Northshore Mining Comany–Furnace 5 Reactivation Project · Enclosed is the Environmental...

May 20, 2005 TO: INTERESTED PARTIES RE: Northshore Mining Company – Furnace 5 Reactivation Project Enclosed is the Environmental Assessment Worksheet (EAW) for the proposed Northshore Mining Company – Furnace 5 Reactivation Project, Lake County. The EAW was prepared by the Minnesota Pollution Control Agency (MPCA) and is being distributed for a 30-day review and comment period pursuant to the Environmental Quality Board (EQB) rules. The comment period will begin the day the EAW availability notice is published in the EQB Monitor, which will likely occur in the May 23, 2005, issue. In addition to the EAW, the draft Air Emission and National Pollutant Discharge Elimination System and State Disposal System (NPDES/SDS) Permits for this Facility will also be available for public comment, beginning May 23, 2005. The contact person for the Air Emission Permit is Jeff Peltola at (651) 296-8638 and for the NPDES/SDS Permit is Jeff Udd at (218) 723-4843. Comments will be accepted on the draft EAW and on both draft permit documents until June 22, 2005. A public meeting will be held on June 7, 2005, from 5:30 to 9:00 p.m. in the auditorium of the William Kelley High School, 137 Banks Boulevard, Silver Bay, Minnesota. Comments received on the EAW will be used by the MPCA in evaluating the potential for significant environmental effects from this project and deciding on the need for an Environmental Impact Statement (EIS). A final decision on the need for an EIS will be made by the MPCA Commissioner after the end of the comment period. If a request for an EIS is received during the comment period, or if the Commissioner recommends the preparation of an EIS, the MPCA Citizens’ Board (Board) will make the final decision. The final EIS need decision will also be made by the Board if so requested by the project proposer, other interested parties, or MPCA staff and if this request is agreed to by one or more members of the Board or the MPCA Commissioner. The Board meets once a month, usually the fourth Tuesday of each month, at the MPCA office in Saint Paul. Meetings are open to the public and interested persons may offer testimony on Board agenda items. A listing of Board members is available on request by calling (651) 296-7306. Please note that comment letters submitted to the MPCA do become public documents and will be part of the official public record for this project. If you have any questions on the EAW, please contact Dana Vanderbosch of my staff at (651) 297-1796. Sincerely, Beth G. Lockwood Supervisor, Environmental Review Unit Environmental Review and Operations Section Regional Division BL:ns Enclosure

p-ear1-04 TDD (for hearing and speech impaired only): (651) 282-5332

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ENVIRONMENTAL ASSESSMENT WORKSHEET Note to reviewers: The Environmental Assessment Worksheet (EAW) provides information about a project that may have the potential for significant environmental effects. This EAW was prepared by the Minnesota Pollution Control Agency (MPCA), acting as the Responsible Governmental Unit (RGU), to determine whether an Environmental Impact Statement (EIS) should be prepared. The project proposer supplied reasonably accessible data for, but did not complete the final worksheet. Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) Monitor. Comments on the EAW should address the accuracy and completeness of information, potential impacts that are reasonably expected to occur that warrant further investigation, and the need for an EIS. A copy of the EAW may be obtained from the MPCA by calling (651) 296-7398. An electronic version of the completed EAW is available at the MPCA Web site http://www.pca.state.mn.us/news/eaw/index.html#open-eaw. 1. Project Title: Northshore Mining Company – Furnace 5 Reactivation Project 2. Proposer: Northshore Mining Company 3. RGU: Minnesota Pollution Control Agency Contact Person Dennis Wagner Contact Person Dana Vanderbosch and Title Sr. Staff Environmental Engineer and Title Project Manager Address 10 Outer Drive Address 520 Lafayette Road North Silver Bay, Minnesota 55614 St. Paul, Minnesota 55155 Phone (218) 226-6056 Phone (651) 297-1796 Fax (218) 226-6037 Fax (651) 297-2343 4. Reason for EAW Preparation:

EIS Scoping

Mandatory EAW

X

CitizenPetition

RGU Discretion

Proposer Volunteered

If EAW or EIS is mandatory give EQB rule category subpart number and name: Minn. R. 4410.4300,

subp 15(A) 5. Project Location: County Lake City Silver Bay NW 1/4 SW 1/4 Section 5 Township 56 Range 7

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

Northshore Mining Company – Furnace 5 Reactivation Project Environmental Assessment Silver Bay, Minnesota 2 Worksheet

Figures attached to the EAW:

Figure 1 Map showing the general project location in Lake County, Minnesota; Figure 2 United States Geological Survey 7.5 minute, 1:24,000 scale map indicating location of Silver

Bay taconite processing facility and Milepost 7 tailings basin; Figure 3 Site plan showing location of significant processes at the taconite processing plant; Figure 4 Process flow diagram of facility; Figure 5 Minnesota Department of Natural Resources (DNR) Natural Heritage Database Review letter; Figure 6 E-mail from DNR staff; Figure 7 Figure showing layout and flow of the Milepost 7 Wastewater Treatment Plant (WWTP)

processes; Figure 8 Locations of ambient air monitoring stations; Figure 9 Locations of Class I areas; Figure 10 Map showing 3 kilometer (km) area around facility and Figure 11 Copy of the Minnesota Historical Society’s State Historic Preservation Office (SHPO) letter

6. Description:

a. Provide a project summary of 50 words or less to be published in the EQB Monitor. Northshore Mining Company (NSM) proposes to reactivate idled equipment including a pelletizing furnace (known as Furnace 5), two fine crushing units, and nine ore concentrator sections at its taconite processing facility (Facility) located at 10 Outer Drive, Silver Bay, Lake County, Minnesota. The proposed project also entails construction of a concentrate handling system consisting of three conveyors and two concentrate silos, an expansion of the WWTP located at the Milepost 7 tailings basin, and a revision of the amphibole mineral fiber limit. The Air Emission Permit and National Pollutant Discharge Elimination System and State Disposal System (NPDES/SDS) Permit for this Facility have been amended as a result of the project proposal and the draft permits will also be available for public comment beginning May 23, 2005. The contact person for the Air Emission Permit is Jeff Peltola at (651) 296-8638 and for the NPDES/SDS Permit is Jeff Udd at (218) 723-4843. Comments will be accepted on the draft EAW and on both draft permit documents until June 22, 2005. A public meeting will be held on June 7, 2005, from 5:30 to 9:00 p.m., in the auditorium of the William Kelley High School, 137 Banks Boulevard, Silver Bay, Minnesota.

b. Give a complete description of the proposed project and related new construction. Attach additional sheets as necessary. Emphasize construction, operation methods and features that will cause physical manipulation of the environment or will produce wastes. Include modifications to existing equipment or industrial processes and significant demolition, removal or remodeling of existing structures. Indicate the timing and duration of construction activities. I. EXISTING OPERATIONS Overview Taconite is a low-grade iron ore which NSM currently mines near Babbitt, Minnesota. The crude ore is transported from the mine to the taconite processing Facility at Silver Bay. The low-grade iron ore is processed at the Facility to produce a magnetic iron concentrate, magnetite (Fe3O4). Magnetite is formed into “green balls” with binding agents. The magnetite is converted to hematite (Fe2O3) when the green balls are fired in the pelletizing furnaces. This creates taconite pellets containing approximately 65 percent iron in an oxidized form. Pellets are sold as raw ingredients for steel production. The oxidized pellets were developed specifically for use by blast furnaces at integrated steel mills. Blast furnaces at the steel mills convert the pellets to metallic iron which is further processed to make steel. Concentrate is also sold for use in other markets, including production of iron nugget (which contains very high—greater than 96 percent—iron content).


Reserve Mining built the Facility in the mid-1950s and operated it until it was shut down in 1986 due to bankruptcy. Cyprus Minerals acquired the Facility in August 1989 and resumed operations. Cleveland-Cliffs Incorporated purchased the Facility from Cyprus Minerals in 1994. NSM has operated it since then as a wholly-owned subsidiary of Cleveland-Cliffs Incorporated. Production of conventional, standard (partially fluxed), and fully fluxed pellets and concentrate has increased since Cyprus Minerals purchased the Facility in 1989. The currently operating equipment can produce 5 million long tons of concentrate per year and approximately 6.7 million long tons of pellets per year (one long ton equals 2,240 pounds). In 2004, the Facility produced 4.8 million long tons of concentrate and 4.9 million long tons of pellets. The Facility has produced as many as 10 million long tons of pellets in the past. Figures 1 and 2 show the general location of the Facility in Lake County and an overview of the Facility and the Milepost 7 tailings basin. Babbitt Mining Operations Crude ore is mined and crushed near Babbitt, Minnesota in two separate pits: the Main Pit and the East Pit. There are two permitted crushers at the mines: Crusher Number 1 is operational and Crusher Number 2 is currently idled. Crusher Number 1 has the capacity to crush 3,200 long tons of crude ore per hour and in 2004, it crushed 13.9 million long tons of crude ore. Coarsely crushed crude ore from the mine is delivered to the taconite processing Facility in Silver Bay by rail and unloaded at a car dump station. All of the operations described below are located at the Facility in Silver Bay. Fine Ore Crushing Crude ore that has been delivered to the Facility proceeds to fine crushing where it is reduced to a three-fourths inch size or smaller. Following fine crushing, the ore is directed to dry cobbing, which is a dry magnetic separation process used to reject the portion of the ore that does not contain sufficient magnetic iron. Approximately 14 percent of the three-fourths inch size material is rejected during dry cobbing, producing coarse aggregate tailings (referred to as coarse tailings throughout the rest of this EAW). This rejected ore is sent to the Milepost 7 tailings basin located approximately four miles to the west of the Facility for dam construction purposes. The fine crushers that are currently operating have the capacity to process a combined total of 4,200 long tons of ore per hour. Concentrate Production Concentrate production involves separating the magnetite ore from host rock. The ore not rejected during dry cobbing is sent to a series of wet grinding and concentrating processes to separate, concentrate, and recover the iron from the incoming ore. Each concentrator section consists of rod and ball mill grinding, particle sizing, magnetic separation, hydraulic cleaning, froth flotation, and fine screening to produce a finely ground concentrate containing approximately 65 percent iron, which is contained in a liquid slurry form. The iron concentrate slurry is then thickened and vacuum filtered to reduce the moisture content to approximately 10 percent. After vacuum filtering, the concentrate is conveyed as a solid containing 9-10 percent moisture to pelletizing operations. Roughly 30 percent of the ore processed becomes iron concentrate. The remaining material is rejected in various size fractions ranging from the three-fourths inch size coarse tailings described in the Fine Ore Crushing section above to a finely ground rock powder (fine tailings). This fine tailings material is directed to the wastewater and Milepost 7 tailings disposal system, which is described in the Process Wastewater and Tailings Disposal System section below. Currently, 11 permitted concentrating lines produce iron ore concentrate and these 11 units have a combined production capacity of 5 million long tons of concentrate per year.


Pellet Production The Facility produces standard and fluxed pellets from the concentrate using a number of processing steps. Fluxed pellets contain additional limestone which enhances the processing of the iron concentrate in a blast furnace. One concentrating line is used to produce ground limestone for flux pellet production. Flux pellet production requires mixing of iron concentrate and limestone in slurry form prior to vacuum filtering. Following vacuum filtering, the iron concentrate is agglomerated. Agglomeration involves adding a small amount of binding agent (e.g., bentonite clay, starch) to the iron concentrate and passing the mixture through inclined rotating drums where it is rolled into one-fourth to one-half inch green balls suitable for feeding to a pelletizing furnace. The green balls are placed onto a traveling grate that passes through the furnace where the green balls are dried and then heated to start an exothermic reaction that converts the magnetite concentrate to hematite. During this process, the pellets are indurated or hardened. Pellets are then cooled and discharged from the furnace for subsequent handling. The furnaces use natural gas, with fuel oil as an alternative, and are equipped with Wet Walled Electrostatic Precipitators (WWESPs) for control of air emissions. There are four permitted pelletizing furnaces at the Facility (Number 5 and Number 6 with a capacity of 160 long tons per hour each and Number 11 and Number 12 with a capacity of 300 long tons per hour each). Only Number 6, Number 11, and Number 12 are currently in operation, and together they have a production capacity of approximately 6.7 million long tons of pellet per year. After leaving the furnaces, the pellets are directed to a series of screening and additional cooling steps. Undersized material is either sold as iron sinter feed for steel mills or is recycled. The final product is then transported to the storage yard for stockpiling or bin storage for eventual shipment to integrated steel making facilities.

Product Storage and Loadout The pellet storage yard has the capacity to store approximately 5 million long tons of pellets. The pellet loadout storage bins have a combined capacity of 50,000 long tons of pellets and are capable of loading boats or railcars. A conveyor network allows filling of the storage bins and the flexibility to locate or direct material throughout the storage yard. Front end loaders are used for truck loading and to move pellets from the storage piles to transfer conveyors.

Power Plant A fossil fuel-fired cogeneration power plant is located at the Facility for production of electricity and process steam. The power plant has two boilers capable of burning solid, liquid, and gaseous fossil fuels that serve two electric generator sets with a total rated capacity of 115 megawatts. The electricity is currently used onsite, and any excess electricity is sold to the electric grid. The boilers burned a combined total of 550,009 short tons of subbituminous coal, 21,000 gallons of number 1 fuel oil, and 69 million cubic feet of natural gas in 2004. Process steam used in the taconite processing operations is produced using special evaporators that extract heat from the power boilers. Additional process steam can be generated by two oil and natural gas-fired process boilers, which are in the existing Air Emission Permit No. 07500003 (Air Emission Permit) that was reissued on February 24, 2004, but they have been idle for many years.

