controls on these 

sources. 

Reasonably Available Control Measures (RACM)

On March 19, 2012, EPA issued guidance for control measures to be included in nonattainment 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 implementation 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 minimum, 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: fabric filters, enclosure hoods and partial enclosures, 

negative pressure total enclosures, paving of roads and 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 measures that can be implemented if the area fails 

to maintain the standard by December 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 identify 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 implement one of the first three 

measures, they must do so within 30 days of notification 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 monitors 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 monitor 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 monitoring 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 design value for the area surrounding GR is 0.259 μg/m3

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/m3

. 

Table 2: Eagan (465) - Gopher Resource 

Maximum Rolling 3-Month Average Concentrations by Year (μg/m3

) 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 the additional Torit ventilation and filtration system 

(August 2009) represented a key step towards attaining 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 attain 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 shows, only four days have had concentrations above 

the standard. 

 

6

 The EPA ID for this 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 criterion. 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/m3

. 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/m3

 

Table 3: GRS-2 Maximum Rolling 3-Month Average Concentrations by Year (μg/m3

) 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

0.9

Lead 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 exceedances uncovered issues that have been corrected 

and are addressed in the Administrative Order. For example, a value of 2.72 μg/m3 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 ambient 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 μg/m3

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

Model Options

Modeling was conducted using the U.S. EPA’s AMS/EPA Regulatory Model (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, AERMET (version 11059) and AERMAP 

(version 11103), were also used in the modeling analysis. AERSURFACE (version 08009), EPA’s nonregulatory surface characteristics preprocessor, was used to determine the surface characteristics of the 

meteorological tower. BPIPPRM (Building Profile Input 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 concentration was chosen for the 

averaging time, as AERMOD currently does not support calculating the design value for lead. Instead 

EPA’s post-processing tool, LEADPOST (version 11237), was 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 coordinate 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 MPCA 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 Torit 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 emission 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 stack test numbers were very small and a culpability 

analysis of these two sources produced a contribution of 0.01%. 

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

that emissions from volume sources were emitted between 7am and 11pm, with no emissions occurring 

between 11pm and 7am. All other sources were assumed 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 then incorporated into the emission calculations for 

the road sources. 

ENVIRON used the most recent compliance stack testing to determine the source release parameters for 

each point source for the facility. For the main stack, the two Torit stacks and the scrubber stack, the 

release parameters represented the average of three test runs from the stack test 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 according to the USEPA’s recommended methodologies in 

the AERMOD User’s Guide. 

Meteorology

The meteorological data set selected 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 Chanhassen, MN (MPX). The five year period of 2006 – 2010 

was processed with AERMET and AERMINUTE (versions 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 characteristics were determined using AERSURFACE 

version 08009 with National Land Cover Data 1992 (NLCD92) from the USGS Land Cover Institute. 

Comparisons of recent aerial images and NLCD92 data reveal that surface characteristics around the 

meteorological surface station have had minimal changes. For more information regarding processing of 

meteorological data, please refer to the MPCA’s Meteorological Data webpage 

(http://www.pca.state.mn.us/wfhy422). 

Background Concentration

Background concentrations were determined using data taken from the EPA’s AirData website 

(http://www.epa.gov/airdata/) for Minnesota. A value of 0.01 μg/m3

 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 available via the AirData page (as it 

was during the time of 2009 analysis), 24-hour monitored values ranged from 0.01 to 0.04 μg/m3 at nonsource oriented monitors. This suggested that background lead levels had not changed significantly, and 
16 

it was decided to continue to use 0.01 μg/m3

, 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 incorporated into the modeling by using AERMAP (version 11103). 1/3 arc 

second National Elevation Dataset (NED) data was obtained 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 nestled 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 extend the receptor grid from the facility itself to a 

distance of 5,000 meters, thus resulting in a 10 kilometer 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 

(μg/m3

) 

Background 

Concentration 

(μg/m3) 

Total NAAQS 

Impact 

(μg/m3) 

Pb NAAQS 

(μg/m3) 

% 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 μg/m3

. This supports the monitoring data from the facility that has 

measured compliance with the lead standard with the exception of malfunction incidents. 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 Implement 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 Consent for the Gopher Resource lead recycling facility 

(Facility), Eagan, Dakota County, Minnesota, pursuant to Minn. 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. Environmental 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 promulgated primary and secondary NAAQS for lead. The 

primary and secondary NAAQS for lead, promulgated in 2008, are 0.15 micrograms per cubic meter, 

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

3. Each state is obligated by Section 110(a) of the 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 Implementation 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 rules 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 standards may relate to source or emissions of air 

contamination or air pollution, to the quality or composition of such emissions, or to the quality of or 

composition of the ambient air or outdoor atmosphere or to any other matter relevant to the 

prevention, abatement, or control of air pollution.” 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 enforcing “reasonable orders, schedules of compliance and 

stipulation agreements.” Minn. Stat. § 116.07, subd. 9 (2011). Specifically, the MPCA has the 

authority to enforce Minn. Rules 7009.0020 (2011) which 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 standard, 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 Quality Models, 40 CFR pt. 51, Appendix W (2011), and 

was developed using the AERMOD dispersion model 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 nonattainment area for the primary and secondary NAAQS for lead. 40 

CFR 81.324 (2011). 

10. This area was previously designated as nonattainment with the 1978 NAAQS for lead on January 6, 

1992, but was redesignated to attainment 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 Highway 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 computer modeling analysis of the Facility that 

demonstrates that the nonattainment 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 AERMOD 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 Emission Permit No. 03700016-003 to Gopher Resource 

authorizing the operation of its facility under specified 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 today, except where specifically superseded by the 

issuance of this Order. 

16. This Order imposes additional requirements for the Facility as specified in Parts I through VI below, 

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

 
3 

ORDER 

NOW, THEREFORE, IT IS ORDERED AND AGREED:

17. For the purpose of demonstrating reasonable progress 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 the 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 measurements of each pipe each time the 

reverberatory furnace is rebricked. It is the 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 install and operate a negative pressure booth in 

the maintenance shop for tasks that require 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 operate 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 maintained, 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 operate at all times a remote infrared camera 

above the blast furnace and add a thermocouple and low-draft alarm to monitor 

temperature and air flow in the blast furnace. 

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

ii. The thermocouple and low draft alarm information 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 immediately 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 (Table 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 demonstrate 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 silt 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/m2

, the lead content of that silt, and the 

subsequent load of lead in silt in g/m2

. 

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

values. 

b. If the tested load values of lead in silt expressed in g/m2 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 shall, 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 more 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 improved 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 sources of fugitive lead emissions that may 

cause or contribute to the monitored exceedance of the 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 contingency measure and keep records of all 

contingency measures undertaken. 

e. These contingency measures supersede and replace 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 information 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 inspection and review. Gopher shall retain the 

records for a minimum of five years following 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 obligation, 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 standards, 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 change at its facility. 

