PolyMet Fiber Monitoring and Quality Assurance Project Plan

4300 MarketPointe Drive, Suite 200

Minneapolis, MN 55435

952.832.2600

www.barr.com

Ambient Fiber Monitoring and Quality Assurance

Project Plan

Prepared for

Poly Met Mining, Inc.

August 2017

aq5-35e

\\barr.com\projects\Mpls\23 MN\69\2369862\WorkFiles\APA\Permitting\Air Permitting\Fibers 2016\Monitoring Plan_QAPP\Ambient Fiber Monitoring and

Quality Assurance Project Plan v2d3.docx

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Ambient Fiber Monitoring and Quality Assurance Project Plan

August 2017

Contents

1.0 Introduction ........................................................................................................................................................................... 1

1.1 Background Information .............................................................................................................................................. 1

1.2 Monitoring Objectives .................................................................................................................................................. 1

2.0 Site Description .................................................................................................................................................................... 3

2.1 General Site Description .............................................................................................................................................. 3

2.1.1 Project Emission Sources ........................................................................................................................................ 3

2.1.2 Neighboring Sources ............................................................................................................................................... 4

2.2 Topographical Description .......................................................................................................................................... 4

2.3 Climatological Description .......................................................................................................................................... 4

3.0 Sampling Program............................................................................................................................................................... 6

3.1 Monitoring Location ...................................................................................................................................................... 6

3.2 Monitor Specifications .................................................................................................................................................. 6

3.3 Sampling Frequency ...................................................................................................................................................... 6

3.4 Duration of Monitoring Program ............................................................................................................................. 6

4.0 Monitoring Operating Procedure.................................................................................................................................. 7

4.1 Sample Acquisition ........................................................................................................................................................ 7

4.2 Quality Control Procedures ........................................................................................................................................ 7

4.3 Calibration Specifications ............................................................................................................................................ 8

4.4 Calibration Methods ...................................................................................................................................................... 8

4.4.1 Frequency ..................................................................................................................................................................... 8

4.5 Reference Standards ...................................................................................................................................................... 9

4.5.1 Flow Rate Transfer Standard ................................................................................................................................. 9

4.5.2 Field Thermometer ................................................................................................................................................... 9

4.5.3 Field Barometer .......................................................................................................................................................... 9

4.6 Quality Control Checks ................................................................................................................................................. 9

4.6.1 Frequency ..................................................................................................................................................................... 9

4.6.2 Corrective Actions ...................................................................................................................................................10

4.7 Monitoring Audits ........................................................................................................................................................13

4.7.1 Conducting Audit ....................................................................................................................................................13

ii

4.7.2 Reference Standard Traceability ........................................................................................................................13

5.0 Program for Corrective Action......................................................................................................................................14

5.1 Failed Control/Audit Limits .......................................................................................................................................14

6.0 Recordkeeping and Reporting .....................................................................................................................................15

6.1 Validation of Data .........................................................................................................................................................15

6.2 Frequency of Reporting .............................................................................................................................................15

6.3 Storage of Historical Results ....................................................................................................................................15

7.0 References ............................................................................................................................................................................16

iii

List of Tables

Table 4-1 Measurement Quality Objectives ................................................................................................................. 8

Table 4-2 Field Quality Control Checks ....................................................................................................................... 10

Table 4-3 Field Corrective Actions ................................................................................................................................. 11

Table 4-4 Sensor Audit Criteria and Frequency ........................................................................................................ 13

Table 6-1 Potential Invalid Sample Codes .................................................................................................................. 15

List of Large Figures

Large Figure 1 Site Location

Large Figure 2 2009 - 2013 Windrose - Hibbing, Minnesota

Large Figure 3 Fiber Monitoring Location

1

1.0 Introduction

1.1 Background Information

Poly Met Mining, Inc. (PolyMet) is proposing to develop the NorthMet copper-nickel-gold/platinum-

group-metal (AuPGM) mine and associated processing facilities in northeastern Minnesota for the

NorthMet Project (Project). The mining and processing operation will be located in an existing mining

region and will use existing infrastructure as much as possible. PolyMet has applied for a total facility air

permit for the Project.