Raw Materials Management Coal for the power plant and limestone for the flux pellet production are stored in an outdoor storage yard. These materials are currently received by ship, although the Facility has the capability to receive these materials by rail or truck. Front end loaders and scrapers are used to transfer the materials to the power plant and taconite production areas.


Taconite pellet binders and other miscellaneous raw materials are received by rail or truck. Powder materials are pneumatically transferred to storage bins and production operations. These materials are stored indoors. A site plan with the location of significant processes and a process flow diagram of the Facility can be found in Figures 3 and 4.

Process Wastewater and Tailings Disposal System Throughout this EAW, two terms will be used when discussing water used at the Facility. Process wastewater is defined as water that has come into contact with the process and includes fine tailings in a slurry form, blowdown from the furnace WWESPs, boiler blowdown, and stormwater runoff. Process water is process wastewater that has been clarified and has then been returned to the process. All process wastewater generated at the Facility is combined and routed to clarifiers at the Facility. After the suspended solids in the water have settled, approximately 95 percent of the clarified water is recycled to the Facility for reuse as process water. On average, 205 million gallons per day (mgd) of process water is recycled to the Facility from the clarifiers. The process wastewater that is not recycled from the clarifiers (10.8 mgd on average) is directed to the Milepost 7 tailings disposal system. The tailings disposal system includes the tailings piping system, which carries process wastewater to the basin, the Milepost 7 tailings basin, a tailings water reclaim system, and the WWTP. The tailings basin receives process wastewater and precipitation from the surrounding watershed. To maintain a water balance within the tailings basin that will ensure the integrity of the basin dams, water from the basin is either recycled to the Facility for use as process water or is treated in the WWTP and discharged to the Beaver River in accordance with NPDES/SDS Permit No. MN 0055301 (NPDES/SDS Permit), which was reissued on January 26, 2004. On average, 11.5 mgd of water from the basin is recycled as process water to the Facility. In 2004, an average of 3.18 mgd of treated effluent was discharged to the Beaver River. Figure 2 is a map showing the Facility in relation to the tailings pipeline and the Milepost 7 tailings basin. II. PROPOSED PROJECT

Overview NSM is proposing to reactivate equipment that is permitted, but has been idle for more than twenty years. Potential air emissions associated with the project after installation of pollution control equipment will increase by over 100 tons per year for nitrogen oxides (NOx). It is the increase in potential air emissions for this pollutant that triggers the need for a mandatory EAW under Minn. R. 4410.4300, subp 15(A). In addition, this proposed project will require Prevention of Significant Deterioration (PSD) permitting and implementation of Best Available Control Technology (BACT) on reactivated equipment. The specific changes will include the following:

• Reactivating two fine crushing lines along with their corresponding existing permitted fabric filters;

• Reactivating nine concentrator sections and upgrading multiclones on all nine with fabric filters as the sections are reactivated;

• Replacing multiclones on all currently operating concentrator sections with new fabric filters;

• Constructing a concentrate handling system consisting of three conveyor belts and two concentrate storage silos;

• Reactivating pelletizing Furnace 5 along with three WWESPs for emission control;

• Rendering the Iron Nugget Pilot Demonstration Research and Development Plant inoperable;


• Expanding the Milepost 7 WWTP and its associated discharge to the Beaver River and

• Revising the effluent amphibole fiber limit.

The proposal is described in more detail below. Babbitt Mining Operations Crusher Number 1 has the capacity to crush 3,200 long tons of crude ore per hour. In 2004, Crusher Number 1 crushed 13.9 million long tons of crude ore. Actual particulate matter (PM) and particulate matter less than 10 um in size (PM10) emissions for 2004 are estimated to be 13.9 tons and 6.95 tons, respectively. The proposed project will increase the amount of crude ore to be crushed by approximately 33 percent and it is expected that there will be a corresponding increase in air emissions. However, the anticipated increase in production is well below the mine’s processing capacity and the proposed project will not require a modification of NSM–Babbitt Air Emission Permit No. 13700032. The crusher’s air emissions are now, and will continue to be, controlled by a fabric filter. Crusher Number 2 at the mine will not be reactivated as a result of this proposed project. Again, all of the following operations are part of the Facility in Silver Bay. All of the equipment to be reactivated is permitted, but has been idle for many years: Fine Ore Crushing The project proposal will reactivate two fine crushing lines at the Facility, along with their corresponding fabric filters which are already BACT. The crushers that are currently operating have the capacity to process a combined total of 4,200 long tons of ore per hour. The proposed project would increase the crushing to 5,600 long tons of ore per hour. Concentrator Sections The proposed project will reactivate nine concentrating sections and will also require some upgrade and repair of existing unit parts as necessary. The currently operating concentrator sections can produce 5 million long tons of concentrate per year. Reactivation of the nine concentrator sections will allow the Facility to produce up to 8 million long tons of concentrate per year. The concentrator sections will be reactivated on a staggered basis as dictated by economic demand. Existing multiclone emission control equipment will be upgraded with fabric filters prior to startup of any concentrator section to assure compliance with BACT and modeling-based emission limits. In addition, the proposed project will replace the existing multiclone control equipment with fabric filters on the concentrator sections that are already in operation. Concentrate Handling System The proposed project will add three conveyor belts and two concentrate storage silos for the purpose of storing concentrate to be sold. The storage silos will each have the capacity to store 1,500 long tons of concentrate. The silos will be approximately 80 feet in height and will be located behind the concentrator building (see Figure 3). Material transfers into and out of the silos are not expected to generate PM and PM10 emissions since concentrate contains 9 to 10 percent moisture; however, the project proposal entails equipping the new storage silos with fabric filter bin vents to control air flows within the silos. Pelletizing Furnace Furnace 5 will be reactivated as a part of this proposed project and may require additional upgrade and repair to parts of the furnace. It will operate in conjunction with Furnaces 6, 11, and 12, which are already in operation. The currently operating furnaces can produce approximately 6.7 million long tons per year of standard pellets. Reactivation of Furnace 5 will allow production of up to 8.1 million long


tons per year of standard pellets. Furnace 5 will be equipped with three WWESPs, which control PM, PM10, sulfur dioxide (SO2), and acid gas emissions before venting to the atmosphere.

Pelletizing Furnace Pellet Discharge When the finished taconite pellets leave the pelletizing furnace, PM and PM10 are emitted at the transfer point. The furnace discharge pellet transfer point is currently equipped with a rotoclone for particulate control and vents to the atmosphere. The project proposal will entail installing a wet scrubber as BACT for control of PM and PM10 emissions from this source. Iron Nugget Pilot Demonstration Research and Development Plant An iron nugget Pilot Demonstration Research and Development Plant is located on the site. It was constructed in an existing building for the purpose of testing the technology for creating iron nuggets, which are pellets containing greater than 90 percent iron. The project proposal will entail taking the Pilot Demonstration Research and Development Plant out of service. Power Plant The electricity usage rate is expected to increase by five to ten megawatts with the reactivation of Furnace 5 and the crushing and concentrating equipment. Currently, the power plant operates at full capacity and electricity not used by the Facility is sold on the grid. To accommodate the proposed project, the Facility will use more of the electricity that the power plant generates and sell less electricity for profit. Therefore, the project will not result in additional fuel combustion at the power plant, nor increased non-contact cooling water appropriation or discharge. If the power plant cannot supply the increased electricity demand, additional electricity will be purchased from the grid.

Wastewater and Tailings Disposal System The proposed project will reactivate Furnace 5, which is equipped with three WWESPs, and nine concentrator sections. There will be an increase in the amount of fine tailings in the wastewater that will be sent to the Milepost 7 wastewater and tailings disposal system, but the volume of water sent to the basin is not expected to increase proportionately because water used for the WWESPs will recirculate. Water is also expected to be consumed (as steam) with the Furnace 5 pelletizing process.

Currently, there is excess water in the tailings basin that needs to be removed to ensure adequate freeboard within the basin. This water is the result of precipitation received over the past 25 years in excess of the tailings basin design and because of lower-than-design production of taconite pellets. Since the capacity of the existing WWTP does not allow needed reduction of water within the basin, the proposed project entails expanding the capacity of the plant from 5.0 mgd to 7.5 mgd. The existing WWTP consists of chemical addition using four multimedia filter beds and related equipment. The proposed project would provide two additional dual media filtration units, giving the WWTP a total of six filtration units. The project proposal also includes a request to reassess the amphibole mineral fiber limit.

III. TIMING AND DURATION OF CONSTRUCTION Initially, NSM plans to restart pelletizing Furnace 5 and two concentrator sections during 2005. The remaining concentrator sections will be reactivated as necessary to accommodate possible future concentrate demand and to provide operational support for maintenance downtime on operating sections. Construction of the proposed concentrate handling system will begin within 18 months from the date the Air Emission Permit modification is issued and is expected to take approximately 6 to 9 months to complete.


Operation of the proposed project will emit air emissions and will create wastewater to be managed through the wastewater and tailings disposal system. Wastewater and tailings disposal is described in detail in Item 18 of this EAW. Air emissions are discussed in detail in Item 23 of this EAW.

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

for the project and identify its beneficiaries. NSM plans to utilize some of its permitted and currently idle taconite processing equipment to meet the growing demand in the taconite, iron, and steel industries.

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

If yes, briefly describe future stages, relationship to present project, timeline and plans for environmental review.

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

*The Facility has been in existence since the mid-1950s. Two other projects proposed in past years have required environmental review: Cyprus Northshore Mining Company, previous owner of the Facility, proposed to install a Direct Reduced Iron (DRI) process at the Facility in the early 1990s. The MPCA prepared an EAW for the project and issued a negative declaration on the need for an (EIS) for the project on May 25, 1993. Before the Air Emission Permit was issued, the project economics changed, and the company decided not to pursue the project. Several years ago, NSM proposed another DRI project, which differed in several respects from the proposal made in the early 1990s. Again, the MPCA prepared and public noticed an EAW for the project. Before the Findings of Fact was finalized, the project economics changed, and NSM decided not to pursue the project.

7. Project Magnitude Data Total Project Area (acres) Est. 0.2-0.4 acres* or Length (miles) Number of Residential Units: Unattached Attached maximum units per building Commercial/Industrial/Institutional Building Area (gross floor space): total square feet Indicate area of specific uses (in square feet): Office 5 acres (existing) Manufacturing Retail Other Industrial 550 acres (existing) Warehouse Institutional Light Industrial Agricultural Other Commercial (specify) Building height 100 ft. If over 2 stories, compare to heights of nearby buildings Car Dump 69 ft. Pelletizer East 89 ft. Crusher 62 ft. Pelletizer West 144 ft. Concentrator 84 - 102 ft. Power House 130 - 140 ft.

*The existing Facility includes approximately 550 acres of industrial complex and five acres of office area. The proposed project will be located entirely within the existing Facility compound. The concentrate silos will be the only units newly constructed and placed outdoors. Their construction is expected to require


the disturbance of an estimated 0.2-0.4 acres of pavement within the compound. The new concentrate silos will be 80 feet in height.

All other activities associated with the project proposal will occur within existing buildings, and the work will entail repair and upgrade of existing equipment so they will be suitable for reactivation.

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

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

Unit of Government Type of Application Status MPCA Air Emission Permit Modification application

submitted; draft permit currently on notice

MPCA NPDES/SDS Permit Modification application submitted; draft permit currently on notice

DNR Water Appropriations Permit No action required* *This permit is required to operate the existing Facility; however, the proposed project will not necessitate a modification to this permit.

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

Discuss project compatibility with adjacent and nearby land uses. Indicate whether any potential conflicts involve environmental matters. Identify any potential environmental hazards due to past site uses, such as soil contamination or abandoned storage tanks, or proximity to nearby hazardous liquid or gas pipelines. The Facility was constructed in the mid-1950s and has been used for the purpose of taconite processing since then. The Facility also includes a harbor for shipping activities. Most of the equipment to be reactivated is contained within existing buildings; only the concentrate silos will be newly constructed and placed outdoors. They will be sited within the existing Facility compound, so the proposed project will not require an expansion of the Facility footprint. The city of Silver Bay (City) has zoned the area as general industrial. The proposed project is consistent with this zoning. On adjacent lands, use and development are diversified and land is used for commercial, municipal, residential, recreational, and industrial purposes. Certain areas are also undeveloped at present. Highway 61 cuts through the Facility. The concentrating, pelletizing, and power plant operations are located east of Highway 61 and west of Lake Superior. The crude ore unloading and fine crushing operations are located to the west of Highway 61. Land west of the crude ore unloading and fine crushing operations is owned primarily by NSM and is undeveloped with the exception of the NSM railroad to Babbitt, the Milepost 7 tailings pipeline road, and the Milepost 7 tailings basin. Directly to the south of the Facility, the City maintains a picnic area with a public access boat landing and a marina on property owned by NSM. To the northwest is the commercial, recreational, and residential development of the City. To the northeast, the City has sited an industrial park and water and wastewater treatment facilities. In 2002 and 2003, a new motel complex was constructed in the industrial park area. Most of the City is located within one mile of some portion of the Facility. These land uses were zoned to be compatible with the industrial activities located nearby. The City indicates that they have not recently received complaints from nearby residences or businesses regarding the operation of the Facility. Review of MPCA databases revealed two permitted solid waste sites; two unpermitted solid waste sites; and one Resource Conservation and Recovery Act Treatment, Storage, and Disposal facility in the general vicinity of the Facility. Further review indicates that none of these sites lie within the proposed


construction area and they will not conflict with the proposed project in such a way as to cause potential environmental hazards.

