DRAFT EIS COMMENTS PAGE ONE
Mesaba Energy Project, PUC Docket No. E6472/GS-06-668
DOE Draft EIS for the Mesaba Energy Project (DOE/EIS-0382D)
Comments on Draft EIS
Submitted by: Citizens Against the Mesaba Project
QUESTIONS REGARDING THE MESABA ENERGY PROJECT DEIS
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1. Carbon Capture and Sequestration (CCS) is arguably the main potential advantage of IGCC technology. Excelsior Energy only added their CCS "plan" when it became politically necessary to do so. MPUC Chair Koppendrayer has stated "You're in the wrong place." The DEIS states that "Excelsior has not established a detailed design for carbon capture and sequestration", and goes on to say that CCS is not feasible or economically viable for the Mesaba Energy Project.
Why allow this project to go forward if it has virtually no hope of realizing the main theoretical advantages of the technology? Given Minnesota's plan to reduce greenhouse gas emissions by 15% by the year 2015 and 80% by 2050, why would we allow a project to go forward that would be the state's 2nd largest polluter of CO2 and has no realistic hope of CCS?
2. Excelsior Energy's plan calls for the Canisteo Mine Pit to be closed to recreational use. The original Joint Permit Application outlined how this extraordinarily clear trout fishery would be ruined by concentrated discharge of cooling tower blowdown water. The appeal of the West Site for Excelsior is the availability of water that is not in the Lake Superior Watershed making it possible to discharge more mercury into our local waters. The DEIS does not reflect the importance of the CMP for local recreation. Excelsior continues to confuse the issue by discussing alternative water discharge plans based on theoretical future changes in water discharge permitting.
Why should we allow Excelsior Energy to take a rare lake trout fishery away from the public, and why should we allow them to pollute our local waters when technology exists to prevent this pollution completely?
Excelsior states that the Mesaba Project will not contribute additional mercury to the water discharge. Although they have repeatedly made this misleading statement, the reality is that the discharge water will carry highly concentrated levels of mercury, sulfates, and dissolved solids into Canisteo Mine Pit and/or Holman Lake and the Mississippi River.
Given the complex relationship of mercury in an aquatic environment, shouldn't the DEIS give accurate detail related to mercury discharge and subsequent impact? Why would the DEIS continue to repeat some of the same misleading statements given by Excelsior regarding mercury discharge? Why would the DEIS use an impact are of 3km when the mercury deposition will affect 720 lakes over 340 square km?
What is the health impact related to the 487,000 fish harvested from those lakes? Please address this health impact, especially as it relates to children and women of childbearing age. The DEIS should also address this impact relative to the information in Excelsior's JPA regarding the increased risk of cardiovascular disease in men even with low level chronic mercury exposure.
4. Adverse health consequences of the Mesaba Project are of significant local concern. Excelsior's early information to the MPUC in 2005 outlined significant negative health impacts related to air quality and plant emissions. These problems have been outlined during the Citizen's Advisory Task Force, in a letter to the MPUC signed by a majority of Itasca County physicians and nurse practitioners, and in citizen comments during the DEIS scoping. The DEIS discusses EMF health concerns, gives statistics related to the percentage of the population that is overweight, smokes, drinks, has hypertension, etc. However, the DOE/DOC ignores the real issue, which is the significant and expected increase in mortality and morbidity (death and illness) should this plant be built. The New England Journal of Medicine recently published a study outlining the 70-80% increase in heart attack and stroke for every 10 mcg/mm3 increase in PM 2.5 (See attached NJM article)
Why does the DEIS fail to address the negative health consequences directly related to the Mesaba Energy Project?
5. The DEIS lists "need" as a benefit of the Mesaba Project based on Excelsior's claim of regional baseload power need in the future. The Army Corps of Engineers and many citizens have challenged these claims, yet the DEIS then goes on to dismiss public comments refuting Excelsior's claims of "need".
Why would the DEIS ignore valid arguments contrary to Excelsior's unproven claim of need, yet list Excelsior's claim of need as a benefit of the Project?
6. The MPUC doesn't believe that the Power Purchase Agreement is in the public interest, as Excelsior's energy will be too expensive and the Project carries excessive risk.
Why does the DEIS indicate the MPUC will determine the public interest of this project, then disregard the MPUC findings/recommendations and instead reference Excelsior's press-release talking points in support of the Project?
