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STATE OF MINNESOTA

MINNESOTA POLLUTION CONTROL AGENCY IN THE MATTER OF THE DECISION ON THE NEED FOR AN ENVIRONMENTAL IMPACT STATEMENT FOR THE PROPOSED AL-CORN CLEAN FUEL FACILITY EXPANSION DODGE COUNTY CLAREMONT TOWNSHIP, MINNESOTA

FINDINGS OF FACT CONCLUSIONS OF LAW AND ORDER

Pursuant to Minn. ch. 4410, the Minnesota Pollution Control Agency (MPCA) staff prepared and distributed an Environmental Assessment Worksheet (EAW) for the proposed Al-Corn Clean Fuel (Al-Corn) Facility Expansion (Project). Based on the MPCA staff environmental review, the EAW, comments and information received during the comment period, and other information in the record of the MPCA, the MPCA hereby makes the following Findings of Fact, Conclusions of Law, and Order.

FINDINGS OF FACT

Project Description 1. Al-Corn is a dry-mill ethanol production facility that currently produces 50 million gallons per year

(MMGY) of 200-proof ethanol, 132,000 tons per year (tpy) of dried distiller’s grains and solubles (DDGS) and 1.6 MMGY of corn oil.

2. The Project is a proposed expansion of the Al-Corn facility located in the NW¼ of the NW¼ of Section 29, Township 107 North, Range 18 West, Claremont Township, Dodge County, Minnesota (Facility). The Project will increase the Facility’s production capacity to 130 MMGY of 200-proof ethanol, 350,000 tpy of DDGS, and nearly 4 MMGY corn oil. Additionally, the Project will include installing a new natural gas combustion turbine with a duct burner for combined heat and power, replacing and relocating grain storage and handling equipment, expanding rail loading/unloading capabilities, adding equipment for additional fermentation, distillation, and product storage, and adding one new natural gas fired boiler and new DDGS dryer.

3. The Project will enable the Facility to increase production by increasing its corn processing capacity

from 18 million bushels per year (MMBu/year) to approximately 47 MMBu/year.

Environmental Review of the Project 4. The Project will be capable of storing one million gallons or more of a hazardous material.

Therefore, Minn. R. 4410.4300, subp. 10(B) requires the preparation of an EAW. 5. The Project will be capable of emitting more than 100,000 tpy of greenhouse gas emissions.

Therefore, Minn. R. 4410.4300, subp. 15(B) requires the preparation of an EAW.

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6. Minn. R. 4410.4300, subp. 10(B) identifies the MPCA as the responsible governmental unit (RGU) for the EAW preparation.

7. Minn. R. 4410.4300, subp. 15(B) identifies the MPCA as the RGU for the EAW preparation.

8. An EAW is a brief document designed to either set out the basic facts necessary to determine

whether the Project has the potential for significant environmental effects such that an Environmental Impact Statement (EIS) is required for a proposed project, or to initiate the scoping process for an EIS. Minn. R. 4410.0200, subp. 24.

9. On April 1, 2016, the Al-Corn submitted a draft EAW to the MPCA for the Project. 10. The MPCA provided public notice of the Project as follows:

a) The MPCA published a Notice of the availability of the EAW for public comment in the EQB Monitor on August 15, 2016, as required by Minn. R. 4410.1500.

b) The EAW was available for review on the MPCA website at http://www.pca.state.mn.us/news/eaw/index.html.

c) The MPCA provided a news release to media, Dodge County and neighboring counties, and other interested parties on August 15, 2016.

11. The public comment period for the EAW began on August 15, 2016, and ended on September 14,

2016. During the 30-day comment period, the MPCA received comments from Dodge County, Minnesota Department of Natural Resources (MDNR), Minnesota Department of Transportation (MnDOT), Minnesota Historical Society and two citizens. The comments are included in Appendix A to these Findings.

12. The MPCA prepared written responses to the comments received during the 30-day public

comment period. The Responses to Comments document is also included in Appendix A to these Findings.

Standard for the Decision on the Need for an EIS

13. The MPCA must base its decision on the need for an EIS on the information gathered during the

EAW process and the comments received on the EAW (Minn. R. 4410.1700, subp. 3). The agency must order an EIS for projects that have the potential for significant environmental effects (Minn. R. 4410.1700, subp. 1). In deciding whether a project has the potential for significant environmental effects, the MPCA must compare the impacts that may be reasonably expected to occur from the project with the criteria set forth in Minn. R. 4410.1700, subp. 7. These criteria are:

A. Type, extent, and reversibility of environmental effects;

B. Cumulative potential effects. The RGU shall consider the following factors: whether the cumulative potential effect is significant; whether the contribution from the project is significant when viewed in connection with other contributions to the cumulative potential effect; the degree to which the project complies with approved mitigation measures specifically designed to address the cumulative potential effect; and the efforts of the proposer to minimize the contributions from the project;

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C. The extent to which the environmental effects are subject to mitigation by ongoing public regulatory authority. The RGU may rely only on mitigation measures that are specific and that can be reasonably expected to effectively mitigate the identified environmental impacts of the project; and

D. The extent to which environmental effects can be anticipated and controlled as a result of other available environmental studies undertaken by public agencies or the project proposer, including other EISs.

Type, Extent, and Reversibility of Environmental Effects 14. The MPCA finds that the types of impacts that may reasonably be expected to occur from the

Project include impacts from air emissions, water appropriation, noise generation, odors, and traffic.

15. The MPCA makes the following findings on the extent and reversibility of impacts that are reasonably expected to occur from the Project:

Findings on Air Quality Impacts

16. The operation of the existing and proposed new equipment at the Facility will generate air

emissions. 17. Al-Corn has applied for a Title V Part 70 Federal air permit (Air Permit). The Air Permit will include a

requirement to operate air pollution control equipment. The pollution control equipment includes: a new wet scrubber to control volatile organic compounds (VOCs) and hazardous air pollutants from fermentation equipment; fabric filters and centrifugal collectors to control particulate matter (PM), PM10, and PM2.5 emissions from grain handling equipment; a new regenerative thermal oxidizer to control VOCs, hazardous air pollutants, and carbon monoxide (CO) emissions; and a new flare to control VOC emissions from the ethanol loading rack.

18. The Air Permit will contain enforceable requirements to ensure the Project will comply with state

and federal applicable requirements.

