Olmsted County Concerned Citizens

THE MINNERGY ETHANOL PLANT EAW PUBLIC COMMENT PERIOD HAS STARTED!

The proposed Eyota MinnErgy Ethanol Plant EAW is now out for public comment.  IMPORTANT NOTICE: The public comment period which originally ended July 2nd has been EXTENDED to end August 1st at 4:30 pm. We encourage people to make comments to the MPCA about the disastrous effects ethanol plants built in SE MN will have on our precious groundwater supply and air quality. Not to mention the devastation ethanol production will have on fish & wildlife habitat because of planting corn in areas that shouldn’t be planted and the removal of wetlands & CRP lands for even more corn production. To reveiw the MinnErgy EAW click on this link: http://www.pca.state.mn.us/news/eaw/minnergy-eaw.pdf

Free hard copies of the MinnErgy EAW for which the MPCA is the responsible government unit may be requested from Mary Osborn, . MPCA is informing the public that if people want a hard copy of the EAW for the proposed Minnergy ethanol plant in Eyota they are to contact Mary Osborn at the following address:  http://www.pca.state.mn.us/news/eaw/index.html 

 Below is an idex that Olmsted County Concerned Citizens (OC3) put together to make it easier to find information in the MinnErgy EAW. Wouldn’t you think the MPCA would include an index with ALL EAW’s that they release for the public comment period. The letter writing instructions for preparing formal comments needs to be followed when making comments on the MinnErgy EAW to the MPCA. Please, consider commenting! We need the public’s help on this issue!

Sincerely,

Tom Dornack
OC3 Co chairman
131 Renabelle St.
Eyota, MN 55934

 
MinnErgy EAW Index

EAW categories:
1. Title; pg 1
2. Proposer; pg 1
3. RGU; pg 1
4. Reason for Preparation; pg 1
5. Location, tables figures and appendices; pg 1-3
6. Description; pg 3-8
7. Project magnitude; pg 8-9
8. Permits and Approvals Required; pg 9-10
9. Land Use; pg 10-11
10. Cover types; pg 11
11. Fish, Wildlife and Ecological Sensitive Resources; pg 12-14
12. Physical Impacts to Water Resources; pg 15-16
13. Water Use; pg 16-22
14. Water-related land use districts; pg 22
15. Water surface use; pg 22
16. Erosion and Sedimentation; pg 22-23
17. Water Quality-Surface-water runoff; pg 23-24
18. Water Quality- Wastewater; pg 25-29
19. Geologic Hazards; pg 29-32
20. Solid Wastes, Hazardous Wastes, Storage Tanks; pg 32-33
21. Traffic, Parking; pg 34-35
22. Vehicle-related air emissions; pg 35-36
23. Stationary Source Air Emissions; pg 36-43
24. Odors, Noise and Dust; pg 43-45
25. Nearby resources; pg 45-47
26. Visual impacts; pg 47
27. Compatibility with plans and land use regulations; pg 48
28. Impact on Infrastructure and Public Services; pg 48
29. Cumulative Impacts; pg 49-53
30. Other Potential Environmental Impacts; pg 53
31. Summary of issues; pg 53
 
OC3 LETTER WRITING INSTRUCTIONS
June 17, 2008
Instruction for requesting an EIS

The statutes and rules that govern environmental review and permitting require specific information and language in correspondence to the MPCA and DNR.

For all requests you must have the following information

NAME
ADDRESS (optional to add other contact information like phone and e-mail)

A Statement from the person or group stating their interest in the permit application or EAW

A Statement of the action the person wishes the agency to take, I’ am officially requesting that an Environmental Impact Statement (EIS) be preformed for the MinnErgy Ethanol Plant in Eyota, Minnesota.
 
You need to provide the reasons supporting your position, with sufficient specifics as to allow the commissioner to investigate the merits of the position.

For the EAW/EIS send to:

Jess Richards
Steve Sommer
Minnesota Pollution Control Agency
Industrial Permitting Section
Biofuels/Ethanol Sector
520 Lafayette Rd North
St. Paul, MN 55155

Re:  MinnErgy EAW
 Request for an Environmental Impact Statement

Dear Mr. Richards and Mr. Sommer:

 

Questions/Comments to ask/send to the MPCA regarding the MinnErgy EAW

 

June 17, 2008

 

Why didn’t you number the pages or include an index?

