Valero Welcome Plant Production Increase EAW · or 136 MMGY of undenatured ethanol, without adding...

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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 651-757-2101. An electronic version of the completed EAW is available at the MPCA website http://www.pca.state.mn.us/news/eaw/index.html#open-eaw. 1. Project Title: Valero Welcome Plant Production Increase 2.

Proposer:

Valero Renewable Fuels Company, LLC d/b/a Valero Welcome Plant

3.

RGU:

Minnesota Pollution Control Agency

Contact Person Tonya Klunder Contact Person Nancy Drach and Title HS&E Manager and Title Project Manager Address 1444 120th Street Address 520 Lafayette Road North Welcome, MN 56181 St. Paul, Minnesota 55155-4194 Phone 507-728-4015 Phone 651-757-2317 Fax 507-728-4050 Fax 651-297-8683 E-mail [email protected] E-mail [email protected] 4. Reason for EAW Preparation:

EIS Scoping

Mandatory EAW

X

Citizen Petition

RGU Discretion

Proposer Volunteered

If EAW or EIS is mandatory give EQB rule category

subpart number and name: Minn. R. 4410.4300, subp. 5.B Fuel Conversion Facilities

5. Project Location: County Martin City/Twp Rolling Green 1/4 S 1/4 Section 5,6 Township 102N Range 31W GPS Coordinates: N 43.66 W -94.58 Tax Parcel Number 420400455

p-ear2-22a TDD (for hearing and speech impaired only): 651-282-5332

Printed on recycled paper containing 30% fibers from paper recycled by consumers

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

mailto:[email protected]

Valero Welcome Plant Production Increase Environmental Assessment Welcome, Minnesota 2 Worksheet

Tables, Figures, and Appendices attached to the EAW: Tables Table 7-1 Stack Heights Table 8-1 Permits and Approvals Required Table 17-1 Stormwater Ponds Discharge (SD001 and SD002) Effluent Limit and Monitoring Requirements Table 22-1 Truck Traffic - Potential to Emit Table 22-2 After Project Maximum Annual Truck Traffic Table 23-1 Change in Potential Emissions Table 23-2 Stack Testing Results Table 23-3 MAAQS/NAAQS (Minnesota Ambient Air Quality Standards/National Ambient Air Quality Standards) Modeling Results Table 23-4 GHG (greenhouse gas) Emissions - Before and After Project Table 23-5 GHG Total Potential Emissions Table 23-6 Estimated GHG Emission Intensity Changes Table 29-1 After Project Cumulative Estimated Air Emissions Risk Analysis Results Figures Figure 1 – County map showing the general location of the project Figure 2 – United States Geological Survey 7.5 minute, 1:24,000 scale map indicating project boundaries Figure 3 – Site plan showing all significant project and natural features Figure 4 – Q/CHI Noncancer Acute Risks Map Figure 5 – Q/CHI Noncancer Chronic Risks Map

Appendices

Appendix 1 – Minnesota State Historic Preservation Office e-mail dated June 16, 2010 Appendix 2 – Greenhouse Gas Emission Inventory Appendix 3 – Estimated Chemical Emissions for the Existing and Post-Project Valero Welcome Plant

6. Description:

a. Provide a project summary of 50 words or less to be published in the EQB Monitor. Valero Renewable Fuels Company, LLC (Valero) proposes to increase production at its existing dry mill corn ethanol production facility (Valero Welcome Plant) located near Welcome in Martin County, Minnesota. Maximum production of 200-proof ethanol will increase from 118 million gallons per year (MMGY) to 136 MMGY; maximum Distiller’s Dried Grains with Solubles (DDGS) production will increase from approximately 320,000 tons per year (TPY) to approximately 450,000 TPY; and maximum corn throughput will increase from approximately 39 million bushels per year (MMBU/year) to approximately 50.4 MMBU/year. This increase will occur without adding new equipment, modifying the facility footprint, or appropriating additional water. The plant can accommodate this increase because it operates more efficiently than originally expected, and because its water use is significantly below the current appropriation. The Valero Welcome Plant will continue to utilize concentration/crystallization technology (also known as zero liquid discharge). The Valero Welcome Plant will continue to have only stormwater discharges.


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. The Valero Welcome Plant, located in Martin County, Minnesota (Figure 1) has been operating since June 1, 2009, and is currently permitted to produce 118 MMGY of undenatured ethanol. The Valero Welcome Plant does not discharge process or utility water. Because the Valero Welcome Plant is more efficient than originally expected, it can be operated at 115 percent of its current permitted capacity, or 136 MMGY of undenatured ethanol, without adding additional equipment, modifying the facility footprint, or appropriating additional water. Valero has conducted a process safety management evaluation of the Valero Welcome Plant at 115 percent of its current permitted capacity and determined that the Valero Welcome Plant can be operated safely at that rate. At 136 MMGY, the Valero Welcome Plant will utilize approximately 50.4 million bushels of corn per year. It will produce approximately 453,000 tons of DDGS or modified distiller’s grains with solubles (MDGS) per year. Existing Operation Ethanol is an alcohol that is used as a fuel additive or extender. It is produced by fermenting corn. The steps in ethanol production are preparing the feedstock, fermentation, distillation, recovering the alcohol, and recovering residual materials. The basis for the production of ethanol is to convert the starch in corn to sugars and then to convert the sugars to ethanol (i.e., grain alcohol). The Valero Welcome Plant receives corn by truck or rail inside a grain receiving building. See Figure 2 for facility layout. The corn is conveyed to storage bins until it is needed for processing. Any corn overflow or spillage that may occur during the offloading is swept up and placed with the corn load. The corn is processed through a milling process, called a hammermill, which finely grinds the corn. The ground corn is then conveyed to the process area. The corn is mixed with water to create a slurry. The slurry is injected with steam to cook it, and liquefacted with enzymes to break down the starch to sugars. The resultant mash is then moved into the fermentation process. The process of fermentation involves the conversion of sugars in the mash to ethanol and carbon dioxide (or CO2). In the fermentation process, yeast and enzymes are added to the mash and the mixture is allowed to ferment. After approximately 48 hours of fermentation, the resultant liquid (referred to as the “beer”) contains about 13 to 14 percent ethanol by weight. The beer is moved to the beerwell and then it is distilled in a three-column distillation process; the resulting liquid is 95 percent ethanol and 5 percent water (190-proof), with the remaining whole stillage consisting of solids and water. Using molecular sieves, the remaining 5 percent water is removed from the liquid ethanol product, resulting in 200-proof ethanol. Prior to shipping the ethanol, a denaturant (typically, natural gasoline) is added to the ethanol to render it unfit for human consumption. The remaining whole stillage is centrifuged to remove water. The removed water is evaporated and syrup remains. This syrup is typically combined with the centrifuged cake and dried in the dryers. The dryers are primarily fired by natural gas, but can be supplemented with biogas from the methanator. The resulting saleable product is sold as DDGS. Emissions from the dryers are controlled by thermal oxidizers (or TOs), which are also fired by natural gas. The TOs are combined with heat recovery steam generators (HRSGs), which recover condensate and turn it to steam that is reused in the production process.


Water generated in the process is recycled back into the slurry tank. Anhydrous ammonia is added in the ethanol production process to adjust the pH. No ethanol production process water is discharged from the Valero Welcome Plant. Denatured ethanol product is generally transferred to rail cars in the ethanol loadout area for shipping off site. The Valero Welcome Plant also has the capability to ship denatured ethanol by truck, though it is typically not shipped that way. Water that flows through the Valero Welcome Plant is classified as ethanol process water and non-contact utility water. Ethanol process water is recycled through the production process. All process water is recycled. Non-contact utility water consists of water that flows through the facility but is not used in the ethanol process. This water stream is composed of water from the cooling towers (cooling tower blowdown), water softener (regeneration process water), multimedia filters (backwash water), and reverse osmosis (RO) process reject water. The characteristics of a utility water stream typically reflect concentrated levels of the naturally occurring components of the groundwater (e.g., chlorides, sulfates, iron, etc.). At many ethanol facilities, this utility water stream is discharged from the facility to surface waters. However, at the Valero Welcome Plant, a brine concentrator/crystallization process is used to treat the non-contact utility water. The brine crystallizer/evaporation system concentrates the non-contact utility water. The evaporated water is recycled. The crystallized solids are disposed of in a landfill. As a result of this treatment system, there is no discharge of utility water to surface waters from the Valero Welcome Plant. Project The Valero Welcome Project will require no new construction. It will require additional receipts of corn, additional trucks to receive the corn, additional throughput of product through the site storage tanks, additional loadout of denatured ethanol product to rail cars or trucks, and shipping of additional DDGS/MDGS by truck. Potential environmental impacts were initially assessed for the construction of this plant in the September 22, 2006, EAW (the 2006 EAW) for the proposed VeraSun Welcome, LLC (previous owner) Ethanol Facility. This EAW addresses potential environmental impacts due to the proposed production increase.

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. The purpose of the Project is to produce additional ethanol and protein-rich animal feed. The modification will provide additional market for local corn growers and make additional DDGS/MDGS feed available for local livestock farmers.

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


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 Valero Welcome Plant was initially constructed with a nameplate capacity of 110 MMGY of undenatured ethanol, and was permitted to produce 118 MMGY of undenatured ethanol. At the time of initial construction, it was not expected that the Valero Welcome Plant would produce undenatured ethanol at a higher throughput than permitted without construction of additional equipment. However, process efficiencies within the Valero Welcome Plant have been identified that will allow production of undenatured ethanol at 136 MMGY. As noted, the original VeraSun Welcome plant project was evaluated by the MPCA in the 2006 EAW, and a findings of fact for a negative declaration on the need for an Environmental Impact Statement for that project was signed in October 2006. In addition, MPCA air emissions, National Pollutant Discharge Elimination System/State Disposal System (NPDES/SDS), and aboveground storage tank (AST) permits, as well as the Minnesota Department of Natural Resources (DNR) Water Appropriation Permit, were issued in 2006.

7. Project Magnitude Data

All of the following represents the facility, as planned and constructed in 2006-2008. No changes to the following are required for the proposed modification

Total Project Area (acres) 395 total property,

103 plant construction or Length (miles) Approximately 12.8

miles of rail

Number of Residential Units:

Unattached

NA

Attached

NA

Maximum Units Per Building:

NA

Commercial/Industrial/Institutional Building Area (gross floor space):

total square feet

720,000

Indicate area of specific uses (in square feet):

Office 3,500 Manufacturing 555,150 Retail 0 Other Industrial Energy Center 31,350 Warehouse 0 Institutional Light Industrial 0 Agricultural

Other Commercial (specify) Storage tanks (including containment) and cooling tower 130,000

Building height

42 feet

If over 2 stories, compare to heights of nearby buildings

25-40 feet

The energy center is 37 feet tall, grain bins are 150 feet tall, and the process building is 34 feet tall. Stack heights are shown in the Table 7-1.


Table 7-1 Stack Heights Stack/Vent Height (ft) Stack/Vent Height (ft) Grain Receiving Baghouse Stack 150 Cooling Tower Cell #4 34 DDGS Baghouse Stack 150 Fire Pump Stack (test only) 15 Hammermill Baghouse Stack 150 190-Proof Tank 34 CO2 Scrubber Stack 75 200-Proof Tank 34 TO/HRSG Stack 125 Denaturant Storage Tank 34 Vapor Combustion Unit 30 Denatured Ethanol Storage Tank #1 53 Cooling Tower Cell #1 34 Denatured Ethanol Storage Tank #2 53 Cooling Tower Cell #2 34 Cooling Drum By-Pass 48 Cooling Tower Cell #3 34 No new construction of equipment, infrastructure, or buildings will be required to accommodate the production increase.