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

Before After Before After Types 1-8 wetlands Lawn/landscaping Wooded/forest Impervious Surfaces 5.8 5.8 Brush/grassland Other (general

industrial) 550.0 550.0

Cropland TOTAL 555.8 555.8 11. Fish, Wildlife, and Ecologically Sensitive Resources. a. Identify fish and wildlife resources and habitats on or near the site and describe how they would be

affected by the project. Describe any measures to be taken to minimize or avoid impacts. The Facility compound itself offers little in wildlife habitat, consisting primarily of roadways, buildings, parking areas, and material storage. The tailings delta, breakwater, and Beaver Island in Lake Superior all have varying degrees of vegetative and tree cover. These areas offer some suitable habitat for wildlife. Small mammals, black bear, white tail deer, songbirds, and gulls are known to inhabit these and other outlying areas. Migratory waterfowl and raptors are occasionally observed in the delta area and other locations. Animals using these areas appear to be accustomed to the industrial activity that occurs on-site and the proposed project is not expected to significantly alter that level of activity. The proposed project will not physically encroach upon these habitats. The Facility is located on the north shore of Lake Superior, which supports recreational and commercial fishing industries for rainbow trout, lake trout, and king and coho salmon, among others. Water is appropriated from Lake Superior to serve as once-through, non-contact cooling water for the power plant. This non-contact cooling water is then discharged back to Lake Superior in accordance with the Facility’s NPDES/SDS Permit. Water appropriation from Lake Superior for the past 12 months has averaged about 130 mgd; the discharge of once-through non-contact cooling water back to Lake Superior has averaged 128.4 mgd. Though the temperature of the cooling water varies seasonally, it has averaged 47.5 degrees Fahrenheit for the past 12 month period. Because the power plant is already operating near full capacity, no change is expected in either the amount of water appropriated or in the amount of water discharged to Lake Superior when the proposed project is implemented. Additional water is also used in the power boiler and several descalants and rust inhibitors are added. These chemicals are identified and regulated (according to the maximum application rate listed for each chemical) in the current NPDES/SDS Permit for the Facility. Blowdown water from the power boiler potentially contains chemical residue and this blowdown water is routed to the tailings disposal system. The NPDES/SDS Permit requires that any proposed change or increase in chemical use must first be approved by MPCA staff. This condition will remain a requirement of the NPDES/SDS Permit after modification. It is important to distinguish non-contact cooling water from other water used in the power boiler: non-contact cooling water has not been treated with chemicals and is discharged to Lake Superior; process wastewater and boiler blowdown water potentially containing chemical residues is sent to the Milepost 7 tailings basin.

All wastewater from taconite processing, air pollution control equipment and site runoff are, and will continue to be, sent to the wastewater and tailings disposal system. As mentioned previously, treated


effluent is discharged from the Milepost 7 tailings basin to the Beaver River under conditions of the NPDES/SDS Permit. Detailed information on the WWTP and on the discharge of treated effluent to the Beaver River is provided in Item 18 of this EAW. Item 23 of this EAW describes numerous air analyses through which the proposed project was reviewed and discusses potential consequences to wildlife resources and habitats.

b. Are any state (endangered or threatened) species, rare plant communities or other sensitive ecological resources such as native prairie habitat, colonial waterbird nesting colonies or regionally rare plant communities on or near the site? Yes No

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

Research program has been contacted give the correspondence reference number. ERBD20050450 Describe measures to minimize or avoid adverse impacts.

The DNR’s Minnesota Natural Heritage and Nongame database has been reviewed to determine if any rare plant or animal species or other significant natural features are known to occur within an approximate one-mile radius of the proposed construction site. Based on this review, there is only one rare species that the DNR feels may be impacted by the proposed project. For the past few years, peregrine falcons have nested at various locations near the Facility’s harbor. To date, 15 young have fledged from these nest sites. The peregrine falcon is protected under the state’s Endangered Species Act and under the Migratory Bird Treaty Act of 1918. A person may not take, import, transport, or sell any portion of an endangered or threatened species and physical disturbance of the falcons’ nesting site is illegal. Nesting sites will not be physically disturbed by Facility staff and so concern about potential disturbance of the birds’ nesting activity centers on indirect impacts such as noise due to construction of the proposed project. DNR staff has recommended that construction activity be located at least 700 feet from an active nest and should ideally be kept as far as 1,500 feet from an active nest between February 1 and August 15. The concentrate handling system will be constructed roughly 1,000 feet from last year’s nesting site, so the proposed project would meet the DNR’s recommended minimum zone of protection if falcons nest near this area in the future; however, it would not meet the DNR’s recommended maximum zone of protection. Construction is expected to last approximately six to nine months, and so this activity will be temporary in nature. Operation of the proposed project will add to the noise already created by the existing Facility; however, most of the equipment is located indoors and the increase in noise heard outdoors is expected to be nominal. The falcons nesting at the Facility appear to have adapted to the industrial activity associated with the Facility’s operation. DNR staff does not believe that the proposed project, once construction has been completed, will have a long term effect on the peregrine falcon nesting activities. Correspondence from the DNR is attached as Figures 5 and 6.

12. Physical Impacts on Water Resources. Will the project involve the physical or hydrologic alteration (dredging, filling, stream diversion, outfall structure, diking, and impoundment) of any surface waters such as a lake, pond, wetland, stream or drainage ditch? Yes No If yes, identify water resource affected. Describe alternatives considered and proposed mitigation measures to minimize impacts. Give the DNR Protected Waters Inventory (PWI) number(s) if the water resources affected are on the PWI. NSM will deplete the mineable reserves in their Main and East Pits near Babbitt, Minnesota, by the end of 2004. In order to continue to meet its taconite production requirements, NSM is planning on extending the Main Pit by approximately 160 acres to the south and the East Pit by approximately 30 acres to the east and south. The mine progressions will result in the loss of approximately 90 acres of wetlands


adjacent to an unnamed tributary of the Dunka River, a tributary of Birch Lake. NSM has submitted a 404 permit application to the U.S. Army Corps of Engineers (USCOE) to grant permission to work within the wetlands, and the USCOE placed this permit on public notice on May 10, 2005; the comment period will end on June 9, 2005. According to NSM, these expansions would be necessary whether or not the proposed project described in this EAW proceeds, therefore the pit extensions are not considered to be a phased or connected action to the project proposal described in this EAW. However, since the 404 permit public notice period will overlap with the EAW public notice period, the above information is provided for clarification and to reduce confusion regarding these two separate processes.

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

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

14. Water-Related Land Use Management Districts. Does any part of the project involve a shoreland zoning district, a delineated 100-year flood plain, or a state or federally designated wild or scenic river land use district? Yes No If yes, identify the district and discuss project compatibility with district land use restrictions. The Facility is located within a shoreland zoning district and City staff indicate that the proposed project will be compatible with district land use restrictions. The proposed project will not increase the footprint of the Facility. The area is zoned industrial and the project appears to be consistent and compatible with the existing zoning restrictions, existing industrial operations and facilities, land uses, and the goals of projected local plans for future development.

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

Yes No If yes, indicate the current and projected watercraft usage and discuss any potential overcrowding or conflicts with other uses. Approximately 150 shiploads of pellets currently depart from the Facility’s Silver Bay dock from mid-April through December each year. It is estimated that the proposed project may result in an additional 30 to 40 ships per year entering and leaving the harbor during the 8 ½ month shipping season. The City’s Silver Bay Marina is located approximately one-half mile to the south of the Facility’s dock; the two docks are separated by a breakwater. Conversations that MPCA staff has had with City staff indicate that the City does not believe that the increased shipping levels from the Facility’s dock will create problems for users of the City’s Silver Bay Marina.

16. Erosion and Sedimentation. Give the acreage to be graded or excavated and the cubic yards of soil to be moved: ~0.2-0.4 acres; cubic yards. Describe any steep slopes or highly erodible soils and identify them on the site map. Describe any erosion and sedimentation control measures to be used during and after project construction.

The proposed project will require the disturbance of approximately 0.2-0.4 acres of pavement for the purpose of constructing the concentrate storage silos. Since the area to be disturbed is less than one acre, a NPDES General Permit for Construction Activities will not be needed. Once the silos are in place, the surrounding area will be re-paved.


All stormwater at the Facility is routed to an on-site retention pond. From there, water flows to the on-site clarifiers. A majority of the water in the clarifiers is recycled to the Facility; the remainder is a slurry containing sediment, and it flows through the tailings pipeline to the Milepost 7 tailings disposal system.

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

controls to manage or treat runoff. Describe any storm-water pollution prevention plans. The proposed project will involve construction of two new concentrate storage silos. They will be sited in an area that is currently paved; no new impervious surface will be created. Routing of stormwater at the Facility is as described in Item 16. The quantity or quality of runoff is not expected to change as a result of the proposed project.

b. Identify routes and receiving water bodies for runoff from the site; include major downstream water bodies as well as the immediate receiving waters. Estimate impact runoff on the quality of receiving waters. The only outdoor construction activities will be the construction of the new concentrate silos. They will be located in the central portion of the Facility compound. Routing of stormwater at the Facility is as described in Item 16. The change to the quantity and quality of runoff as a result of the proposed project is expected to be negligible.

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

produced or treated at the site.

Sanitary Wastewater Sanitary wastewater generated at the Facility is discharged to the City’s WWTP. The proposed project is expected to result in approximately 27 new jobs and an additional 540 gallons of sanitary wastewater per day. The municipal WWTP will be able to accommodate the increased sanitary wastewater without the need to expand or upgrade. Process Wastewater/Process Water All process wastewater generated at the Facility (which includes fine tailings in a slurry, blowdown from the furnace WWESPs, boiler blowdown, and Facility-area stormwater runoff) are combined and routed to four, 400-foot-diameter water clarifiers (approximate total holding capacity of 50 million gallons) that are located on site. The clarifier overflow is recycled through a common sump to the Facility as process water. Remaining process wastewater (containing the fine tailings and other sediment) is transported via pipeline to the Milepost 7 tailings disposal system for final settling and treatment. On average, 205 mgd of process water is recycled to the Facility from the clarifiers and 10.8 mgd of process wastewater is sent through the pipeline to the Milepost 7 tailings disposal system. The Milepost 7 tailings basin is located about 4 miles to the west of the Facility and is roughly 1,610 acres in size. The basin is contained by two main dams at the north and south ends of the basin and by a smaller dam on a portion of the east side. These dams are constructed of a mixture of coarse tailings material, dry cobb reject material, and belt filter sands and are transported to the basin by rail. Once at the basin, the aggregate material is moved by bulldozers, trucks, and scrapers to where it is needed. The dams include clay cores and seepage cutoff trenches of fine tailings to reduce seepage through the dams. At the foot of the dams are seepage recovery ponds that collect any water that seeps through the dams. Seepage collected by the seepage recovery pond is pumped back into


the main basin. Fine tailings from the Facility are pumped to the basin via a series of pipelines and are then spigotted at various locations around the basin perimeter. A reclaim dike that is composed of coarse tailings isolates a small portion of the tailings basin. The area within this reclaim dike is referred to as the reclaim water pond. Water from the main portion of the tailings basin flows over a weir in the reclaim dike and into the reclaim water pond where it is either recycled to the Facility as process water or is routed through a WWTP prior to discharge to the Beaver River. Water from the reclaim water pond is returned to the Facility for reuse as process water at an average rate of 10.8 mgd. Water in the reclaim water pond that is not returned as process water enters the WWTP and is treated by a four-cell dual media filtration bed system designed to reduce turbidity (tiny colloidal or suspended particles), suspended solids, and amphibole mineral fibers prior to discharge. The WWTP equipment has an average discharge design rate of 4.0 mgd and a maximum design discharge rate of 5.0 mgd. Between December 2003 and November 2004, an average of 3.2 mgd was actually treated and discharged to the Beaver River. The discharge to the Beaver River is regulated by NPDES/SDS Permit No. MN 0055301 (“NPDES/SDS Permit”), which was reissued on January 26, 2004. A modification application to this NPDES/SDS Permit was submitted on February 22, 2005. Figure 2 is a map that shows the tailings pipeline and a majority of the Milepost 7 tailings basin. Figure 7 is a layout plan showing existing Milepost 7 WWTP processes.

Table 1 provides the typical chemical composition of process water sent from the clarifiers back into the Facility process and of the treated process wastewater (effluent) discharged from the WWTP to the Beaver River. Item 18b describes expected changes to these parameters in more detail.

TABLE 1

Typical Chemical Analysis of Facility Process Waters and WWTP Effluent

Parameter Process Water (mg/L)

WWTP Effluent (mg/L)

Parameter

Process Water (mg/L)

WWTP Effluent (mg/L)

Calcium, mg/L 12 14.5 Cadmium <0.0002 <0.0002 Magnesium, mg/L 7.3 8.3 Lead, mg/L <0.001 <0.001 Sodium, mg/L 133 103.6 Cobalt, mg/L <0.001 <0.001 Potassium, mg/L 14 12.6 Chromium, mg/L <0.001 <0.001 Alkalinity, mg/L 190 198 Mercury 1.2 ng/L[1] <0.5 ng/L Sulfate, mg/L 55 50.1 Silver, mg/L <0.001 <0.001 Chloride, mg/L 65 75.3 Arsenic, mg/L <0.002 0.007 Fluoride, mg/L 18 12.4 Selenium, mg/L <0.003 <0.003 Silica, mg/L 7.3 8.7 Barium, mg/L 0.01 0.01 Iron, mg/L 0.09 0.18 Strontium, mg/L 0.158 0.108 Manganese, mg/L <0.01 0.07 Boron, mg/L 0.490 0.450 pH, units 9 7.4 Copper, mg/L <0.001 <0.003 Spec. Conductance, umhos/cm@25ºC

778 701.9 Nickel, mg/L <0.002 0.003

Color, units <5 <5 Zinc, mg/L <0.010 <0.010 [1] Natural Resources Research Institute, Mercury Emissions from the Taconite Pellet Production, September 1997 Report to the MPCA. mg/L = milligrams per liter

b. Describe waste treatment methods or pollution prevention efforts and give estimates of composition after treatment. Identify receiving waters, including major downstream water bodies, and estimate the discharge impact on the quality of receiving waters. If the project involves on-site sewage systems, discuss the suitability of site conditions for such systems.