20. This Order shall be binding upon the Company and its respective officers, employees, successors and 

assigns. The Company shall provide a copy of this Order to any successor in interest prior to transfer 

of that interest, and shall simultaneously inform the 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 approves such transfer or assignment. 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 NAAQS. To the extent that any federal or state 

statute, rule, permit, order, stipulation agreement, consent decree or schedule of compliance now in 

force or subsequently issued imposes limits and requires actions additional to those required in this 

Order, the Company shall comply with 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 that 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: __ {,; ..:........r / _1_:>+/ _..;./_"'2... ____ _ 

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/m2 silt) 

Pb surface 

loading in silt 

(g/m2

 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 15.97 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/A
Name Description ACTUAL TESTED (mg/dscm) FLOW RATE (dscfm) CALCULATED EMISSION RATE (lbs/hr) CALCULATED EMISSION RATE (g/s) SCALE FACTOR MODELLED EMISSION RA

(lbs/hr) *** 

MSTACK01 Main stack 0.069 94000 2.43E-02 3.06E-03 7 1.70E-01 

TSTACK01 Torit stack 0.234 143000 1.25E-01 1.58E-02 7 8.77E-01 

TSTACK02 Torit stack 0.016 126000 7.55E-03 9.51E-04 7 5.29E-02 

RSTACK01 Refinery stack 1 0.230 1210 1.04E-03 1.31E-04 1 1.04E-03 

RSTACK02 Refinery stack 2 0.190 530 3.77E-04 4.75E-05 1 3.77E-04 

RSTACK03 Refinery stack 3 0.130 565 2.75E-04 3.47E-05 1 2.75E-04 

RSTACK04 Refinery stack 4 0.240 524 4.71E-04 5.94E-05 1 4.71E-04 

RSTACK05 Refinery stack 5 0.480 548 9.85E-04 1.24E-04 1 9.85E-04 

RSTACK06 Refinery stack 6 0.320 529 6.34E-04 7.99E-05 1 6.34E-04 

RSTACK07 Refinery stack 7 0.090 765 2.58E-04 3.25E-05 1 2.58E-04 

RSTACK08 Refinery stack 8 (w/ deflector) 0.080 566 1.70E-04 2.14E-05 1 1.70E-04 RSTACK09 Refinery stack 9 0.190 669 4.76E-04 6.00E-05 1 4.76E-04 

SSTACK01 Scrubber stack 0.129 13400 6.47E-03 8.16E-04 6 3.88E-02 

PLSFAN01 Plastic bldg exhaust 1 0.015 29500 1.66E-03 2.0884E-04 1 1.66E-03 

PLSFAN02 Plastic bldg exhaust 2 0.015 29500 1.66E-03 2.0884E-04 1 1.66E-03 

*** The modelled emission ra

are higher than calculated 

conservatism in the 
Name X Y Ht(m) D(m) radius (ft) acfm src velocity (ft/min) velocity (m/s) T (F) 

MSTACK01 490648.080 4964581.070 60.7 1.83 3.0019685 120000 pdf 4238.57 21.53 150 

TSTACK01 490624.750 4964566.340 24.4 2.44 4.00262467 164000 pdf 3258.40 16.55 119 

TSTACK02 490604.380 4964589.550 24.4 2.13 3.49409449 133000 pdf 3467.63 17.62 76 

RSTACK01 490677.850 4964583.000 8.4 0.49 0.80380577 2240 pdf 1103.56 5.61 442 RSTACK02 490676.270 4964586.410 8.4 0.49 0.80380577 1000 pdf 492.66 2.50 512 RSTACK03 490675.710 4964587.510 8.4 0.49 0.80380577 1525 pdf 751.31 3.82 768 

RSTACK04 490674.680 4964589.730 8.4 0.49 0.80380577 1013 pdf 499.07 2.54 477 RSTACK05 490670.720 4964597.650 8.4 0.49 0.80380577 944 pdf 465.07 2.36 342 RSTACK06 490668.580 4964597.890 8.4 0.49 0.80380577 957 pdf 471.48 2.40 371 RSTACK07 490668.270 4964598.840 8.4 0.49 0.80380577 1991 pdf 980.89 4.98 732 RSTACK08 490669.850 4964599.630 8.4 0.49 0.80380577 1741 pdf 857.72 4.36 904 

RSTACK09 490673.970 4964604.780 8.4 0.49 0.80380577 1330 pdf 655.24 3.33 387 

SSTACK01 490585.810 4964667.440 17.8 0.71 1.16469816 15000 pdf 3519.77 15.97 86 

PLSFAN01 490428.360 4964938.330 11.3 1.47 2.41141732 29500 xl 1614.83 8.20 68 

PLSFAN02 490450.570 4964952.550 11.3 1.47 2.41141732 29500 xl 1614.83 8.20 68 

LINKED LINKED LINKED 
Paved Roads

AP-42 Section 13.2.1

E = [k(sL)0.91 x (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/m 2) Surface Silt Loading (sL) from direct measurements conducted at Gopher Resource Corporation, Eagan, Minnesota, Octob

W = 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 daily

Segment Distance (ft) Distance (yards) 4.1148 Truck height (m)

AB 337 112 3.32 Loader Height (m)

BC 345 115

CD 264 88

DE 402 134

BF 216 72

CG 363 121

DH 161 54

AI 356 119

IJ 84 28

IK 350 117

KL 156 52

LOADER 119 40

SLGLDR 40 13

Vehicle Traffic

Shipping Daily Empty Load Loaded

Total Trucks Days Trucks Weight Weight Weight

Incoming junk batteries to warehouse bldg D 2555 365 7 16 20 36

Incoming junk batteries to RMPC 14600 365 40 16 20 36 Na

Lead shipping out 8395 365 23 16 20 36 SAMPLE A s

Loader trips 1825 365 5 12 3 15 SAMPLE B sLoader trips to slag bins 5475 365 15 12 3 15 SAMPLE C s

Slag trucks 1460 365 4 10 20 30 SAMPLE D s

UPS trucks 1095 365 3 5 5 SAMPLE E s

Plastic shipments out 365 365 1 16 20 36 SAMPLE F s

Lead Samp
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 2.625116
Description Distance (ft) Segment(s) Trips/Year W (tons) sL VMT (miles) E (PM10) E (TSP) E (Pb) T

(to

SEGMENT AB

LOADED JUNK BATTERY TRUCK TO BUILDING D 337 AB 2555 36.0 1.46 163 1.1E-01 5.6E-01 5.9E-03 4.53UNLOADED JUNK BATTERY TRUCK FROM BUILDING D 337 AB 2555 16.0 1.46 163 4.9E-02 2.4E-01 2.6E-03 1.98LOADED JUNK BATTERY TRUCK TO RMPC 337 AB 14600 36.0 1.46 932 1.1E-01 5.6E-01 5.9E-03 2.59UNLOADED JUNK BATTERY TRUCK FROM RMPC 337 AB 14600 16.0 1.46 932 4.9E-02 2.4E-01 2.6E-03 1.13UNLOADED SLAG TRUCK IN 337 AB 1460 10.0 1.46 93 3.0E-02 1.5E-01 1.6E-03 7.01