19. The initial air modeling conducted by Al-Corn was a Significant Impact Level (SIL) analysis using air dispersion modeling following an MPCA-approved modeling protocol. The U.S. Environmental Protection Agency (EPA) established the SILs for criteria pollutants with a National Ambient Air Quality Standard (NAAQS) including sulfur dioxide (S02); nitrogen dioxide (NO2); particulate matter less than 10 microns (PM10); particulate matter less than 2.5 microns (PM2.5); and CO. The SIL analysis revealed that modeled values for S02 and CO were below their respective SIL values and therefore required no further modeling. Modeled values for NO2, PM10, and PM2.5 exceeded the SIL; this required a refined air quality dispersion modeling demonstration that included nearby sources to evaluate potential air quality impacts from the Project.

20. Al-Corn conducted refined air quality dispersion modeling for the Project and nearby sources,

consistent with best modeling practices. The air quality dispersion modeling followed an MPCA-approved protocol to evaluate the Project’s potential air quality impacts. Al-Corn used the EPA’s

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preferred model, the American Meteorological Society/Environmental Protection Agency Regulatory Model Improvement Committee’s Dispersion Model (AERMOD), to conduct the analysis.

21. The MPCA finds Al-Corn’s refined modeling results for NO2, PM10 and PM2.5 were below the

applicable NAAQS. 22. Al-Corn prepared an Air Emissions Risk Analysis (AERA) as required by the MPCA for projects that

trigger the preparation of an EAW under Minn. R. 4410.4300, subp. 15(B). The AERA includes a qualitative and quantitative analysis of potential human health risks from exposure to air toxics emitted from the Facility. Cancer and non-cancer risks from inhalation and ingestion exposures were analyzed using the MPCA’s Risk Assessment Screening Spreadsheet. The MPCA finds that the Project does not present any significant increases in the levels of non-cancer or cancer risk that warrant further study.

23. With respect to the reversibility of air quality impacts that are reasonably expected to occur from the Project, air emissions will continue while the Facility remains in operation, and would cease only if the Facility were to temporarily or permanently close. While in operation, the Facility is expected to meet applicable air quality standards and criteria. If excessive air emissions or violations of the ambient air standards were to occur, air quality impacts are likely to be temporary in nature and because of ongoing regulatory oversight, corrective measures would be implemented. Such measures could include requiring the Project owner or operator to make physical or operational changes to ensure compliance with all applicable requirements.

24. The MPCA finds that information presented in the EAW and other information in the environmental

review record are adequate to address the concerns related to air emissions. The impacts on air emissions that are reasonably expected to occur from the Project have been considered during the review process; appropriate mitigation measures are available and will be required to prevent significant adverse impacts.

25. The MPCA finds that air emissions from the Project, as it is proposed, do not have the potential for

significant environmental effects based on the type, extent, and reversibility of impacts related to air emissions that are reasonably expected to occur from the Project.

Findings on Water Appropriation Impacts

26. Al-Corn currently holds an active MDNR water appropriation permit (1995-5160) originally issued in

1995. Under this permit, Al-Corn is authorized to withdraw up to 200 MMGY from four existing wells at a pumping rate not to exceed 400 gallons per minute (gpm) from the shallow Dubuque-Galena Group aquifer.

27. Al-Corn will submit an application to MDNR requesting an amendment to its current permit to increase the amount of permitted water withdrawal to a total of 400 MMGY.

28. Al-Corn will use an existing well at the Facility, not currently used for production and screened

within the deeper aquifer (Prairie du Chien-Jordan), to support the increased ethanol production as well as provide a back-up to existing water supply wells screened in the shallower Dubuque-Galena Group.

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29. An Aquifer Test Report prepared for this well by Natural Resources Group, LLC (June 6, 2008) is on file with the MDNR. Based on Al-Corn and MDNR’s analysis of the pump test results, the aquifer parameters were favorable for development. Based on the aquifer test data and the analysis results, the well is capable of sustaining a yield in excess of 700 gpm without long-term depletion of the groundwater resource.

30. Al-Corn believes that sustained pumping of this well, at less than 700 gpm, will not result in any

water use conflict with the overlying Dubuque-Galena Group aquifer, and the pumping influence of the well will not significantly affect the operation of other existing water supply wells.

31. Due to the MDNR oversight and permitting of water appropriations, the MPCA does not expect

significant adverse impacts to water quantity. However, if the MDNR determines there is well interference based on concerns or well interference claims, the operator must fix the causes of the interference. The impacts to waters will then be reversed. Therefore, the MPCA finds that the water appropriation impacts that are reasonably expected to occur from the Facility are reversible.

32. The MPCA finds that information presented in the EAW and other information in the environmental review record are adequate to assess potential impacts to the quantity of groundwater that are reasonably expected to occur from the Facility.

33. The MPCA finds that the water appropriation for the Project, as it is proposed, does not have the potential for significant environmental effects based on the type, extent, and reversibility of impacts related to water appropriation that are reasonably expected to occur from the Project.

Findings on Noise Generation Impacts

34. Vehicle deliveries, vehicles working on site preparation, and building and equipment erection and

installation, will generate noise during the construction of the Project. 35. Most of the new equipment will be installed indoors. Noise levels from this equipment are

equivalent to, or improved, compared to existing noise levels. Enclosing the new hammermills is an improvement over existing noise levels.

36. The new cooling tower and ethanol dehydration system and existing equipment that are located outdoors (grain and DDGS bins and conveyors, DDGS cooler, distillation and dehydration towers, fermenters, cooling towers, carbon dioxide scrubbers, generators, and regenerative thermal oxidizers) will generate noise at levels similar to existing levels.

37. The Project is required to meet the Minnesota Noise Standards as found in Minn. R. ch. 7030.

38. Al-Corn will mitigate noise from the Project by installing most of the new equipment, including the

hammermills and the new natural gas powered turbine, indoors and by requiring construction contractors to use equipment with sound abatement consistent with industry standards.

39. With respect to the reversibility of noise impacts that are reasonably expected to occur from the

Project, noise from the Project will continue while the Project remains in operation and would

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cease only if the Project were to temporarily or permanently close. While in operation, the Project is expected to meet the Minnesota Noise Standard. If violations of the Minnesota Noise Standard occur, impacts are likely to be temporary in nature and the Proposer could implement corrective measures. Such measures could include physical or operational changes to ensure compliance with the noise standards. Therefore, the MPCA finds that the noise impacts that are reasonably expected to occur from the Facility are reversible.

40. The MPCA finds that information presented in the EAW and other information in the environmental

review record are adequate to address the concerns related to noise generation. The MPCA has considered the impacts on noise generation that are reasonably expected to occur from the Project during the review process and appropriate mitigation measures are available and will be required to prevent significant adverse impacts.