Background Currently, there is excess water in the tailings basin that needs to be removed for dam safety and to ensure the basin can manage large storm events. This water is the result of precipitation received over the past 25 years in excess of the tailings basin design and because of lower-than-design production of taconite pellets. The proposed project entails expanding the WWTP’s capacity from a maximum design discharge rate of 5.0 mgd to a maximum design discharge rate of 7.5 mgd. The existing WWTP consists of chemical addition (ferric chloride) using four multimedia filter beds and related equipment. Backwash from the filter beds is routed to one of the seepage recovery ponds. The proposed project would provide two additional dual media filtration units, giving the WWTP a total of six filtration units. Figure 7 shows the layout and flow of the existing WWTP.

Effluent will be discharged through the existing outfall structure to the Beaver River, a tributary to Lake Superior. The Beaver River is a class 1B, 2A, 3B, 3C, 4A, 4B, 5, and 6 water and is designated an Outstanding International Resource Waters. Five miles downstream, the Beaver River enters Lake Superior, which is a class 1B, 2A, 3A, 3C, 4A, 4B, 5, and 6 water and is designated an Outstanding Resource Value Water. The designated use allows domestic consumption of the water after approved disinfection and also allows protection of aquatic life and recreation, industrial consumption, agriculture and wildlife, aesthetic enjoyment and navigation, and other uses. The Beaver River, from its headwaters down to Lake Superior, is listed on Minnesota’s 303(d) list of impaired waters for mercury, turbidity, and for high pH. Lake Superior is on the 303(d) list of impaired waters for mercury and polychlorinated biphenyls. The information below summarizes the MPCA’s review of the project proposer’s request for an NPDES/SDS Permit modification. This summary is not intended to completely capture all aspects of the review. A more detailed description of the MPCA’s review for the purpose of modifying the NPDES/SDS Permit can be found in the Fact Sheet for the draft NPDES/SDS Permit modification and in Attachment 4 to the Fact Sheet, both of which can be found on the MPCA’s Web site: http://www.pca.state.mn.us/hot/northshore-mining.html Nondegradation Review Determination Two provisions were used to determine if nondegradation review for the proposed project was required: 1. The proposed project entails restarting Furnace 5 and associated concentrators. Since the

existing NPDES/SDS Permit already covers the operation of this existing portion of the Facility, the proposed project will not increase existing production capability (i.e. existing capacity and processes). Consequently, the proposed project falls under the provisions of Minn. R. 7052.0310, subp. 5(A)(4) and, therefore, does not trigger a nondegradation demonstration for mercury.

2. The increase in the discharge flow rate is subject to the provisions of 40 CFR § 440.14(c)(2),

which allows the Facility to discharge the accumulated precipitation from the tailings basin. The authorization allowing the discharge of accumulated precipitation was included in the first NPDES/SDS Permit issued to the Facility in 1984 and has been included in subsequent permit reissuances. Since 1985, the highest volume of annual net precipitation received by the basin has been 3.16 billion gallons. If released on a constant daily basis for a year, as is currently the practice, the authorized discharge rate would be 8.64 mgd, and so this becomes the nondegradation design flow rate. Also, the concentration of mercury, fluoride, and fibers will remain the same or decrease within the range currently observed. Therefore, there will be no mass loading increase calculated from the baseline authorized discharge rate. The proposed flow increase to 7.5 mgd, which would be allowed under the modified permit, would not serve to trigger nondegradation. The proposal would serve to increase the rate of loading over the current discharge rate, but would remain less than the loading allowed at 8.64 mgd.

http://www.pca.state.mn.us/hot/northshore-mining.html


These two provisions indicate that mercury, fluoride, and fibers are not subject to a nondegradation review under either Minn. R. ch. 7050 or Minn. R. ch. 7052, because there is no mass increase above allowable loadings under these two provisions. Amphibole Mineral Fibers Overview The ore processed at the Facility contains amphibole minerals. When the ore is crushed, the amphibole minerals break along cleavage planes into tiny fiber particles. These amphibole mineral fibers (fibers) are also present in the coarse tailings and fine tailings slurry sent to the Milepost 7 tailings disposal system. An effluent fiber limit of 1 million total long fibers per liter (MF/L) determined by the MPCA based on the implementation of Best Available Technology (BAT), was set in the Facility’s NPDES/SDS Permit in the 1980s. The NPDES/SDS Permit also contains language (Chapter 11, Section 8.5 of the current permit) that states that if this limit is being exceeded and the MPCA determines that the exceedences are not the result of failure by NSM to operate or maintain the treatment system according to the Facilities Operation requirements, this determination shall be cause for modifying the effluent total long fiber limit.

Over the years, the effluent limits for turbidity, suspended solids, and amphibole fibers have been of great interest because the working assumption has been that keeping turbidity low will ensure a low fiber concentration in the discharged effluent. In actuality, though the treated effluent discharged to the Beaver River complies with the turbidity and Total Suspended Solids (TSS) limits and removes 99.9+ percent of the fibers, the discharge nevertheless has often exceeded the 1 MF/L effluent fiber limit. A comparison of turbidity and fiber trends within the basin indicates that although there is some general correlation, the two parameters do not strictly follow the same trends. The fiber concentrations tend to be variable: between January 2004 and March 2005 the effluent fiber concentrations ranged between <1 MF/L to >5 MF/L. NSM has contended that the current effluent fiber limit of 1 MF/L is unachievable. The project proposal includes a request to revise the fiber limit based on actual BAT performance data. Existing Conditions Water in the reclaim water pond is typically lower in turbidity, TSS, and fibers than water in the main part of the basin because the reclaim pond is segregated from the main basin where spigotting activities and wave action stir particles. Reclaim pond water must be maintained at a fairly high quality (i.e. containing low solids and fibers) for both plant processing purposes and for optimal operation of the WWTP. Recently, a v-notch weir (sometimes referred to as a ‘bypass weir’) was cut into the reclaim pond dike to increase the flow of water into the reclaim water pond. The quality of the water entering the reclaim water pond has diminished due, in part, to the installation of the v-notch weir. A few modifications have recently been made that seek to improve the quality of water entering the reclaim water pond. • Addition of ferric chloride at the reclaim pond weir has been ongoing since December 2003.

Overall, this has resulted in enhanced solids removal in the reclaim water pond, a better quality influent entering the WWTP, and satisfactory quality process water recycled to the Facility. However, influent water to the WWTP is still not of a quality to allow for optimized flow rates through the treatment plant, which ultimately adversely affects the water levels and water balance within the basin.

• In 2004, construction began on a splitter dike that will span most of the width of the tailings

basin. The splitter dike will split the tailings basin in two and is expected to reduce wave action and more evenly distribute tailings within the basin. The splitter dike is being constructed of fine tailings and coarse tailings discarded during the ore concentrating process. Construction of


the splitter dike is ongoing at this time and is expected to be complete in 2008 depending upon plant production, availability of coarse tailings, and dam safety requirements.

Though these changes are expected to increase particulate settling and reduce the turbidity of the water entering the reclaim water pond, the specific impact on influent to the WWTP and to effluent discharged to the Beaver River is uncertain.

Review of BAT to Determine Revised Amphibole Mineral Fiber Limit/Anti-Backsliding As a result of the project proposal, MPCA staff has reviewed actual performance data of BAT which has been operated and maintained properly for the WWTP. The MPCA has also considered the WWTP’s hydraulic loading, filter efficiency, process, and turbidity control changes made from the original plant design proposed in the 1980s and the recent changes begun at the Milepost 7 tailings basin described above. Based on a statistical analysis of effluent data, the MPCA has determined that an effluent fiber limit based on BAT would be 6.8 MF/L total amphibole fibers. Future performance will utilize continued operation of the WWTP to maintain BAT effluent turbidity limits, continued operation of filter dike bypass weir, continued addition of chemical flocculent addition at the bypass weir, and the re-construction of the splitter dike. The monitoring frequency will remain unchanged at one sample every other month (January, March, May, July, September, November). The MPCA has considered whether a revision of the fiber limit from 1 MF/L to 6.8 MF/L falls under the exception provisions for the state anti-backsliding rule (Minn. R. 7050.0212, subp. 3A) and finds that it does satisfy one of the criterion for exception to anti-backsliding regulations. With this, the NPDES/SDS Permit can be modified to include a revised effluent limit for total amphibole fibers of 6.8 MF/L. More information can be found on the anti-backsliding review in Attachment 4 to the Fact Sheet on the MPCA’s Web site: http://www.pca.state.mn.us/hot/northshore-mining.html Turbidity Turbidity is a measure of water clarity. The existing discharge fully complies with the Facility’s turbidity limits and is much less turbid than the receiving water. The proposed addition of two treatment units and resulting flows will provide additional low-turbidity water to the Beaver River. It will not contribute to the river’s turbidity impairment and may even provide a benefit through dilution. Fluoride, Sulfate, and Sodium Caustic soda (sodium hydroxide) is used to adjust the pH of the pellet furnace WWESP blowdown. Sodium carbonate is also used to control calcium and magnesium hardness. Fluoride is present in raw materials (i.e. limestone and ore) used in taconite processing and is emitted to the waste air stream when the pellets are indurated in the pelletizing furnaces. Some fluoride and sulfate is captured in the WWESPs, and thus the WWESP blowdown is a source of fluoride and sulfate to the tailings basin system. Fluoride The current NPDES/SDS Permit contains a compliance schedule for fluoride as a result of exceedences of the Facility’s 2.5 mg/L effluent fluoride limit. As part of that compliance schedule, a fluoride pretreatment system that will reduce fluoride in water sent to the Milepost 7 basin was installed and began operation in November 2004. The available monitoring data show that the pretreatment system is removing an average of 80-90 percent of the fluoride in the water before it is sent to the clarifiers. The waste fluoride sludge generated by the fluoride removal pretreatment system is not hazardous and is disposed of in NSM’s permitted industrial solid waste land disposal facility (Solid Waste Permit No. SW-409). To ensure that continued progress is made towards reducing fluoride concentrations in the basin, additional requirements have been added to the modified NPDES/SDS Permit. The treated effluent



must demonstrate compliance with an intermediate monthly average effluent fluoride limit of 4.8 mg/L within five years of the issuance of the NPDES/SDS Permit modification. If an evaluation of the basin’s fluoride concentration completed prior to submittal of an application for permit reissuance indicates that the discharge is not on schedule to comply with the intermediate fluoride limits, the Facility will be required to include a request for a variance from the fluoride limit with the application for NPDES/SDS permit reissuance. These additional requirements will verify that reasonable progress is being made to reduce fluoride in the Milepost 7 basin. Though the pretreatment system is demonstrating desired removal efficiencies, it will take years for reductions achieved by the pretreatment system to be fully realized in the fluoride concentration of water in the Milepost 7 tailings basin and in the discharge to the Beaver River. The additional two treatment units at the WWTP and resulting expanded discharge from the basin is expected to help turn the basin water over more quickly. With reactivation of all idled units and the pretreatment system in place, the discharge is expected to comply with the fluoride limit within 20-25 years. The expanded discharge is expected to reduce this timeframe to 13-15 years. Sulfate Currently, the sulfate concentration of water within the Milepost 7 basin is at a sufficiently low level where there is no need for an effluent sulfate limit. The proposed project will reactivate three WWESPs, so more sulfate will be produced. The pretreatment system was installed in 2004 primarily to remove fluoride, but it also removes sulfate. The pretreatment system’s removal of sulfate is sufficient to offset increases that may be realized with the reactivation of the additional WWESPs. The concentration of sulfate within the basin is expected to remain steady or to decline (due to the expanded discharge) after the proposed project has become operational. Effluent sulfate monitoring is, and will continue to be, required by the NPDES/SDS Permit. Sodium Water in the Milepost 7 basin contains sodium and since the proposed project will result in an increased use of caustic soda, the sodium concentration within the basin is also expected to increase. Though effluent sodium monitoring is already required, there are not enough data to determine if sodium concentrations, once diluted in the receiving water, will have a reasonable potential to violate the water quality standard. A requirement for quarterly instream monitoring will be added to the modified NPDES/SDS Permit. The data compiled will be assessed with the next NPDES/SDS Permit reissuance to determine if an effluent sodium limit is needed. pH In recent years, the pH of the discharge has remained within the acceptable range contained in the NPDES/SDS Permit (6.5-8.5). As mentioned previously, the Beaver River is listed as impaired for high pH. As long as the discharged effluent from the Milepost 7 basin remains within the acceptable pH, the expanded discharge will not contribute to the river’s impairment. Mercury The majority of mercury associated with the Facility is contained within the ore that the Facility processes and is, therefore, present in the tailings slurry sent to the Milepost 7 tailings disposal system. A 1999 mercury mass balance study for the Facility found that an estimated 99.6 percent of the mercury input to the tailings basin is bound to the fine tailings particles and is permanently trapped in the basin. The Great Lakes Initiative (Minn. R. 7052) water quality standard for mercury is 1.3 nanograms per liter (ng/L). Though no effluent mercury limit has been incorporated into the NPDES/SDS Permit, the Facility does monitor the effluent for low-level mercury. Monitoring data from the past year show that treated effluent discharged to the Beaver River contains less than 0.6 ng/L of mercury and is well below the mercury water quality standard.