LOADED SLAG TRUCK OUT 337 AB 1460 30.0 1.46 93 9.2E-02 4.6E-01 4.9E-03 2.15

UNLOADED PLASTICS TRUCK IN 337 AB 365 16.0 1.46 23 4.9E-02 2.4E-01 2.6E-03 2.83

LOADED PLASTICS TRUCK OUT 337 AB 365 36.0 1.46 23 1.1E-01 5.6E-01 5.9E-03 6.47

TOTAL 

SEGMENT BC

LOADED JUNK BATTERY TRUCK TO BUILDING D 345 BC 2555 36.0 1.46 167 1.1E-01 5.6E-01 5.9E-03 4.63

UNLOADED JUNK BATTERY TRUCK FROM BUILDING D 345 BC 2555 16.0 1.46 167 4.9E-02 2.4E-01 2.6E-03 2.03LOADED JUNK BATTERY TRUCK TO RMPC 345 BC 14600 36.0 1.46 954 1.1E-01 5.6E-01 5.9E-03 2.65UNLOADED JUNK BATTERY TRUCK FROM RMPC 345 BC 14600 16.0 1.46 954 4.9E-02 2.4E-01 2.6E-03 1.16UNLOADED PLASTICS TRUCK IN 345 BC 365 16.0 1.46 24 4.9E-02 2.4E-01 2.6E-03 2.89

LOADED PLASTICS TRUCK OUT 345 BC 365 36.0 1.46 24 1.1E-01 5.6E-01 5.9E-03 6.62

TOTAL 

SEGMENT CD

LOADED JUNK BATTERY TRUCK TO BUILDING D 264 CD 2555 36.0 1.03 128 8.1E-02 4.0E-01 9.7E-03 2.59

UNLOADED JUNK BATTERY TRUCK FROM BUILDING D 264 CD 2555 16.0 1.03 128 3.5E-02 1.8E-01 4.3E-03 1.13

UNLOADED PLASTICS TRUCK IN 264 CD 365 16.0 1.03 18 3.5E-02 1.8E-01 4.3E-03 1.61

LOADED PLASTICS TRUCK OUT 264 CD 365 36.0 1.03 18 8.1E-02 4.0E-01 9.7E-03 3.69

TOTAL 

SEGMENT DE

UNLOADED PLASTICS TRUCK IN 402 DE 365 16.0 1.03 28 3.5E-02 1.8E-01 4.3E-03 2.46

LOADED PLASTICS TRUCK OUT 402 DE 365 36.0 1.03 28 8.1E-02 4.0E-01 9.7E-03 5.61

TOTAL 

SEGMENT BF

UNLOADED SLAG TRUCK IN 216 BF 1460 10.0 4.42 60 8.2E-02 4.1E-01 8.9E-03 1.23

LOADED SLAG TRUCK OUT 216 BF 1460 30.0 4.42 60 2.5E-01 1.3E+00 2.7E-02 3.77

TOTAL 

SEGMENT CG

LOADED JUNK BATTERY TRUCK TO RMPC 363 CG 14600 36.0 1.03 1,003 8.1E-02 4.0E-01 9.7E-03 2.03

UNLOADED JUNK BATTERY TRUCK FROM RMPC 363 CG 14600 16.0 1.03 1,003 3.5E-02 1.8E-01 4.3E-03 8.86

TOTAL 

SEGMENT DH

LOADED JUNK BATTERY TRUCK TO BUILDING D 161 DH 2555 36.0 1.03 78 8.1E-02 4.0E-01 9.7E-03 1.57

UNLOADED JUNK BATTERY TRUCK FROM BUILDING D 161 DH 2555 16.0 1.03 78 3.5E-02 1.8E-01 4.3E-03 6.87

TOTAL 
SEGMENT AI

UPS TRUCK IN 356 AI 1095 5.0 1.46 74 1.5E-02 7.4E-02 7.9E-04 2.74

UPS TRUCK OUT 356 AI 1095 5.0 1.46 74 1.5E-02 7.4E-02 7.9E-04 2.74

UNLOADED TRUCK IN 84 AI 8395 16.0 1.46 133 4.9E-02 2.4E-01 2.6E-03 1.61LOADED LEAD SHIPMENT OUT 84 AI 8395 36.0 1.46 133 1.1E-01 5.6E-01 5.9E-03 3.69

TOTAL 

SEGMENT IJ

UPS TRUCK IN 84 IJ 1095 5.0 1.46 17 1.5E-02 7.4E-02 7.9E-04 6.43

UPS TRUCK OUT 84 IJ 1095 5.0 1.46 17 1.5E-02 7.4E-02 7.9E-04 6.43

TOTAL 

SEGMENT IK

UNLOADED TRUCK IN 350 IK 8395 16.0 1.46 557 4.9E-02 2.4E-01 2.6E-03 6.76

LOADED LEAD SHIPMENT OUT 350 IK 8395 36.0 1.46 557 1.1E-01 5.6E-01 5.9E-03 1.55

TOTAL 

SEGMENT KL

UNLOADED TRUCK IN 156 KL 8395 16.0 1.09 248 3.7E-02 1.9E-01 3.8E-03 2.31

LOADED LEAD SHIPMENT OUT 156 KL 8395 36.0 1.09 248 8.5E-02 4.3E-01 8.6E-03 5.28

TOTAL 

LOADER

LOADER TRIPS - LOADED 119 LOADER 1825 15.0 6.08 41 1.7E-01 8.3E-01 1.7E-02 1.72

LOADER TRIPS - UNLOADED 119 LOADER 1825 12.0 6.08 41 1.3E-01 6.6E-01 1.3E-02 1.37

TOTAL 

SLGLDR

SLAG LOADER TRIPS - LOADED 40 SLGLDR 5475 15.0 4.42 41 1.2E-01 6.2E-01 1.3E-02 1.29

SLAG LOADER TRIPS - UNLOADED 40 SLGLDR 5475 12.0 4.42 41 9.9E-02 5.0E-01 1.1E-02 1.03

TOTAL 
X Y x0 y0 x1 y1 N Length(m) 

Plastics 490456.781 4964494.500 1 A 1-2 A-B 490456.781 4964494.500 490440.656 4964596.000 11 10.28 