41. The MPCA finds that the Project, as proposed, does not have the potential for significant

environmental effects based on the type, extent, and reversibility of noise impacts that are reasonably expected to occur from the Project.

Findings on Truck Traffic Impacts

42. Increased truck traffic is anticipated to occur at the Facility due to the increase in grain receiving

and product load out.

43. MnDOT traffic counts indicate the existing roadways have sufficient capacity to handle the increased truck traffic.

44. Dodge County will determine if access is adequate and whether improvements are necessary as a

result of increased truck traffic.

45. Al-Corn will mitigate the truck traffic by utilizing rail transportation as the preferred method of transit for the ethanol and DDGS products. In addition, the Facility will have up to four lanes of parking within the Project area to accommodate truck traffic.

46. Due to Dodge County and MnDOT oversight of traffic issues, the MPCA does not expect significant

adverse impacts regarding truck traffic. However, if Dodge County or MnDOT determines there are safety concerns, Al-Corn will work with Dodge County and MnDOT to implement improvements. Traffic impacts will then be reversed. Therefore, the MPCA finds that the truck traffic impacts that are reasonably expected to occur from the Facility are reversible.

47. The MPCA finds that information presented in the EAW and other information in the environmental review record are adequate to address the concerns related to truck traffic impacts. The MPCA has considered the impacts on truck traffic that are reasonably expected to occur from the Project during the review process; the MPCA finds that appropriate mitigation measures are available and will be required to prevent significant adverse impacts.

48. The MPCA finds that the Project as proposed does not have the potential for significant environmental effects based on the type, extent, and reversibility of truck traffic impacts that are reasonably expected to occur from the Project.

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Findings on Odor Impacts

49. Two commenters expressed concern regarding odors from the Facility.

50. The MPCA, Dodge County, and the city of Claremont are not aware of any odor complaints about the existing Facility.

51. No significant change in type or quantity of odors from the Facility is expected as a result of the

Project. 52. Al-Corn is currently in compliance with, and will remain in compliance with, applicable state and

federal air emission laws.

53. Odor complaints are addressed on the county or local level. If odor complaints are received, the impacts are likely to be temporary in nature and Al-Corn could implement corrective measures such as physical or operational changes. Therefore, the MPCA finds that any odor impacts that are reasonably expected to occur from the Facility are reversible.

54. The MPCA finds that information presented in the EAW and other information in the environmental review record are adequate to address the concerns related to odor impacts. The MPCA has considered the impacts on air quality with respect to odors that are reasonably expected to occur from the Project during the review process. The MPCA finds that appropriate mitigation measures are available and will be required to prevent significant adverse impacts.

55. The MPCA finds that the Project, as proposed, does not have the potential for significant environmental effects based on the type, extent, and reversibility of odor impacts that are reasonably expected to occur from the Project.

Cumulative Potential Effects 56. The second criterion that the MPCA must consider when determining if a project has the potential

for significant environmental effects is the “cumulative potential effects.” In making this determination, the MPCA must consider “whether the cumulative potential effect is significant; whether the contribution from the project is significant when viewed in connection with other contributions to the cumulative potential effect; the degree to which the project complies with approved mitigation measures specifically designed to address the cumulative potential effects; and the efforts of the proposer to minimize the contributions from the project.” Minn. R. 4410.1700 subp.7.b. The MPCA findings with respect to this criterion are set forth below.

57. The EAW, public comments, and MPCA follow-up evaluation did not disclose any related or anticipated future projects that may interact with the Project in such a way as to result in significant cumulative potential environmental effects.

58. The EAW addressed the following areas for cumulative potential effects for the Project.

· Air Quality · Groundwater

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Air Quality 59. The MPCA considered the cumulative potential effects for the Project on air quality. This analysis

included consideration of background concentrations for the area and the impacts from the Project.

60. Operation of the Project will generate air emissions. Al-Corn conducted air dispersion modeling to evaluate cumulative effects specifically for this EAW. This evaluation considered background conditions and the Project impacts. See Findings 16 through 25 above. Based on the modeling, the MPCA expects that the anticipated increase in air emissions will not result in significant cumulative potential effects.

61. Based on information on the Project obtained from air modeling, permit application processes,

information presented in the EAW, and in consideration of potential effects due to related or anticipated future projects, the MPCA finds no potential for significant cumulative effects from the Project with respect to air quality.

Groundwater

62. The MPCA considered the cumulative potential effects for the Project on groundwater.

63. The Project will result in an increased need for water. See Findings 26 through 33. Al-Corn will use

an existing well at the Facility, not currently used for production and screened within the deeper aquifer (Prairie du Chien-Jordan), to support the increased ethanol production as well as provide a back-up to existing water supply wells screened in the shallower Dubuque-Galena Group.

64. Based on the aquifer test data and the analysis results, the well is capable of sustaining a yield in

excess of 700 gpm without long-term depletion of the groundwater resource.

65. Based on the information on the Project obtained from the aquifer test report, water appropriation permit application processes, information presented in the EAW, and in consideration of potential effects due to related or anticipated future projects, the MPCA finds no potential for significant cumulative effects from the Project with respect to groundwater.

The Extent to Which the Environmental Effects Are Subject to Mitigation by Ongoing Public Regulatory Authority 66. The third criterion that the MPCA must consider when determining if a project has the potential for

significant environmental effects is "the extent to which the environmental effects are subject to mitigation by ongoing public regulatory authority. The RGU may rely only on mitigation measures that are specific and that can be reasonably expected to effectively mitigate the identified environmental impacts of the project." Minn. R. 4410.1700, subp. 7.C. The MPCA findings with respect to this criterion are set forth below.

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67. The following permits or approvals will be required for the Project:

Unit of Government Permit or Approval Required MPCA Title V Part 70 Federal Air Permit

National Pollutant Discharge Elimination System (NPDES)/State Disposal System (SDS) Construction Stormwater General Permit NPDES/SDS Individual Permit Modification/Reissuance Above Ground Storage Tank Permit Section 401 Certification

Minnesota Department of Natural Resources (MDNR)

Water Appropriation Permit Endangered and Threatened Species Taking Permit

Dodge County Minnesota Wetland Conservation Act Design and Septic Permit Building Permit

U.S. Army Corps of Engineers (USACE) Section 404 Permit 68. Title V Part 70 Federal Air Permit. Al-Corn must modify its current Air Permit from the MPCA before

construction for the Project can begin. The Air Permit will contain operational and emission limits, including requirements for use of control equipment, that will help prevent or minimize the potential for significant environmental effects.