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. All of these final decisions are prohibited until all appropriate environmental review has been completed. See Minn. R. 4410.3100.

Table 8-1. Permits and Approvals Required Unit of Government Type of Application Status MPCA Total Facility (Air) Permit Application

09100062 - 004 Submitted

MPCA NPDES/SDS Permit MN0068161 Reissuance, with modifications

Submitted

The MPCA air emissions permit 09100062-003 will be modified to address emissions at the higher permitted capacity. Air emissions are discussed further in Item 23. The MPCA NPDES/SDS Permit MN0068161 will be modified so that the facility description in the permit reflects the new permitted capacity and corn throughput. Valero has also requested approval to decommission the emergency on-site brine storage basin. This is discussed further in Section 18.b. The project will not require any modification of the MPCA AST Permit. The project will not require any modification of the existing DNR Water Appropriation 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. Adjacent land use surrounding the Valero Welcome Plant has not changed since it was constructed. The land adjacent to the Valero Welcome Plant location is primarily in active agricultural production. The site is bordered by swine production facilities to the west and northeast, an active rail line to the north, and


one homestead directly south. An active grain elevator is located approximately one mile to the northwest. Ten houses are within approximately one mile of the Valero Welcome Plant. No environmental conflicts or past hazards resulting from the plant or its previous uses, including known soil or water contamination, have been identified, nor are they expected from this modification.

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 3.2 3.2 Lawn/landscaping 5 5 Wooded/forest 0 0 Impervious Surfaces 26.3 26.3 Brush/grassland 0.4 0.4 Stormwater pond 2 2 Cropland 331.1 331.1 Other (railroad) 27 27 TOTAL 395 395

No changes in cover type will result from the modification.

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 EAW prepared in 2006 identified no significant fish or wildlife resources or habitats on or near the site that would be disturbed or affected as a result of the plant construction and operation. To date, no apparent impacts to fish or wildlife or their habitats have been observed as a result of the Valero Welcome Plant construction and operation. As no physical or structural changes will be made to the Valero Welcome Plant, no new impacts are expected.

b. Are any state (endangered or threatened) species, rare plant communities or other sensitive ecological resources on or near the site? Yes No

If yes, describe the resource and how it would be affected by the project.

A National Heritage and Nongame Research database review (Appendix 1) was conducted in June 2010 to determine if any fish or wildlife resources or habitats would be affected by the project. As determined for the 2006 EAW, no known locations of threatened and endangered species were identified within the sections around the Valero Welcome Plant. As noted in the 2006 EAW, the database listed a rare southern mesic prairie plant community located within the Union Pacific Railroad right-of-way within one mile to the east of the plant (Figure 3). The southern mesic prairie community is listed as rare in the database, but does not have state or federal protected status. The proposed project includes no construction or modification to the Valero Welcome Plant, so the identified resource will not be affected.


Describe any measures that will be taken to minimize or avoid adverse impacts. Provide the license agreement number (LA-501) and/or Division of Ecological Resources contact number (ERDB____) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources. Indicate if any additional survey work has been conducted within the site and describe the results. No additional survey work was conducted, because the modification does not include new construction or use of additional land outside the Valero Welcome Plant boundary.

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 and give the DNR Public Waters Inventory (PWI) number(s) if the water resources affected are on the PWI. Describe alternatives considered and proposed mitigation measures to minimize impacts. No physical modifications will be made to the Valero Welcome Plant and, therefore, the project will not involve the physical or hydrologic alteration of any surface water.

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. As noted above, this project will not require new water wells, new public water supply connections, or new appropriations permitting. The Valero Welcome Plant is currently authorized under DNR Water Appropriation Permit Number 2005-4066 to appropriate water from two wells at a total rate not to exceed 1,090 gallons per minute or 482 MMGY. This project will not require the Valero Welcome Plant to request an increase above the authorized amount in the current DNR Water Appropriation Permit; therefore, a modification to the DNR Water Appropriation Permit will not be necessary. A revised DNR Water Appropriation Permit will be pursued in the near future, but the change is not associated with this Project, and it will not change the amount of the appropriation. One of the two Valero Welcome Plant wells was damaged and is being replaced with a new well in the same hydrogeologic formation. The DNR Water Appropriation Permit will be revised to update the well number of the replaced well.

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

15. Water Surface Use. Will the project change the number or type of watercraft on any water body? Yes No


16. Erosion and Sedimentation. Give the acreage to be graded or excavated and the cubic yards of soil to be moved: 0 acres; 0 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. When the Valero Welcome Plant was originally built, approximately 103 acres were graded or excavated. Because the modification requires no additional construction at the Valero Welcome Plant, no new acreage will be graded or excavated.

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. Stormwater is collected on site and diverted through a series of ditches to one of two stormwater detention ponds, with discharge points discharging to a ditch along State Highway 90. The two stormwater discharge points, which are manually controlled, have both monitoring and effluent requirements. As required by the NPDES/SDS Permit MN0068161, the Valero Welcome Plant has a Stormwater Pollution Prevention Plan (SWPPP) that identifies housekeeping and structural and non-structural best management practices used to minimize exposure of grain, feed, denatured ethanol product, and chemicals to stormwater. The SWPPP also addresses facility inspections, personnel training, recordkeeping, and reporting. Because there are no physical changes to the Valero Welcome Plant as part of this modification, there will be no change in the quantity and quality of site runoff or controls. The SWPPP will not require modification to address changes in significant materials or stormwater exposure because there will be no change in materials or exposure; however, the SWPPP may need to be updated to reflect changes in the NPDES/SDS Permit MN0068161 (e.g., stormwater inspection frequencies).

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. Both stormwater detention ponds, discussed in (a) above, discharge to ditches (Surface Discharge Stations SD001 and SD002) along State Highway 90, which in turn discharge to a tributary of Swan Slough, then into Eagle Lake, which is the head waters of Lily Creek. There is no expected change in the water quality or quantity of stormwater because of the project. Table 17-1 lists the NPDES/SDS Permit MN0068161 limit and requirements applicable to the Valero Welcome Plant stormwater ponds’ discharges.


Table 17-1 – Stormwater Ponds Discharge (SD001 & SD002) Effluent Limits and Monitoring Requirements Parameter Limit Units Limit Type Effective

Period BOD1, Carbonaceous 05 Day (20 Deg C)

25 mg/L Calendar Month Average

Jan-Dec

Duration of Discharge Monitor Only day/ month

Calendar Month Total Jan-Dec

Ethanol (Ethyl Alcohol) Monitor Only ug/L Calendar Quarter Average

Jan-Dec

Flow Monitor Only MGD Calendar Month Average

Jan-Dec

Flow Monitor Only MGD Calendar Month Maximum

Jan-Dec

Flow Monitor Only MG Calendar Month Total Jan-Dec Organics, Gasoline Range as gasoline, Total

Monitor Only ug/L Calendar Quarter Maximum

Jan-Dec

pH 6.0-9.0 SU Calendar Month Min/Max

Jan-Dec

Phosphorus, Total (as P) Monitor Only mg/L Calendar Month Average

Jan-Dec

Solids, Total Suspended (TSS) 30 mg/L Calendar Month Average

Jan-Dec

Specific Conductance Monitor Only umh/cm Calendar Month Average

Jan-Dec

1 Bio-chemical oxygen demand

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

produced or treated at the site. No process wastewater is discharged from the Valero Welcome Plant, nor will it be discharged following the modification. All process wastewater is recycled back through the production process. Non-process (utility water) including cooling tower blowdown, softener, multimedia filters, and reverse osmosis reject water is treated in a brine concentrator/crystallization process (discussed further in (b)). The process used by the Valero Welcome Plant is considered a Zero Liquid Discharge, or ZLD, in the industry. Sanitary wastewater generated from restrooms, break rooms, and the on-site production support laboratory is discharged to the city of Welcome wastewater treatment facility.


b. Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment. Identify receiving waters, including major downstream water bodies (identifying any impaired waters), 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. No new waste treatment methods will be used as a result of the modification, nor will there be any discharges to receiving waters. The Valero Welcome Plant currently operates a water treatment facility that serves to treat groundwater for use in the plant. Residuals from the water treatment include treatment sludge, multimedia filter cleaning backwash, and reverse osmosis reject water. These residuals generally consist of concentrates of the naturally occurring minerals in the groundwater and chemicals used in the treatment process to help remove those minerals (brine). These residuals are further treated in a filter press and the brine concentrator/crystallizer that further removes water and results in a salt mix that is disposed off site at a licensed solid waste facility. The water treatment facility is designed to treat groundwater at approximately 900 gallons per minute. At design capacity, the plant generates approximately 22 tons per day of solid waste for disposal. At current production capacity, the plant has utilized approximately 510 gallons per minute and generated an average of approximately 17 tons per day of solid waste. After the proposed modification, the plant will utilize approximately 570 gallons per minute and generate an average of 20 tons per day of solid waste. The Valero Welcome Plant has an on-site storage basin that was authorized on an emergency back-up basis to store high-solids rinse or cleaning water (reject brine) from the water treatment system brine crystallizer that could not be recycled or stored in water treatment system tanks. Storage was allowed for a maximum holding time of 90 days. There has been no use of the emergency storage brine pond since it was constructed. The revised NPDES/SDS Permit MN0068161 for the Valero Welcome Plant will allow for decommissioning of the emergency storage basin because brine waste can be managed via other permitted disposal methods discussed below. The Valero Welcome Plant has previously applied for, and received, Industrial Discharge Permit #2303 from Metropolitan Council Environmental Services (MCES) that allows for disposal of reverse osmosis concentrate at the Metropolitan Wastewater Treatment Plant (MCES Metro WWTP) in St. Paul, Minnesota. The MCES Metro WWTP has an NPDES/SDS Permit MN0029815. Industrial Discharge Permit #2303 was obtained as a contingency measure that would allow for hauling and disposal of this concentrate in abnormal situations. That permit will not be required to be modified as a result of this project. The NPDES/SDS Permit MN0068161 for the Valero Welcome Plant includes monitoring and reporting requirements when, under an abnormal situation, Valero must transport reverse osmosis brine concentrate to the MCES Metro Plant. As part of the initial construction of the storage basin, the Valero Welcome Plant was required to conduct groundwater sampling around the basin to establish background groundwater chemistry and groundwater flow information. Since the pond is scheduled for decommissioning and removal, the wells will be abandoned and sealed.


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. Under normal operation, neither the current Valero Welcome Plant nor the project includes wastes, other than sanitary waste, being discharged into a publicly owned wastewater treatment facility. See Item 18(a) for a discussion on sanitary wastes.

19. Geologic hazards and soil conditions. a. Approximate depth (in feet) to Groundwater: 90 minimum; 106 average. Bedrock: 275 minimum; 435 average.

Describe any of the following geologic site hazards to groundwater 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. No geologic site hazards or karst conditions exist at the site.

b. Describe the soils on the site, giving Natural Resources Conservation Service classifications, if known. Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils. Discuss any mitigation measures to prevent such contamination. As discussed in the 2006 EAW, the Natural Resource Conservation Service’s Soil Survey Geographic Database identifies the soils at the site as Clarion loam, 1 to 6 percent slopes, Webster clay loam, Crippin loam, Nicollet clay loam, Delft loam, Clarion-Swan lake loams, 2 to 6 percent slopes, Clarion-Storden loams, 6 to 12 percent slopes, and Canisteo-Glencoe clay loams. The Valero Welcome Plant storage tanks and load in/load out areas have containment structures for capturing spills, if they were to occur. Mitigation measures for preventing soil and groundwater contamination include implementation of a SWPPP and Spill Prevention, Containment and Countermeasures Plan.