The Project area, which includes the Mine Site, Plant Site, and the Transportation and Utility Corridors

(primarily Dunka Road), is located in St. Louis County, Minnesota, at the eastern end of the Mesabi Iron

Range (Large Figure 1). The Mine Site is located within the Superior National Forest in an area that has not

previously been mined. It is located approximately 6 miles south of the City of Babbitt (Large Figure 1)

and directly south of the Northshore Mining Peter Mitchell Mine, which is an active taconite/iron mine

(Large Figure 1). The Plant Site is located to the southwest of the Mine Site at the former LTV Steel Mining

Company (LTVSMC) taconite facility, which PolyMet purchased from Cliffs Erie LLC.

A Final Environmental Impact Statement (FEIS) was prepared during the course of the Project’s

environmental review. The FEIS review concluded that because the health impact from exposure to fibers

cannot be evaluated at this point in time, the approach is to minimize the release of fibers through control

and treatment technology and to conduct ambient air monitoring for fibers. For the purposes of the

Project monitoring program, “fiber” refers to mineral particles with a length-to-width aspect ratio of 3:1 or

greater with no minimum length, as quantified by Minnesota Department of Health (MDH) Method 852

(Reference (1)). As part of the monitoring to assess potential ambient air impacts from the Project,

PolyMet has performed, and may continue to perform, monitoring for fibers before operations begin at

the Plant Site and will conduct additional monitoring after operations begin at the Plant Site for a period

to be determined. Operations will be considered to have begun at the Plant Site upon the

commencement of the feeding of ore to the Crusher/Concentrator. Baseline monitoring (i.e., before

project construction and/or operations commence) began in the spring of 2008.

1.2 Monitoring Objectives

The primary objective of the monitor in Hoyt Lakes is to monitor ambient fibers in the community. The

Project will be the first mine to operate with Duluth Complex ore. The iron ore of the Biwabik Iron

Formation has been the focus of attention with regard to fibers and much of the attention has been

focused on the eastern end of the Mesabi Iron Range. Given the Project’s location near this area, PolyMet

has conducted, its own fiber monitoring to better understand pre-operations baseline conditions near the

Project with regards to fibers.

Fiber monitoring will also be conducted after operations at the Plant Site have commenced. NorthMet ore

processing has the potential to generate some types of mineral fibers, based on the results of pilot-plant

sampling and analysis. The results showed predominantly “short” fibers, most of which were less than 10

microns (µm) and most of which were less than 2.5 µm (fine particles). None of the fibers monitored to-

2

date have been asbestiform minerals. The purpose of this plan is to provide quality assured monitored

data from the Hoyt Lakes monitor during the operations phase of the Project. Depending on Project

timing and other factors, this plan may also be relevant to some or all of the baseline monitoring. This

plan was prepared with the Minnesota Pollution Control Agency (MPCA) Fiber Monitoring Quality

Assurance Project Plan (QAPP) as a guide (Reference (2)).

This plan introduces specific requirements for verification of the operation of the fiber sampler. However,

the same sampler and analytical procedures will be used during the operating period as was used during

the ongoing baseline sampling period. The sampler has and will continue to be operated consistent with

the manufacturer’s instructions. Therefore, although more detailed procedures may be implemented with

this plan, the data collected during the baseline period can be compared directly to data collected after

the Project commences operations.

3

2.0 Site Description

2.1 General Site Description

2.1.1 Project Emission Sources

The Project area, which includes the Mine Site, Plant Site, and the Transportation and Utility Corridors

(primarily Dunka Road), is located in St. Louis County, Minnesota, at the eastern end of the Mesabi Iron

Range (Large Figure 1). The Mine Site is located within the Superior National Forest in an area that has not

previously been mined. It is located approximately 6 miles south of the City of Babbitt (Large Figure 1)

and directly south of the Northshore Mining Peter Mitchell Mine, which is an active taconite/iron mine

(Large Figure 1). The Plant Site is located southwest of the Mine Site at the former LTVSMC taconite

facility, which PolyMet purchased from Cliffs Erie LLC. The Plant Site is located approximately 6 miles north

of the City of Hoyt Lakes.