69. MPCA - NPDES/SDS Construction Stormwater General Permit. Al-Corn must obtain a National Pollutant Discharge Elimination System/State Disposal System (NPDES/SDS) Construction Stormwater (CSW) General Permit for the Project. A NPDES/SDS CSW General Permit is required when a project disturbs one or more acres. It provides for the use of best management practices (BMPs) such as silt fences, bale checks, and prompt revegetation to prevent eroded sediment from leaving the construction site. The Project must have a Stormwater Pollution Prevention Plan detailing the BMPs to be implemented and that will also address phased construction, vehicle tracking of sediment, inspection of erosion control measures implemented, and timeframes in which erosion control measures will be implemented. The general permit also requires the Proposer to provide adequate stormwater treatment capacity to assure that water quality will not be impacted by runoff once the Project is constructed.

70. MPCA - NPDES/SDS Individual Permit Modification/Reissuance. Al-Corn is required to obtain a modified NPDES/SDS Individual permit for the Project. The NPDES/SDS Individual Permit requires that specific conditions be adhered to for design and operation of the Facility, and for overall water quality compliance, including regular monitoring and limits for discharge.

71. MPCA - Above Ground Storage Tank Permit. Al-Corn is required to obtain a modified Above Ground Storage Tank permit for the Project. The Above Ground Storage Tank Permit includes operational limits and construction requirements that would help prevent or minimize the potential for significant environmental effects. Requirements include a secondary containment area, routine monitoring for leaks, corrosion protection for the floor of the tank, overfill prevention equipment, and areas where substances are transferred must be equipped with spill containment.

72. MPCA - Section 401 Certification. The Project must obtain a Water Quality Certification from the MPCA, which is issued with the U.S. Army Corps of Engineers (USACE) Section 404 Wetlands and Section 10 (Rivers and Harbors) Permits and Federal Energy Regulatory Commission licenses to hydropower facilities.

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73. MDNR - Water Appropriation Permit. Al-Corn is required to obtain a modified Water Appropriation Permit from the MDNR for the Project. The Water Appropriation Permit is required for all users withdrawing more than 10,000 gallons of water per day or one MMGY. The purpose of the permit program is to ensure water resources are managed so that adequate supply is provided to long-range seasonal requirements for domestic, agricultural, fish and wildlife, recreational, power, navigational, and quality control.

74. MDNR - Endangered and Threatened Species Taking Permit. Al-Corn is required to obtain a taking permit from the MDNR. Minn. Stat. § 84.0894 and associated rules prohibit take of a threatened species without a permit from the MDNR. Further, a permit may not be issued unless the benefits of the taking outweigh the harm caused by it. Compensatory mitigation provides the means for creating a net benefit to the species that offsets the harm caused by the taking. The terms of the permit and accompanying compensatory mitigation will be negotiated between the MDNR and the prospective permittee.

75. Dodge County – Minnesota Wetland Conservation Act Permit. Al-Corn is required to obtain a

Wetland Conservation Act Permit from Dodge County to ensure replacement of wetlands impacted by the Project.

76. Dodge County – Design and Septic Permit. Al-Corn is required to obtain a design and septic permit

from Dodge County to ensure compliance with local septic ordinances and state code.

77. Dodge County – Building Permit. Al-Corn is required to obtain a building permit from Dodge County. The building permit helps to ensure compliance with local zoning ordinances and building codes.

78. USACE - Section 404 General Permit/Letter of Permission (LOP)/Individual Permit. Al-Corn is

required to obtain a Section 404 Permit or LOP from the USACE. · General permits authorize the discharge of dredge and fill material into waters of the United

States, and perform work in Section 10 navigable waters, for specific activities listed in the general permit and is limited to the conditions and terms of the general permit.

· A letter of permission is a type of individual permit issued by the USACE through an abbreviated process that includes coordination with the Federal and state agencies.

· An Individual Permit requires specific information and the project is public noticed. It is used to authorize the discharge of dredge and fill material into waters of the United States, and perform work in Section 10 navigable waters.

79. The above-listed permits include general and specific requirements for mitigation of environmental

effects of the Project. The MPCA finds that the environmental effects of the Project are subject to mitigation by ongoing public regulatory authority.

The Extent to Which Environmental Effects can be Anticipated and Controlled as a Result of Other Available Environmental Studies Undertaken by Public Agencies or the Project Proposer, Including Other EISs 80. The fourth criterion that the MPCA must consider is “the extent to which environmental effects can

be anticipated and controlled as a result of other available environmental studies undertaken by

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public agencies or the project proposer, including other EISs,” Minn. R. 4410.1700, subp. 7. D. The MPCA findings with respect to this criterion are set forth below.

81. MPCA staff reviewed the following documents as part of the environmental impact analysis for the

Project: · Data presented in the EAW · Air permit application · Air dispersion modeling report · Air risk assessment screening spreadsheet

82. The list above is not intended to be exhaustive. The MPCA also relies on information provided by

the proposer, persons commenting on the EAW, staff experience, and other available information obtained by staff.

83. The MPCA finds that the environmental effects of the Project have been addressed by the design

and permit development processes and by ensuring conformance with regional and local plans. There are no elements of the Project that pose the potential for significant environmental effects.

84. Based on the environmental review, previous environmental studies by public agencies or the

Project proposer, and staff expertise and experience on similar projects, the MPCA finds that the environmental effects of the Project that are reasonably expected to occur can be anticipated and controlled.

85. The MPCA adopts the rationale stated in the attached Response to Comments (Appendix A) as the

basis for response to any issues not specifically addressed in these Findings.

CONCLUSIONS OF LAW

86. The MPCA has jurisdiction and is the RGU for determining the need for an EIS for the Project.

87. The EAW, the permit development process, and the evidence in the record are adequate to support a reasoned decision regarding the potential for significant environmental effects that are reasonably expected to occur from the Project.

88. Areas where the potential for significant environmental effects may exist have been identified and

appropriate mitigation measures have been incorporated into the Project design and permits. The Project is expected to comply with all MPCA standards.

89. Based on a comparison of the impacts that are reasonably expected to occur from the Project with

the criteria established in Minn. R. 4410.1700, subp. 7, the MPCA concludes that the Project as proposed and as regulated by the required permits does not have the potential for significant environmental effects.

90. Based on the record, an EIS is not required for the Al-Corn Clean Fuel Facility Expansion.

APPENDIX A

Minnesota Pollution Control Agency

Al-Corn Clean Fuel Facility Expansion Environmental Assessment Worksheet (EAW)

LIST OF COMMENT LETTERS RECEIVED

1. Melissa DeVetter, Dodge County. Letter received August 31, 2016. 2. Kevin Mixon, Minnesota Department of Natural Resources. Letter received September 8, 2016. 3. Don Kubat. Letter received on September 8, 2016. 4. Mark Schoenfelder, Minnesota Department of Transportation. Letter received September 13, 2016. 5. Sarah J. Beimers, Minnesota Historical Society. Letter received September 16, 2016. (Received after

comment period ended). 6. Esther Smith. Letter received on September 19, 2016. (Received after comment period ended).