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. Solid wastes generated from the water treatment facility at the Valero Welcome Plant were discussed in Item 18.b. These wastes consist of the following major compounds: magnesium sulfate, calcium carbonate, and water. They also include minor constituents of ferrioxyhydroxide, manganese dioxide, and strontium carbonate. The wastes are currently disposed off site at a licensed solid waste disposal facility in Spirit Lake, Iowa.


Hazardous wastes generated by the Valero Welcome Plant include laboratory wastes and waste acids and bases from the water treatment plant. The plant has U.S. Environmental Protection Agency (EPA) hazardous waste registration Number MNS000132902.

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 groundwater. 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. Ethanol, natural gasoline used as a denaturant, and sulfuric acid are stored at the Valero Welcome Plant in Aboveground Storage Tanks (ASTs). The ASTs are located in outdoor secondary containment areas. No new toxic or hazardous materials will be used on-site as a result of the project.

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 Valero Welcome Plant currently has a lined (secondary containment) tank farm, which is where the existing ASTs are located (Figure 3). A sulfuric acid AST is also located within a secondary containment structure on the south side of the fermentation/distillation building. The facility holds MPCA Aboveground Major Facility Permit Number 124184, which addresses ASTs in the tank farm and the sulfuric acid AST. Each tank in the tank farm is equipped with electronic overfill protection, electronic level gauge, and emergency relief valve. ASTs in the tank farm storing 190-proof ethanol, 200-proof ethanol, denatured ethanol, and denaturant have internal floating roofs, which help control air emissions from the tank. All tanks in the tank farm and the sulfuric acid tank have secondary containment sized to hold 110 percent of the contents of the largest tank, as well as runoff from a 25-year storm event. Product transfers occur on concrete containment. No new regulated ASTs will be added for this project, so the MPCA Aboveground Major Facility Permit 124184 will not be modified.

21. Traffic. Parking spaces added: 0 Existing spaces (if project involves expansion): 50 Estimated total average daily traffic generated: 370 vehicles

Estimated maximum peak hour traffic generated and time of occurrence: 90 percent between 7:30 am and 4:30 pm

Indicate source of trip generation rates used in the estimates.

Roads in the vicinity of the Valero Welcome Plant include Interstate 90 (one mile to the north), Minnesota 263 (one mile to the west), and County Road 26 (120th Street) bordering the south boundary of the facility. Additionally, the Valero Welcome Plant property is bordered to the west by 140th Avenue and to the east by 150th Avenue. All traffic enters the facility off 120th Street. Increased vehicle traffic is anticipated due to the increase in grain receiving and DDGS/MDGS shipping. The Valero Welcome Plant has the capability to ship ethanol by truck; however, most ethanol is shipped by rail. Traffic rates are discussed further in Item 22. Traffic congestion is not anticipated as a result of the modification. In fact, the modification seeks to relieve congestion that occurs under the current


permit constraints on truck traffic through the Valero Welcome Plant. For example, corn truck deliveries to the Valero Welcome Plant are currently limited to 135 trucks per day. Local farmers delivering corn do not want to be turned away as the 136th or later truck of the day. Therefore, many trucks arrive at the Valero Welcome Plant as early as possible in the day, and as a result, get backed up on the entrance road, and even 120th Street. By increasing the flexibility in truck throughputs, trucks will more freely flow through the Valero Welcome Plant, resulting in less congestion on the Valero Welcome Plant roads and on 120th Street. The maximum daily truck traffic following the project will be 520 trucks in May through October, and 320 trucks in November through April.

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. The following table summarizes the potential to emit from truck traffic at the existing Valero Welcome Plant and after the project is completed. Table 22-1. Truck Traffic – Potential to Emit PM (tpy) PM10 (tpy) PM2.5 (tpy) Current Paved Road Emissions 30.06 5.87 2.01 After Project Paved Road Emissions 60.76 12.15 2.98 PM = Particulate Matter PM10 = Particulate Matter less than 10 micron aerodynamic diameter PM2.5 = Particulate Matter less than 2.5 micron aerodynamic diameter The post production increased paved road emissions estimates calculated above are based on truck traffic activity summarized in the following table: Table 22-2. After Project Maximum Annual Truck Traffic Activity

Quantity Transported By

Truck

Number of Trucks Per Year

Miles Traveled Per

Truck

Vehicle Miles Traveled Per

Year Grain Receiving 1,410,370 tons 56,415 1.7 95,905 DDGS/MDGS Shipping 453,333 tons 18,133 1.7 30,827 Ethanol Shipping1 139,400,000 17,425 1.7 29,623 Denaturant Delivery 3,400,000 gallons 425 1.7 723 WTF Waste Shipping/ Chemical Delivery

Average 20 trucks per day

7,300 1.7 12,410

1 To date, all ethanol has been shipped by rail; paved road emissions conservatively account for all ethanol being shipped by truck. Vehicle combustion emissions are not directly regulated, but these emissions have the potential to effect air quality in the vicinity of the Valero Welcome Plant. In an effort to minimize vehicle combustion emissions, including ozone-depleting compounds (e.g., carbon monoxide, nitrogen oxides, sulfur dioxide), the Valero Welcome Plant has developed and implemented a diesel idling prevention plan in accordance with its MPCA air emissions permit. This plan contains procedures to minimize truck idling, thereby minimizing vehicle combustion emissions.


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 CO2, methane, and nitrous oxides), and ozone-depleting chemicals (chlorofluorocarbons, hydrofluorocarbons, perfluorocarbons or sulfur hexafluoride). Also describe any proposed pollution prevention techniques and proposed air pollution control devices. Describe the impacts on air quality. The Valero Welcome Plant currently operates in accordance with requirements listed in the MPCA Air Emission Permit Number 09100062-003. The current facility is a synthetic minor source with respect to the Federal Prevention of Significant Deterioration (PSD) and Title V regulations under the Clean Air Act. Because of the proposed project, a total facility permit application was submitted to MPCA concurrently with the EAW. The project will result in the Valero Welcome Plant being subject to Title V regulations, but the Valero Welcome Plant will remain a synthetic minor source under PSD. This is based on emissions from point sources, such as stacks, and nonpoint, or fugitive emissions, such as paved road dust. Sources of Air Emissions and Pollution Control Equipment The following is a summary of air emission sources and emission control equipment at the Valero Welcome Plant. Corn Receiving, Handling and Storage. Corn is received at the Valero Welcome Plant in a receiving building, via truck and rail. Currently, most of the corn is received by truck. The corn is then transferred through an outside conveyer/elevator system to one of five concrete storage bins. It is then moved to a surge bin, passed through a scalper cleaner, and ground in the hammermill system. Particulate emissions from the truck unloading area, elevators, conveyers, and corn bins are exhausted through a negative pressure ventilation system, which continuously pulls air from these sources through a baghouse for dust control. Corn Milling. Milled corn from the hammermill is conveyed to the slurry blender, where it is mixed with water and other ingredients to start the conversion process. Dust emissions from the hammermills and all associated equipment pass through a baghouse dust collector before discharging to the atmosphere. Batch Fermentation. The process of fermenting sugar to ethanol produces CO2 as a major byproduct. Fermentation occurs in seven batch fermentation tanks. CO2 vented from the fermentation tanks and the beerwell is routed to the inlet of a direct contact water scrubber. The gas entering this scrubber flows through a packed bed with water flowing through the bed in a counter-current direction. This water is returned to the process stream via a continuous discharge from the scrubber. CO2, along with minor amounts of other non-condensing gases and other components, exits the scrubber and is vented to the atmosphere. Distillation/Dehydration. The fermentation process results in beer, which goes through a continuous vacuum distillation system to remove and rectify the ethanol. The vapor from the distillation column is piped to a set of condensers that discharge liquid ethanol to the 190-proof reservoir. Non-condensable gases and CO2 contained in the beer move into the 190-proof reservoir and must be exhausted to maintain a vacuum in the system. The gases are vented to a thermal oxidizer (TO) before being discharged to the atmosphere.


DDGS/MDGS Drying, Storage and Shipping. Distiller’s grain is dried in a rotary dryer system using natural gas as the heating source. Exhaust from the dryers is initially sent to cyclones to separate any entrained dried grain from the exhaust stream. The exhaust from the cyclones is routed to a TO where it is exposed to high temperatures, which destroy almost all remaining organic components and most particulates. The exhaust, containing moisture from the drying process and minor levels of other components, is routed through a TO/HRSG and then is vented to the atmosphere. Steam recovered from the TO/HRSG is used for cooking, distilling, evaporating, and other Valero Welcome Plant uses. The DDGS is cooled to ambient temperature in a drum cooler, and then conveyed to the storage facility, comprised of two concrete storage bins and a flat storage building. The DDGS is loaded onto trucks and rail cars for shipping from the plant. Emissions from all equipment in the DDGS storage and loading area pass through a baghouse dust collector before discharging to the atmosphere. Ethanol Storage and Shipping. Ethanol is pumped from the distillation/dehydration system to the 190-proof storage tank in the tank farm. From this tank, it is processed through the molecular sieves to remove water, and pumped to the 200-proof storage tank. The ethanol is then transferred to one of the two 1,785,000-gallon denatured ethanol storage tanks and is denatured with no greater than 2.5 percent natural gasoline pumped from the denaturant storage tank. The denatured ethanol can be shipped from the plant in trucks or rail cars. To date, all ethanol has been shipped by rail. Emissions from the truck and rail car loading facilities are controlled using a vapor recovery system and a flare. The following table summarizes the change in potential emissions resulting from the modification and the new potential to emit (PTE) for the Valero Welcome Plant after the project is completed, including fugitive emissions.

Table 23-1. Change in Potential Emissions Pollutant

Current PTE (tpy)

PTE Change (tpy)

After Project PTE (tpy)

PM 94.4 72.9 167.3 PM10 69.0 6.7 75.7 PM2.5 (1) 58.7 CO 98.4 30.5 128.9 NOx 96.0 23.9 119.9 SO2 80.8 -0.2 80.6 VOC 95.3 2.1 97.4 Highest HAP 9.0 -4.8 4.2 Total HAPs 20.4 -4.5 15.9

1PM2.5 was not included in previous versions of the permit or applications. CO = carbon monoxide NOx = nitrogen oxide SO2 = sulfur dioxide VOC = volatile organic compound HAP = hazardous air pollutants As part of its existing MPCA Air Emission Permit 09100062-003, the Valero Welcome Plant is required to conduct stack testing to demonstrate that emissions from certain sources are less than permitted values. The following table summarizes the results of stack testing conducted at the Valero Welcome Plant in October and November 2009 and October 2010 for the current operation.