The proposed project will increase the amount of water discharged from the basin, but due to research that demonstrates that mercury is strongly attached to the particles in the basin, there is no reasonable potential that mercury concentrations will exceed the 1.3 ng/L mercury water quality standard. Monitoring for low-level mercury is, and will continue to be, required for this Facility to ensure the treated effluent does not exceed the mercury water quality standard. A discussion of mercury emitted to the air from the pelletizing furnaces and from the power plant is included in Item 23 of this EAW.

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

pretreatment provisions and discuss the facility’s ability to handle the volume and composition of wastes, identifying any improvements necessary. Sanitary wastewater will continue to be directed to the City’s WWTP, which will not need to expand to manage the additional flow resulting from the proposed project.

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

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

19. Geologic Hazards and Soil Conditions. a. Approximate depth (in feet) to Ground water: N/A minimum; N/A average. Bedrock: 0 minimum; 0 average. Describe any of the following geologic site hazards to ground water and also identify them on the site

map: sinkholes, shallow limestone formations or karst conditions. Describe measures to avoid or minimize environmental problems due to any of these hazards. There are no geologic site hazards to ground water (i.e., no sinkholes, shallow limestone formations, or karst conditions). Soils in this area are thin and are underlain with bedrock.

b. Describe the soils on the site, giving SCS classifications, if known. Discuss soil granularity and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils. Discuss any mitigation measures to prevent such contamination. Soils are shallow over bedrock, consisting of loamy clay or clay soils associated with the Lake Superior basin. Due to the absorption capacity of loamy and clay soils, small amounts of wastes or materials spread or spilled on the soils would likely be absorbed and not move a significant distance. Large spills have the potential for concern since the bedrock is so close to the surface. Tanks and their concrete containment structures are checked monthly for cracks or deterioration. The Facility has a Spill Prevention, Control, and Countermeasures Plan and a Facility Response Plan that is being implemented to provide containment and emergency response plans for any wastes or chemicals that may be spilled.

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

manure, sludge and ash, produced during construction and operation. Identify method and location of disposal. For projects generating municipal solid waste, indicate if there is a source separation plan; describe how the project will be modified for recycling. If hazardous waste is generated, indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments.


Coarse Tailings and Fine Tailings Approximately 30 percent of the iron ore crushed is processed into iron concentrate; the remainder includes various sizes of coarse tailings and fine tailings that are sent to the wastewater and Milepost 7 tailings disposal system. Larger coarse aggregate tailings are used for dam construction at the tailings basin; the finer material arrives at the tailings basin in a slurry form. The Milepost 7 tailings basin was designed in the late 1970s (actual disposal began in June 1980) to accommodate 18 to 20 million tons of coarse and fine tailings per year. It is anticipated that the basin will have capacity for tailings for the next 50 years (this estimate includes consideration of tailings resulting from the proposed project).

The current NPDES/SDS Permit for the tailings basin is based on a maximum concentrate production of 8 million long tons per year. The estimated amount of material to be sent to the Milepost 7 tailings basin is shown below:

TABLE 2 Tailings Projections

Fine Tailings (MLT/Y) Coarse Tailings (MLT/Y) 2004 5.8 2.9 2005 6.3 3.3 2006 8.2 4.3 2007 9.6 5.0

MLT/Y = Million Long Tons per Year These numbers are maximum values and are valid only if all phases of proposed reactivations described in this EAW are actually implemented. Other Wastes Hazardous and non-hazardous wastes are currently generated at the Facility and will increase to a minor degree with the proposed project. They include used oil, greases, solvents, batteries, fluorescent lights, oil filters, and coal ash. Existing programs at the Facility address these waste streams as follows: • Used oils generated at the Facility are, and will continue to be, collected and shipped to the

mine in Babbitt for burning in a permitted waste oil boiler for energy recovery purposes or shipped to an approved energy recovery facility.

• All waste greases and solvents are recycled to the maximum extent possible. When recycling is not practical (i.e. contaminated with rock) or the waste is non-hazardous, waste grease and solvents are shipped to licensed fuel blenders for energy recovery.

• Paper wastes are recycled to the maximum extent practical. • Spent batteries are recycled through purchase agreement with vendors or through approved

battery recyclers. • Fluorescent light bulbs, currently regulated in Minnesota, are collected for recycling through

approved recycling facilities. • Oil filters are collected for shipment to reclaim/recycling facilities. • Fly ash, bottom ash, and pyritic coal fines from the burning of coal in the power plant are

disposed of in a permitted industrial landfill. To the maximum extent possible, fly ash is marketed as a useable by product for the production of concrete.

• The waste fluoride sludge generated by the fluoride/sulfate removal pretreatment system is not hazardous and is disposed of in NSM’s permitted industrial solid waste land disposal facility (Solid Waste Permit No. SW-409).

• Waste tires are recycled.


• Scrap metal is recycled. • General refuse is handled through local refuse contractors.

b. Identify any toxic or hazardous materials to be used or present at the site and identify measures to be

used to prevent them from contaminating ground water. If the use of toxic or hazardous materials will lead to a regulated waste, discharge or emission, discuss any alternatives considered to minimize or eliminate the waste, discharge or emission. Hazardous materials such as caustic soda and acetic acid are used at the Facility. Safeguards (i.e. containment berms and structures) are built into the existing storage systems.

c. Indicate the number, location, size and use of any above or below ground tanks to store petroleum products or other materials, except water. Describe any emergency response containment plans. The proposed project will not involve the installation of above-, or below-ground storage tanks. The Facility currently has above-ground storage tanks for petroleum products and chemicals used in existing operations. A listing of these tanks is found in Tables 3 and 4 below.

TABLE 3 Active Above-Ground Storage Tanks

Tank No.

Location Capacity (gal) Product

7 Truck Dump – S. of Pellet Plant 47,600 No. 2 Fuel oil 12 S. of Power Plant 40,000 No. 2 Fuel oil 14 Reagent Building 20,000 Amine 15 Reagent Building 20,000 Amine 16 Reagent Building 6,000 Acetic acid 17 Reagent Building 30,000 Flotation reagent 18 Reagent Building 30,000 Flotation reagent 19 Reagent Building 20,000 Flocculent 20 Reagent Building 20,000 Flocculent 33 S. Car Dump – R.R. Area 20,000 Calcium chloride 00 Silver Bay Plant 20,000 Coherex

Fuel Oil Tanks Tank Numbers 7 and 12 are used to store number 2 fuel oil, which is either used for heating purposes or as a fuel backup to systems in the power plant and pellet plant that primarily use natural gas. These tanks have secondary containment systems. Leak detection is accomplished by inventory control and monitoring carried out by staff on a routine schedule. Amines, Acetic Acid, Flotation Reagent, Frother and Flocculent Tanks 14, 15, 16, 17, 18, 19, and 20 are used to store chemicals used in the Facility. The amines and acetic acid are mixed with each other and water to provide the flotation reagent used in the concentrator to produce a low silica concentrate. This flotation reagent and the frother are completely consumed in the flotation process, which takes place in the concentrator sections. The flocculent is used to clarify process wastewaters prior to recycling to the Facility and is also consumed in the process. The tanks have secondary containment and leak detection systems. Calcium Chloride Tank 33 contains calcium chloride. It is used as required to spray ore and ore car surfaces to prevent ore from freezing in railroad cars when in transit between the mine in Babbitt and the Facility during the winter and for dust control. The tank has secondary containment.


Coherex Tank 00 contains Coherex. This material is used for dust control on roads, parking lots, and coarse aggregate.

TABLE 4

Underground Storage Tanks Tank No.

Location Capacity (gal) Product

035 R.R. Loadout 15,000 Coherex 301 Reagent Building 15,000 Frother

Tank 035 has been used historically for the storage of the chemical stabilizer used for fugitive emission controls at the Facility. Tank 301 is used to store a frother for use in the flotation process. Tanks and their concrete containment structures are checked monthly for cracks or deterioration. The Facility has a Spill Prevention, Control, and Countermeasures Plan and a Facility Response Plan that is being implemented to provide containment and emergency response plans for any wastes or chemicals spilled.

21. Traffic. Parking spaces added: 0 Existing spaces (if project involves expansion): 300-400 Estimated total average daily traffic generated: 27 Estimated maximum peak hour traffic generated (if known) and its timing: Staggered Provide an estimate of the impact on traffic congestion affected roads and describe any traffic improvements necessary. If the project is within the

Twin Cities metropolitan area, discuss its impact on the regional transportation system. There are controlled accesses into and out of the Facility, and there are no traffic congestion issues currently. Approximately 410 persons are currently employed at the Facility. The proposed project would add 27 jobs—a 7 percent increase over current levels—to the workforce during 2005, distributed over three shifts. The Minnesota Department of Transportation (MNDOT) is planning on upgrading the portion of Highway 61 from the Facility’s entrance gate up to Illgen City in the near future. Though the project proposal will increase the number of staff coming and leaving the Facility, the increase will be small and starting and quitting times for personnel are staggered depending on operational needs. Raw materials used in the Facility’s process largely arrive by rail and finished product is expected to be shipped by rail or from the Facility’s harbor. It is possible that concentrate may need to be shipped by truck for a period of time (estimated between 6-12 months) until appropriate rail loading/unloading facilities are constructed at the buyer’s facility. Trucks containing concentrate would add more traffic for a short stretch of Highway 61, but as mentioned, this shipment method would be temporary. The proposer is willing to work with MNDOT and the City to ensure that any inconvenience caused by temporary truck shipping will be kept to a minimum. The proposed project is not expected to result in long-term traffic congestion on Highway 61. Under certain weather conditions, the steam plumes from the pelletizing furnace WWESP stacks can combine with fog or high moisture conditions from Lake Superior blowing across Highway 61 towards the west and create poor visibility for drivers. An electronic sign warns travelers of adverse road conditions when this occurs. The proposed project will reactivate three WWESP stacks and the steam from their stacks can be expected to contribute to the occasional foggy weather effect from Lake Superior; however, the additional plumes are not expected to increase the incidence of adverse visibility conditions.

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


There will be only a minimal increase in the number of new personnel at the Facility after the proposed project is in operation. Therefore, the potential impact to traffic-related air emissions is expected to be insignificant.

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

emissions from stationary sources of air emissions such as boilers, exhaust stacks or fugitive dust sources. Include any hazardous air pollutants (consult EAW Guidelines for a listing), any greenhouse gases (such as carbon dioxide, methane, and nitrous oxides), and ozone-depleting chemicals (chlorofluorocarbons, hydrofluorocarbons, perfluorocarbons or sulfur hexafluoride). Also describe any proposed pollution prevention techniques and proposed air pollution control devices. Describe the impacts on air quality. Sources of Air Emissions and Pollution Control Equipment The following is a summary of air emission sources and emission control equipment at the Facility. Item 6b of the EAW includes a description of the process steps. The Facility operates in accordance with requirements listed in the Air Emission Permit, issued by the MPCA. This permit will require modification as a result of the proposed project.

Fine Ore Crushing and Dry Cobbing. Ore receiving, conveying, crushing, and dry cobbing produce PM and PM10 emissions. Emissions are controlled by baghouses. Concentrate Production. The ore transfer points are equipped with multiclones to control PM and PM10 emissions. The multiclones will be replaced by fabric filters to enhance PM and PM10 emission control. In the remainder of the ore concentration processing steps, the ore is wet and there are no air emissions from these operations. Pellet Production. The pelletizing furnaces emit carbon monoxide (CO), NOx, PM, PM10, SO2, volatile organic compounds (VOCs), mercury, other metals, and organic compounds. These furnaces are equipped with WWESPs, which control PM, PM10, SO2 emissions and acid gases. PM and PM10 emissions from material handling processes downstream of the furnaces are controlled by wet control devices, by screening fines from the product, and by wetting the product with water. Product Storage and Loadout. Air emissions from these operations include pellet handling PM and PM10 emissions. PM and PM10 emissions from pellet handling operations are currently controlled by wetting the pellets with water, application of chemical dust suppressants, and screening fines from the pellets. Power Plant. Wastes from the power plant include a small amount of boiler blowdown, boiler flue gas, and coal ash. Fly ash, bottom ash, and pyritic coal fines from the burning of coal in the power plant are disposed of at NSM’s permitted industrial solid waste land disposal facility (Solid Waste Permit No. SW-409). To the maximum extent possible, fly ash is marketed as a useable byproduct for the production of concrete and only the remainder is landfilled. The boilers emit CO, NOx, PM, PM10, SO2, VOC, mercury, other metals, and organic compounds. Fabric filters control the PM and PM10 and associated metals emissions. Raw Materials Management. PM and PM10 emissions from pellet binders and other materials stored indoors are controlled by fabric filters. Materials stored in the storage yard can produce fugitive PM and PM10 emissions. Fugitive PM and PM10 are controlled by water sprays, screening, and using chemical stabilizers. Air Quality Analysis Overview A proposed project may initially be reviewed, in part, by examining ‘potential’ air emissions, which are the air emissions expected when the equipment is operating 24 hours a day, 7 days a week, and 365 days a year without using control equipment and in the absence of any rule-, or permit-based limitations. Since


facilities rarely operate under these conditions, actual air emissions are typically much lower. Here, the potential additional air emissions associated with the project, reflecting emission limits and the operation of pollution control equipment, will increase by over 100 tons per year for NOx. It is the increase in potential air emissions for this pollutant that triggers the need for a mandatory EAW under Minn. R. 4410.4300, subp 15(A). Estimated potential criteria pollutant air emissions reflecting emission limits and the operation of pollution control equipment for the Facility are shown in Table 5:

TABLE 5 Facility Air Emissions in Tons per Year (TPY)

Pollutant Total Post-Project Potential Emissions

2004 Total Actual Emissions

Anticipated Post-Project Total Actual Emissions

CO 729 381 434 NOx 7,097 4,091 4,280 Lead 0.20 0.19 0.06 PM 1,719 1,084 1,142

PM10 1,644 982 1,037 SO2 9,095 2,797 2,818

VOCs 72 24 34

For determining applicability of Prevention of Significant Deterioration (PSD) permitting, the project emissions of the new or modified units after installation of pollution control equipment have been calculated as shown in Table 6. The emissions surpass PSD major modification thresholds for SO2, NOx, PM, and PM10.