RESPONSES TO COMMENTS ON THE EAW

1. Melissa DeVetter, Dodge County. Letter received August 31, 2016. Comment 1-1: Page 1: Project Location. Tax Parcel Number 09.029.0602 no longer exists as it was combined with the adjacent parcel. Response: Noted. Thank you for the comment. Comment 1-2: Page 5: Item 8 – Permits and Approvals Required. Dodge County would require an amendment of the existing Conditional Use Permit prior to expansion. In addition, for any structures, a Zoning Permit would be required. Dodge County does not administer the State Building Code so a Building Permit would not be required. However, project proposers are required to comply with the state of Minnesota Building Code and Department of Labor and Industry requirements. Response: Al-Corn will seek an amendment to the Conditional Use Permit and any required zoning permits at the completion of the environmental review. All structures must comply with Minnesota Building Codes and Department of Labor and Industry standards. Comment 1-3: Page 5: Item 8 – Permits and Approvals Required. There will be approvals required from Claremont Township and Minnesota Department of Transportation (MnDOT) for the approval of the gravel township road. Response: Noted. Thank you for the comment. Comment 1-4: Page 5: Item 8 – Permits and Approvals Required. Are there permits or approvals required from MnDOT for the rail spur? Response: The MnDOT Railroad office will be notified by Canadian Pacific Railroad. This is the only requirement related to the railroad spur that requires MnDOT involvement. Comment 1-5: Page 6: Item 9 – Land Use. Item a. (Describe), i., paragraph 2 states "Coordination with the Natural Resources Conservation Service (NRCS) is typically required to assess impacts to farmland.

Al-Corn Clean Fuels Facility Expansion Responses to Comments on the Claremont, Minnesota Environmental Assessment Worksheet

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However, in this case the areas impacted by the Project are currently under Al-Corn ownership. Therefore, the farmlands impacted by the Project are not subject to the Farmland Protection Policy Act, and Al-Corn is not required to coordinate with the NRCS to assess any impacts to the areas under its ownership." Projects are subject to Farm Protection Policy Act (FPPA) requirements if they may irreversible convert farmland (directly or indirectly) to nonagricultural use and are completed by a Federal agency or with assistance from a Federal agency. The means that although Al-Corn owns the property and is not a federal agency, if Al-Corn or any renters of the property receive any federal assistance or are involved with farm service agency financial farm programs, they may be subject to the FPPA. If they have not already, it is recommended that they contact the United States Department of Agriculture Farm Service Agency (USDA FSA)/NRCS to verify that the project is not subject to the FPPA. Response: Al-Corn has contacted USDA FSA/NRCS. Short Elliot Hendrickson Inc. (SEH), a consultant for Al-Corn, is working with the agencies on determining the applicability of the AD-1006 or Farmland Conversion Impact Rating Form. Should it be deemed appropriate, SEH will work in coordination with the agencies on completing the necessary paperwork. Comment 1-6: Page 6: Item 9 – Land Use - Item a. (Describe), iii (Zoning). The zoning of the property on the parcels located in the unincorporated area are zoned “Industrial." Response: Noted. Thank you for the comment. Comment 1-7: Page 8: Item 10 (b) – Geology, Soils and Topography/Land Forms. Item b. (Soils and topography) fourth paragraph states that approximately 280,000 cubic yards of soil will be excavated over a 60.3-acre area and 135,000 will be reused. Where is the location of the permanent stockpile on the project site? Response: There will be no permanent stockpile. The excess soil will be graded and seeded on-site. Comment 1-8: Page 12: Item 11 – Water Resources. The EAW indicates that the Facility will only discharge stormwater. However, an EAW completed in 2006 indicated that cooling water blow down, reverse osmosis reject water, and media filter backwater was permitted to be discharged to Ditch No. 7 at a rate of 190,000 gallons per day. It is not clear in the current EAW, if this discharge still occurs and if the expansion will increase the amount of discharge or impact water quality. Response: In the past, Al-Corn was permitted to discharge cooling water blow down, reverse osmosis reject water, and media filter backwater into Judicial Ditch No. 7. Since 2008, these non-process water streams have been recycled back into the process as a standard operational practice. With the Facility expansion, these non-process water streams will continue to be recycled back into the process. There will be no authorized discharges from the Facility other than stormwater. Comment 1-9: Page 12: Item 11 – Water Resources. The EAW does not indicate the quantity of stormwater runoff, only the changes in volume and flow. There are no specific best management practice site locations identified, or specific erosion control sedimentation control or stabilization measures identified.

Al-Corn Clean Fuels Facility Expansion Responses to Comments on the Claremont, Minnesota Environmental Assessment Worksheet

3

Response: The quantity of stormwater at the Facility will vary on an annual basis with relation to weather and climate patterns. The increased stormwater holding capacity will provide for greater retention on-site and is designed based on existing and proposed impervious surface as shown on Figure 3 of the EAW. Erosion prevention and sediment control requirements will be followed in accordance with the Facility Stormwater Pollution Prevention Plan. There are no existing steep slopes within the Project area. The disturbed soils will be permanently stabilized after construction through the use of vegetation or will be returned to agricultural production. Temporary soil stabilization techniques will be employed during construction. See the attached Plant Erosion Control Plan and Rail Erosion Control Plan for more information. Tables A and B, attached, show the existing and proposed stormwater volumes generated at and leaving the Facility. Comment 1-10: Page 21: Item 13 – (Fish, Wildlife, Plant Communities and Sensitive Ecological Resources). Will the Valerian be moved, reestablished or destroyed if the permit to take is granted? Response: If the Minnesota Department of Natural Resources (MDNR) issues a permit to take the valerian, the permit will authorize the destruction of the plants. As a separate action, the MDNR may or may not choose to salvage (transplant to another location) the plants or to issue a permit for another party to salvage the plants before they are destroyed. Comment 1-11: Page 23: Item 15 – Visual. There are vapor plumes and light visible from Al-Corn. In addition, it indicates that additional lighting will be added. How far is this project visible during the night? This section is incomplete as it doesn’t evaluate visual effects of the project or identify any measures to mitigate. Response: Lighting added during the expansion will meet Dodge County Zoning Ordinance Section 17.16 and will be installed so as to deflect light away from any adjacent property and/or from public streets, when applicable. No lighting is needed or planned for the Facility stacks as they are below the heights needing lights. Lighting required for safe and efficient operations on the expanded Facility will be similar to existing. Comment 1-12: Page 26: Item 16 – Air. Does the analysis take into effect the prevailing wind direction? There is a statement that indicates that the nearest sensitive air receptor is located southwest approximately 2,200 feet from the thermal oxidizer; however, the prevailing wind is typically from the south/south west to the north/northeast and would carry the plume in that direction. Dodge County has received complaints from northern properties about a film from Al-Corn covering their buildings as well as odor. Response: Prevailing wind direction is part of the U. S. Environmental Protection Agency (EPA) AERMOD plume dispersal modeling completed for the air quality analysis. MPCA processes the meteorological data used by facilities and consultants for air dispersion modeling following EPA guidelines and specifications. These data are from the National Weather Service/Federal Aviation Administration (NWS/FAA) stations located throughout the state. Hourly measurements for up to five years are used in modeling analyses; thus approximately 43,000 observations are utilized. Air temperature, dew point, wind direction and speed, precipitation, and cloud cover are all measured parameters from these observations. In this modeling demonstration, the Owatonna (KOWA) Municipal Airport data were used