7. The DEIS cites Excelsior's claims of economic benefit based on a single limited and poorly conducted study of economic impact that grossly overstates the Mesaba Project's economic impact. The DEIS then dismisses strong arguments against the claimed economic impact of this study stating that this will be evaluated by the MPUC. The MPUC has determined that a Power Purchase agreement with Excel Energy is not in the public interest due to the expense and risk to ratepayers. No cost benefit or total impact studies have been performed.
Why were citizen comments dismissed yet Excelsior's unfounded claims included? Why is the MPUC referenced as evaluating the economic merits of the project only to have that evaluation ignored?
8. The Minnesota DNR submitted numerous scoping comments related to water discharge and mercury deposition. The DNR has also maintained a strong interest in the Canisteo Mine Pit lake trout fishery, as well as in restoring water flow to Trout Lake (and thus improving Trout Lake water quality) from the CMP watershed.
Why does it appear that these comments have not been taken into consideration?
9. The DEIS outlines an ambitious emissions reduction program by Minnesota Power (MP), and states that these reductions would potentially offset visibility impacts related to the Mesaba Energy Project.
Why should we allow Excelsior Energy to "offset" Minnesota Power's emissions reductions and negate this improvement to our air quality?
10. The East Range site (Hoyt Lakes) carries less environmental impact than the West Range site. Although the air emissions, cost issues, and risk would be roughly the same, the West Site is more advantageous for Excelsior primarily because they can discharge higher mercury concentration water and might have greater ease obtaining land in the proposed footprint. There are many environmental disadvantages to the West Site.
Why does the DEIS appear to give preference to the more environmentally sensitive site just because of cost advantage for the developer?
11. Excelsior Energy did not perform a thorough investigation of the environmental permitting process as it relates to their original East Range site. Excelsior now says it would be too expensive to eliminate water discharge, so the West Site is preferred. This is because they apparently didn't realize the East Site is in the Lake Superior watershed and has a lower mercury standard. If this is the case, then they really don't have an "alternative" site, which is required. It may also mean that they don't even have a preferred site as their current plan won't allow permitting for water discharge. The current plan seems as poorly thought out as the first as they now need to rely on a "variance" or a possible future TMDL system which does not currently exist.
The DEIS could give scenarios on possible future options if regulations change, but the DEIS should first outline how Excelsior plans to meet permit requirements under current conditions.
12. Cumulative air quality effects are poorly outlined in this DEIS. For example, MSI already exceeds the Class I (BWCAW) limit for NOx and is supposed to buy NOx offsets to meet its permit requirement. It is unlikely these offsets will be able to be purchased. Since Mesaba is behind MSI in the permit line, Mesaba must have a NOX emission of zero, or purchase 100% of their NOx offset in addition to what MSI is supposed to buy. The DEIS makes no mention of this problem.
Why does the DEIS have such gross omissions with regard to cumulative effects? Why does the air quality modeling give no input assumptions/data? Why does the air quality information use modeling that gives low/conservative estimates?
13. The only way the Mesaba Project can meet environmental permitting criteria for water discharge (East or West site) is to totally eliminate water discharge. The DEIS gives a brief superficial description of this process.
The Final EIS should clearly indicate that total elimination of water discharge is necessary to comply with environmental regulations, and should give a detailed description of the Zero Liquid Discharge Process to be used. Only then can the actual environmental impact of the Mesaba Project be assessed as it relates to water quality.
DEIS Water Comments
Waste water discharge.
This section states that key water quality constituents associated with Outfall 001 and 002 discharges will be mercury, TDS, and hardness. It also states that the mass of mercury discharged to Holman Lake through Outfall 002, combined with the mass of mercury discharged to Panasa Lake from the HAMP will not exceed the mass of mercury currently permitted to be discharged to Panasa Lake under existing NPDES Permit No. MN0030198 currently held by the Minnesota DNR. Panasa and Holman Lake are tributary to the Swan River and Mississippi.
The next statement, "Therefore, this system will not contribute additional pollutants to the Swan River watershed." is inaccurate and misleading.
To correct this, the company needs to:
- 1. Acknowledge that additional mercury, sulfates, phosphorus, dissolved solids, and suspended solids will be present in this discharge stream, leading to an overall increase of these constituents in the Swan River/Mississippi tributary system.
2. Accurately and completely describe the makeup and amounts of the constituents described above.
3. Quantify the current mass or concentration of mercury discharged to Panasa Lake from the HAMP under NPDES permit No.MN0030198.