The key processing steps with the potential for air emissions to the environment consist of:

Mine Site (loading, haul road traffic, material handling and blast hole drilling

Plant Site

o Crusher/Concentrator and Tailings Basin (two-stage crushing, milling, flotation process,

ore and concentrate material handling, and Flotation Tailings management)

o Hydrometallurgical Plant and Hydrometallurgical Residue Facility (HRF)

(Hydrometallurgical Process Tanks, Autoclave, process consumables handling and

storage, and Residue management)

An open pit mine will be operated at the Mine Site. This operation will include the West Pit, the

East/Central Pit, the Ore Surge Pile, the Overburden Storage and Laydown Area, the Category 1 Waste

Rock Stockpile and the Rail Transfer Hopper, where ore will be loaded into railcars for transportation to

the Plant Site for processing. Two temporary stockpiles will also be located at the Mine Site: the

Category 4 Waste Rock Stockpile (on top of what later will become the Central Pit) and the Category 2/3

Waste Rock Stockpile.

Particles meeting the definition of a mineral fiber are most likely to be generated from the size reduction

process for the ore (i.e., comminution) and from the handling and storage of fine ore or tailings.

Therefore, the primary sources of concern for potential mineral fiber emissions are the

Crusher/Concentrator and the Flotation Tailings Basin, both of which are located at the Plant Site. The ore

handled at the Mine Site is blast rock that has not been crushed or ground, so there is little potential for

mineral fiber emissions from these sources.

4

2.1.2 Neighboring Sources

The Plant Site is about eight miles to the west of the Mine Site. The Cliffs Erie Pellet Yard to the south is

located adjacent to the Plant Site. The Peter Mitchell Mine (taconite/iron ore) is located immediately to

the north of the Mine Site.

2.2 Topographical Description

The land on the east side of the Mine Site generally slopes down towards the east to the Partridge River.

The land on the west side of the Mine Site generally slopes down to the south, again towards the

Partridge River. The headwaters of the Partridge River surround the Mine Site on the north, east, and

south. The Dunka Road is a mining road constructed by Erie Mining Company (now Cliffs Erie) for access

to the Dunka Mine, which is about 9 miles to the northeast. It is currently used by Cliffs Northshore

Mining personnel for access between the Peter Mitchell Mine and Cliffs Erie. The Dunka Road crosses the

southeastern corner of the Mine Site, as does the Cliffs Erie rail line formerly used to transport pellets to

the shipping facility at Taconite Harbor and ore from the Dunka Mine to the former LTVSMC taconite

plant.

Elevations north of the Dunka Road range from 1,635 feet above mean sea level (MSL) along the western

boundary to 1,545 feet MSL near the southeastern boundary. Elevations south of the Dunka Road range

from 1,580 feet MSL in the north to 1,540 feet MSL along the Partridge River in the south.

2.3 Climatological Description

The Project is located in northeastern Minnesota near the headwaters of the Partridge and Embarrass

Rivers. The climate classification in Minnesota is defined as continental. The northeastern region of

Minnesota is subject to continental polar air masses throughout most of the year and during the cold

season is subject to occasional Arctic air masses. During summer months, warm air moves northward from

the Gulf of Mexico that occasionally pushes toward the northern portion of Minnesota.

Mean annual temperatures in northeastern Minnesota range from 36 degrees Fahrenheit (°F) in the

extreme north to approximately 40° F near Duluth, Minnesota. Temperature extremes in the northeastern

portion of the state range from approximately -60 to 100° F. Monthly mean temperatures in the

Arrowhead Region vary from approximately 4° F to during the coldest month (January) to approximately

68° F in the warmest month of the year (July).

The majority of precipitation in the region (approximately two-thirds) occurs between May and

September, with annual precipitation ranging from approximately 23 inches in the extreme north and

gradually increasing southeastward across the northeastern portion of the state to approximately

32 inches near Lake Superior. Northeastern Minnesota generally receives approximately 70 inches of snow

per year in the northeast highlands, with annual snowfall decreasing to 45 inches per year near the

western end of the Arrowhead Region. Northern Minnesota averages 140 days of snow cover each year.

Large Figure 2 is a wind rose based on data collected at the Hibbing airport from 2009 to 2013. This is the

same dataset that was used for the Mine Site and Plant Site near field (i.e., Class II) air dispersion modeling

5

completed for the SDEIS. The prevailing wind directions are northwest in the winter and southeast in the

summer.