TABLE 6 PSD Review Determination

Pollutant Potential Emissions, After Control (TPY)

PSD Significant Thresholds for Major

Sources (TPY)

PSD Review

Required? CO 56 100 No NOx 200 40 Yes PM 149 25 Yes

PM10 149 15 Yes SO2 56 40 Yes

VOCs 10 40 No A major modification subject to PSD review is required to ensure that Best Available Control Technology (BACT) is used for each pollutant for which there is a significant net emissions increase. BACT is the maximum degree of emission reduction that can be achieved when determined on a case-by-case basis, taking into account energy and environmental and economic impacts. The Facility, with the proposed project factored in, has undergone air impact evaluations for ambient air quality standards, Class I and II PSD increment consumption, Air Quality Related Values (AQRVs – flora/fauna, acid deposition, and visibility) and an Air Risk Analysis. The evaluations are summarized below. Ambient Air Quality Standards The U.S. Environmental Protection Agency (USEPA) and the State of Minnesota have established National and Minnesota Ambient Air Quality Standards (NAAQS and MAAQS, respectively), which are


not to be exceeded. These standards are designed to be protective of public health and the environment. As part of the air quality permit application, an air dispersion modeling assessment has been completed to determine compliance with the NAAQS and MAAQS. Air dispersion modeling is the primary predictive tool used by regulatory agencies for evaluating air impacts from facilities that are being modified. Air dispersion modeling uses comprehensive facility information (emission rate, stack height, stack diameter, and stack gas temperature and velocity) coupled with representative meteorological data (such as temperature, wind direction, and wind speed) to predict ambient air concentrations at and beyond the Facility boundary. Ambient air monitoring commenced at the Facility during 1990. Ambient monitoring for total suspended particulate (TSP), PM10, nitrogen dioxide (NO2), and SO2 was initiated at that time to monitor compliance with NAAQS and MAAQS for those pollutants and to provide the on-site monitoring data necessary to conduct a Model Evaluation Study (MES). TSP and PM10 ambient monitoring continue today. The MES was designed to evaluate the applicability of standard USEPA modeling techniques given the Facility’s location on the north shore of Lake Superior in an area of complex terrain. The MES was completed in late 1995 and resulted in the development of a “Site Specific Model.” The modeling for this project proposal was completed using the site specific model (a modified version of Industrial Source Complex Short-Term Model, version 2) and Industrial Source Complex Short-Term Model, version 3. The USEPA has approved this modeling methodology. The current monitoring program at the Facility consists of eight monitors placed at five distinct stations. Four monitors measure ambient TSP and four monitors measure PM10. At two stations, PM10 and TSP monitors are co-located and at one station, two PM10 monitors are co-located for quality control purposes. The five stations are located as follows: • Northeast of the Facility at the Silver Bay Municipal Wastewater Treatment Facility (Station T13) • North of the Facility on the corner of Highway 61 and Outer Drive (Station NM18/T18) • Northwest of the Facility, between Northshore and Silver Bay (Station NM7/T7) • South of the Facility just beyond the pellet storage yard (Station NM10/NM10A) • Southwest of the Facility in East Beaver Bay (Station T12) Figure 8 shows the locations of the ambient air monitoring stations. TSP monitoring did identify ambient air violations in 1999, 2000, 2001, 2002, and 2003 that were cited in stipulation agreements finalized in 2000 and 2003. One on-site monitor detecting the most violations had been placed off of U.S. Highway 61, on NSM property, and was screened from public access by a fence. MPCA staff determined that monitoring data from this station wasn’t representative of ambient air quality where public exposure would occur and in 2003 the monitor was moved. There have been no ambient air exceedences since April 2003. The air dispersion modeling completed to assess the proposed project showed that no criteria pollutant ambient air quality standards would be violated by the reactivation of the units described in this EAW. Class II PSD Increment Analysis The Facility is a major source of air pollution with respect to PSD, and the proposed project represents a major modification of the Facility. Therefore, a PSD increment review was required. The federal PSD regulations include an “increment consumption” program that places a ceiling on the total amount of “new” air pollution allowed resulting from new sources to prevent significant deterioration of air quality. The federal regulations have identified different increments for different class areas. Class I areas are designated as having outstanding quality that is to be protected and they include national parks, wilderness areas, and other specially designated areas. A discussion of the analysis of Class I areas is provided below under the heading ‘Class I PSD Increment’. Class II areas essentially comprise all areas in the country that are not classified as Class I. The PSD increment analysis for Class II areas applies to three criteria pollutants: SO2, NO2, and PM10. Once a baseline date is established, all new sources of that pollutant


combined are not allowed to exceed the PSD increment as determined by a dispersion modeling analysis. Table 7 identifies the various standards and the modeled results for both the ambient air quality analysis and the Class II PSD increment analysis. Three modeling scenarios (A, B and C) were assessed. Footnotes to the table explain the details of these scenarios. The analysis shows that the Facility, after implementation of the proposed project, will not exceed allowable increment consumption.

TABLE 7

Ambient Air Quality and Class II PSD Increment Standards and the Modeled Results Pollutant

Averaging

Time

Category

Modeled Impact [1] (µg/m3)

Standard (µg/m3)

1-Hour

MAAQS

995

1300

MAAQS

712

915

Primary/Secondary NAAQS

712

1300

3-Hour

PSD Increment/Class II

13

512


235

365

24-Hour

PSD Class II Increment

6

91

Primary NAAQS

20

80

Secondary NAAQS

20

60

SO2

Annual


0.5

20


33

100

NO2

Annual


10

25

A[2]


145

150

B[3]


144

150

C[4]


146

150

A


9

30

B


8

30

24-Hour

C


11

30

A


29

50

B


28

50

C


28

50

A


0.1

17

B


0.1

17

PM10

A n n u a l

C


0.1

17


MAAQS

91

35,000

1-Hour

Primary NAAQS

91

40,000

CO

8-Hour

Primary NAAQS

46

10,000

[1] Modeled impact values include the respective background air concentration for comparison to the NAAQS and MAAQS.

[2] Modeling scenario whereby the five dry cobbing stacks were raised by five meters each and all concentrator emissions left as proposed.

[3] Modeling scenario whereby the dry cobbing stacks were left at their current height and the number of concentrator stacks reduced by five by venting indoors through post filters.

[4] Interim modification phase (timing of upgrades to fabric filters on concentrators relative to Furnace 5 re-start).

µg/m3 = microgram per cubic meter Class I Area Analyses The Clean Air Act requires that potential impacts to AQRVs (foliage, acid deposition, and visibility) and increment consumption be reviewed for all major sources potentially affecting Class I areas. Four Class I areas have been evaluated for Class I increment consumption and for impacts to AQRVs resulting from the proposed project. The Boundary Waters Canoe Area Wilderness (BWCAW, 33 miles to the north) and the Rainbow Lakes Wilderness (57 miles to the south) fall under the jurisdiction of the U.S. Department of Agriculture (U.S. Forest Service). The other two areas, Isle Royale National Park (101 miles to the northeast) and Voyageurs National Park (93 miles to the northwest), fall under the jurisdiction of the U.S. Department of the Interior (National Park Service and Fish and Wildlife Service). Figure 9 shows the locations of the four Class I areas in relation to the Facility.

The CALPUFF modeling system was used to evaluate potential Class I increment and AQRV impacts. The Federal Land Managers have reviewed the modeling protocol and the modeling results. The discussion below summarizes the findings of the Class I area analyses; this summary is not intended to completely capture all detailed aspects of the analyses. For more information, interested parties can visit the MPCA’s Web site at http://www.pca.state.mn.us/hot/northshore-mining.html and view the report titled ‘Class I Areas Analysis’. Class I PSD Increment. As mentioned previously, in an effort to prevent significant deterioration of air quality in locations that are achieving the NAAQS, the USEPA uses increments (Class I and Class II) to define how much additional air pollution can be added to an area. Due to the desire to protect the high quality of Class I areas, applicable Class I increments are lower than the Class II increments. The model-generated atmospheric concentrations of SO2, PM10, and NO2 were compared to the PSD Class I increment[1] and the USEPA Significant Impact Level (SIL)[2]. The SILs are used by USEPA and other regulatory agencies as a decision threshold and are set at 4 percent of the Class I area increment. USEPA’s working assumption is that as long as no individual source contribution exceeds 4 percent of a Class I increment, it is unlikely that the accumulation of sources over time will exceed that increment. A comparison of the maximum CALPUFF-generated pollutant concentrations for various averaging times in the four Class I areas to the PSD increments and SILs is provided in Table 8. The results indicate that all of the maximum pollutant concentrations are below the corresponding SILs and PSD Class I increments. Therefore, the emissions associated with the proposed project are not expected to deteriorate

1 40 CFR 52.21 2 USEPA. 1996. Prevention of Significant Deterioration (PSD) and Nonattainment New Sources Review (NSR). Federal Register: July 23, 1996, Volume 61, Number 142. Proposed Rules. Pp. 38249-38344.



the air quality significantly in the four modeled Class I areas and the Federal Land Managers have not requested additional analyses.

TABLE 8 Comparison of modeled maximum air concentrations for SO2, NO2, and PM10 to the PSD Class I

Increments and USEPA SILs

Pollutant

Averaging Period

PSD

Class I Increment

(µg/m3)

USEPA

SIL (µg/m3)

BWCAW (µg/m3)

Voyageurs National

Park (µg/m3)

Isle Royale

National Park

(µg/m3)

Rainbow Lake Area

Wilderness (µg/m3)

3-Hour

25

1.0 0.251 0.024 0.021 0.039

24-Hour 5 0.2 0.070 0.006 0.007 0.014

SO2

Annual 2 0.1

0.003

0.000

0.001

0.001

24-Hour 8 0.3 0.294 0.044 0.101 0.107 PM10 Annual 4 0.2

0.012

0.001

0.005

0.003

NO2 Annual 2.5 0.1

0.008

0.001

0.003

0.002

µg/m3 = micrograms per cubic meter Foliage Impacts. Adverse effects to foliage (plants) and fauna (animals) are generally accepted to mean any changes in growth, reproduction, mortality, and diversity of native plant and animal species caused by human activities. In evaluating potential adverse effects to flora and fauna, lichen species are generally used as a “threshold” indicator of potential air pollution damage because they are especially susceptible to air pollution and show adverse effects before other plant and animal species. According to U.S. Forest Service guidance, if pollutant concentrations in a Class I area are sufficiently low that no damage occurs to native lichens, then it can reasonably be concluded that all other flora and fauna species are protected. The U.S. Forest Service has developed green-line thresholds for atmospheric concentrations of SO2 for the protection of lichens and sensitive trees[3]. The three-hour and annual time-averaged SO2 green-line concentrations are 100 and 5 µg/m3, respectively. A comparison of the modeled maximum SO2 concentrations for the BWCAW and the Rainbow Lakes Wilderness to the U.S. Forest Service’s “green-line” SO2 concentrations is provided in Table 9. The modeled results for both wildernesses are small compared to the green-line concentrations and the background concentrations. When the modeled maximum concentrations are added to the background SO2 concentrations, the resulting combined concentrations are again below the green-line SO2 concentrations. Since the green-line SO2 concentrations are not exceeded, the modeling results suggest that no adverse effects on lichens or tree foliage are expected from the proposed project. The Federal Land Managers believe it is unlikely that foliage in either of the Class I Areas would be directly damaged by emissions from this project.

3 Adams M. G., et al. 1991. Screening Procedure to Evaluate Effects of Air Pollution on Eastern Region Wildernesses Cited as Class I Air Quality Areas. USDA, Forest Service, Northeastern Forest Experimental Station, General Technical Report NE-151. 4FLAG, 2000. Federal Land Managers' Air Quality Related Values Workgroup (FLAG). Phase I Report. U.S. Forest Service - Air Quality Program; National Park Service - Air Resources Division; U.S. Fish and Wildlife Service - Air Quality Branch. December 2000. 5 National Park Service and U.S. Fish and Wildlife Service. 2002. Guidance on Nitrogen and Sulfur Deposition Analysis Thresholds. 7 pg.


The National Parks do not have a screening threshold for potential impacts to foliage. Ozone monitoring has revealed no foliar damage in Voyageurs National Park or Isle Royale National Park, and the respective websites for each park did not identify ozone as a pollutant adversely impacting AQRVs when information was reviewed in September 2004. US EPA and the Federal Land Managers agree that modeling a single source for ozone impacts is not feasible at this time[4].

TABLE 9 Comparison of modeled atmospheric SO2 concentrations for the BWCAW and the Rainbow Lakes

Wilderness to the U.S. Forest Service “green-line” SO2 concentrations

Area

Averaging

Time

Green-Line SO2 Concentration

(µg/m3)[1]

Modeled Maximum SO2 Concentration

(µg/m3)

Background SO2

Concentration (µg/m3)

Combined SO2

Concentration (µg/m3)

3-Hour

100

0.251

10.8

11.05

BWCAW Annual 5

0.003 1.2 1.20

3-Hour 100 0.039 14.4 14.44 Rainbow Lakes

Annual 5

0.001 1.6 1.60

µg/m3 = micrograms per cubic meter Acid Deposition. Potential acid deposition impacts were assessed using two separate methodologies. Voyageurs National Park and Isle Royale National Park The National Park Service and the US Fish and Wildlife Service have developed Deposition Analysis Thresholds (DATs) for evaluating the contribution of additional nitrogen or sulfur to deposition within Class I areas. A DAT is the additional amount of nitrogen or sulfur deposition within a Class I area below which estimated impacts from a proposed new or modified source are considered insignificant[5]. A DAT value of 0.01 kilogram per hectare per year (kg/ha/yr) = for total nitrogen deposition and total sulfur deposition, respectively, for Voyageurs National Park and Isle Royale National Park were compared, and are provided in Table 10, with the additional deposition resulting from the source as modeled by CALPUFF. The maximum modeled sulfur and nitrogen deposition rates associated with the proposed project at the two national parks are below the corresponding DATs, which indicate that acidic deposition associated with the proposed project will be insignificant at the two parks.