490440.656 4964596.000 2 B 2-3 B-C 490440.656 4964596.000 490489.625 4964689.000 11 10.51 

490489.625 4964689.000 3 C 3-4 C-D 490489.625 4964689.000 490493.375 4964769.500 9 10.07 

490493.375 4964769.500 4 D 4-5 D-E 490493.375 4964769.500 490471.219 4964890.000 13 10.21 

490471.219 4964890.000 5 E 2-6 B-F 490440.656 4964596.000 490492.563 4964636.500 7 10.97 

X Y 3-7 C-G 490489.625 4964689.000 490591.000 4964733.000 12 10.05 

Slag 490456.781 4964494.500 1 A 4-8 D-H 490493.375 4964769.500 490474.125 4964814.500 6 9.79 

490440.656 4964596.000 2 B 1-9 A-I 490456.781 4964494.500 490565.344 4964495.000 11 10.86 

490492.563 4964636.500 6 F 9-10 I-J 490565.344 4964495.000 490564.750 4964520.500 4 8.50 

X Y 9-11 I-K 490565.344 4964495.000 490672.063 4964496.500 11 10.67 

RMPC 490456.781 4964494.500 1 A 11-12 K-L 490672.063 4964496.500 490705.875 4964530.000 6 9.52 

490440.656 4964596.000 2 B

490489.625 4964689.000 3 C490591.000 4964733.000 7 G

X Y

WRHSD 490456.781 4964494.500 1 A

490440.656 4964596.000 2 B VERTEX X (UTM) Y (UTM) ZONE LONG LAT

490489.625 4964689.000 3 C A 490456.781 4964494.500 15 93.1207350000 44.8337951672

490493.375 4964769.500 4 D B 490440.656 4964596.000 15 93.1209410000 44.8347084974490474.125 4964814.500 8 H C 490489.625 4964689.000 15 93.1203210932 44.8355441516

X Y D 490493.375 4964769.500 15 93.1202770000 44.8362693278

UPS 490456.781 4964494.500 1 A E 490471.219 4964890.000 15 93.1205570000 44.8373550420

490565.344 4964495.000 9 I F 490492.563 4964636.500 15 93.1202850000 44.8350769012490564.750 4964520.500 10 J G 490591.000 4964733.000 15 93.1190410000 44.8359396742

X Y H 490474.125 4964814.500 15 93.1205180000 44.8366750000

PbShip 490456.781 4964494.500 1 A I 490565.344 4964495.000 15 93.1193650000 44.8338014178

490565.344 4964495.000 9 I J 490564.750 4964520.500 15 93.1193660000 44.8340249346490672.063 4964496.500 11 K K 490672.063 4964496.500 15 93.1180110000 44.8338116305490705.875 4964530.000 12 L L 490705.875 4964530.000 15 93.1175836622 44.8341129166

VERTEX 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: 

07-21907A

 Air 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 Resource 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 Average Concentrations at each Receptor 
 Air 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 International 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 

m3 cubic meter 

mg milligram 

s second 

yr year 

μg microgram 
 Air 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 perform 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.com 
 Air 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 conducted 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 using 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 Protocol 

SIP Attainment Demonstration 

 Modeling Methodologies, Settings, and Input 5 

Table 1: Lead Emitting Point Sources Included in Dispersion Modeling Analysis 

Name Source Description 

UTM Zone 

15 Easting 

(m) 

UTM Zone 

15 Northing 

(m) 

Elevation 

(m) 

Pb 

Emission 

Rate (g/s) 

Stack 

Height 

(m) 

Stack 

Temperature 

(K) 

Ve

(

MSTACK01 Main stack 490648.1 4964581.1 272.7 2.20E-02 60.7 339 2

TSTACK01 Torit stack 490624.8 4964566.3 272.2 1.09E-02 24.4 321 1TSTACK02 Torit stack 490604.4 4964589.6 271.6 6.79E-03 24.4 298 1

RSTACK01 Refinery stack 1 490677.9 4964583.0 273.2 1.39E-04 8.4 501 5RSTACK02 Refinery stack 2 490676.3 4964586.4 273.2 5.04E-05 8.4 540 2RSTACK03 Refinery stack 3 490675.7 4964587.5 273.2 3.78E-05 8.4 682 3RSTACK04 Refinery stack 4 490674.7 4964589.7 273.2 6.30E-05 8.4 520 2RSTACK05 Refinery stack 5 490670.7 4964597.7 273.1 1.26E-04 8.4 445 2RSTACK06 Refinery stack 6 490668.6 4964597.9 273.1 7.56E-05 8.4 461 2RSTACK07 Refinery stack 7 490668.3 4964598.8 273.1 3.78E-05 8.4 662 4RSTACK08 Refinery stack 8 (w/ deflector) 490669.9 4964599.6 273.1 2.52E-05 8.4 758 4RSTACK09 Refinery stack 9 490674.0 4964604.8 273.2 6.30E-05 8.4 470 3

SSTACK01 Scrubber stack 490585.8 4964667.4 271.1 4.84E-03 17.8 303 1

PLSFAN01 Plastic bldg exhaust 1 490428.4 4964938.3 274.6 2.09E-04 11.3 293 8PLSFAN02 Plastic bldg exhaust 2 490450.6 4964952.6 272.9 2.09E-04 11.3 293 8
 Air 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 Server (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 (complex terrain), as with earlier regulatory 

models that distinguished between simple terrain and complex terrain (USEPA 2004a), 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 (incorporated 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 8.8
 Air 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 meters 
 Air Quality Dispersion Modeling Protocol 

 SIP Attainment Demonstration 

 10 References 

3 Model Input, Output, and Results Submittal 

The dispersion modeling results will be submitted 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 Agency (USEPA). 2004a. User's Guide for the 

AMS/EPA Regulatory Model - AERMOD. Office of Air Quality Planning and Standards. 

Emissions Monitoring and Analysis Division. Research Triangle Park, North Carolina. EPA454/B-03-001. September. 

United States Environmental Protection Agency (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 Agency (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 Agency (USEPA). 2009c. User's Guide for the 

AMS/EPA Regulatory Model – AERMOD (Addendum 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 

 SIP Attainment Demonstration 

 Figures 

Figures 

 

€NV I RON 
 Air Quality Dispersion Modeling Protocol 

 SIP Attainment Demonstration 

 14 References 

Figure 1-1: Site Location Map for Gopher Resource Facility 
 Air Quality Dispersion Modeling Protocol 

 SIP Attainment Demonstration 

 Figures 

Figure 2-1: Location of Lead Sources, Buildings, and Facility Boundary 
 Air Quality Dispersion Modeling Protocol 

 SIP Attainment Demonstration 

 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) 

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 Air Quality Dispersion Modeling Protocol 

 SIP Attainment Demonstration 

 Figures 

Figure 2-3: Receptor Placement Used in Modeling Analysis 
 Air Quality Dispersion Modeling Protocol 

 SIP Attainment Demonstration 

 18 References 

Figure 3-1: Maximum Three-Month Average Concentrations at each Receptor 
AQ Facility ID No: 03700016

Facility Name: Gopher ResourceFacility Address: 3385 South Highway 149 Eagan, MN Facility Contact: Steve Yates (651) 405-2213

Model Input KeyParameters Units Description

Type = 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)LOCATION

Air Quality Dispersion Modeling (

Protoc

SRCPARAM Easting Northin

Stack Vent Pollutant Base_Elev Height Diam Exit_Vel Exit_Temp Release_Type Emission_Rate Emission_Rate X1 Y1 

ID [m] [m] [m] [m/s] [K] (g/sec) (lb/hr) [m] [m]

SV001 NO2 450.31 48.77 5.77 15.31 327.6 VERTICAL 149 1182.56 495489.98 5251009.