 

Why are all the maps and air photos old?  It looks like the air photos are at least 5 years old because there is no Arbor Gardens (assisted living), Kwik Trip or houses.  Shouldn’t you use the most current data to assess the health risks to the residents and employees? 

 

The City Limits of Eyota are adjoining the MinnErgy site, but you say the plant is a mile away from Eyota.  The way we measure it, the plant is 0.6 miles from developed areas in Eyota.  How can your models be correct?  You don’t even know how close the plant is to Eyota!

 

Won’t it smell all the time?

 

Can’t you be consistent with the units of measurement?  Sometimes you talk about receptors a mile away, other times a kilometer away.  All distances and all map scales should be in English and metric units.

 

Can’t you put the units of discharge into pounds per day instead of ppm (parts per million).  If you know the discharge rate and the concentration it should be easy to calculate how many pounds per day the plant will discharge.

 

How many hours have you put into the MinnErgy EAW review?  Does MinnErgy reimburse the state for the time?  What is the monetary value of the MPCA work?  How much is it costing the State of Minnesota?  How can there be so many omissions and errors when you spend so much time?  (ie: metric and English units in the same paragraph)

 

• How big is the Ethanol Sector?  Are you authorized to charge for the applicant for the time?

 

Lake Zumbro is currently impaired for nutrients, including phosphorous that creates algae blooms.  What is the effect on Bear Creek, Silver Lake, the South Branch of the Zumbro River and Lake Zumbro of discharging an added 64 pounds of phosphorous a month?

 

The impaired waters are impaired due to nutrients, turbidity, and pesticides

 

Please define the watersheds.  Based on the site maps in the EAW the plant is in the Whitewater, Root and Zumbro River Watersheds.

 

Phase I of the plant uses 18 million bushels of corn.  How many acres of corn will it take to satisfy the corn demand?

 

 

The traffic calculations don’t seem to add up.  The traffic analysis assumes that every truck will haul 800 bushels but most farmers use gravity boxes or smaller trucks.  If the average is 500 bushels how many trucks?  How does this change the emission calculations?

The traffic analysis the peak travel ties did not include the time the school is out in the afternoon.  It is my observation that traffic increased dramatically when school lets out?  How do we know the applicant’s data is correct? 

 

The pump test has a lot of questions:

• Were any groundwater / surface water interactions monitored?
• The water levels were still falling in the observation wells after 7 days. Doesn’t that indicate that the test should have been longer?
• Why didn’t they monitor water quality during the pump test?
• Assumption that each truck will haul

 

The plant emissions put out a cancer footprint.  We have had people review the MPCA records who say that MinnErgy has run numerous models that did not pass muster due to high cancer risks

 

MinnErgy has proposed a fence for pollution control and even revised the fence to make the air emission risk model pass.  What is this about?  How does a fence protect us from air pollution and cancer?

 

Describe the carcinogen footprint from the air emissions?

 

How do you know that the storm water coming off the plant site will flow in the subsurface to Bear Creek?  Don’t you need to do dye trace studies to prove the way the subsurface water flows.  We are concerned about the fate of contaminants

 

Where will spills and leaks flow to.

 

We have heard that a chemical spill could require evacuation of miles?  What are the evacuation distances for?

• Ethanol
• Gasoline
• Chlorine
• Sulfuric acid
• Ammonia
• Industrial bleach
• Ferric chloride
• Phosphoric acid
• Sodium metabisulfite
• Urea

 

 

 

Who is responsible for the emergency response plan? 

 

Is this pristine groundwater in the Jordan aquifer?  Are there any records of contaminated Jordan groundwater in the area?

 

How much water is used at the plant compared to Eyota?  Compared to a golf course in Rochester?

 

What happens to the water?

 

What is the anticipated expense to the City? 

• Emergency response like fire trucks, training, communications
  • Evacuations, spill response
• Roads and street upgrades and maintenance
• Sewer and water

 

The air dispersion modeling uses old wind data from Rochester and St. Cloud.  Why not use the MNDOT weather station on the interstate by Eyota?