Al-Corn Clean Fuels Facility Expansion Responses to Comments on the Claremont, Minnesota Environmental Assessment Worksheet

4

as this was the most representative observation site to the Al-Corn Facility in nearby Claremont. The years used in this demonstration are 2009-2013. The overall prevailing wind from the Owatonna dataset show the prevailing winds to be out of the northwest and southeast as is typical of most observation sites across Minnesota. However, depending on the weather pattern (i.e. high and low pressure systems, cold and warm fronts, etc.) the winds can vary and blow out of non-prevailing directions. The wind speeds and durations are representative of what is seen in southern/south central Minnesota due to the geography of the region. Modeled concentrations patterns reflect these prevailing wind directions with the majority of these occurring from the northwest to north of the Facility as well as to the east/southeast. Based on the MPCA Air Emissions Risk Analysis (AERA), the levels of pollutants emitted will continue to remain below the National Ambient Air Quality Standards (NAAQS) and Minnesota Ambient Air Quality Standards (MAAQS). Al-Corn used the MPCA’s Risk Assessment Screening Spreadsheet (RASS) to evaluate the acute toxicity, chronic toxicity, and health risks associated with emissions from the Project. The RASS conservatively considers the relative health risk for each pollutant emitted by the Project. The Project was found to not affect any sensitive receptors (i.e., residences, parks, day cares, and schools) located beyond the Facility fence lines. The results of the RASS show that the Project does not need further evaluation. Al-Corn and MPCA do not expect the Project to adversely affect human health and the environment. The AERA Report was provided as Attachment 7 to the EAW. In addition, the Air Products facility currently operating at the Al-Corn Facility will cease operation as part of the Project. The carbon dioxide currently vented by Air Products will be treated in a new carbon dioxide scrubber with a stack centrally located to Al-Corn’s existing operation. Al-Corn will fully comply with all requirements regarding air emissions and fugitive dust management and will implement state of the art control equipment to minimize emissions. Comment 1-13: Page 26: Item 16 – Air, item c (Dust and Odors). The information provided does not address the question nor any proposed mitigation. Response: The Facility started operations in late April 1996. In approximately 2002, all ethanol facilities were required to install thermal oxidizers on dryer exhausts to address volatile organic compound emissions associated with drying dried distiller’s grains and solubles (DDGS). Al-Corn was an early adopter of this technology, and once its new oxidizer was operating properly, odors associated with drying DDGS were eliminated. No significant change in type or quantity of odors from the Facility is expected as a result of the Project. All distillers’ grains are dried. Wet distillers’ grains can be a source of odor, but Al-Corn does not produce and store wet distiller’s grains outdoors. Exhaust from the new dryer, existing biogas from methanators, and dryer exhaust are routed to the existing thermal oxidizer or to the proposed regenerative thermal oxidizers. These existing and proposed emission controls are state of the art, and very effective. Al-Corn is unaware of any activity at the existing operation or other existing activities in the area that could produce the film and odors.

Al-Corn Clean Fuels Facility Expansion Responses to Comments on the Claremont, Minnesota Environmental Assessment Worksheet

5

In accordance with the Facility’s air permit, Al-Corn will maintain a Fugitive Dust Emission Control Plan to minimize fugitive dust emissions from Facility operations, including paved haul roads. Accordingly, dust emissions are not expected to change as all emissions, including dust controls will be equivalent or improved compared to existing operations. Al-Corn is currently in compliance with, and MPCA expects it will remain in compliance with, applicable state and federal air emission laws. Comment 1-14: Page 27: Item 17 – Noise. This section is incomplete. There is no discussion on the anticipated noise levels in the area or the effect on nearby sensitive receptors from the noise level or the duration (hours and days). It is noted that the Facility operates 24 hours per day, 7 days per week. There are statements made that there are no significant additional noise impacts from the Facility expected as a result of the project. However, there is no analysis of existing or proposed noise levels at the nearby sensitive receptors provided. Only a statement that doubling of sources will result in minimal noise increase and a list of the standards that must be met for residential receptors. It does not indicate whether Al-Corn is currently in compliance with noise standards, nor whether it will meet noise standards after expansion. The noise information does not consider noise from the increase in truck traffic, increase in rail traffic and rail car loading and transport which can take place 24 hours per day. Response: The Facility has been in operation since 1996 and has never received a noise complaint. The noise levels from the new equipment will be equivalent to or improved compared to existing noise levels. Enclosing the new hammermills indoors will be an improvement over existing noise levels. Most of the new equipment will be installed indoors. Outside noise generating equipment includes the addition of a second cooling tower and ethanol dehydration system which represents no more than doubling those systems. However, according to the MPCA guidance “A Guide to Noise Control in Minnesota” dated November 2015, (Noise Guidance), doubling sources of the same or lower noise levels will result in minimal noise increases; thus a minimal change from existing conditions in expected. Distances to receptors are not substantially different from existing and proposed equipment, and the Facility has existing background noise from U.S. Highway 14 to the north and the main line rail to the south between the Facility and the nearest receptors. Construction activities and associated noise will be conducted primarily during daylight hours. The nearest sensitive receptor to the Facility is a residence, located approximately 0.4 miles to the northwest across U.S. Highway 14. According to the Noise Guidance, this residential property is a Noise Classification Area (NAC) 1. The Minnesota noise standard requires that the noise reaching a NAC 1 property must conform to the most stringent standards. The Facility will not exceed the state noise standards under Minn. R. ch. 7030 at the nearest receptor: For residential locations, the limits are L10 = 65 decibels (dBA) and L50 = 60 dBA during the daytime (7:00 am to 10:00 pm) and L10 = 55 dBA and L50 = 50 dBA during the nighttime (10:00 pm to 7:00 am).