4. Address increased concentrations of phosphorus to this discharge stream (JPA Appendix 6 Section 5) and how this relates to the Annondale-Maple Lake Court Decision (currently under appeal) which does not currently allow for any new source NPDES/SDS permits above Lake Pepin.
5. Address the ability to use NDPES permit No MN0030198 vs. the need for a new permit.
6. Address and completely describe the relationship and impact of mercury and sulfur with regard to increased methyl-mercury formation and discharge limits on methyl-mercury to the Swan River system.
7. Thoroughly address the discharge of mercury and sulfur to wetlands and the anaerobic conditions of this environment leading to formation of methyl mercury.
8. Address the potential for discharge limits for methyl mercury (including secondary formation in the above environments) in addition to a total mercury discharge limit.
9. Thoroughly address the above issues with regard to increasing levels of sulfur, mercury, TDS, etc in the source water over time due to operation of the plant at the west site.
10. Quantify the average and maximum amount of dissolved solids due to concentration of TDS in this discharge stream, and identify subsequent impact on Holman Lake, Swan River, and the Mississippi River.
11. Address how adjustments of water discharged directly to Holman Lake ("every 5 years, or as needed during Phase I and II operation, to limit the mass of mercury discharged") will further impact quality of the Canisteo waters.
To correct these important issues of local concern, Excelsior Energy would need to incorporate a Zero Liquid Discharge system for the cooling tower blowdown at the West Range Site, similar to what has been proposed for the East Range Site. Excelsior also needs to outline a complete plan as to how this process would take place, as the information regarding ZLD is limited to only a paragraph or two and gives no specific technical information.
Water Sources: This section is inaccurate and incomplete in that it does not adequately address pollution of Canisteo Lake and potential for municipal water supply contamination as explained below.
The project proposes drawing process water from four sources and sending discharge water to Canisteo Lake with a minor restricted flow to Holman Lake. Most of the process water will be lost to evaporation in the cooling towers. The remaining discharge waters will have increased levels of mercury, phosphorus, sulfate and other dissolved solids. This results in a continuous increase in the contamination of Canisteo Lake as documented in Appendix 6 of the JPA.
The south wall of the old Canisteo pit cuts through all geological layers above the iron ore body. The upper layer is glacial deposits from the last Ice Age. Studies by USGS (Water-Resources Investigations Report 02-4198) show a south flow of ground water from Canisteo Lake to Trout Lake. The municipal wells for Bovey and Coleraine draw water from aquifers in this glacial layer.
The project proposal describes the nearby public water supplies for Bovey and Coleraine as having a possible hydrologic connection between groundwater captured by wells and local surface waters. The Minnesota Department of Health has found high tritium concentrations in groundwater pumped from these public water supply wells indicating that the water supply is more sensitive to land surface activity and more vulnerable to potential contamination.
These municipal wells appear to recharge fairly quickly, and because the iron ore body at the south end of Canisteo Lake slopes southward toward Bovey/Coleraine, gravitational flow of subsurface water would also be in this direction. Thus it appears that these aquifers are at risk for contamination as Canisteo Lake is polluted.
The MN Department of Health has confirmed the hydrologic connection between the CMP and municipal drinking water supply for Coleraine and Bovey. The DEIS makes no mention of this problem.
Section 5 JPA Appendix 6 shows that over time, (approximately 30 years), Canisteo Lake process water will have significantly increased levels of mercury, sulfates, and hardness. Water discharge will eventually exceed the mercury water quality standard of 6.9 ng/L. Canisteo water will exceed water quality standards for hardness and total dissolved solids (TDS) necessitating treating the power station effluent or further reducing the cycles of concentration. Mercury concentrations in Canisteo Lake will rise from 0.9 ng/L to 2.2 ng/L. There only a vague plan in Appendix 6 Section 5.2.2.1.1 for dealing with this problem.
This same scenario is taking place at Minntac now whereby the process water supply has become heavily polluted over the life of the plant. This water now has super-high levels of sulfates and hardness causing heavy scaling and makes water discharge issues extremely difficult and complex.