6

3.0 Sampling Program

3.1 Monitoring Location

The fiber monitor is located at the wastewater treatment plant, on city property in the community of Hoyt

Lakes. The monitoring location is shown in Large Figure 3.

3.2 Monitor Specifications

The equipment performing the sample collection is the Partisol® - FRM Model 2000 Air Sampler. The

sampler passes ambient air through an inlet system prior to passing through a filter cassette containing a

47 mm diameter sample filter. A mass flow controller downstream of the sample filter maintains a

constant volumetric flow rate through the system. Any potential for contamination through direct contact

with the filter is mitigated by using a carrier that holds the filter cassette during its entire time outside of a

laboratory environment.

3.3 Sampling Frequency

Every 12 days the sampling monitor will collect a 96-hour sample on a 47 mm filter to capture airborne

material. The samples will be shipped to a MPCA-approved laboratory for fiber analysis. The same

sampling protocol used for baseline monitoring, i.e., prior to commencing operations, will be used for

monitoring during operations.

Data collection may occasionally be interrupted due to electrical or equipment failures or due to

maintenance or audits being conducted.

3.4 Duration of Monitoring Program

A monitoring program in the Project area was begun in the spring of 2008 to establish a monitored fiber

baseline. The monitoring program will continue after operations at the Plant Site have commenced until

PolyMet obtains a permit amendment allowing the termination of the fiber-related monitoring program.

7

4.0 Monitoring Operating Procedure

4.1 Sample Acquisition

Sample recovery of any individual filter from the fiber sampler will occur within 96 hours of the end of the

sample period for that filter. Any potential for contamination through direct contact with the filter is

mitigated by using a carrier that holds the filter cassette during its entire time outside of a laboratory

environment. Sampling frequency will be one sample every 12 days. Samples collected will be forwarded

to a MDH-approved laboratory for fiber analysis. The current approved laboratory is Pace Analytical

Services in Minneapolis, Minnesota.

4.2 Quality Control Procedures

The quality of the data must be evaluated and controlled to evaluate if it is maintained within the

established acceptance criteria. Measurement quality objectives are designed to evaluate and control

various phases (sampling, preparation, analysis) of the measurement process to verify that total

measurement uncertainty is minimized. Table 4-1 lists the measurement quality objectives for this fibers

monitoring program. Accuracy acceptance criteria are based on the sampler manufacturer’s specifications

from the monitor operating manual (Reference (3)) and the EPA Quality Assurance Handbook for Air

Pollution Measurement Systems (Reference (4)).

8

Table 4-1 Measurement Quality Objectives

Requirement Frequency Acceptance Criteria

Reporting Units All data Fibers per cubic meter (f/m3 )

Detection Limit

Lower DL All data 2 f/m3

Upper Conc. Limit All data None(1)

Data Completeness Quarterly 75%

Filter

Visual defect check All Filters No defects

Lot Blanks Minimum of 3 filters per lot

Lab QC Checks

Field Filter Blank

See method reference(2) Lab Filter Blank

Duplicate Filter

Accuracy

Flow Rate Audit Monthly + 7% of audit standard

Internal/External Leak Check Quarterly no leaks (1/2 of original vacuum

reading during 10 second period)

Temperature Audit Quarterly + 2 o C

Pressure Audit Quarterly ± 15 mm Hg

(1) The fiber loading can be adjusted by varying the parameters of the indirect preparation process.

(2) Reference (1)

4.3 Calibration Specifications

Calibration is the comparison of a measurement standard or instrument with another standard or

instrument to report, or eliminate by adjustment, any variation (deviation) in the accuracy of the item

being compared. The purpose of calibration is to minimize bias. A multi-point calibration of the sampler,

including temperature and pressure sensors is essential in order to maintain the entire measurement

process within statistical control. The calibrations specifications for the critical field equipment are listed in

Table 4-1 in Section 4.2.

4.4 Calibration Methods

The Partisol® - FRM Model 2000 Air Sampler uses a mass flow controller downstream of the filter to

maintain a constant volumetric flow rate selected by the user (16.7 l/min by default) and the temperature

and pressure are monitored with internal sensors. In the event a flow check, temperature verification or

pressure verification indicates a need for a calibration, the calibration will be performed using a NIST

traceable standard and meet the criteria listed in Table 4-1.