Railroad noise is the jurisdiction of the Federal Railroad Administration. Noise on MnDOT highways is handled by MnDOT, although most highways are exempt from the Minnesota noise standard. Roads owned by counties are also exempt from the Minnesota noise standards.

Al-Corn Clean Fuels Facility Expansion Responses to Comments on the Claremont, Minnesota Environmental Assessment Worksheet

6

Comment 1-15: Pages 28-30: Item 18 – Transportation. Access to the site occurs off of County Road 1. The applicant should coordinate with the Dodge County Highway engineer to determine if access is adequate and whether improvements are necessary based upon the increase in truck traffic. According to the Dodge County Highway engineer, the intersection with CSAH 1 and the section of CSAH 1 from TH 14 to the intersection will need reconstruction. In addition, they are studying the need for a right turn lane off of CSAH 1 and the size of the intersection for turning trucks. Response: Al-Corn has met with the Dodge County Zoning administrator and has initiated the course of action recommended by the EAW comments. Al-Corn has been and will continue to be in contact with the Dodge County Highway engineer as the Project moves forward following completion of the environmental review process. The existing roadways have sufficient capacity to handle the increase in truck traffic based on review of the MnDOT traffic counts as stated in Section 16B and 18 of the Al-Corn EAW. It is noted that Dodge County has commented that there is a potential for reconstruction on CSAH 1. As a further note, Al-Corn understands that the city of Claremont is considering an improvement to 5th Street, which will likely require coordination with the Dodge County Highway engineer. Comment 1-16: Pages 28-30: Item 18 – Transportation. Has there been any determination from MnDOT (rather than MPCA) that the project will cause an increase in traffic congestion or contribute to future increase in traffic associated with other development in the area? Response: As stated in the EAW, increased vehicle traffic is anticipated due to the increase in grain receiving and product load out. The expansion will create an approximate maximum 2% increase in traffic on U.S. Highway 14 with a maximum of 146 vehicles added to the existing 7,800 annual average daily traffic (AADT) collected by MnDOT. The expansion will create an approximate maximum 9% increase in traffic on 120th Avenue with a maximum of 146 vehicles added to the existing 1,650 AADT. The 2013 AADT traffic counts include existing vehicle traffic to the Facility. Traffic congestion is not anticipated. No traffic improvements are planned at this time. MnDOT has been contacted and Al-Corn will continue to work with them once environmental review is complete. MnDOT’s comments on the EAW, and responses to those comments, are provided below. 2. Kevin Mixon, Minnesota Department of Natural Resources. Letter received September 8, 2016. Comment 2-1: Coordination should continue with Richard Baker, Endangered Species Coordinator, concerning the required takings permit for impacts to state-listed plants. Response: Thank you for the information. Al-Corn will continue to work with Mr. Baker on the required takings permit. 3. Don Kubat. Letter received on September 8, 2016. Comment 3-1: The commenter has concerns regarding strong odors coming from the Facility. Response: Please see the response to comment 1-13 regarding odors.

Al-Corn Clean Fuels Facility Expansion Responses to Comments on the Claremont, Minnesota Environmental Assessment Worksheet

7

Comment 3-2: The commenter has concerns regarding air quality impacts and particulate matter coming from the Facility. Response: Please see the response to comment 1-12 regarding air emissions. Comment 3-3: The commenter has concerns regarding noise levels at the Facility and if any studies were conducted on air quality. Response: Please see the response to comment 1-14 regarding noise. Regarding air quality, Al-Corn conducted a dispersion modeling analysis to show that the Facility will be in compliance with NAAQS and MAAQS for fine particulate matter (PM10 and PM2.5), nitrogen dioxide, sulfur dioxide, and carbon monoxide. The dispersion modeling used five years of recent meteorological data from Owatonna. Al-Corn also used the MPCA’s RASS to evaluate the acute toxicity, chronic toxicity, and health risks associated with air emissions from the Project. Results from the RASS indicate that the Project will not adversely affect human health and the environment. Please also see comment 1-12 regarding air emissions for additional information. Comment 3-4: The commenter has concerns regarding the long term effects of the volume of water used at the Facility. Response: The use of a new well (Prairie du Chien-Jordan aquifer) proposed for the expansion is going to lessen the impact on neighboring wells (Dubuque-Galen Group aquifer) because the new well is in a separate, deeper aquifer. The MDNR is the governmental agency that regulates water appropriation. Al-Corn is required to report its water usage on an on-going basis as part of the water appropriation permit. An Aquifer Test Report prepared for this well by Natural Resources Group, LLC (June 6, 2008) is on-file with the MDNR. Based on Al-Corn and MDNR’s analysis of the pump test results, the aquifer parameters were favorable for development. Based on the aquifer test data and the analysis results, the well is capable of sustaining a yield in excess of 700 gpm without long-term depletion of the groundwater resource. Al-Corn believes that sustained pumping of this well, at less than 700 gpm, will not result in any water use conflict with the overlying Dubuque-Galena Group aquifer, and the pumping influence of the well will not significantly affect the operation of other existing water supply wells. However, if the MDNR determines there is well interference based on concerns or well interference claims, Al-Corn must fix the causes of the interference. 4. Mark Schoenfelder, Minnesota Department of Transportation (MnDOT). Letter received

September 13, 2016. Comment 4-1: There is a concern of truck traffic queuing back to U.S. Highway 14. Additional review of where the new parking will be located will be required. Response: Thank you for the comment. Al-Corn has been in contact with MnDOT and will complete the additional review after completion of the EAW.