SV001 PM2.5 450.31 47.57 5.47 15.31 327.35 VERTICAL 0.005 0.04 495494.98 5251011.

SV003 PM2.5 450.31 46.37 5.17 15.31 327.1 VERTICAL 10 79.37 495499.98 5251013.

Stack Parameter Input Table

Easting Northin

Stack Vent Pollutant Base_Elev Height Diam Exit_Vel Exit_Temp Release_Type Emission_Rate Emission_Rate X1 Y1 

ID [m] [m] [m] [m/s] [K] (g/sec) (lb/hr) [m] [m]

MSTACK01 Pb 272.73 60.7 1.83 21.53 338.7 VERTICAL 2.20E-02 1.75E-01 490648.08 4964581.

TSTACK01 Pb 272.204 24.4 2.44 16.55 321.5 VERTICAL 1.09E-02 8.65E-02 490624.75 4964566.

TSTACK02 Pb 271.572 24.4 2.13 17.62 297.6 VERTICAL 6.79E-03 5.39E-02 490604.38 4964589.

RSTACK01 Pb 273.211 8.4 0.49 5.61 500.9 VERTICAL 1.39E-04 1.10E-03 490677.85 4964583.RSTACK02 Pb 273.194 8.4 0.49 2.50 539.8 VERTICAL 5.04E-05 4.00E-04 490676.27 4964586.RSTACK03 Pb 273.188 8.4 0.49 3.82 682.0 VERTICAL 3.78E-05 3.00E-04 490675.71 4964587.RSTACK04 Pb 273.176 8.4 0.49 2.54 520.4 VERTICAL 6.30E-05 5.00E-04 490674.68 4964589.RSTACK05 Pb 273.132 8.4 0.49 2.36 445.4 VERTICAL 1.26E-04 1.00E-03 490670.72 4964597.RSTACK06 Pb 273.108 8.4 0.49 2.40 461.5 VERTICAL 7.56E-05 6.00E-04 490668.58 4964597.RSTACK07 Pb 273.105 8.4 0.49 4.98 662.0 VERTICAL 3.78E-05 3.00E-04 490668.27 4964598.RSTACK08 Pb 273.123 8.4 0.49 4.36 757.6 POINTCAP 2.52E-05 2.00E-04 490669.85 4964599.

RSTACK09 Pb 273.168 8.4 0.49 3.33 470.4 VERTICAL 6.30E-05 5.00E-04 490673.97 4964604.

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Stack Parameter Input Table

Easting Northin

Stack Vent Pollutant Base_Elev Height Diam Exit_Vel Exit_Temp Release_Type Emission_Rate Emission_Rate X1 Y1 

ID [m] [m] [m] [m/s] [K] (g/sec) (lb/hr) [m] [m]

SSTACK01 Pb 271.079 17.8 0.71 15.97 303.2 VERTICAL 4.84E-03 3.84E-02 490585.81 4964667.

PLSFAN01 Pb 274.556 11.3 1.47 8.20 293.0 VERTICAL 2.09E-04 1.66E-03 490428.36 4964938.

PLSFAN02 Pb 272.921 11.3 1.47 8.20 293.0 VERTICAL 2.09E-04 1.66E-03 490450.57 4964952.

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I I I I I I I 
AQ Facility ID No: 03700016

Facility Name: Gopher R

Facility Address: 3385 South Hi h 149 Eagan, MN

Facility Contact: Steve Yates (651) 405-2213

Model Input KeyParameters Units Description

ID = 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]

Air Quality Dispersion Modelin

Pr

Lateral Dimension Vertical Dimension Easting 

ID Pollutant Base_Elev Height SigmaY SigmaZ Length_X Emission_Rate Emission_Rate X1 

[m] [m] [m] [m] [m] (g/sec) (lb/hr) [m] 

CONCWE PM2.5 469.24 5 0.2 0.47 483070.73 

SPACEHT NO2 469.24 5 15.2 4.65 483070.73 

Lateral Dimension Vertical Dimension Easting 

ID Pollutant Base_Elev Height SigmaY SigmaZ Length_X Emission_Rate Emission_Rate X1 

[m] [m] [m] [m] [m] (g/sec) (lb/hr) [m] 

SLGBIN01 Pb 274.04 1.50 0.71 0.70 3.78E-05 3.00E-04 490509.00 

LOADER ROUTE 40.00 

LOADER01 Pb 270.99 2.82 12.09 2.63 5.89E-06 4.67E-05 490584.61 

LOADER02 Pb 270.73 2.82 12.09 2.63 5.89E-06 4.67E-05 490566.17 

LOADER03 Pb 271.41 2.82 12.09 2.63 5.89E-06 4.67E-05 490546.61 

SLGLDR ROUTE 120.00 

SLGLDR01 Pb 270.80 2.82 12.09 2.63 2.05E-06 1.62E-05 490581.04 

SLGLDR02 Pb 270.66 2.82 12.09 2.63 2.05E-06 1.62E-05 490562.18 

SLGLDR03 Pb 271.27 2.82 12.09 2.63 2.05E-06 1.62E-05 490547.03 

SLGLDR04 Pb 271.90 2.82 12.09 2.63 2.05E-06 1.62E-05 490534.27 

SLGLDR05 Pb 272.64 2.82 12.09 2.63 2.05E-06 1.62E-05 490525.83 

SLGLDR06 Pb 273.46 2.82 12.09 2.63 2.05E-06 1.62E-05 490517.33 

SLGLDR07 Pb 274.29 2.82 12.09 2.63 2.05E-06 1.62E-05 490506.37 

SEGMENT AB 102.77 

AB01 Pb 277.85 3.50 7.57 3.25 1.46E-05 1.16E-04 490455.98 

AB02 Pb 276.66 3.50 7.57 3.25 1.46E-05 1.16E-04 490454.36 

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Lateral Dimension Vertical Dimension Easting 

ID Pollutant Base_Elev Height SigmaY SigmaZ Length_X Emission_Rate Emission_Rate X1 

[m] [m] [m] [m] [m] (g/sec) (lb/hr) [m] 