4.4.1 Frequency

Calibration of the flow rate, temperature, and pressure monitor will be performed upon installation of the

monitoring system and if there is a failure during verification or audit of a sensor. A pressure sensor

9

calibration will be performed once per year. The frequency of sensor verification checks and audits are

listed in Table 4-1.

4.5 Reference Standards

The reference standards used in the calibration/verification of the flow rate, temperature, and pressure

sensors are detailed in the following sections.

4.5.1 Flow Rate Transfer Standard

The flow rate standard apparatus used for flow-rate calibration will have a valid certification stating its

traceability to a NIST standard for volume or flow rate. A calibration relationship for the flow-rate

standard, such as an equation, curve, or family of curves, will be established by the manufacturer (and

verified if needed) that is accurate to within 2% over the expected range of ambient temperatures and

pressures at which the flow-rate standard is used. The flow rate standard will be recalibrated and

recertified at least annually.

4.5.2 Field Thermometer

The temperature standard used for temperature calibration will have its own certification and be

traceable to a NIST primary standard. A calibration relationship to the temperature standard (an equation

or a curve) will be established at an accuracy within 2% over the expected range of ambient temperatures

at which the sensor is to be used. The temperature standard must be reverified and recertified at least

annually.

4.5.3 Field Barometer

The pressure measurement standard used for barometer calibration will have its own certification and be

traceable to a NIST primary standard. The pressure measurement standard must be reverified and

recertified at least annually.

4.6 Quality Control Checks

Mineral fiber air monitoring quality control is implemented through the use of various checks and

instrument comparisons. The measurement quality objectives (Table 4-1) in Section 4.2 contains a

complete listing of these QC samples as well as other requirements for the fiber monitoring program. The

following information provides some additional descriptions of the QC activities, how they will be used in

the evaluation process, and what corrective actions will be taken when they do not meet acceptance

criteria.

4.6.1 Frequency

Table 4-2 outlines the frequency of quality control checks to be performed on the monitoring system as

well as the acceptance criteria.

10

Table 4-2 Field Quality Control Checks

Requirement Frequency Method

Calibration Instrument

Calibration Standards

Flow Rate Transfer Std. Once per year 7 point against NIST traceable std.

Flow Temperature Once per year 3 point against NIST traceable std.

Remote Temperature Once per year 3 point against NIST traceable std.

Barometer Once per year 3 point against NIST traceable std.

Partisol

Calibration/Verification

Interface Board Calibration Once per year Per Mfg. procedures

Flow Rate (FR) Calibration Once per year Per Mfg. procedures

Temperature Calibration Once per year Per Mfg. procedures

Pressure Calibration Once per year Per Mfg. procedures

4.6.2 Corrective Actions

Corrective action measures will be taken as needed with the goal of attaining the data quality objectives.

There is the potential for many types of sampling and measurement system corrective actions. Table 4-3

details the expected problems and corrective actions needed for a well-run fiber monitor.

11

Table 4-3 Field Corrective Actions

Item Problem Action Notification

Filter Inspection

(Pre-sample)

Pinhole(s) or

torn

1) If additional filters have been

brought, use one of them. Void filter

with pinhole or tear.

1) Document on field data sheet

2) Use new field blank filter as

sample filter. 2) Document on field data sheet

3) Obtain a new filter from lab. 3) Document on field data sheet

Filter Inspection

(Post-sample)

Torn or

otherwise

suspect

particulate

bypassing 47

mm filter.

1) Inspect area downstream of

where filter rests in sampler and

determine if particulate has been

bypassing filter.

1) Document on field data sheet

2) Inspect in-line filter before sample

pump and determine if excessive

loading has occurred. Replace as

necessary.

2) Document in logbook

Sample Flow

Rate Verification

Out of

Specification

(+ 4% of

transfer

standard)

1) Completely remove flow rate

device, re-connect and re-perform

flow rate check.

1) Document on data sheet

2) Perform leak test. 2) Document on data sheet

3) Check flow rate at 3 points (15.0

LPM, 16.7 LPM, and 18.3 LPM) to

determine if flow rate problem is

with zero bias or slope.