Table 23-2. Stack Testing Results Emission Source Pollutant Tested Permit Limit (lb/hr) Test Result (lb/hr) Receiving Baghouse PM 1.71 0.17 PM10 1.71 0.60 DDGS Baghouse PM 0.34 0.06 PM10 0.34 0.12 Hammermill Baghouse PM 0.82 0.06 PM10 0.82 0.14 CO2 Scrubber VOC 8.87 5.68 Acrolein Plantwide individual

HAPs <9 tons/yr, cumulative <24 tons/yr

<0.00002 Acetaldehyde <0.263 Formaldehyde <0.060 Methanol <0.128 TO/HRSG PM 9.31 0.16 PM10 9.31 3.52 VOC 6.06 3.82 Acrolein Plantwide individual

HAPs <9 tons/yr, cumulative <24 tons/yr

<0.30 Acetaldehyde <0.41 Formaldehyde <0.08 Methanol <0.33 Cooling Drum Bypass PM 1.0 ton/yr 0.13 PM10 0.26 VOC <5.0 <1 ton/yr The results of this analysis demonstrate that actual emissions are well below permitted limits and well below the potential to emit for the Valero Welcome Plant. The Valero Welcome Plant will remain a synthetic minor source of HAPs because the potential to emit will be less than 25 tons per year for total HAPs and less than 10 tons per year for any individual HAP. The Valero Welcome Plant is not a regulated source category under the National Emission Standards for Hazardous Air Pollutants (NESHAPs) under 40 CFR Part 61, nor does it fall under an area source (non-major) source category in the NESHAPs under 40 CFR Part 63. Air Dispersion Modeling – Criteria Air Pollutants Air dispersion modeling was conducted to evaluate ambient impacts of criteria pollutants, NO2, CO, PM10, PM2.5, and SO2, and for attainment of National Ambient Air Quality Standards (NAAQS) and Minnesota Ambient Air Quality Standards (MAAQS). This modeling evaluates whether worst-case emissions (in lb/hr or ton/year), when released from the plant and dispersed to potential receptors at the property boundary, will result in air concentrations (micrograms per square meter [ug/m3]) above standards established as safe for human exposure. The modeling also included existing nearby and regional air emission sources of NO2, PM10, PM2.5, CO and SO2 and pollutant concentrations in the ambient air (i.e., background conditions). The NAAQS modeling was conducted using the “paired sums” technique for 24-hour PM 2.5 NAAQS modeling and one-hour NO2 NAAQS modeling. In April 2010, the MPCA requested approval from the EPA to use the “paired sums” technique. The MPCA also requested the EPA to provide its written comments to the MPCA no later than June 15, 2010. To date, the MPCA has not received a response or approval from the EPA. Therefore, the air dispersion proceeded with the “paired sums” approach. Joint efforts by the EPA and the National Association of Clean Air Agencies PM2.5 background concentration


subgroup are moving forward with the “paired sums” approach. In January 2011, this subgroup recommended that the AERMOD model be revised to accommodate background concentrations on an hour-by-hour basis; the latest version of the AERMOD model (version 11059) now includes this option. Dispersion modeling was also conducted for PM10 in order to demonstrate compliance with the PSD Class II increment. The PSD increments represent the allowable increase in modeled pollutant concentrations above a baseline concentration, with the baseline concentration representing air quality at the minor source baseline date. That is, back in 1999, a large source was constructed elsewhere in the county; as a result, new facility construction or facility modification (such as Valero Welcome Plant) within the county must have low enough emissions so that existing air quality at the property boundary is not degraded. Nearby increment consuming sources evaluated in the analysis included the following: Lakefield Junction, Buffalo Lake Energy, and Cenex Harvest States. The primary modeling driver at the Valero Welcome Plant was fugitive dust from the haul roads and grain receiving. For many plants in Minnesota located outside of Martin County that contemplate similar modifications, the driving standard would be the NAAQS for 24-hour PM10, or 150 ug/m3. For this modification, the driving standard is the PSD increment for 24-hour PM10, or 30 ug/m3. Current MPCA policy is to limit PSD increment consumption by any single project to one significant impact level, which is 5 ug/m3 for 24-hour PM10 , below the increment standard, which, for 24-hour PM10, is 30-5 = 25 ug/m3. The Valero Welcome Plant is located in a rural location with the maximum modeled PM10 increment impacts occurring at the facility’s fence-line. As the likelihood is low that the availability of increment would negatively impact future development near the Valero Welcome Plant, the MPCA has determined that a consumption of increment up to the federal standard of 30 ug/m3 would be allowed for this project on a temporary basis. However, the amended air permit will require that Valero: 1) submit a notification to the MPCA, within one year of permit issuance, documenting how the company intends to demonstrate compliance with the MPCA’s PM10 24-hour PSD increment policy standard of 25 ug/m3, and 2) submit a report to the MPCA, within two years of permit issuance, that demonstrates modeled compliance with the standard. The 24-hour PM2.5 and 1-hour NO2 NAAQS modeling was conducted by pairing hourly Valero Welcome Plant and nearby source impacts with hourly background data. Supplemental 1-hour NO2 NAAQS modeling tests (including nearby sources and hourly background concentrations) were performed to test three different EPA NO2 modeling options:

• Tier 1 assumes full conversion of NO to NO2 (very conservative worst-case) • Tier 2 assumes 75 percent conversion of NO to NO2 (annual Ambient Ratio Method [ARM]) • Tier 3 assumes variable conversion of NO to NO2 (Ozone Limiting Method [OLM] using hourly ozone

monitoring data from Marshall, Minnesota)

The modeling, as indicated in Table 23-3, determined that the Valero Welcome Plant will meet MAAQS and NAAQS (including the new federal NAAQS for 1-hour NO2 and 1-hour SO2) and attainment with the annual and 24-hour PM10 PSD increment has been demonstrated.


Table 23-3. MAAQS/NAAQS Modeling Results

Model Run Pollutant Averaging

Period Standard (µg/m3)

Maximum Modeled Ambient Impacts for Valero Sources (µg/m3)

Total Modeled Ambient Impacts

Including Background and Nearby Sources

(µg/m3) PSD Increment

PM10 24-hour 30 29.99 NA

Annual 17 5.1 NA NAAQS

PM10 24-hour 150 28.5 62

Annual 50 4.4 36

PM2.5 24-hour 35 6.2 31.8 Annual 15 1.6 12.8

NO2

1-hour 188

136 (Tier 1: 100%) 102 (Tier 2: ARM) 85 (Tier 3: OLM)

170 (Tier 1: 100%) 137 (Tier 2: ARM) 131 (Tier 3: OLM)

SO2 1-hour 196 15 164 Annual 80 0.3 20

CO 1-hour 2,000 153 NA 8-hour 500 50 NA

Air Emissions Risk Analysis (AERA) Process The MPCA developed the AERA process to provide: 1) streamlined health review of facility air emissions, and 2) a consistent format for presenting quantitative risk estimate, along with contextual qualitative information. An AERA estimates cancer and non-cancer risks to human health from a proposed project and/or existing facility. Facility risk guidelines, which are consistent with EPA guidance, were developed by the MPCA in consultation with the Minnesota Department of Health. The guidelines were established such that the increased chance of a person getting cancer over the course of their lifetime from exposure to the carcinogenic chemical emissions from a given facility should not exceed 1 in 100,000. The facility guideline for non-carcinogenic chemicals is that the sum of the risks (called the “hazard index”) should not exceed 1. If emissions from a facility result in estimated risks in excess of these levels, MPCA staff evaluates whether further refinement, further investigation, or modifications are warranted. All quantitative risk estimates have uncertainty related to the following factors: air emission estimates, air dispersion modeling, exposure assumptions, and toxicity information. These uncertainties are considered qualitatively within the AERA process and assumptions are made to minimize the potential for understanding risks. Interested readers can find more detailed information on the air risk analysis process at http://www.pca.state.mn.us/air/aera.html. Valero Welcome Plant AERA Evaluation The Valero Welcome Plant AERA looked at emissions for both the existing facility and facility post proposed production increase (Appendix 3). Potential health risks were estimated from 28 pollutants from 15 different emission sources from the Valero Welcome Plant after the proposed project was completed. The estimated change in potential health risks after the proposed project was completed

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


were well below risk driver levels (0.1 for hazard indices and 1 in 1 million for cancer risks). Overall, the maximum screening and refined risk results for the Valero Welcome Plant, after the completion of the project, for both inhalation and multi-media exposures, were below MPCA risk guidelines. The refined modeling showed the maximum potential risks from one hour of exposure (acute) to be along the northern fence line and diminishing with distance from the property boundary (Figure 4). The refined modeling showed the maximum potential risks from long term exposure (chronic) to occur along the north part of the western fence line and diminishing with distance from the property boundary (Figure 5). The multimedia exposure risks, which include inhalation and non-inhalation pathways, were assessed in the AERA screening analysis for a hypothetical residential and farming exposure scenario. All chemicals contributing to the non-inhalation risks were due to natural gas combustion and were well below facility risk guidelines at all locations. The residential exposure scenario assumes that the resident breathes the air 24 hours a day at the location of maximum modeled air concentrations and ingests soil and eats vegetables grown at that location. The farming exposure scenario has the same assumptions as the residential scenario and, in addition, assumes that the person raises and eats beef, pork, and chicken, and also consumes milk and eggs produced from the animals raised on forage grown at the location of maximum predicted air concentrations. This assumes that the air pollutants deposit onto the animal feed. No fisher pathway analysis was conducted because the chemicals contributing to fisher risks were due to natural gas combustion. Natural gas has a low level of emissions of pollutants that are considered persistent, bio-accumulative or toxic through ingesting fish. The pollutants that contributed the most to the risk estimates were acrolein (which was evaluated for respiratory effects), nitrogen oxide (which was evaluated for respiratory effects), and acetaldehyde (which was evaluated as a carcinogen). The air emissions were estimated from previous stack testing results at the Valero Welcome Plant, the Air Emission Permit 09100062 limits, EPA’s AP-42 air emission factors, EPA’s air emission calculation program for tanks (TANKS), air emissions stack testing results from other ethanol plants, and engineering estimates. The AERA did not include risk estimates from on-site vehicles at the Valero Welcome Plant for the following reasons: under typical operating conditions the Valero Welcome Plant will not have vehicles in line idling continuously for long periods of time, the Valero Welcome Plant has an idling prevention plan that requires drivers to turn engines off when they are in the staging area for more than 10 minutes, and there is no standard method for estimating risks from vehicles on the project level.

Greenhouse Gas (GHG) Emissions Potential GHG emissions were estimated for both the existing Valero Welcome Plant and after completion of the Project, and a summary of the results is shown in the following table:


Table 23-4 GHG Emissions –Before and After Project

Emission Sources

Existing Facility Emissions

(metric tons CO2-e/yr)

Facility Emissions After Project

(metric tons CO2-e/yr) Stationary Combustion DDGS dryers 78,875 78,875 Thermal Oxidizers 153,111 153,111 Water Treatment Facility Boiler 7,766 7,766 Biomethanator Flare 2,969 2,969 Ethanol Loadout Vapor Combustor 6,449 6,449 Fire water pump 117 117 Biogenic Process Emissions CO2 Scrubber 348,435 401,586 Mobile Combustion Onsite Vehicles1 371 412 Purchased Electricity 62,953 72,556 TOTAL 661,046 723,842 1 Includes corn trucks, DDGS/MDGS/wet cake/syrup trucks, ethanol trucks, filter cake/brine/publicly owned treatment works trucks, denaturant trucks, chemical trucks and on-site usage of employee vehicles.