AB03 Pb 275.44 3.50 7.57 3.25 1.46E-05 1.16E-04 490452.75 

AB04 Pb 274.21 3.50 7.57 3.25 1.46E-05 1.16E-04 490451.14 

AB05 Pb 272.97 3.50 7.57 3.25 1.46E-05 1.16E-04 490449.53 

AB06 Pb 271.71 3.50 7.57 3.25 1.46E-05 1.16E-04 490447.91 

AB07 Pb 270.93 3.50 7.57 3.25 1.46E-05 1.16E-04 490446.30 

AB08 Pb 271.04 3.50 7.57 3.25 1.46E-05 1.16E-04 490444.69 

AB09 Pb 271.16 3.50 7.57 3.25 1.46E-05 1.16E-04 490443.08 

AB10 Pb 271.28 3.50 7.57 3.25 1.46E-05 1.16E-04 490441.46 

SEGMENT BC 105.10 

BC01 Pb 271.61 3.50 7.68 3.25 1.41E-05 1.12E-04 490443.10 

BC02 Pb 272.14 3.50 7.68 3.25 1.41E-05 1.12E-04 490448.00 

BC03 Pb 272.67 3.50 7.68 3.25 1.41E-05 1.12E-04 490452.90 

BC04 Pb 273.20 3.50 7.68 3.25 1.41E-05 1.12E-04 490457.80 

BC05 Pb 273.74 3.50 7.68 3.25 1.41E-05 1.12E-04 490462.69 

BC06 Pb 274.27 3.50 7.68 3.25 1.41E-05 1.12E-04 490467.59 

BC07 Pb 274.72 3.50 7.68 3.25 1.41E-05 1.12E-04 490472.49 

BC08 Pb 275.14 3.50 7.68 3.25 1.41E-05 1.12E-04 490477.38 

BC09 Pb 275.14 3.50 7.68 3.25 1.41E-05 1.12E-04 490482.28 

BC10 Pb 275.02 3.50 7.68 3.25 1.41E-05 1.12E-04 490487.18 

SEGMENT CD 80.59 

CD01 Pb 275.03 3.50 7.48 3.25 3.68E-06 2.92E-05 490489.86 

CD02 Pb 275.15 3.50 7.48 3.25 3.68E-06 2.92E-05 490490.33 

CD03 Pb 275.27 3.50 7.48 3.25 3.68E-06 2.92E-05 490490.80 

CD04 Pb 275.40 3.50 7.48 3.25 3.68E-06 2.92E-05 490491.27 

CD05 Pb 275.53 3.50 7.48 3.25 3.68E-06 2.92E-05 490491.73 

CD06 Pb 275.61 3.50 7.48 3.25 3.68E-06 2.92E-05 490492.20 

CD07 Pb 275.67 3.50 7.48 3.25 3.68E-06 2.92E-05 490492.67 

CD08 Pb 275.72 3.50 7.48 3.25 3.68E-06 2.92E-05 490493.14 

SEGMENT DE 122.52 

DE01 Pb 275.83 3.50 7.54 3.25 4.67E-07 3.70E-06 490492.45 

DE02 Pb 275.99 3.50 7.54 3.25 4.67E-07 3.70E-06 490490.61 

DE03 Pb 276.16 3.50 7.54 3.25 4.67E-07 3.70E-06 490488.76 

DE04 Pb 276.34 3.50 7.54 3.25 4.67E-07 3.70E-06 490486.91 

DE05 Pb 276.53 3.50 7.54 3.25 4.67E-07 3.70E-06 490485.07 

DE06 Pb 276.72 3.50 7.54 3.25 4.67E-07 3.70E-06 490483.22 

DE07 Pb 276.51 3.50 7.54 3.25 4.67E-07 3.70E-06 490481.37 

DE08 Pb 276.17 3.50 7.54 3.25 4.67E-07 3.70E-06 490479.53 

DE09 Pb 275.75 3.50 7.54 3.25 4.67E-07 3.70E-06 490477.68 

DE10 Pb 275.28 3.50 7.54 3.25 4.67E-07 3.70E-06 490475.84 

DE11 Pb 274.87 3.50 7.54 3.25 4.67E-07 3.70E-06 490473.99 

DE12 Pb 274.49 3.50 7.54 3.25 4.67E-07 3.70E-06 490472.14 

SEGMENT BF 65.84 

BF01 Pb 271.70 3.50 7.89 3.25 5.16E-06 4.10E-05 490444.98 

BF02 Pb 272.43 3.50 7.89 3.25 5.16E-06 4.10E-05 490453.63 

BF03 Pb 273.15 3.50 7.89 3.25 5.16E-06 4.10E-05 490462.28 

BF04 Pb 273.88 3.50 7.89 3.25 5.16E-06 4.10E-05 490470.94 

BF05 Pb 274.50 3.50 7.89 3.25 5.16E-06 4.10E-05 490479.59 

BF06 Pb 274.21 3.50 7.89 3.25 5.16E-06 4.10E-05 490488.24 

SEGMENT CG 110.51 

CG01 Pb 274.79 3.50 7.46 3.25 1.84E-05 1.46E-04 490494.23 

CG02 Pb 274.45 3.50 7.46 3.25 1.84E-05 1.46E-04 490503.45 

CG03 Pb 274.13 3.50 7.46 3.25 1.84E-05 1.46E-04 490512.67 

CG04 Pb 273.82 3.50 7.46 3.25 1.84E-05 1.46E-04 490521.88 

CG05 Pb 273.53 3.50 7.46 3.25 1.84E-05 1.46E-04 490531.10 

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Lateral Dimension Vertical Dimension Easting 

ID Pollutant Base_Elev Height SigmaY SigmaZ Length_X Emission_Rate Emission_Rate X1 

[m] [m] [m] [m] [m] (g/sec) (lb/hr) [m] 