3) Document on data sheet.

Notify Field Coordinator

4) Re-calibrate flow rate 4) Document on data sheet

Leak Test

Leak outside

acceptable

tolerance

(80 mL/min)

1) Completely remove flow rate

device, re-connect and re-perform

leak test.


2) Inspect all seals and O-rings,

replace as necessary and re-perform

leak test.

2) Document in logbook, notify

Field Manager, and flag data

since last successful leak test

3) Check sampler with different leak

test device. 3) Document in log book

Sample Flow

Rate

Consistently low

flows

documented

during sample

run

(< 15.5 l/min)

1) Check programming of sampler

flowrate. 1) Document in logbook

2) Check flow with a flow rate

verification filter and determine if

actual flow is low.


3) Inspect in-line filter downstream

of 46.2 mm filter location, replace as

necessary.


12

Item Problem Action Notification

Ambient

Temperature

Verification and

Filter

Temperature

Verification.

Out of

Specification

(4 C of

standard)

1) Make certain thermocouples are

immersed in same liquid at same

point without touching sides or

bottom of container.


2) Use ice bath or warm water bath

to check a different temperature. If

acceptable, re-perform ambient

temperature verification.


3) Connect new thermocouple. 3) Document on data sheet.

Notify Field Coordinator.

4) Check ambient temperature with

another NIST traceable

thermometer.


Ambient Pressure

Verification

Out of

Specification

(10 mm Hg)

1) Make certain pressure sensors are

each exposed to the ambient air and

are not in direct sunlight.


2) Call local Airport or other source

of ambient pressure data and

compare that pressure-to-pressure

data from monitor’s sensor. Pressure

correction may be required


3) Connect new pressure sensor 3) Document on data sheet

Elapsed Sample

Time

Out of

Specification

(1 min/month)

Check Programming, Verify Power

Outages Document on data sheet

Elapsed Sample

Time

Sample did not

run

1) Check Programming 1) Document on data sheet.

Notify Field Coordinator.

2) Try programming sample run to

start while operator is at site. Use a

flow verification filter.


Power Power

Interruptions Check Line Voltage

Power

LCD panel on,

but sample not

working.

Check circuit breaker, some

samplers have battery back-up for

data but will not work without AC

power.

1) Document in log book

Data

Downloading

Data will not

transfer to

laptop

computer

Document key information on

sample data sheet. Make certain

problem is resolved before data is

written over in sampler

microprocessor.

13

4.7 Monitoring Audits

Periodic audit of the sensors used in collecting the fiber sample will be performed. A minimum of four

audits on the flow rate sensor will be performed per year in addition to internal and external leak checks.

The temperature and pressure sensors will be audited for accuracy a minimum of twice per year. Audits

will be performed by a technician other than the routine operator.

4.7.1 Conducting Audit

The measurements made by the mass flow rate sensor, temperature sensor and pressure sensor in the

monitor will be compared to the corresponding values measured using the audit sensors and

documented. The audit sensors should be different from the field standards used to perform routine

verifications or calibration checks. The audit results shall show a correlation between each parameter’s

sensors that meet the criteria listed below in Table 4-4.

Table 4-4 Sensor Audit Criteria and Frequency

Requirement Frequency Acceptance Criteria

Accuracy

Flow Rate Audit 4 per yr + 4% of audit standard

External Leak Check 4 per yr < 80 mL/min

Internal Leak Check 4 per yr < 80 mL/min

Temperature Audit 2 per yr + 2 o C

Pressure Audit 2 per yr ± 10 mm Hg

4.7.2 Reference Standard Traceability

The flow rate, temperature, and pressure standard apparatus used for audits will have a valid certification

stating its traceability to a NIST standard. The standards used for auditing the fiber monitor sensors will

be recalibrated and recertified at least annually.

14

5.0 Program for Corrective Action

5.1 Failed Control/Audit Limits

Specific measures will be implemented on an ongoing basis with the goal of achieving the data quality

objectives for this project. Quality control and audit limits are one measure used to evaluate the operation

of the monitor so that accurate results are achieved from the monitoring program. In the event that a

quality control or audit check shows operation of a sensor outside of quality control or audit limits, a

recalibration of the sensor will be performed using the field transfer standards. If the sensor is unable to

be recalibrated within the specifications listed in Table 4-1, a replacement sensor or parts will be ordered

immediately after troubleshooting the source of the failure. Monitor results will be flagged appropriately,

if the failed sensor is determined to have affected any previous measurements.