This issue is perhaps the most important local cause for concern. Polluting Canisteo Lake puts municipal wells at risk for contamination, will make Power Station use of this water inefficient, and will eventually make this water difficult if not impossible to discharge. The life of a power plant is not forever, and at some time in the future, we will need to deal with the issue of discharging polluted Canisteo water as surface levels rise. How will this be accomplished if the water exceeds quality standards, especially if future mercury standards for Swan River and Mississippi River are lowered similar to Lake Superior standards? In addition, Excelsior has offered no plan for reclamation of water quality after the life of the plant.
At this time, we have the potential for using Canisteo water to improve the water quality in Trout Lake. If the MEP is built on the West Range Site, we lose this opportunity, and we also lose the opportunity to keep and continue to develop an excellent recreational lake and lake trout fishery.
Excelsior Energy needs to address the problems defined above as it would be irresponsible for the company to ignore the future reality of this important issue. Committing to Zero Liquid Discharge on cooling tower blowdown discharge water from day one of operation appears to be the only way to prevent this situation from occurring.
Water Resources and Water Quality Canisteo Mine Pit
These sections are inaccurate in that they minimize the recreational importance of Canisteo Lake. The Canisteo fishery is not included in the DEIS, and is a super clear 5 mile long oligotrophic lake. The lake experiences more than "occasional" recreational use as described in the JPA, although "occasional use" is not defined. This report also describes low amounts of nutrients and biota, but this would be expected in any oligotrophic system, and the report is inaccurate in that it describes the lake as a "resulting poor fishery". The fish survey report used in the JPA appears to have been taken prior to the occurrence of lake trout stocking, and from personal experience and local anecdotal reports this lake has developed into an excellent lake trout and crappie fishery.
Fish in Canisteo Lake, especially lake trout as they are a fatty fish, will bioaccumulate increasing levels of mercury over time due to cooling tower blowdown discharge as described in JPA Appendix 6 Section 5. Excelsior Energy should address how this will affect fish consumption advisories over time. In addition, lowering water levels, especially over the winter, could expose lake trout eggs on shoals and negatively impact the fishery. In addition, introducing Prairie River water into Canisteo Lake could accelerate eutrophication due to much higher levels of phosphorous in the Prairie River.
Excelsior Energy also proposes to remove the MDNR Buckeye Mine Pit boat launch and close Canisteo Lake to recreational use for "safety, security, and operational reasons". The DNR and Western Mesabi Mine Planning Board are working to stabilize Canisteo Lake near the 1300ft-msl elevation with a siphon to Trout Lake. This would allow permanent access facilities to be established on the south shore near Coleraine, Bovey, and/or Taconite with resulting improvement in the water quality of Trout Lake and increased access to recreational use of Canisteo Lake.
Excelsior Energy should avoid introducing higher phosphorous water into Canisteo Lake, and commit to maintaining the Canisteo Lake level within a range compatible with fish reproduction and permanent recreational use facilities.
Cooling tower blowdown sludge from the proposed East Range ZLD system is "expected to be non-hazardous and will be tested to confirm such condition." The company should address the following questions:
- 1. How will this testing be performed, and how will the dry cake be stored prior to transport offsite?
2. How will storage containment measures and offsite transport be accomplished or change if the materials tested are found to be hazardous?
The JPA and DEIS quantifies the amounts of solids requiring disposal from the proposed East Range cooling tower blowdown ZLD system. The amount of solids requiring disposal is listed at 109 tons/day at peak flows and 73 tons/day annual average. There is no comparison to a similar system on the West Range Site. The company should address the following questions:
- 1. Quantify the maximum and average amounts of solids discharged to Holman Lake and Canisteo Lake in the absence of a ZLD system on the West Site.
2. Quantify the maximum and average amounts of solids requiring disposal with a ZLD system for cooling tower blowdown at the West Range Site.
3. Address appropriate disposal of these solids, and where this landfill would be located.
4. Address any potential environmental impact from this landfill.
Improvements from "lessons learned": The DEIS refers to improvements upon the Wabash River plant. The paragraph describes DOE funded studies of potential performance and technological upgrades but does not list the studies referenced. The company should:
- 1. Give citations of the DOE referenced studies.
2. Describe the performance upgrades that Wabash River required to meet discharge permit criteria for selenium, arsenic, and cyanide.
3. Submit data from Wabash River proving subsequent ability of that plant to meet these discharge permit limits.
Wetlands: The Mesaba Project proposal describes high groundwater levels in the soils in the vicinity of the West Range Site footprint, and states that the site may require permanent water table control measures. Given that over 300 acres of wetland exist on the West Range Site and adjacent utility corridors the company should:
- 1. Provide details on the acres and types of wetlands that will be affected.