Total potential annual emissions of the six primary GHGs for both the existing Valero Welcome Plant and after completion of the Project are estimated in the following table: Table 23–5. GHG Total Potential Emissions

Gas Type

Existing Facility Emissions (metric

tons CO2-e/yr)

Facility Emissions After Project Completion

(metric tons CO2-e/yr)

Carbon Dioxide (CO2) 660,520 723,275

Methane (CH4) 138 141

Nitrous Oxide (N2O) 388 426

Hydrofluorocarbons (HFCs) 0 0 Perfluorocarbons (PFCs) 0 0

Sulfur Hexafluoride (SF6) 0 0

TOTAL 661,046 723,842 For a comparison, the GHG emissions generated from all Minnesota sources were estimated at 152.5 million tons of CO2 equivalent in 2006. While it is not possible to directly link GHG emissions from a specific proposed project to specific regional or global climate change, the GHG emissions from the proposed Valero Welcome Plant can be measured and evaluated in relation to other facilities or fuels that emit GHG. A complete listing of estimated emissions can be found in Appendix 3. Energy Conservation The expansion of production at the Valero Welcome Plant will result in lower GHG intensity of operation. Due to the design of the existing Valero Welcome Plant, there are certain efficiencies that can be taken advantage of by expanding production. Notably, because the TO/dryers already operate year round, the expanded operations will result in minimal increase in fuel use for production. The only areas where expanded production will result in greater GHG emissions are overall facility power usage,


biogenic emissions from the process and vehicle use associated with product transport. This increase in efficiency results in lower GHG emissions per unit produced, or lower GHG intensity. The following table provides an overview of GHG improvement resulting from the project. Table 23-6. Estimated GHG Emission Intensity Changes

Permitted production

(gallons/year) GHG Emissions (metric

tons CO2-e/yr)

GHG Emission Intensity (metric tons CO2-

e/gallon) Existing Facility 118,000,000 661,046 0.0056 Facility Post-Project Increase

136,000,000 723,842 0.0053

Indirect GHG emissions associated with energy use account for a notable fraction of total facility GHG emissions (~20 percent). Indirect GHG emissions are calculated using emission factors available from MPCA for specific power providers in the state of Minnesota. These emission factors reflect the different fuel and technology types that make up the overall energy mix for each power provider. Federated Rural Electric Association, a Great River Energy (GRE) Co-op, is power provider for the Valero Welcome Plant, and MPCA CO2 emission factors specific to GRE have been used in the GHG calculation. Federated Electric Association, however, owns a 2.1 MW wind turbine near the Valero Welcome Plant that provides energy with a low GHG footprint directly to the facility. Given the use of power from this low carbon energy source, using general GRE emission factors results in a very conservative estimate of the indirect emissions attributable to operation of the Valero Welcome Plant.

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

operation? Yes No

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

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. Under certain weather conditions, water vapor plumes are visible from the TO/HRSG stack and cooling towers at the Valero Welcome Plant. However, the project will not result in a change in the steam plumes.

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

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


29. Cumulative potential effects. 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 potential effects. (Such future projects would be those that are actually planned or for which a basis of expectation has been laid.) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects. Cumulative impacts include those caused by the addition of the project to past, present, and foreseeable future activities. This includes projects that: 1) either exist, are planned for, or for which a basis of expectation has been laid, 2) are located in the surrounding area, and 3) might reasonably be expected to affect the same natural resources. The following is a summary of the issues included in the overall cumulative effects analysis. Air Quality Cumulative potential effects to air quality that may result from the proposed production increase project at the Valero Welcome Plant have been evaluated using air dispersion modeling tools that consider potential emissions from the proposed project, along with existing Valero Welcome Plant emissions, and nearby sources. Other regional/background sources, including mobile sources, were also added to the cumulative effects analysis. Potential human health effects from the project were also evaluated using the AERA process. Air Dispersion Modeling As a result of the project, the Valero Welcome Plant will be subject to Title V regulations. Air dispersion modeling was conducted to determine compliance with NAAQS and MAAQS and applicable PSD increment standards. The air dispersion modeling analysis determined that potential increases in air emissions from the proposed Project are expected to meet all ambient air quality standards and applicable PSD increment standards (Table 23-3). AERA The AERA for the Valero Welcome Plant was supplemented with a cumulative Air Emissions Risk Analysis. This cumulative analysis estimated the cumulative potential inhalation health risks from the Valero Welcome Plant after completion of the Project, plus health risks estimated from ambient air monitors in rural areas (“background risks”). The background risk estimates reflect air sources such as other industrial facilities, traffic, gas stations, wood-burning stoves, etc. See Table 23-4.

Table 29-1. After Project Cumulative Estimated Air Emissions Risk Analysis Results (at the point of maximum predicted air concentrations)

Exposure Scenario Valero Welcome Plant – After Project

Background Cumulative Total

Acute Respiratory Effects 0.6 b 0.22a 0.7 Chronic Respiratory Effects 0.63b (<0.3) c 0.41a 1(<0.7) c Cancer 0.2 b per 100,000 2.1a per 100,000 2.3 per 100,000

(a) Background values are the estimated hazard indices based on historical measured concentrations of pollutants in ambient air. These values are calculated using representative data from MPCA’s ambient monitoring network.

(b) This value is the maximum predicted hazard index at the point of maximum air concentration from the refined modeling.

(c) The value in parenthesis is the maximum predicted hazard index at the nearest residence.


Cumulative Non-cancer Risk Results As seen in Table 29-1 , the maximum cumulative inhalation respiratory hazard indices at the location of residences are below MPCA facility risk guidelines for both acute and chronic risk (i.e., they are both less than 1). The maximum cumulative total acute and chronic non-cancer hazard indices (i.e., 0.7 and 1.0, respectively) are below or at the MPCA facility-specific health risk guideline of 1; however, there are no residences in the area where these maximum hazard indices are predicted to occur. Cumulative Cancer Risk Results As seen in Table 29-1, the cumulative cancer risk is 2.3 per 100,000, which is above the MPCA facility-specific risk guideline of 1 per 100,000, but within EPA’s acceptable risk range of 1 in 1 million to 1 in 10,000. The majority of the cumulative cancer risk for this project (i.e., 2.1 per 100,000 out of 2.3 per 100,000) is due to background air quality conditions that exist throughout the state of Minnesota. Most of the background risks are due to heritage pollutants or those that are everywhere in the environment. The cancer risk from the Valero Welcome Plant Project alone is 0.2 per 100,000, which is below both facility risk guidelines and EPA guidelines. Overall, the risk estimates from the Valero Welcome Plant after the proposed project plus the rural monitoring data were similar to other ethanol facilities and areas in the state. The contribution from the proposed production increase was one percent or less. Climate Change Impacts of climate change on North America will not occur in isolation, but in context of technological, economic, social, and ecological changes. Regional impacts from climate change include the following observed or potential effects: increased mean annual air temperature (summer and winter warming), increased surface waters temperatures; later onset of winter and earlier onset of spring; precipitation may fall in fewer, but more intense, storms; species adapted to cold climates shift out of the Great Lakes basin into Canada; and aspen and birch forests will be replaced by hardwood forests of oak and hickory. Moderate climate change will likely increase agricultural yields and food production, with some regional and annual variability. The project is not expected to contribute significantly to an adverse cumulative potential effect. Water Use See the discussion in Item 13 regarding water use at the Valero Welcome Plant. Water users in the vicinity of the Valero Welcome Plant include private home owners and the Buffalo Lake Energy ethanol plant in Fairmont. Water level monitoring in private wells and observation wells between the Valero Welcome Plant and Buffalo Lake Energy have demonstrated that the water usage at the Valero Welcome Plant has caused no water use conflicts with either the private wells or Buffalo Lake Energy’s wells. Although there will be an increase in the pumping rate by up to 40 percent because of the project, the rate will continue to be within the existing DNR Water Appropriation Permit limit. The DNR regulates water use in Minnesota through its water appropriation permitting program. The purpose of this program is to protect water resources from depletion. Permits issued by the DNR require the permittee to monitor water use, keep records, report water use to the DNR, and suspend water use if required by the DNR. If a water resource is becoming negatively affectively by a permittee’s water use or due to natural conditions, (e.g., drought), the DNR can suspend the permittee’s water use. In this way, water resources are protected from overuse. The proposed project at the Valero Welcome Plant is not expected to have a negative environmental impact on the groundwater in the project area.

Utility Water


The utility water, including cooling tower blowdown, softener, multimedia filters, and reverse osmosis project reject water is treated in a brine concentrator/crystallization process also known as ZLD. The resulting salt mix is disposed of off site at a licensed solid waste facility. As a contingency measure for abnormal situations, the Valero Welcome Plant has applied for and received an MCES permit to dispose of reverse osmosis concentrate at the MCES Metropolitan Wastewater Facility, which is permitted by the MPCA under NPDES/SDS Permit MN0029815. Because of this, the emergency storage basin will be decommissioned, and the monitoring wells for the basin will be abandoned and sealed. The Valero Welcome Plant is subject to NPDES/SDS Permit requirements regarding the disposal of all wastes related to the brine concentrator/crystallization process. Surface Water/Stormwater The Valero Welcome Plant has been designed and constructed to control on-site stormwater. Stormwater currently flows to two stormwater detention ponds on site. Changes in stormwater quantity and quality are not expected since no additional area will be impacted and no additional significant materials, as defined by stormwater regulations, will be exposed to stormwater. The amount of impervious surface is not changing with this modification. The Valero Welcome Plant is required by its NPDES/SDS Permit to direct stormwater to detention ponds, meet discharge limits, and to implement an industrial SWPPP for stormwater discharge. The SWPPP will remain in effect through the expansion project. The ponds, discharge limits, and SWPPP will ensure that stormwater quality will not violate water quality standards and that stormwater quality will be the same as pre-project conditions. No significant environmental effects to stormwater are anticipated with the project.

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. No additional potential environmental impacts are expected as a result of the proposed modification.

31. Summary of issues. (Do not complete this section if the EAW is being done for EIS scoping; instead, address relevant issues in the Draft Scoping Decision Document, which must accompany the EAW.) 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.

No issues were identified that would require additional evaluation/ongoing coordination.

ValeroWelcome

Plant

Valero WelcomePlant Rail Spur

M a r t i nM a r t i nC o u n t yC o u n t y

ISTH 90

140th St

120th St

130th Ave

150th

Ave

120th

Ave

140th

Ave

110th St

Guide

St

142n

d Ave

Duga

n St2nd St

130th St

125th St

Bidwe

ll St

ISTH 90

140th

Ave

150th

Ave

130th Ave

130th

Ave

110th St

Welcome

§̈¦90§̈¦90

263

Barr Footer: Date: 6/14/2010 3:18:06 PM File: I:\Projects\23\46\1012\Maps\Reports\Fig01 Plant Location.mxd User: mbs2

!;N

2,500 0 2,500Feet

Figure 1PLANT LOCATION

Valero Welcome Plant1444 120th Street

Welcome, MN

800 0 800Meters

TankFarm

CoolingTowers

Fermentation/Distillation

Water Treatment

Facility

DDGSFlat

Storage

EnergyCenter

AdminitrationBuilding

Property Boundary

StormwaterDetention

Pond

StormwaterDetention

Pond

Grain Receiving/DDGS Shipping

120th St

140th

Ave

142n

d Ave

Barr Footer: Date: 6/14/2010 3:20:42 PM File: I:\Projects\23\46\1012\Maps\Reports\Fig02 Plant Layout.mxd User: mbs2

!;N

600 0 600Feet

Figure 2PLANT LAYOUT

Valero Welcome Plant1444 120th Street

Welcome, MN

180 0 180Meters

Plant Boundary

T102 R31S 6

T102 R31S 7

T102 R32S 1 T102 R31S 5

T102 R31S 8T102 R32S 12

T102 R31S 4

T102 R31S 9

T103 R31S 31 T103 R31S 32 T103 R31S 33T103 R32S 36

T102 R32S 2

T102 R32S 11

¯2,000 0 2,0001,000 Feet

Figure 3RARE PLANT COMMUNITY LOCATION

Township 102, Range 31, Secitons 5 and 6Martin CountyWelcome, MN

Barr Footer: Date: 7/15/2010 1:32:36 PM File: I:\Projects\23\46\1012\Maps\Basemaps\NHIS.mxd User: ksw

Site Location

Vertebrate AnimalCommunity Invertebrate AnimalVascular PlantNonvascular Plant; FungusAnimal AssemblageGeologic

Approximate Location of Natural Heritage Information System Rare FeaturesData Copyright 2009 State of Minnesota, Department of Natural Resources

Data included here were provided by the Division of EcologicalResources, Minnesota Department of Natural Resources (DNR),

and were current as of June 2010. These data are not basedon an exhaustive inventory of the state. The lack of data for any

geographic area shall not be construed to mean that no significantfeatures are present.