CG06 Pb 273.26 3.50 7.46 3.25 1.84E-05 1.46E-04 490540.31 

CG07 Pb 273.01 3.50 7.46 3.25 1.84E-05 1.46E-04 490549.53 

CG08 Pb 272.78 3.50 7.46 3.25 1.84E-05 1.46E-04 490558.74 

CG09 Pb 272.56 3.50 7.46 3.25 1.84E-05 1.46E-04 490567.96 

CG10 Pb 272.61 3.50 7.46 3.25 1.84E-05 1.46E-04 490577.18 

CG11 Pb 272.66 3.50 7.46 3.25 1.84E-05 1.46E-04 490586.39 

SEGMENT DH 48.94 

DH01 Pb 275.87 3.50 7.34 3.25 3.13E-06 2.49E-05 490491.45 

DH02 Pb 276.11 3.50 7.34 3.25 3.13E-06 2.49E-05 490487.60 

DH03 Pb 276.37 3.50 7.34 3.25 3.13E-06 2.49E-05 490483.75 

DH04 Pb 276.65 3.50 7.34 3.25 3.13E-06 2.49E-05 490479.90 

DH05 Pb 276.68 3.50 7.34 3.25 3.13E-06 2.49E-05 490476.05 

SEGMENT AI 108.56 

AI01 Pb 278.64 3.50 7.84 3.25 1.80E-06 1.43E-05 490462.21 

AI02 Pb 279.02 3.50 7.84 3.25 1.80E-06 1.43E-05 490473.07 

AI03 Pb 279.14 3.50 7.84 3.25 1.80E-06 1.43E-05 490483.92 

AI04 Pb 278.98 3.50 7.84 3.25 1.80E-06 1.43E-05 490494.78 

AI05 Pb 278.82 3.50 7.84 3.25 1.80E-06 1.43E-05 490505.63 

AI06 Pb 278.65 3.50 7.84 3.25 1.80E-06 1.43E-05 490516.49 

AI07 Pb 278.49 3.50 7.84 3.25 1.80E-06 1.43E-05 490527.35 

AI08 Pb 278.33 3.50 7.84 3.25 1.80E-06 1.43E-05 490538.20 

AI09 Pb 278.16 3.50 7.84 3.25 1.80E-06 1.43E-05 490549.06 

AI10 Pb 278.00 3.50 7.84 3.25 1.80E-06 1.43E-05 490559.92 

SEGMENT IJ 25.51 

IJ01 Pb 277.45 3.50 6.75 3.25 1.32E-07 1.05E-06 490565.25 IJ02 Pb 276.51 3.50 6.75 3.25 1.32E-07 1.05E-06 490565.05 IJ03 Pb 275.58 3.50 6.75 3.25 1.32E-07 1.05E-06 490564.85 

SEGMENT IK 106.73 

IK01 Pb 277.89 3.50 7.75 3.25 6.84E-06 5.43E-05 490570.68 

IK02 Pb 278.03 3.50 7.75 3.25 6.84E-06 5.43E-05 490581.35 

IK03 Pb 278.17 3.50 7.75 3.25 6.84E-06 5.43E-05 490592.02 

IK04 Pb 278.31 3.50 7.75 3.25 6.84E-06 5.43E-05 490602.70 

IK05 Pb 278.45 3.50 7.75 3.25 6.84E-06 5.43E-05 490613.37 

IK06 Pb 278.59 3.50 7.75 3.25 6.84E-06 5.43E-05 490624.04 

IK07 Pb 278.73 3.50 7.75 3.25 6.84E-06 5.43E-05 490634.71 

IK08 Pb 278.87 3.50 7.75 3.25 6.84E-06 5.43E-05 490645.38 

IK09 Pb 279.01 3.50 7.75 3.25 6.84E-06 5.43E-05 490656.06 

IK10 Pb 278.65 3.50 7.75 3.25 6.84E-06 5.43E-05 490666.73 

SEGMENT KL 47.60 

KL01 Pb 277.95 3.50 7.22 3.25 8.87E-06 7.04E-05 490675.44 

KL02 Pb 277.13 3.50 7.22 3.25 8.87E-06 7.04E-05 490682.21 

KL03 Pb 276.40 3.50 7.22 3.25 8.87E-06 7.04E-05 490688.97 

KL04 Pb 275.75 3.50 7.22 3.25 8.87E-06 7.04E-05 490695.73 

KL05 Pb 275.20 3.50 7.22 3.25 8.87E-06 7.04E-05 490702.49 

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AQ Facility ID No: 03700016

Facility Name: Gopher ResourceFacility Address: 3385 South Highway 149 Eagan, MN

Facility Contact: Steve Yates (651) 405-2213

Stack Vent Emission Pollutant Description Emission Factor Emission Factors References/Assumptions/Equations

ID Unit Used to generate short - term emission rate

SV001 EU001 NO2 Emergency Power Generator Concentrator - Diesel 0.01 1,200 kW capacity provided by vendor x 1.341 hp/kW = 1,609 hp lb/hp-hr emission factors from AP-42 'Large Stationary Diesel And All Stationary Dual-fuel Engines' 

(10/96)T bl 3 4 1 SO2 0 00809

Emission Calculations Table

Stack Vent Emission Pollutant Description Emission Factor Emission Factors References/Assumptions/Equations

ID Unit Used to generate short - term emission rate

ROADWAYS Pb Roadway emission factors for TSP VARIABLE E = [k(sL)0.91 x (W)1.02] (1 - P/4N) Õ E = emission factor (lb/VMT)

Formula from AP-42 Section 13.2.1 k = particle size multiplier (lb/VMT, 

sL = road surface silt loading (g/m2

SLAG BIN Pb TSP emission factor for slag transfer 0.0015 4% Pb content; 60 tons/day slag moved W = average weight of vehicles tra

Emission factor from AP-42 Table 11.19.2-1 VMT = vehicle miles traveled

P = number of "wet" days with at le

N = number of days in the averagin

AQDMPS-01

Air Quality Dispersion Modeling (AQDM) Protocol Spreadsheet

Protocol Form for Criteria Pollutant Modeling

Doc Type: Air Dispersion Modeling

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M30(TSP))

veraging period (110 days for GOPHER)

above)

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aq2-40 • 7/22/11 Page 1 of 12

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 concentrations 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 Information 
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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 – please explain:

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

No 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, please 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 yes, 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)?

NO2 PM10 PM2.5 SO2

PSD major source baseline (PM2.5 trigger date will be on Oct. 20, 2011, 1 year after F.R. publication date.)

NO2 1988 PM10 1975 PM2.5 2010 SO2 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. Additional 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-PRIME version 04274 be used? Yes No

If no, please explain:
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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 Prevention 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 characteristics 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 by 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 version 11237

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

AERMET v11059 (SFC & PFL) meteorological files from MSP-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 NO2 PM2.5 PM10 SO2 Pb H2S 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 for correct pollutant IDs to use. Use EPA’s most recent 

modeling guidance’ methods for PM2.5.

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:
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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 NO2 is required to be analyzed for the 1-hour and annual NAAQS, what tier methodology(s) is proposed?

N/A, NO2 not required (skip to question 6)

Tier 1 (100% NOx to NO2 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 justification 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 NO2/NOx (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 O3 File (μg/m3) (OZONEFIL)

File name: DMAX: km

MPCA-generated Maximum Hourly Monitored O3 File (μg/m3) (OZONEFIL)

File name: DMAX: km

Other - please explain:

c. Is EPA approval needed for the modeling protocol (e.g., Tier 3 NO2)? Tier 3 NO2 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, paragraph (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. Additional information for this section (including justification for non-default or additional values listed in 5a or 5b):

Pb 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 modeling 

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 – exit velocity(s) = 0.001 m/s Non-Default POINTCAP/POINTHOR*

*Please provide justification for use of non-default option in question b, below.
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b. Additional information for this subsection (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. Additional 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. Additional 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. Additional 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 Section 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 PM10, with emissions over 0.1 lb/hr and for PM2.5, 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.

Please scale for other pollutants. For example, (0.1 lb/hr)/(150 μg/m3) = (X lb/hr)/(35 μg/m3), where X = 0.02 lb/hr.