2. Provide detail on how extensive these water table control measures would be, and how such measures would be accomplished.
3. Describe in detail how loss of wetlands will be mitigated.
HVTL: The project describes HVTL route proposals from the plant site to the Blackberry substation. There is significant local concern regarding these routes, as well as the needed upgrades beyond Blackberry. The information is incomplete in that:
- 1. The preferred route selection and alternatives do not list the amount of existing right of way vs. need for new property easements along each proposed route.
2. A list of affected landowners is not included, nor have landowners been notified.
3. HVTL routes should include information on landowners already affected by existing right of way, and separately identify landowners who will be affected by new right of way.
4. Identify the necessary upgrades required beyond Blackberry as well as the landowners affected by these upgrades.
Proposed Gas Pipeline Routes: This section describes NG pipeline preferred routes and alternatives. The information is deficient in that:
- 1. The proposed routes do not detail or compare the number of properties on existing corridors vs. new corridors.
2. There is an existing NG pipeline (Northland?) from Virginia and Hibbing that currently goes to the MSI site, and is much closer to the proposed MEP West Range Site. This route would appear to have significantly less impact on landowners and would follow an existing corridor.Why is this route (with the required upgrade) not included as an alternative to the routes proposed?
Issues of local concern include:
- 1. Alternative 3 appears to have the least impact on undisturbed land, is the shortest route, and has more existing corridor than the preferred option. How many property owners are in the new corridor vs. existing corridor for this proposal?
2. Alternative 2 is the longest route, but has over 10 miles of existing corridor and 5 affected property owners. How many property owners are in the new vs. existing corridor for this route?
3. Explain why, in light of the above questions, Alternative 1 is preferred.
4. Please also see alternative route submitted in DEIS comments by Bob Norgard, Bovey
Excelsior Energy should commit to utilizing a NG pipeline route that has the least environmental impact and affects the fewest landowners along new right of way corridors.
Carbon Capture: This section describes the potential for carbon capture retrofit. The claim is to be "carbon capture ready" and to assess CO2 management options, but states that the system "has yet to be engineered".
The company should address the following questions:
- 1. Excelsior Energy has claimed that carbon capture is viable option, yet how can this be if the system is yet to be engineered?
2. If, as Excelsior Energy states, CO2 caps/limits are inevitable, why not plan to capture CO2 now?
3. If a main advantage of IGCC technology is CO2 capture, why not plan to do this from the start?
4. How much CO2 capture is possible?
5. Given the geology of this region and inability to sequester CO2 in Minnesota, what are the details of a long term plan for CO2 sequestration?
6. What is the expected decrease in capacity and efficiency of the plant fitted for carbon capture? If carbon capture is not cost efficient IGCC may not be the right technology for this project. Alternatively, if carbon capture is cost efficient it should be put in place from the start.
Excelsior Energy should commit to taking full advantage of the benefits of IGCC technology and plan CO2 capture and sequestration from day one. If, as the DEIS states, CCS is not a viable option for the Mesaba Project, then the Mesaba Project is truly without merit, and should not go forward.
Mercury: The JPA described mercury removal and appears to state that 90% of the mercury will be removed from the solid IGCC feed stock.
- 1. If the Eastman process has been shown to remove 95% of mercury, why does this section state only 90%? The DEIS should hold Excelsior Energy to the higher standard.
Feedstock receiving and storage. Outdoor coal storage areas will have water runoff from rainwater and regular hosing/watering. Studies on a Wabash River coal plant in Lafayette, Indiana (not the demonstration plant) demonstrate that leachant from coal piles contain sufficient contaminants to be of concern.
The West Range Site has ground water flow southwest to Canisteo Lake and north into wetland. There is also evidence of a hydrological connection between the CMP and Bovey/Coleraine drinking water aquifers. (See Section 2.5.2.3.1 Environmental Supplement). The JPA p173 is vague in their measures to prevent ground water contamination. It does not appear that this has been rectified in the DEIS.
- 1. The company needs to commit to detailed measures for handling these waters and thus prevent ground water and municipal water contamination.
2. The DEIS does not adequately describe the impact of fugitive particulates from incoming or exiting rail cars, especially with regard to impacts on nearby local communities including Taconite, Marble, Bovey, Coleraine, Grand Rapids, Cohasset, and Deer River.