From: Cinadr, Thomas [mailto:[email protected]]

Sent: Wednesday, June 16, 2010 9:19 AM

To: Karen Wold

Subject: RE: database review request

THIS EMAIL IS NOT A PROJECT CLEARANCE.

This message simply reports the results of the cultural resources datThis message simply reports the results of the cultural resources datThis message simply reports the results of the cultural resources datThis message simply reports the results of the cultural resources database search you abase search you abase search you abase search you requested. The database search produced results for only previously known requested. The database search produced results for only previously known requested. The database search produced results for only previously known requested. The database search produced results for only previously known archaeological sites and historic properties. Please read the note below carefully.archaeological sites and historic properties. Please read the note below carefully.archaeological sites and historic properties. Please read the note below carefully.archaeological sites and historic properties. Please read the note below carefully. No archaeological sites or historic structures were identified in a search of the Minnesota Archaeological Inventory and Historic Structures Inventory for the search area requested. The result of this database search provides a listing of recorded archaeological sites and historic architectural properties that are included in the current SHPO databases. Because the majority of archaeological sites in the state and many historic architectural properties have not been recorded, important sites or structures may exist within the search area and may be affected by development projects within that area. Additional research, including field survey, may be necessary to adequately assess the area’s potential to contain historic properties. If you require a comprehensive assessment of a project’s potential to impact archaeological sites or historic architectural properties, you may need to hire a qualified archaeologist and/or historian. If you need assistance with a project review, please contact Kelly Gragg-Johnson in Review and Compliance @ 651-259-3455 or by email at [email protected]. The Minnesota SHPO Survey Manuals and Database Metadata and Contractor Lists can be found at http://www.mnhs.org/shpo/survey/inventories.htmhttp://www.mnhs.org/shpo/survey/inventories.htmhttp://www.mnhs.org/shpo/survey/inventories.htmhttp://www.mnhs.org/shpo/survey/inventories.htm

Tom Cinadr

Survey and Information Management Coordinator

Minnesota State Historic Preservation Office

Minnesota Historical Society

345 Kellogg Blvd. West

St. Paul, MN 55102

651-259-3453

Appendix 1

From: Karen Wold [mailto:[email protected]]

Sent: Monday, June 14, 2010 11:33 AM

To: Cinadr, Thomas

Cc: Chandler P. Taylor

Subject: database review request

Dear Mr. Cinadr,

I would like to request a database review of any known historic or cultural resources in the vicinity of the

following location:

Martin County

Township 102, Range 31, Sections 5 and 6

Welcome, Minnesota

See attached site location figure.

Please let me know if you need any additional information.

Thanks,

Karen Wold

Senior Environmental Scientist

Minneapolis office: 952.832.2707

cell: 651.307.4394

[email protected]

www.barr.com

Valero Welcome

GHG Emission Inventory

Pollutant Type Global

Em. C C N Annual Annual Note Emission Emission Emission Estimated Warming Estimated

Unit Emission O H 2 Rate Rate Factor Factor Factor Actual Emissions Potential Actual Emissions

ID # Unit Description Pollutant 2 4 O Units Number Units Source (m.t./yr) (GWP) (m.t. CO2-e /yr)

Scope 1 Direct Emissions

Stationary Combustion

EU052, EU053, EU056, EU057 DDGS dryers CO2 x 1,489,200 MMbtu/yr [1] 5.29E+01 kg/MMBtu [4] 78,794 1 78,794

EU052, EU053, EU056, EU057 DDGS dryers CH4 x 1,489,200 MMbtu/yr [1] 1.00E-03 kg/MMBtu [5] 1.49 25 37

EU052, EU053, EU056, EU057 DDGS dryers N2O x 1,489,200 MMbtu/yr [1] 1.00E-04 kg/MMBtu [5] 0.15 298 44

EU055, EU059 Thermal Oxidizers CO2 x 2,890,800 MMbtu/yr [1] 5.29E+01 kg/MMBtu [4] 152,952 1 152,952

EU055, EU059 Thermal Oxidizers CH4 x 2,890,800 MMbtu/yr [1] 1.00E-03 kg/MMBtu [5] 2.89 25 72

EU055, EU059 Thermal Oxidizers N2O x 2,890,800 MMbtu/yr [1] 1.00E-04 kg/MMBtu [5] 0.29 298 86

EU073 Water Treatment Facility Boiler CO2 x 146,625 MMbtu/yr [1] 5.29E+01 kg/MMBtu [4] 7,758 1 7,758

EU073 Water Treatment Facility Boiler CH4 x 146,625 MMbtu/yr [1] 1.00E-03 kg/MMBtu [5] 0.15 25 4

EU073 Water Treatment Facility Boiler N2O x 146,625 MMbtu/yr [1] 1.00E-04 kg/MMBtu [5] 0.01 298 4

NA Biomethanator Flare CO2 x 56,064 MMbtu/yr [2] 5.29E+01 kg/MMBtu [4] 2,966 1 2,966

NA Biomethanator Flare CH4 x 56,064 MMbtu/yr [2] 1.00E-03 kg/MMBtu [5] 0.06 25 1

NA Biomethanator Flare N2O x 56,064 MMbtu/yr [2] 1.00E-04 kg/MMBtu [5] 0.01 298 2

NA Ethanol Loadout Vapor Combustor CO2 x 121,764 MMbtu/yr [2] 5.29E+01 kg/MMBtu [4] 6,443 1 6,443

NA Ethanol Loadout Vapor Combustor CH4 x 121,764 MMbtu/yr [2] 1.00E-03 kg/MMBtu [5] 0.12 25 3

NA Ethanol Loadout Vapor Combustor N2O x 121,764 MMbtu/yr [2] 1.00E-04 kg/MMBtu [5] 0.01 298 4

NA Fire water pump CO2 x 1,600 gal/yr [3] 7.32E+01 kg/MMBtu [6] 117 1 117

NA Fire water pump CH4 x 1,600 gal/yr [3] 3.00E-03 kg/MMBtu [7] 0.00 25 0

NA Fire water pump N2O x 1,600 gal/yr [3] 6.00E-04 kg/MMBtu [7] 0.00 298 0

Process Emissions

No ID assigned CO2 Scrubber CO2 x 118,000,000 gallons [8] 2.95E-03

Metric

ton/gallon [9] 3.48E+05 1 348,435

Mobile Combustion

Mobile Source, No ID Assigned Corn Trucks CO2 x 2,405 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 176 1 176

Mobile Source, No ID Assigned Corn Trucks CH4 x 98,627 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned Corn Trucks N2O x 98,627 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Mobile Source, No ID Assigned DDGS/MDGS/Wet Cake/Syrup Trucks CO2 x 752 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 55 1 55

Mobile Source, No ID Assigned DDGS/MDGS/Wet Cake/Syrup Trucks CH4 x 30,821 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned DDGS/MDGS/Wet Cake/Syrup Trucks N2O x 30,821 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Page 1 Table 1 ExistingFacility

Mobile Source, No ID Assigned Ethanol Trucks CO2 x 738 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 54 1 54

Mobile Source, No ID Assigned Ethanol Trucks CH4 x 30,256 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned Ethanol Trucks N2O x 30,256 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Mobile Source, No ID Assigned Filter Cake/Brine/POTW Trucks CO2 x 37 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 3 1 3

Mobile Source, No ID Assigned Filter Cake/Brine/POTW Trucks CH4 x 1,513 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned Filter Cake/Brine/POTW Trucks N2O x 1,513 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Mobile Source, No ID Assigned Denaturant Trucks CO2 x 20 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 1 1 1

Mobile Source, No ID Assigned Denaturant Trucks CH4 x 800 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned Denaturant Trucks N2O x 800 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Mobile Source, No ID Assigned Chemical Trucks CO2 x 223 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 16 1 16

Mobile Source, No ID Assigned Chemical Trucks CH4 x 9,125 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned Chemical Trucks N2O x 9,125 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Mobile Source, No ID Assigned Employee Vehicles CO2 x 890 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 65 1 65

Mobile Source, No ID Assigned Employee Vehicles CH4 x 36,500 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned Employee Vehicles N2O x 36,500 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Scope 2 Indirect Emissions

No ID assigned Total Facility Electricity Consumption CO2 x 63,153 MWh/yr [15] 2.19E+03 lb/MWh [16] 62,685 1 62,685

No ID assigned Total Facility Electricity Consumption CH4 x 63,153 MWh/yr [15] 2.80E-02 lb/MWh [17] 0.80 25 20

No ID assigned Total Facility Electricity Consumption N2O x 63,153 MWh/yr [15] 2.90E-02 lb/MWh [17] 0.83 298 248


Appendix 2

Valero Welcome


Totals

Scope 1 Totals

CO2 597,835

CH4 118

N2O 141

Total CO2e 598,093

Scope 2 Totals

CO2 62,685

CH4 20

N2O 248

Total CO2e 62,953

TOTAL CO2 EMISSIONS 660,520

TOTAL CH4 EMISSIONS 138

TOTAL N2O EMISSIONS 388

TOTAL GHG EMISSIONS 661,046

Notes:

Emissions are calculated using The Climate Registry's (TCR) Draft General Reporting Protocol (GRP).

Global Warming Potentials (GWPs) from page 43 of TCR's Draft GRP.

References:

[1] Fuel usage rates documented in Valero Renewable Fuels Company LLC Welcome, MN Greenhouse Gas Monitoring Plan Version 1 (March 21, 2010)

[2] Fuel Usage rate per fire pump specification

[3] Diesel Fire Water Pump at 340 hp

[4] Table 12.1 of TCR's General Reporting Protocol v. 1.1 lists a factor of 52.91 kg CO2/MMBtu for natural gas with heat content 1,000-1,025 Btu/Scf (Natural Gas Heat Content: AP-42 Table 1.4-1 Note "a")

[5] Table 12.9 of TCR's General Reporting Protocol v. 1.1 lists factors of 1 g CH4 / MMBtu and 0.1 g N2O / MMBtu for Industrial Natural Gas

[1 g CH4 / MMBtu] * [kg / 1000 g] = 1.0E-03 kg CH4 / MMBtu.

[0.10 g N O / MMBtu] * [kg / 1000 g] = 1.0E-04 kg N O / MMBtu.

/MMBtukgCO 15.73C g 12

CO g 44

MMbtu

C kg 19.952

2=


[0.10 g N2O / MMBtu] * [kg / 1000 g] = 1.0E-04 kg N2O / MMBtu.

[6] Table 12.1 of TCR's General Reporting Protocol v. 1.1 lists a factor of 19.95 kg C/MMBtu for Distillate Fuel Oil (#1, 2, & 4)

[7] Table 12.9 of TCR's General Reporting Protocol v. 1.1 lists a factor of 3 g CH4 / MMBtu and 0.6 g N2O / MMBtu for Industrial Petroleum Products

[3 g CH4 / MMBtu] * [kg / 1000 g] =3.0E-03 kg CH4 / MMBtu.