TABLE 10

Comparison of modeled acid deposition rates for the Voyageurs and Isle Royale National Parks to the National Park Service’s DATs

National Park

Deposited Material

NPS DAT (kg/ha/yr)

Modeled Max. Deposition Rate

(kg/ha/yr) total sulfur 0.01 0.00027 Voyageurs total nitrogen 0.01 0.00042 total sulfur 0.01 0.00042 Isle Royale

total nitrogen 0.01 0.00039

kg/ha/yr = kilogram per hectare per year

BWCAW and the Rainbow Lakes Wilderness Area The acid deposition impact analysis for the BWCAW and Rainbow Lake Wilderness was conducted according to the “Green-Yellow-Red” screening procedure methodology outlined in the U.S. Forest


Service publication entitled “Screening Procedures to Evaluate Effects of Air Pollution on Eastern Wildernesses Cited as Class I Air Quality Areas” (Adams et al., 1991). The acid deposition impact on terrestrial (vegetation and soil) and aquatic ecosystems is judged to be acceptable if ambient air concentrations and/or deposition are not above the respective “green line” values that have been calculated for each Class I area (Adams et al., 1991). The U.S. Forest Service uses the “green line” terrestrial and aquatic deposition rates to define the threshold of potential adverse impacts. The “green line” deposition rates are the loading levels below which no adverse impacts are expected.[4] When evaluating the potential to exceed the green-line deposition rate for the BWCAW and the Rainbow Lakes Wilderness, the sum of the background deposition rates and the modeled deposition rates associated with the proposed project were used. A comparison of the modeled maximum acid deposition rates for the BWCAW and the Rainbow Lakes Wilderness to the U.S. Forest Service’s “green-line” deposition rates is provided in Table 11. The modeled maximum deposition rates associated with proposed project are small compared to background deposition rates and to the terrestrial and aquatic green-line deposition rates. When the background deposition rates for the BWCAW and the Rainbow Lakes Wilderness are added to the project’s deposition rates, the combined deposition rates (project + background) are below or within the green-line deposition range, which indicates that no adverse impacts due to acid deposition associated with the proposed project emissions are expected at the two wilderness areas.

TABLE 11

Comparison of modeled acid deposition rates for the BWCAW and the Rainbow Lakes Wilderness to the U.S. Forest Service’s “green-line” deposition rates

Wilderness Area

Ecosystem Type

Pollutant

Green-Line Deposition

Rate (kg/ha/yr)

Modeled Maximum

Project Deposition

Rate (kg/ha/yr)

Background Deposition

Rate (kg/ha/yr)

Combined Deposition

Rate (Project +

Background) (kg/ha/yr)

Terrestrial Total S Total N

5.0 – 7.0 5.0 – 8.0

0.0017 0.0031

2.15 3.85

2.152 3.853

Boundary Waters

Aquatic Total S Total S + 20% N

7.5 – 8.0 9.0 – 10.0

0.0017 0.0023

2.15 2.92

2.152 2.922

Terrestrial Total S Total N

5.0 – 7.0 5.0 – 8.0

0.0004 0.0007

2.98 5.88

2.980 5.881

Rainbow Lakes

Aquatic Total S Total S + 20% N

3.5 – 4.5 4.5 – 5.5

0.0004 0.0005

2.98 4.16

2.980 4.161

kg/ha/yr = kilogram per hectare per year S = sulfur N = nitrogen The Federal Land Managers believe it is unlikely that deleterious impacts from acid deposition would occur in either of the Class I Areas as a result of emissions from this proposed project.

Visibility. A visibility analysis was also completed to address the concerns of the Federal Land Managers. Sources of air pollution can cause visible plumes if emissions of particulates, sulfur dioxide, and nitrogen oxides are sufficiently large. The potential for visibility impairment was assessed for the BWCAW, Voyageurs National Park, and Isle Royale National Park using the refined CALPUFF approach


for regional haze[6]. The U.S. Forest Service has determined that visibility is not an AQRV for the Rainbow Lake Wilderness. The CALPUFF modeling generated 24-hour time-averaged light extinction coefficients based on the emissions from the proposed project. These modeled light extinction coefficients were combined with two sets of background light extinction coefficients. The first set consists of hypothetical pristine or natural background coefficients (i.e. estimate for pre-industrial conditions) developed by the USEPA [7].5 The second set of background extinction coefficients is calculated from existing monthly-averaged background concentrations of visibility-impairing pollutants in the three Class I areas. The increase in the maximum daily extinction coefficients associated with the proposed project emissions was determined for each set of background light extinction coefficients. The number of days for which the modeled increase in the maximum daily extinction coefficient (Δbext, Mm-1) exceeded 5 and 10 percent of the background extinction coefficient was identified. The visibility results for the pristine background extinction coefficients are provided in Table 12 for the BWCAW, Isle Royale National Park, and Voyageurs National Park. No exceedences of the 5 percent visibility threshold were identified in the Class I areas when the modeled results were compared to existing background conditions. Additionally, no exceedences of the visibility thresholds for pristine background conditions were identified for Isle Royale and Voyageurs National Parks, respectively; however, the modeling results did indicate the potential for the proposed project to exceed a 5 percent increase over the pristine background extinction coefficients for several days out of a modeled year within the BWCAW.

TABLE 12 Maximum modeled changes in the daily extinction coefficients and the estimated number of days per modeled year in which the increase in the daily extinction coefficient exceeds 5 and 10 percent

for the pristine background condition Area Parameter 1990 1992 1996

Maximum Δbext (%) 4.90 7.17 3.04 Days with Δbext ≥ 5% 0 4 0

BWCAW

Days with Δbext ≥ 10%

0 0 0

Maximum Δbext (%) 2.79 2.13 1.20 Days with Δbext ≥ 5% 0 0 0

Isle Royale National Park

Days with Δbext ≥ 10%

0 0 0

Voyageurs National Park Maximum Δbext (%) 0.84 1.94 0.94 Days with Δbext ≥ 5% 0 0 0 Days with Δbext ≥ 10% 0 0 0

The Federal Land Managers have reviewed the modeling protocol and the modeled results and believe that they are the best representation available of the impact of this project on visibility based on their current understanding of the pollutants emitted from the Facility. Anywhere from a 2 percent to a 10 percent change in light extinction as compared to natural background is generally just noticeable in most landscapes. Due to the low frequency of the modeled impact (only four days in three years over 5 percent), low magnitude (a highest impact of 7.2 percent extinction and the impacted areas occur over a

6 U.S. Forest Service, National Park Service, and U.S. Fish and Wildlife Service. 2000. Federal Land Managers’ Air Quality Related Values Workgroup (FLAG) Phase I Report. December 2000. 210 pages. 7 USEPA. 2003. Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Program. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, EPA-454/B-03-005.


small geographical portion of the BWCAW for those days with receptors over 5 percent), and short duration (no consecutive days of impact and all impacts are focused during the time of the year that has low visitor use), the Federal Land Managers view these impacts to visibility as minor. Additional information on the modeled visibility results are provided in the Air Dispersion Modeling Results for the Furnace 5 Reactivation Project Class I Areas Analysis, which can be accessed at the MPCA’s Web site: http://www.pca.state.mn.us/hot/northshore-mining.html.

Air Risk Analysis The MPCA developed risk analysis tools in response to a growing demand from the public to know more about the quality of air. The MPCA generally uses the term “risk” to refer to estimated cancer risks and potential noncancer health effects. Potential health effects from individual noncarcinogenic chemicals are expressed as a “hazard quotient.” Potential health effects from all noncarcinogens added together are expressed as a “hazard index.” Risk analyses assume that some level of risk is acceptable because no human activity is without risk. The level of risk generally deemed to be acceptable for all carcinogenic chemicals added together is less than 1 in 100,000 (10-5) excess cancers based on the MPCA’s interpretation of Minnesota Department of Health guidance. The level of risk deemed to be acceptable for all noncarcinogenic chemicals added together is a hazard index of 1.0. If a project shows a risk in excess of these levels, the MPCA examines the project analysis to determine whether future investigation or project modification is warranted. Interested readers can find more detailed information on the air risk analysis process at http://www.pca.state.mn.us/air/aera.html. Potentially emitted chemicals that have calculable emission rates and inhalation health benchmarks were assessed as part of the Furnace 5 reactivation air risk analysis. These chemicals were identified from a review of available information (a 1999 air toxic review study for the Facility, site-specific stack test information, testing for the taconite maximum achievable control technology delisting proposal, the USEPA utility Hazardous Air Pollutant study, and USEPA's AP-42 emission factor compendium). The air risk analysis generally followed protocols approved by the MPCA and the Minnesota Department of Health. Air dispersion modeling was used to predict ambient concentrations of chemicals potentially emitted at hypothetical human receptors located on a close-in receptor grid covering approximately a four kilometer (km) by four km area around the Facility, including the City. Risks were computed for receptors assumed to be present at the locations of highest modeled air concentrations (which typically occur within a three km radius of stacks shorter than 100 meters). A map showing land use and receptors within a three km area is attached as Figure 10. Potential inhalation risks to receptors were calculated for 1-hour (acute) and 70-year (chronic) exposure periods under maximum future operating conditions. A 30-year (chronic) vegetable ingestion risk to residents potentially living at the location of maximum modeled air concentration was also assessed. The evaluation indicates that, with the exception of the acute hazard index threshold, all hazard indices and carcinogenic risks for the chemicals and pathways evaluated for the proposed project are below the recommended MPCA thresholds. Exceedence of the acute (hourly) threshold is primarily due to NO2, with a hazard quotient of 1.4. The maximum modeled hourly NO2 concentration falls on Highway 61 where it is unlikely a person would be exposed continuously for an hour (the exposure time frame of concern). NO2 concentrations generally decrease as distance from the highway increases. Locations of modeled concentrations greater than the benchmark for the most part fall to the northeast of the Facility in an area zoned industrial/commercial. One other is immediately west of the Facility near the property line.

The proposed project is not expected to pose unacceptable risks to the general public from the chemicals and exposure pathways assessed. A copy of the Risk Summary Form, which summarizes the findings of the Air Risk Analysis for this project and contains a list of the chemicals assessed and their associated risks, can be found at http://www.pca.state.mn.us/hot/northshore-mining.html.


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



The estimation of additive lifetime cancer risk in this Air Risk Analysis did not include the potential inhalation risk from amphibole mineral fibers that are emitted from the Facility because there is no inhalation health benchmark available to quantify the contribution of fiber emissions to the estimated lifetime cancer risk from the Facility. Further discussion on fibers can be found below. Amphibole Mineral Fibers The taconite ore processed at the Facility contains amphibole mineral fibers. The industrial activities at the Facility emit PM and PM10 to the atmosphere and these emissions contain amphibole mineral fibers. The presence of these fibers in exhaust emitted to the air from processing equipment has been verified through stack testing and by ambient air monitoring.

The proposed project will entail reactivating existing, idled equipment. The MPCA has assessed potential fiber emissions from the proposed Facility and has found that although additional equipment will be in operation, emissions from the concentrators and from Furnace 5 will decrease because existing multiclone control equipment will be replaced with fabric filters, which are more efficient at removing particulate matter (including fibers) from the exhaust before venting to the atmosphere. As a result, there will be no net increase in fiber air emissions. The Air Emission Permit does currently, and will continue to, require fiber monitoring. A discussion on amphibole mineral fibers with respect to the Milepost 7 basin can be found in Item 18.

Mercury Mercury is contained within the ore that NSM mines and processes, and some of the mercury volatilizes to the air when the taconite pellets are indurated in the pelletizing furnaces. Mercury is also present in coal and is released when coal is combusted in the power plant boilers. Mercury air emissions from the existing Facility at maximum production are very low when compared to other mercury emitting facilities. Based on the MPCA’s calculations, the Facility emitted an estimated 11 pounds of mercury to the air in 2004. The amount of coal burned in the power plant is not expected to increase as a result of the proposed project (see the previous discussion under ‘Power Plant’ in Section II of Item 6b of this EAW); however, the reactivation of Furnace 5 will mean that an increased number of pellets will be indurated. At maximum capacity and considering control equipment, the reactivation of this furnace has the potential to emit up to 1.5 pounds of additional mercury to the air each year. The MPCA relied upon a conservative screening assessment conducted in 1999 of potential mercury deposition from taconite processing and fuel combustion to a number of receptor sites (including seven small lakes located west and northwest of the Facility) to evaluate potential impacts from this proposed project. In 1999, NSM proposed to incorporate a new process at the Facility (which was ultimately never implemented). Using the assumption that 50 percent of the elemental mercury emitted would be deposited locally, an estimated 2.3 additional pounds of mercury would have been emitted from the project proposed. The screening assessment determined that the proposed project would cause no measurable increases in local mercury deposition to nearby lakes.

Based on the method used for the 1999 study, and considering that the reactivation of Furnace 5 has the potential to emit less mercury that the 1999 project proposal, the MPCA has concluded there will be no measurable increase in local mercury deposition to nearby lakes as a result of reactivation of Furnace 5.