Al-Corn Clean Fuels Facility Expansion Responses to Comments on the Claremont, Minnesota Environmental Assessment Worksheet

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Comment 4-2: The northerly portion of the proposed railroad loop goes through the existing MnDOT R/W sight corners along the south side of US 14 at 110th Avenue. These sight corners are shown on the enclosed Right of Way Plats 20-10 and 20-11. To move forward with the proposal as shown, the sight corners will need to be conveyed to the proposer. Please contact Brandon Marsh, MnDOT District 6 Right of Way at 507-286-7612 to begin the process. A plan sheet showing the area to be conveyed (in red) is included for your reference. Response: Thank you for the comment. Al-Corn has been in contact with Brandon Marsh with MnDOT and will complete the conveyance after completion of the EAW. Comment 4-3: A determination for the need of a MnDOT drainage permit cannot be made at this time. MnDOT will require a review the hydraulic calculations to ensure that there is not an increase to MnDOT’s centerline culverts from the proposed holding ponds. Please contact Terry Condon, MnDOT Permits, at 507-446-5505. Response: Thank you for the comment. Al-Corn has been in contact with Terry Condo with MnDOT and will complete the permit after completion of the EAW. 5. Sarah J. Beimers, Minnesota Historical Society. Letter received September 16, 2016. Comment 5-1: We have reviewed the EAW and the cultural resources survey report that was prepared for this project. Based on the results of the survey, we conclude that there are no properties listed in the National or State Registers of Historic Places, and no known or suspected archaeological properties in the area that will be affected by this project. Please note that this comment letter does not address the requirement of Section 106 of the National Historic Preservation Act of 1966 and 36CFR800, Procedures of the Advisory Council on Historic Preservation for the protection of historic properties. If this project is considered for federal assistance, or requires a federal permit or license, it should be submitted to our office by the responsible federal agency. Response: Noted. Thank you for the comment. 6. Esther Smith. Letter received September 19, 2016. Comment 5-1: I am supporting to expand the expansion of the Al-Corn plant. Response: Noted. Thank you for the comment.

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© 2015 Karges-Faulconbridge, Inc.

670 COUNTY ROAD B WESTST. PAUL, MINNESOTA 55113

Tel. (651) 771-0880Fax (651) 771-0878

E-mail kfi@kfi-eng.com

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Project Title: Sheet Title:

Sheet Number:

Revision Number:

© 2015 Karges-Faulconbridge, Inc.

670 COUNTY ROAD B WESTST. PAUL, MINNESOTA 55113

Tel. (651) 771-0880Fax (651) 771-0878

E-mail kfi@kfi-eng.com

Table A

Stormwater Volumes Generated

Al‐Corn Environmental Assessment Worksheet

Claremont, Minnesota

Generated Volume 

(acre‐ft) Average cfs Peak cfs

Generated Volume 

(acre‐ft) Average cfs Peak cfs

Generated Volume 

(acre‐ft) Average cfs Peak cfs

Generated Volume 

(acre‐ft) Average cfs Peak cfs

Generated Volume 

(acre‐ft) Average cfs Peak cfs

SW 3.82 1.93 15.36 8.74 4.40 38.33 12.96 6.53 57.94 16.82 8.48 75.71 21.18 10.68 95.61

NW 7.89 3.98 24.62 18.10 9.12 61.19 26.88 13.55 92.71 34.91 17.60 121.33 43.99 22.18 153.41

SE 4.56 2.30 24.93 10.40 5.24 61.71 15.42 7.77 93.12 20.00 10.08 121.59 25.18 12.69 153.46

NE 1.63 0.82 9.55 3.72 1.88 23.64 5.52 2.78 35.70 7.16 3.61 46.61 9.01 4.54 58.81

Generated Volume 

(acre‐ft) Average cfs Peak cfs

Generated Volume 

(acre‐ft) Average cfs Peak cfs

Generated Volume 

(acre‐ft) Average cfs Peak cfs

Generated Volume 

(acre‐ft) Average cfs Peak cfs

Generated Volume 

(acre‐ft) Average cfs Peak cfs

SW 8.47 1.45 7.70 16.46 3.25 19.36 23.06 5.50 29.26 27.99 8.19 38.21 35.61 11.24 48.15

NW 9.13 3.96 24.27 19.53 8.79 57.37 28.32 12.99 86.02 36.30 16.95 113.16 45.27 21.42 135.10

SE 5.83 2.30 14.68 10.84 5.24 36.72 14.88 7.33 57.94 18.48 9.11 80.66 22.47 11.10 105.65

NE 1.63 0.82 9.55 3.72 1.88 23.64 5.52 2.78 35.70 7.16 3.61 46.61 9.01 4.54 58.81

2 Year 24 Hour 10 Year 24 Hour 25 Year 24 Hour 50 Year 24 Hour 100 Year 24 Hour

Existing Conditions

2 Year 24 Hour 10 Year 24 Hour 25 Year 24 Hour 50 Year 24 Hour 100 Year 24 Hour

Post‐Expansion Conditions

Table B

Stormwater Volumes Leaving Site

Al‐Corn Environmental Assessment Worksheet

Claremont, Minnesota

Volume (acre‐ft) Average cfs Peak cfs Volume (acre‐ft) Average cfs Peak cfs Volume (acre‐ft) Average cfs Peak cfs Volume (acre‐ft) Average cfs Peak cfs Volume (acre‐ft) Average cfs Peak cfs

SW 3.82 1.93 15.36 8.74 4.40 38.33 12.96 6.53 57.94 16.82 8.48 75.71 21.18 10.68 95.61

NW 7.89 3.98 24.62 18.10 9.12 61.19 26.88 13.55 92.71 34.91 17.60 121.33 43.99 22.18 153.41

SE 4.56 2.30 24.93 10.40 5.24 61.71 15.42 7.77 93.12 20.00 10.08 121.59 25.18 12.69 153.46

NE 1.63 0.82 9.55 3.72 1.88 23.64 5.52 2.78 35.70 7.16 3.61 46.61 9.01 4.54 58.81

Volume (acre‐ft) Average cfs Peak cfs Volume (acre‐ft) Average cfs Peak cfs Volume (acre‐ft) Average cfs Peak cfs Volume (acre‐ft) Average cfs Peak cfs Volume (acre‐ft) Average cfs Peak cfs

SW 2.87 1.45 7.70 6.46 3.25 19.36 10.91 5.50 29.26 16.24 8.19 38.21 22.30 11.24 48.15

NW 7.85 3.96 24.27 17.43 8.79 57.37 25.77 12.99 86.02 33.62 16.95 113.16 42.48 21.42 135.10

SE 4.56 2.30 14.68 10.40 5.24 36.72 14.53 7.33 57.94 18.07 9.11 80.66 22.01 11.10 105.65

NE 1.63 0.82 9.55 3.72 1.88 23.64 5.52 2.78 35.70 7.16 3.61 46.61 9.01 4.54 58.81

10 Year 24 Hour 25 Year 24 Hour 50 Year 24 Hour 100 Year 24 Hour2 Year 24 Hour

10 Year 24 Hour 25 Year 24 Hour 50 Year 24 Hour 100 Year 24 Hour2 Year 24 Hour

Existing Conditions

Post‐Expansion Conditions

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