[8] Total production permitted for existing facility = 118,000,000 gallons/year

[9] Biogenic process emissions calculated using stack test data extrapolated to an annual basis and total permitted production

Permitted Production (gallons per year)

Stack Test

CO2 %

Stack Test

Moisture %

Stack

Gas flow

rate

(scfh)

Operation

hours/year

CO2 (metric tons

CO2-e/yr)

118,000,000 100% 2% 768,000 8,760 348,435

[10] Diesel fuel usage converted to MMBtu using AP-42 Section 3.1 fuel heat content value 0.139 MMBtu/gallon

[11] Total fuel usage calculated based on a vehicle fuel efficiency fo 5.7 miles/gallon (approximate fuel efficiency for trucks 5.7 miles per gallon for heavy-duty trucks (national average: http://www.epa.gov/ttn/chief/conference/ei15/session11/davies.pdf)), converted to MMBtu using AP-42 Section 3.1 fuel heat

content value 0.139 MMBtu/gallon


CO g 44

MMbtu

C kg 19.952

2=


Valero Welcome


Ethanol Produced (Undenatured) 118,000,000 Gal 136,000,000 Gal

Ethanol Produced (Denatured) 121,025,641 Gal 139,487,179 Gal

Production Efficiency 2.68 gal/bu 2.7 gal/bu

Corn Received 44,029,851 bushels 50,370,370 bushels

Corn Density 56 lb/bushel 56 lb/bushel

Corn Received 1,232,836 tons 1,410,370 tons

DDGS Yield 17.5 lb/bushel 18 lb/bushel

DDGS Produced 385,261 tons 453,333 tons

Denaturant By Volume 2.5% 2.5%

Denaturant 6,051,282 Gal 3,487,179 Gal

Annual Per Truck Trucks/Yr

Miles/Tr

uck VMT

Fuel Usage

(gallons)

Fuel Usage

(MMBtu) Annual Per Truck Trucks/Yr

Miles/Truc

k VMT

Fuel Usage

(gallons) Fuel Usage (MMBtu)

Grain Receiving (tons) 1,232,836 25 49313 2 98,627 17,303 2,405 1,410,370 25 56415 2 112,830 19,795 2,751

DDGS Loadout (tons) 385,261 25 15410 2 30,821 5,407 752 453,333 25 18133 2 36,267 6,363 884

EtOH Loadout (gallons) 121,025,641 8000 15128 2 30,256 5,308 738 139,487,179 8000 17436 2 34,872 6,118 850

Denaturant Delivery (gallons) 6,051,282 8000 756 2 1,513 265 37 3,487,179 8000 436 2 872 153 21

Water Treatment Salt Loadout (tons) 20,000 25 800 1 800 140 20 20,000 25 800 1 800 140 20

Employee Vehicles (50 per day) 18,250 0 18,250 0.5 9,125 1,601 223 18,250 0 18,250 0.5 9,125 1,601 223

Miscellaneous (50 per day) 18,250 0 18,250 2 36,500 6,404 890 18,250 0 18,250 2 36,500 6,404 890

Existing Permit Revised Permit


CO g 44

MMbtu

C kg 19.952

2=


[12] Table 13.1 of TCR's General Reporting Protocol v. 1.1 lists a factor of 19.95 kg C/MMBtu for Diesel Fuel No.1 and 2

[13] Table 13.4 of TCR's General Reporting Protocol v. 1.1 lists a factor of 0.0051 g CH4/mile for Diesel Fuel heavy duty vehicles (all model years)

[14] Table 13.4 of TCR's General Reporting Protocol v. 1.1 lists a factor of 0.0048 g N2O/mile for Diesel Fuel heavy duty vehicles (all model years)


CO g 44

MMbtu

C kg 19.952

2=

/MMBtukgCO 15.73

C g 12

CO g 44

MMbtu

C kg 19.952

2=


Valero Welcome


Em. C C N Annual Annual Note Emission Emission Emission Estimated Warming EstimatedUnit Emission O H 2 Rate Rate Factor Factor Factor Actual Emissions Potential Actual Emissions

ID # Unit Description Pollutant 2 4 O Units Number Units Source (m.t./yr) (GWP) (m.t. CO2-e /yr)

Scope 1 Direct Emissions

Stationary Combustion

EU052, EU053, EU056, EU057 DDGS dryers CO2 x 1,489,200 MMbtu/yr [1] 5.29E+01 kg/MMBtu [4] 78,794 1 78,794

EU052, EU053, EU056, EU057 DDGS dryers CH4 x 1,489,200 MMbtu/yr [1] 1.00E-03 kg/MMBtu [5] 1.49 25 37

EU052, EU053, EU056, EU057 DDGS dryers N2O x 1,489,200 MMbtu/yr [1] 1.00E-04 kg/MMBtu [5] 0.15 298 44

EU055, EU059 Thermal Oxidizers CO2 x 2,890,800 MMbtu/yr [1] 5.29E+01 kg/MMBtu [4] 152,952 1 152,952

EU055, EU059 Thermal Oxidizers CH4 x 2,890,800 MMbtu/yr [1] 1.00E-03 kg/MMBtu [5] 2.89 25 72

EU055, EU059 Thermal Oxidizers N2O x 2,890,800 MMbtu/yr [1] 1.00E-04 kg/MMBtu [5] 0.29 298 86

EU073 Water Treatment Facility Boiler CO2 x 146,625 MMbtu/yr [1] 5.29E+01 kg/MMBtu [4] 7,758 1 7,758

EU073 Water Treatment Facility Boiler CH4 x 146,625 MMbtu/yr [1] 1.00E-03 kg/MMBtu [5] 0.15 25 4

EU073 Water Treatment Facility Boiler N2O x 146,625 MMbtu/yr [1] 1.00E-04 kg/MMBtu [5] 0.01 298 4

NA Biomethanator Flare CO2 x 56,064 MMbtu/yr [2] 5.29E+01 kg/MMBtu [4] 2,966 1 2,966

NA Biomethanator Flare CH4 x 56,064 MMbtu/yr [2] 1.00E-03 kg/MMBtu [5] 0.06 25 1

NA Biomethanator Flare N2O x 56,064 MMbtu/yr [2] 1.00E-04 kg/MMBtu [5] 0.01 298 2

NA Ethanol Loadout Vapor Combustor CO2 x 121,764 MMbtu/yr [2] 5.29E+01 kg/MMBtu [4] 6,443 1 6,443

NA Ethanol Loadout Vapor Combustor CH4 x 121,764 MMbtu/yr [2] 1.00E-03 kg/MMBtu [5] 0.12 25 3

NA Ethanol Loadout Vapor Combustor N2O x 121,764 MMbtu/yr [2] 1.00E-04 kg/MMBtu [5] 0.01 298 4

NA Fire water pump CO2 x 1,600 gal/yr [3] 7.32E+01 kg/MMBtu [6] 117 1 117

NA Fire water pump CH4 x 1,600 gal/yr [3] 3.00E-03 kg/MMBtu [7] 0.00 25 0

NA Fire water pump N2O x 1,600 gal/yr [3] 6.00E-04 kg/MMBtu [7] 0.00 298 07,766

Process Emissions

No ID assigned CO2 Scrubber CO2 x 136,000,000 gallons [8] 2.95E-03

Metric

ton/gallon [9] 4.02E+05 1 401,586

Mobile Combustion

Mobile Source, No ID Assigned Corn Trucks CO2 x 2,751 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 201 1 201

Mobile Source, No ID Assigned Corn Trucks CH4 x 112,830 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned Corn Trucks N2O x 112,830 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Mobile Source, No ID Assigned DDGS/MDGS/Wet Cake/Syrup Trucks CO2 x 884 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 65 1 65

Mobile Source, No ID Assigned DDGS/MDGS/Wet Cake/Syrup Trucks CH4 x 36,267 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned DDGS/MDGS/Wet Cake/Syrup Trucks N2O x 36,267 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Mobile Source, No ID Assigned Ethanol Trucks CO2 x 850 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 62 1 62

Mobile Source, No ID Assigned Ethanol Trucks CH4 x 34,872 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned Ethanol Trucks N2O x 34,872 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Mobile Source, No ID Assigned Filter Cake/Brine/POTW Trucks CO2 x 21 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 2 1 2

Mobile Source, No ID Assigned Filter Cake/Brine/POTW Trucks CH4 x 872 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned Filter Cake/Brine/POTW Trucks N2O x 872 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Page 1 Table 2 Post ExpansionFaciltity

2

Mobile Source, No ID Assigned Denaturant Trucks CO2 x 20 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 1 1 1

Mobile Source, No ID Assigned Denaturant Trucks CH4 x 800 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned Denaturant Trucks N2O x 800 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Mobile Source, No ID Assigned Chemical Trucks CO2 x 223 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 16 1 16

Mobile Source, No ID Assigned Chemical Trucks CH4 x 9,125 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned Chemical Trucks N2O x 9,125 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Mobile Source, No ID Assigned Employee Vehicles CO2 x 890 MMbtu/yr [10] 7.32E+01 kg/MMBtu [12] 65 1 65

Mobile Source, No ID Assigned Employee Vehicles CH4 x 36,500 miles/yr [11] 5.10E-06 kg/mi [13] 0.00 25 0

Mobile Source, No ID Assigned Employee Vehicles N2O x 36,500 miles/yr [11] 4.80E-06 kg/mi [14] 0.00 298 0

Scope 2 Indirect Emissions

No ID assigned Total Facility Electricity Consumption CO2 x 72,786 MWh/yr [15] 2.19E+03 lb/MWh [16] 72,247 1 72,247

No ID assigned Total Facility Electricity Consumption CH4 x 72,786 MWh/yr [15] 2.80E-02 lb/MWh [17] 0.92 25 23

No ID assigned Total Facility Electricity Consumption N2O x 72,786 MWh/yr [15] 2.90E-02 lb/MWh [17] 0.96 298 285

Totals

Scope 1 Totals

CO2 651,028

CH4 118

N2O 141

Total CO2e 659,052


Valero Welcome


Scope 2 Totals

CO2 72,247

CH4 23

N2O 285

Total CO2e 72,556

TOTAL CO2 EMISSIONS 723,275

TOTAL CH4 EMISSIONS 141

TOTAL N2O EMISSIONS 426

TOTAL GHG EMISSIONS 723,842

Notes:

Emissions are calculated using The Climate Registry's (TCR) Draft General Reporting Protocol (GRP).

Global Warming Potentials (GWPs) from page 43 of TCR's Draft GRP.

References:

[1] Fuel usage rates documented in Valero Renewable Fuels Company LLC Welcome, MN Greenhouse Gas Monitoring Plan Version 1 (March 21, 2010)

[2] Fuel Usage rate per fire pump specification

[3] Diesel Fire Water Pump at 340 hp

[4] Table 12.1 of TCR's General Reporting Protocol v. 1.1 lists a factor of 52.91 kg CO2/MMBtu for natural gas with heat content 1,000-1,025 Btu/Scf (Natural Gas Heat Content: AP-42 Table 1.4-1 Note "a")

[5] Table 12.9 of TCR's General Reporting Protocol v. 1.1 lists factors of 1 g CH4 / MMBtu and 0.1 g N2O / MMBtu for Industrial Natural Gas

[1 g CH4 / MMBtu] * [kg / 1000 g] = 1.0E-03 kg CH4 / MMBtu.


[6] Table 12.1 of TCR's General Reporting Protocol v. 1.1 lists a factor of 19.95 kg C/MMBtu for Distillate Fuel Oil (#1, 2, & 4)

[7] Table 12.9 of TCR's General Reporting Protocol v. 1.1 lists a factor of 3 g CH4 / MMBtu and 0.6 g N2O / MMBtu for Industrial Petroleum Products

[3 g CH4 / MMBtu] * [kg / 1000 g] =3.0E-03 kg CH4 / MMBtu.