24. Odors, noise and dust. Will the project generate odors, noise or dust during construction or during

operation? Yes No If yes, describe sources, characteristics, duration, quantities or intensity and any proposed measures to

mitigate adverse impacts. Also identify locations of nearby sensitive receptors and estimate impacts on them. Discuss potential impacts on human health or quality of life. (Note: fugitive dust generated by operations may be discussed at item 23 instead of here.)


Odor Neither the construction nor the operation of the proposed project is expected to result in nuisance odors. Noise During construction of the concentrate silos, noise will be generated. Construction will be temporary in nature and is expected to be complete in six to nine months. Additional activities associated with the proposed project will be completed inside. Operation of the proposed Facility is not expected to significantly increase noise compared to that already caused by the operation of the existing Facility. Peregrine falcons have nested at the Facility for the past several years. Potential impacts to their nesting activities are described in Item 11b of this EAW. Dust Dust is created from the existing operation from pellet handling which occurs outdoors. PM and PM10 emissions from pellet handling operations are currently controlled by wetting the pellets with water, application of chemical dust suppressants, and screening fines from the pellets. During construction of the concentrate silos, dust will be generated. As stated above, construction will be temporary in nature and is expected to be complete in six to nine months. Additional construction activities will be completed inside. Operation of the proposed Facility is not expected to cause significant increases in dust as compared to that already caused by the operation of the existing Facility. The City indicates that they have received no complaints in recent years from nearby residences or businesses regarding the operation of the Facility and there is no reason to believe that operation of the proposed project will be a nuisance to residents in the area.

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

measures to minimize or avoid adverse impacts. The Facility is located along the north shore of Lake Superior, an area that is valued for its scenic beauty and recreational opportunities. Other resources, such as the Superior Hiking Trail, Tettegouche State Park, and Silver Bay Safe Harbor and Marina are located within a few miles of the Facility. The existing Facility was constructed in the 1950s. The proposed project will involve the outdoors construction of two concentrate storage silos; other construction activities will occur indoors. The construction phase will be short term and is not expected to have the potential for significant noise, dust, or visual impacts. The silos will be blocked from view by other buildings already in existence at the Facility. The proposed project will not increase operating hours at the Facility beyond their current schedule, and operational changes that will incorporate the new or reactivated units are unlikely to be noticed by the general public. Impacts on natural resources in northeastern Minnesota are discussed in various items of this EAW, including Item 23 (air), Item 18 (wastewater and tailings basin), and Item 26 (visibility). The Minnesota State Historical Society was contacted to perform a database review of the proposed project area and found no archaeological, historical, or architectural resources in proximity to the site. The correspondence is attached as Figure 11.


26. Visual Impacts. Will the project create adverse visual impacts during construction or operation? Such as glare from intense lights, lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks? Yes No If yes, explain. The concentrate silos will be located within the existing Facility compound area where they will be blocked from view, so the construction phase and operation of the silos should pose no adverse visual impacts. Currently, thirteen stacks produce visible plumes, though not on a continuous basis. The project will require the reactivation of three WWESP units on Furnace 5 that are currently idle, and these three stacks will have a visible steam plume. The additional steam plumes will not greatly alter the visual impact of the Facility from its current appearance. The Facility currently operates three shifts and so safety lighting is on during the night. The proposed project will not require the need for additional lighting.

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

If yes, describe the plan, discuss its compatibility with the project and explain how any conflicts will be resolved. If no, explain. The Facility operations will continue to be consistent with local, regional, state, and federal land use plans and other applicable land use, water, and resource management plans.

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

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

“cumulative potential effects of related or anticipated future projects” when determining the need for an environmental impact statement. Identify any past, present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative impacts. Describe the nature of the cumulative impacts and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to cumulative impacts (or discuss each cumulative impact under appropriate item(s) elsewhere on this form).

Air All of the idled equipment at the Facility is included in the proposal described in this EAW and the corresponding applications for air and water permit modifications. In this manner, the cumulative impacts of restarting all currently idle equipment will be addressed at one time. No other projects are proposed for the Facility for the foreseeable future. Additionally, there are no other known projects proposed for the nearby city or county area that are anticipated to result in the potential for significant cumulative air impacts.

Other projects are known to have been proposed for northeastern Minnesota. Four mining projects (in addition to the one described in this EAW) and one electrical generation expansion project have moved beyond the exploratory phase and are now in various stages of environmental and/or permit review. These are the project names and their proposed locations:


• PolyMet Mining Inc.; Hoyt Lakes, Minnesota • Minnesota Steel Industries (MSI); Nashwauk, Minnesota • Ispat Inland Steel Mining Co.; Virginia, Minnesota • Mesabi Nugget LLC; at the former LTV taconite processing plant site in Hoyt Lakes, Minnesota • Laurentian Biomass; Hibbing, MN and Virginia, Minnesota

All of these projects will require air emission permits, and all of the mining projects will also require NPDES/SDS permits. The DNR is in the process of preparing respective scoping EAW and EIS documents for the PolyMet, MSI, and Ispat Inland projects at this time and these documents are expected to be available for public comment soon. Draft air emission and water permit documents for the Mesabi Nugget project and a draft EAW and air emission permit for the Laurentian Biomass project have been prepared by the MPCA, and these documents are all currently on public notice. Ongoing regulatory authorities will ensure that these projects comply with applicable federal, state, and local regulations. The proposed Facility project described in this EAW was required to undergo modeling to demonstrate compliance with the criteria pollutant ambient air quality standards and PSD Class I and II increments. As discussed in Item 23, a PSD Class I increment review considers existing and currently proposed projects through the use of the SILs for SO2, NOx, and PM10, respectively, to ensure they will not significantly deteriorate air quality from baseline conditions. In addition, the modeled air concentrations that are compared to the ambient air quality standards include background. In this sense, the Class I increment analysis and the ambient air quality analysis are cumulative. It is customary to compare model-generated pollutant concentrations from a proposed project to SILs as an initial screening tool to determine if impacts to the Class I increment can be anticipated. SILs are policy and decision thresholds established by the USEPA which are set at 4 percent of the Class I area increment. In developing the 1996 proposal for New Source Review Reform, the USEPA determined that as long as no individual source contribution exceeds the SIL, it is unlikely that the accumulation of sources over time will exceed the Class I increment. In other words, if a new or modified source’s modeled impacts are below the respective SILs, there is reasonable assurance that cumulative impacts will not be a concern. The model-generated atmospheric concentrations of SO2, PM10, and NO2 from the proposed project were compared to the USEPA SILs and to the PSD Class I increment of four nearby Class I areas: the BWCAW, the Rainbow Lakes Wilderness, Voyageurs National Park, and Isle Royale National Park. The results indicate that the pollutant concentrations are below the designated SILs and the applicable Class I increments. Therefore, potential cumulative impacts from this project are not expected. The National Park Service addresses potential cumulative impacts for acid deposition by applying the USEPA SILs methodology in developing (DATs), which are then used for evaluating the contribution of additional nitrogen or sulfur to deposition within Class I areas. A DAT is the additional amount of nitrogen or sulfur deposition within a Class I area below which estimated impacts from a proposed new or modified source are considered insignificant. According to the National Park Service, by incorporating the SIL methodology into the DAT equations, new sources whose modeled deposition amounts are below the DATs are not likely to significantly contribute to cumulative impacts from nitrogen or sulfur deposition. The maximum modeled sulfur and nitrogen deposition rates associated with the proposed project at Voyageurs National Park and Isle Royale National Park are below the corresponding DATs. Therefore, the proposed project is not expected to result in cumulative acid deposition impacts to the two national parks. The DAT analysis was not applied to the BWCAW and the Rainbow Lakes Wilderness because these areas fall under the jurisdiction of the U.S. Forest Service, which uses a different approach to assessing acid deposition. However, the modeled contribution of the proposed project’s emissions to acid deposition in the two wilderness areas is less than 0.01 kg/ha/yr. When the respective modeled project contributions of sulfur and nitrogen are added to background deposition rates for each wilderness area, the combined deposition is the same as the background deposition (i.e., the project is not expected to increase


sulfur and nitrogen deposition in the two wilderness areas). If one applies the DAT thresholds to the wilderness areas, the modeled contribution of sulfur and nitrogen to the two wilderness areas is below the respective DATs. This indicates that emissions associated with the proposed project are not expected to result in cumulative acid deposition impacts to the two wilderness areas. A more detailed explanation of these air analyses and tables showing modeled results can be found in Item 23 under Class I Area Analyses subheadings, ‘Class I PSD Increment’, and ‘Acid Deposition’. Tables 8 and 10 include comparisons of modeling results to PSD Class I increments, SILs, and DATs. Water This proposed Facility project entails adding two additional treatment units to the Milepost 7 WWTP. Item 18 provides full details on the proposal and anticipated impacts to the receiving waters. The project proposal also entails construction of a concentrate handling system, which will require disturbance of a small area of ground. Please refer to Items 16 and 17 of this EAW for information on the management of stormwater runoff from this construction. No other projects are proposed for the Facility in the foreseeable future that would result in the potential for significant cumulative water impacts to the Beaver River or to Lake Superior. The Facility and Milepost 7 tailings basin are located within the Lake Superior (MN South) watershed. MNDOT is planning to upgrade the portion of Highway 61 from the Facility’s entrance gate up to Illgen City in the near future. Additionally, a business park located within the City has been platted, and its development is ongoing, dependent on economic factors. Construction from these projects will be implemented in accordance with current zoning and land use requirements and will comply with applicable local ordinances and state codes and regulations intended to manage, minimize, or eliminate any adverse impacts. Any construction project that disturbs more than one acre of soil will be required to comply with the requirements and conditions set in the NPDES/SDS General Stormwater Permit for Construction Activity, which includes implementation of Best Management Practices measures and the development of a stormwater pollution prevention plan to manage pollutants in stormwater runoff from the site that will occur during construction and after construction is complete. While most of the proposed projects referenced earlier are located within the Lake Superior Basin (MSI will be located within the Upper Mississippi River Basin), none are located within the Lake Superior (MN South) watershed, and so the potential for significant cumulative impacts from point and nonpoint source discharges to this watershed from those projects are not anticipated. The ore that is processed at the Facility contains amphibole mineral fibers, and discussions on anticipated impacts relative to fibers from the proposed project are discussed in Items 18 (wastewater) and 23 (air) of this EAW. The particular geology that results in the formation of the amphibole mineral fibers is confined to the extreme eastern end of the Mesabi Iron Range where NSM’s mine is located. Ore processed by the other taconite processing plants located at more central and western portions of the Iron Range contains minimal amphibole fibers. Therefore, the potential for significant cumulative impacts from fibers to the air and water are not anticipated. The proposed project will add a small amount of mercury to the air through the induration of taconite pellets. Many lakes and streams in northeastern Minnesota are designated as impaired for mercury (i.e. there are fish consumption advisories due to mercury contamination) and the MPCA has developed a Statewide Mercury Total Maximum Daily Load (TMDL) Pollutant Reduction Plan that, when implemented, is intended to reduce air sources of mercury by 93 percent from 1990 levels. The TMDL Plan is described in detail at the following MPCA Web site: http://www.pca.state.mn.us/water/tmdl/tmdl-mercuryplan.html.

http://www.pca.state.mn.us/water/tmdl/tmdl-mercuryplan.html




Miscellaneous The potential for significant cumulative visual impacts and cumulative impacts from traffic and noise on wildlife and on the environment have been considered. There will be a small amount of construction on-site, which will be of short-term duration. Though additional equipment will be reactivated, a majority of it is located within enclosed buildings. Most of the raw materials used at the Facility are received by rail and product is shipped either by rail or from the Facility’s harbor. It is possible that concentrate may need to be shipped by truck for a period of time (estimated between 6-12 months) until appropriate rail loading/unloading facilities are constructed at the buyer’s facility. Trucks containing concentrate would add more traffic for a short stretch of Highway 61, but as mentioned, this shipment method would be temporary. The proposer is willing to work with MNDOT and the City to ensure that any inconvenience caused by temporary truck shipping will be kept to a minimum. Operating conditions at the Facility will not change significantly from pre-, to post-construction, and though additional equipment will become operational, a majority of it is located within enclosed buildings. A few short-term construction projects may occur within the City, but no other projects resulting in long-term noise or traffic effects are known for the City and so the potential for significant cumulative impacts are not expected. Other construction projects have been proposed for the northeastern region of Minnesota; however, these projects are located more than 45 miles from the Facility and the potential for regional cumulative visual impacts and cumulative impacts from traffic and noise to wildlife and the environment are not anticipated. More information on visual impacts and impacts from traffic and noise on wildlife and on the environment can be found in Items 11, 21, 24, and 25 of this EAW.

30. Other Potential Environmental Impacts. If the project may cause any adverse environmental impacts not addressed by items 1 to 28, identify and discuss them here, along with any proposed mitigation. N/A

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

None identified.


RGU CERTIFICATION. I hereby certify that: • The information contained in this document is accurate and complete to the best of my knowledge. • The EAW describes the complete project; there are no other projects, stages or components other than those

described in this document, which are related to the project as connected actions or phased actions, as defined at Minn. R. 4410.0200, subps. 9b and 60, respectively.

• Copies of this EAW are being sent to the entire EQB distribution list. Name and Title of Signer: Beth G. Lockwood, Supervisor, Environmental Review Unit Environmental Review and Operations Section

Regional Division Date:

The format of the Environmental Assessment Worksheet was prepared by the staff of the Environmental Quality Board at Minnesota Planning. For additional information, worksheets or for EAW Guidelines, contact: Environmental Quality Board, 658 Cedar St., St. Paul, MN 55155, 651-296-8253, or at their Web site http://www.eqb.state.mn.us/review.html.

http://www.eqb.state.mn.us/review.html

Northshore Mining Comany–Furnace 5 Reactivation Project · Enclosed is the Environmental...

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