15

6.0 Recordkeeping and Reporting

6.1 Validation of Data

Validation of measurement data will require two stages, one at the instrument performance level, and the

second at the analytical level. Records of all invalid samples will be filed. Information will include a brief

summary of why the sample was invalidated along with the associated flags. Table 6-1 summarizes some

potential causes of invalid samples.

Table 6-1 Potential Invalid Sample Codes

Problem Explanation Error code

Flow rate < +/- 4% of 16.67 l/min AH

Filter Damage Tear or Hole in filter AJ

Sampler Malfunction Sample did not run AN

Power Failure Sample did not run AV

Leak Check Failure Leak Rate > 80ml/min AK

High Field Blank Contamination AQ

Vandalism Sample destroyed AP

Insufficient data Sampler data lost AI

Other flags may be used alone or in combination with those listed above to invalidate samples. Because

the possible flag combinations are overwhelming and cannot be anticipated, the flags will be reviewed

and a determination will be made whether single values or values from the site for a particular time period

will be invalidated. Records of the combination of flags that resulted in invalidating a sample or set of

samples will be maintained.

6.2 Frequency of Reporting

PolyMet will maintain records of fiber monitoring including field and laboratory data and data relevant to

any calibrations or audits performed. PolyMet will provide the fiber monitoring data to MPCA upon

request within 30 calendar days of the request. The data provided will include any results received from

the laboratory on or before the date of the request from MPCA.

6.3 Storage of Historical Results

All samples and results will be stored at PolyMet offices for a minimum of five years and will be available

upon request.

16

7.0 References

1. Minnesota Department of Health. T.E.M. Analysis for Mineral Fibers in Air - 852.

2. Minnesota Pollution Control Agency. Asbestos Fiber Air Monitoring Quality Assurance Project Plan.

DRAFT. November 2005.

3. Rupprecht & Patashnick Co., Inc. Partisol Model 2000 Air Sampler Operating Manual: Revision A (R&P

Part Number 42-002522). July 2004.

4. U.S. Environmental Protection Agency. Quality Assurance Handbook for Air Pollution Measurement

Systems, Volume II: Ambient Air Quality Monitoring Program. May 2013. Vols. EPA-454/B-08-003.

Large Figures

Peter Mitchell Mine

HOYTLAKES

BABBITT

PROCESSINGPLANT AREA

PLANT SITE

MINE SITE

TRANSPORTATION ANDUTILITY CORRIDORS

RAILROADCONNECTION

CORRIDOR

Partrid

ge River

Wyman CreekSecond Creek

ColvinCr

eek

Stubble Creek

Wetlegs Creek South Branch Partridge River

Yelp Creek

Unnamed Creek

Partridge River

UnnamedCreek

SpringM

ineCreek

LongnoseCreek

Unna

med C

reek

Embar

rass River

AREA 1 SHOPS

Colby Lake

Mud Lake Creek

Trimble Creek

135

4567138

456721

45671004567130

456726

4567110

SITE LOCATIONNorthMet Project

Poly Met Mining, Inc.

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EIS Project AreasPublic Waters Inventory (PWI) Watercourses1

National Hydrography Dataset (NHD)Rivers & Streams2

1These are provisional representations of PWI watercourses found on the current paper regulatory maps.2The NHD is a feature-based database that interconnects and uniquely identifies the stream segments orreaches that make up the nation's surface water drainage system. NHD features are created fromMnDNR 24K Streams and 1:24,000 USGS quadrangle maps.Note: Due to previous disturbance, both data sources may show watercourses that no longer exist.

MINNESOTA

PROJECT LOCATIONMesabi Iron Range

St. LouisCounty

Rainbow LakeWilderness

Voyageurs NP IsleRoyale

NPBWCAW

LakeSuperior

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PolyMet Fiber Monitoring and Quality Assurance Project Plan

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Transcript of PolyMet Fiber Monitoring and Quality Assurance Project Plan