[8] Total production permitted for expanded facility = 136,000,000 gallons/year

[9] Biogenic process emissions calculated using stack test data extrapolated to an annual basis and total permitted production

Permitted Production (gallons per year)

Stack Test

CO2 %

Stack

Test

Moisture

%

Stack

Gas flow

rate

(scfh)

Operatio

n

hours/ye

ar

CO2 (metric

tons CO2-e/yr)

136,000,000 100% 2% 768,000 8,760 348,435



CO g 44

MMbtu

C kg 19.952

2=


Ethanol Produced (Undenatured) 118,000,000 Gal 136,000,000 Gal

Ethanol Produced (Denatured) 121,025,641 Gal 139,487,179 Gal

Production Efficiency 2.68 gal/bu 2.7 gal/bu

Corn Received 44,029,851 bushels 50,370,370 bushels

Corn Density 56 lb/bushel 56 lb/bushel

Corn Received 1,232,836 tons 1,410,370 tons

DDGS Yield 17.5 lb/bushel 18 lb/bushel

DDGS Produced 385,261 tons 453,333 tons

Denaturant By Volume 5% 2.5%

Denaturant 6,051,282 Gal 3,487,179 Gal

Annual Per Truck

Trucks/Y

r

Miles/Tr

uck VMT

Fuel Usage

(gallons)

Fuel Usage

(MMBtu) Annual Per Truck Trucks/Yr

Miles/Truc

k VMT

Fuel Usage

(gallons) Fuel Usage (MMBtu)


[11] Total fuel usage calculated based on a vehicle fuel efficiency fo 5.7 miles/gallon (approximate fuel efficiency for trucks 5.7 miles per gallon for heavy-duty trucks (national average: http://www.epa.gov/ttn/chief/conference/ei15/session11/davies.pdf)), converted to MMBtu using AP-42

Section 3.1 fuel heat content value 0.139 MMBtu/gallon

Existing Permit Revised Permit


CO g 44

MMbtu

C kg 19.952

2=


Valero Welcome


Grain Receiving (tons) 1,232,836 25 49313 2 98,627 17,303 2,405 1,410,370 25 56415 2 112,830 19,795 2,751

DDGS Loadout (tons) 385,261 25 15410 2 30,821 5,407 752 453,333 25 18133 2 36,267 6,363 884

EtOH Loadout (gallons) 121,025,641 8000 15128 2 30,256 5,308 738 139,487,179 8000 17436 2 34,872 6,118 850

Denaturant Delivery (gallons) 6,051,282 8000 756 2 1,513 265 37 3,487,179 8000 436 2 872 153 21

Water Treatment Salt Loadout (tons) 20,000 25 800 1 800 140 20 20,000 25 800 1 800 140 20

Employee Vehicles (50 per day) 18,250 0 18,250 0.5 9,125 1,601 223 18,250 0 18,250 0.5 9,125 1,601 223

Miscellaneous (50 per day) 18,250 0 18,250 2 36,500 6,404 890 18,250 0 18,250 2 36,500 6,404 890

[12] Table 13.1 of TCR's General Reporting Protocol v. 1.1 lists a factor of 19.95 kg C/MMBtu for Diesel Fuel No.1 and 2

[13] Table 13.4 of TCR's General Reporting Protocol v. 1.1 lists a factor of 0.0051 g CH4/mile for Diesel Fuel heavy duty vehicles (all model years)

[14] Table 13.4 of TCR's General Reporting Protocol v. 1.1 lists a factor of 0.0048 g N2O/mile for Diesel Fuel heavy duty vehicles (all model years)

[15] Electricity usage scaled to production based on actual usage and production rates provided by Valero Welcome for period from 9/1/09 to 5/31/10

[16] Valero Welcome's power provider is Federated Rural Electric Association, a GRE Co=op. An emission factor of 2188.3 lbs CO2/MWH for GRE power is used per Table 5 in MPCA’s “General Guidance for Carbon Footprint Development in Environmental Review”

[17] MROW Region 2004 Emission Factor of 0.028 lbs/MWh for CH4 and 0.029 lbs/MWh for N2O US EPA eGRID2006 Version 2.1 (2004 data); CH4 and N2O factors provided by EPA Climate Leaders based on US EPA’s Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2005, April 2007 (Annex 3, Table A-69).


CO g 44

MMbtu

C kg 19.952

2=


CO g 44

MMbtu

C kg 19.952

2=


CO g 44

MMbtu

C kg 19.952

2=

/MMBtukgCH 004173.01000g

kg1

MMBtu 0.139

gallon1

gallon

CH g 0.584

4=

year

MMbtu 6596

gallon

MMBtu .1390

year

days operating 17.73

day

hours 42

hour

gal 6.2=

⋅


CO g 44

MMbtu

C kg 19.952

2=



CO g 44

MMbtu

C kg 19.952

2=

/MMBtuOkgN 00187.01000g

kg1

MMBtu 0.139

gallon1

gallon

ON g 0.262

2=

/MMBtukgCH 004173.01000g

kg1

MMBtu 0.139

gallon1

gallon

CH g 0.584

4=

year

MMbtu 6596

gallon

MMBtu .1390

year

days operating 17.73

day

hours 42

hour

gal 6.2=

⋅


CO g 44

MMbtu

C kg 19.952

2=


Valero Welcome


cars 975,7econcentrat tonsmetric 0.90718474

short tons 1

short tons 60.9

cars 1econcentrat tonsmetric 440,610 =

MMBtu/year 101,180 Btu 1000000

MMBtu 1

mile

Btu 14,926

car

miles 850

year

cars 7,975 =

/yeargallons 914,727MMBtu 0.139

gallon1

year

tu101,180MMB=

gallons 236,280,1miles 0016*miles ton 607

diesel ofgallon

econcentrat tonsmetric 0.90718474

short tons 1econcentrat tonsmetric 440,610 =


cars 975,7econcentrat tonsmetric 0.90718474

short tons 1

short tons 60.9

cars 1econcentrat tonsmetric 440,610 =

MMBtu/year 101,180 Btu 1000000

MMBtu 1

mile

Btu 14,926

car

miles 850

year

cars 7,975 =

/yeargallons 914,727MMBtu 0.139

gallon1

year

tu101,180MMB=

gallons 236,280,1miles 0016*miles ton 607

diesel ofgallon

econcentrat tonsmetric 0.90718474

short tons 1econcentrat tonsmetric 440,610 =


Appendix 3. Estimated Emissions for the Existing and Post-Project Valero Welcome Plant

(post-project means potential total facility emissions after the production increase)

Chemical Name *evaluated

quantitatively in the AERA

Post Project Total Facility

Emissions

Existing Total Facility

Emissions

Percent Change in Emissions (existing facility to

post-project)

(tpy) lb/hr tpy lb/hr tpy 2-Methylnaphthalene 1.51E-05 6.63E-05 1.51E-05 6.63E-05 0.00% 2,3-Butanedione 7.00E-02 3.07E-01 7.00E-02 3.07E-01 0.00% 2,3-Butanediol 1.50E-01 6.57E-01 1.50E-01 6.57E-01 0.00% *Acetaldehyde 7.73E-01 3.38E+00 7.73E-01 3.38E+00 0.00% Acetic Acid 1.73E+00 7.58E+00 1.73E+00 7.58E+00 0.00% Acetoin 1.10E-01 4.82E-01 1.10E-01 4.82E-01 0.00% Acetone 5.00E-02 2.19E-01 5.00E-02 2.19E-01 0.00% *Acrolein 1.67E-01 7.30E-01 1.67E-01 7.30E-01 0.00% *Arsenic 1.26E-04 5.53E-04 1.26E-04 5.53E-04 0.00% *Barium 2.78E-03 1.22E-02 2.78E-03 1.22E-02 0.00% *Benzene 8.32E-03 3.65E-02 7.49E-03 3.28E-02 11.1% Butane 1.33E+00 5.81E+00 1.33E+00 5.81E+00 0.00% *Cadmium 6.96E-04 3.05E-03 6.96E-04 3.05E-03 0.00% *Chromium 8.83E-04 3.87E-03 8.83E-04 3.87E-03 0.00% Cobalt 5.31E-05 2.33E-04 5.31E-05 2.33E-04 0.00% *Copper 5.37E-04 2.35E-03 5.37E-04 2.35E-03 0.00% *Dichlorobenzene 7.60E-04 3.33E-03 7.60E-04 3.33E-03 0.00% Ethane 1.96E+00 8.58E+00 1.96E+00 8.58E+00 0.00% *Ethanol 1.76E+00 7.72E+00 1.66E+00 7.29E+00 5.9% *Ethyl Acetate 4.09E+00 1.79E+01 4.09E+00 1.79E+01 0.00% *Ethylbenzene 1.37E-03 5.99E-03 1.14E-03 5.01E-03 19.6% Fluoranthene 1.89E-06 8.30E-06 1.89E-06 8.30E-06 0.00% Fluorene 1.77E-06 7.76E-06 1.77E-06 7.76E-06 0.00% *Formaldehyde 1.73E-01 7.59E-01 1.73E-01 7.59E-01 0.00% *Formic Acid 1.27E+00 5.58E+00 1.27E+00 5.58E+00 0.00% *Furfural 1.25E-01 5.48E-01 1.25E-01 5.48E-01 0.00% *Hexane 1.14E+00 5.00E+00 1.14E+00 4.99E+00 0.07% *Isoamyl Alcohol 1.62E+00 7.09E+00 1.62E+00 7.09E+00 0.00% *Lactic Acid 7.04E-01 3.08E+00 7.04E-01 3.08E+00 0.00% *Lead 3.16E-04 1.38E-03 3.16E-04 1.38E-03 0.00% *Manganese 2.40E-04 1.05E-03 2.40E-04 1.05E-03 0.00% *Mercury 1.64E-04 7.20E-04 1.64E-04 7.20E-04 0.00% *Methanol 5.20E-01 2.28E+00 5.18E-01 2.27E+00 0.3% Molybdenum 6.95E-04 3.04E-03 6.95E-04 3.04E-03 0.00%

Appendix 3

Chemical Name *evaluated

quantitatively in the AERA

Post Project Total Facility

Emissions

Existing Total Facility

Emissions

Percent Change in Emissions (existing facility to

post-project)

(tpy) lb/hr tpy lb/hr tpy *Naphthalene 3.85E-04 1.69E-03 3.85E-04 1.69E-03 0.00% *Nickel 1.33E-03 5.81E-03 1.33E-03 5.81E-03 0.00% *Nitrogen dioxide 2.74E+01 1.20E+02 2.36E+01 1.04E+02 16.0% Pentane 1.64E+00 7.20E+00 1.64E+00 7.20E+00 0.00% Phenanthrene 1.08E-05 4.71E-05 1.08E-05 4.71E-05 0.00% Propane 1.01E+00 4.43E+00 1.01E+00 4.43E+00 0.00% Pyrene 3.16E-06 1.38E-05 3.16E-06 1.38E-05 0.00% *Toluene 1.20E-02 5.24E-02 1.05E-02 4.61E-02 13.6% *Vanadium 1.45E-03 6.36E-03 1.45E-03 6.36E-03 0.00% *Xylene 4.20E-03 1.84E-02 3.52E-03 1.54E-02 19.4% Zinc 1.83E-02 8.02E-02 1.83E-02 8.02E-02 0.00%

Total VOC's (tpy) 89.4631 89.0100 0.5% Total HAP's (tpy) 12.2816 12.2566 0.2%

Total Emissions (tpy) 209.6014 209.1483 0.2% Total VOC's Evaluated (tpy) 61.7853 61.3322 0.7%

lb/hr = pound per hour tpy = ton per year

Valero Welcome Plant Production Increase EAW · or 136 MMGY of undenatured ethanol, without adding...

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