Refer to guidance in section 10 of the 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 NO2/NOx 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. Additional information for this section (if not applicable, place N/A in field):
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N/A

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 PM10 and PM2.5 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 PM10 and PM2.5 (NAAQS modeling must 

include background concentrations). 

1. Does your facility have paved road fugitive dust emissions for PM10 and PM2.5?

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. Additional 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/m3

)

Modeled NAAQS 

Impact 

Concentrations 

(μg/m3) % of NAAQS

PSD Class II 

Increments 

(μg/m3)

Modeled Class II 

Increment Impact 

Concentrations 

(μg/m3)

% of Class II 

Increments

PM10

24-hour 150 0.0 30 0.0

Annual 50 0.0 17 0.0

PM2.5

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 PM10 and PM2.5 (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. 3
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PM10 0.00 # < 60% 60% < # < 95% 95% < # 0.00 # < 35% 35% < # < 75% 75% < #

PM2.5 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 fugitive 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. Additional 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?

N/A
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4. 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. Additional 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 which 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/m3)

SILs (μg/m3)

*As of 

10/26/2010

% of SIL Exceed SIL? Radius of Impact 

(If exceeds SIL)

SO2

1-hr 7.83 0.0

(blank) km

3-hr 25 0.0

24-hr 5 0.0

Annual 1 0.0

PM10

24-hr 5 0.0

(blank) km

Annual 1 0.0

PM2.5

24-hr 1.2 0.0

(blank) km

Annual 0.3 0.0

NOx

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. Additional 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. 
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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 usergenerated background concentrations.

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

Other – explain:

Examined monitors out to a distance of: km

Facility 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, 98th 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

SO2 - - -

PM10 - - - - -

PM2.5 - - - - -

NOx - - - - -

CO - - - - -

Pb - - - - - 0 -

H2S - - - - - -

Other -

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

N/A

Appendix 

Figure A.1 
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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 - - -

NO2 98th percentile of the daily max. 1-hour values - - - - H1H

Pb - - - - H1H -

PM10 - - - H6H of the multiyear values - H1H

PM2.5 - - - 98th percentile of daily max. 24-hour values - H1H

SO2 99th 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

NO2 - - - H1H

PM10 - - H2H H1H

PM2.5 - - H2H* H1H

SO2 - 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-hour 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. 
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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 NO2 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-PRIME 

Carbon Dioxide (CO) 

Digital Elevation Model (DEM) 

Environmental Assessment Worksheet (EAW) 

Environmental Impact Statement (EIS) 

U.S. Environmental Protection Agency (EPA) 

Hydrogen Sulfide (H2S) 

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 (NO2) 

Particulate Matter less than 10 um in size (PM10) 

Particulate Matter less than 2.5 um in size (PM 2.5) 

Lead (Pb) 

POINTCAP 

POINTHOR 

Prevention of Significant Deterioration Program (PSD)

Plume Volume Molar Ratio Method/Ozone Limiting Method 

(PVMRM/OLM) 

Standardized Air Modeling (SAM) 

Significant Impact Level (SIL) 

Sulfur Dioxide (SO2) 

State Implementation Plan (SIP)

Standardized Mobile Source (SMS) 

Universal Transverse Mercator (UTM)
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AQDMPRF-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 

Section and section 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 0.128097. 

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 POINTCAP 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 results 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. 
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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 torit stacks, and 

the scrubber stack were all modeled at more conservative emission rates 

than the stack tests resultant emissions. 

Modeling Protocol is: Approved

Approval of Modeling Protocol by Sections – Completed by Air Permit Engineer 

Section and section name

Acceptable/

Unacceptable 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 • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats 

aq2-43 • 9/23/11 Page 1 of 1 

AQDM PAN-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 address: 3385 South Highway 149

City: Eagan State: MN Zip code: 55121

Protocol prepared by: ENVIRON International Corp. Preparer phone: 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 calculations have not been reviewed by a permit 

engineer, as of yet.
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 Section 172 of the Clean Air Act with regards to the 

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

available for public comment. 

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

NAAQS for lead of 0.15 μg/m3

. 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 the 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 requirements for Gopher Resource, LLC, that are included in an Administrative Order 

(Order) that will be issued to the facility, and modeling 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 period. 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: 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 email: 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 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. 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 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 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, 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 
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 writing, 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. 
 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 State 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 Microsoft 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 Minnesota

libraries; 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.minnesotasbookstore.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, Minnesota,

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 Lafayette

Road, St. Paul, Minnesota, 55155-4020; or by calling the DNR at (651) 296-6157. The contest application and information are also

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 172 of

the Clean Air Act with regards to the National Ambient Air Quality Standards (NAAQS) for lead (40 CFR 50.16). The draft SIP Revision

is now available for public comment.

 Background. The United States Environmental Protection Agency (EPA) has promulgated a NAAQS for lead of 0.15 μg/m3

. 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 the

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 requirements

for Gopher Resource, LLC, that are included in an Administrative Order (Order) that will be issued to the facility, and modeling 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 period.

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 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 Notices
Page 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 inspection 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 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 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, 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

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 writing,

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) for

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 that 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 necessary

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, such 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 CFR 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 Hedman. 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 acting 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 and duties of the MPCA or the Commissioner. The 

Commissioner shall comply with any and all requirements of such federal law or such rules and 

regulations promulgated thereunder to facilitate application 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 ‘document’) 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 legal authority under State 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 revision including a maintenance plan update for the 

area. On June 3, 2008, EPA published a direct final approval of the maintenance plan (73 FR 31614). 
On July 29, 2010, the MPCA submitted a SIP revision to include the joint Title I/Title V document and the 

SIP enforceable document. This Air Emission 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). 

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 for issuing the permit as well as the SIP revision. 

5) Public Notice: 

“Evidence that public notice was given of the proposed 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 and ending on May 25, 2012. During the public 

comment period, a copy of the SIP revision request was made available at the MPCA office located in St. 

Paul and on the MPCA’s website. A copy of the public notice is attached. (Attachment 4). 

6) Public Hearing Certification: 

“Certification that public hearing(s) were held in accordance with the information provided in the public 

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

The public notice states: “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 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, 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 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.” 

No public meeting was requested. 

7) Public Comments and State Response: 

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

EPA SIP staff made several comments on how to improve 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 this SIP revision request is lead. 

2) Source Identification 

“Identification of the locations of affected sources 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 County 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 emissions of lead from the source. 

4) NAAQS Protections: 

“The State’s demonstration that the NAAQS, prevention of significant deterioration increments, 

reasonable further progress demonstration, and visibility, as applicable, are protected 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 proposed 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 Background Document and included in Attachment 2. 

6) Continuous Emission Reduction 

“Evidence, where necessary, that emission limitations 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 limitations, 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 how 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 Technological 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 area will attain the lead NAAQS of 0.15 μg/m3

.