Sanitary Discharges: The project desctiption gives options for sanitary water discharges including MEP building its own WWTF vs. use of Bovey/Coleraine/Taconite WWTF.
The B/C/T WWTF already has problems with excess flow. Since 1999 there have been six separate events resulting in discharge to prior Cleveland Cliffs basins and Holman Lake. The MEP would further burden a system in need of attention and upgrade. If Excelsior dismisses building their own WWTF in favor of using B/C/T:
- 1. How and when will this WWTF be updated?
2. This is a local issue in that there will be a direct financial impact on the local municipalities. What technology upgrades need to be evaluated if the local municipal WWTF is utilized for the MEP. What is the cost of this upgrade directly attributable to the MEP, and how does this compare to potential cost shifting to the public at the East Range Site?
Canisteo overflow: The Draft EIS continues to state that the IGCC Power Station will play an important long term role at the West Range Site in regard to flood prevention of the CMP waters, and will be an important "pollution prevention feature." This is inaccurate and deceptive in that:
- 1. The project plan as described will direct cooling tower blowdown(CTB) discharge water to the Canisteo Mine Pit which currently has clarity to depths of over 50 ft. The CTB discharge water will result in increasing levels of mercury, sulfates, TDS, etc. If the company's statement is to be accurate, they need to commit to ZLD on the CTB.
2. Flood control of the Canisteo water will be accomplished through a planned siphon independent of the MEP. This siphon will be built regardless of if the MEP is approved or not. Trout Lake water quality will benefit from the discharge of low phosphorous CMP water to Trout Lake. The Trout Lake Association is on record as being in support of receiving water from this siphon, and a recent survey cited by lake association members revealed Trout Lake residents to be in favor of siphoning CMP to Trout Lake by an 8:1 vote.
Sections 4.11 (Socioeconomics)
and 4.12 (Environmental Justice)
Summary Comments
Section 4.11 analyzes the economic impact of building Phase I and Phase II of the Mesaba Energy Project, particularly the impact that construction and then continued operation would have on employment, income, business, population and housing. The outlook for employment, income and business is predictably positive and virtually unchanged from earlier reports (i.e. UMD/BBER IMPLAN software modeling). The CAMP position paper entitled "Economics of the Mesaba Energy Project" does an excellent job of illustrating the faults and inaccuracies of the BBER report.
This section also investigates the impact on population levels and housing during construction and operation. The EIS finds both the East and West Range sites capable of supporting temporary and permanent increases in population, with little impact to real property. Long-term housing requirements are not viewed as an issue, however the EIS does find that "...depending on the percentage of construction jobs that could be filled by existing residents, the influx of workers from outside the region could create a demand for rental housing and lodging that may exceed available capacity." (4.11-4).
Section 4.12 investigates the impact the Mesaba Energy Project might have on minority or low-income populations in the following areas: 1) would health effects be significant or above generally accepted norms, 2) is the risk or rate of hazard exposure likely to exceed that of the general, or comparison, population and 3) would health effects occur due to cumulative or multiple adverse exposures from environmental hazards. The EIS finds no issues with these three factors for either low-income, or minority populations (surprise, surprise!) due in no small part to the narrowly defined 'region of influence'.
General Comments Section 4.11 Socioeconomics
- 1. The wide range of influence is the 7 county area (Aitkin, Carlton, Cook, Itasca, Koochiching, Lake and St. Louis) the local range of influence is Census Tract 9810 (Iron Range Twp and Taconite) for the West Range Site and Census Tract 140 (Hoyt Lakes) for the East Range Site. The economic analysis is supposedly for the 7 county area the population and housing analysis is done from the Census Tracts.
2. The BBER, 2006 study does not do a cost/benefit analysis; it is strictly a benefit analysis. Even the BBER authors recognize this and caution against using their study as a complete view of the impacts of building Mesaba Phase I and II.
3. The BBER study is misleading in stating the economic value to Itasca County or the seven county wide range of influence. That is because much of the economic value supposedly coming to the area in the form of costs for coal, transportation, profits, interest, etc will actually be accrued where those services are provided or purchased. Most wages will be provided in Itasca County although 20% are estimated to be provided to residents of other counties.
4. The BBER study estimates the number of jobs that would be created in construction and during operation of Phase I and II as well as additional positions created as a result of having additional workers in the area. However, these predictions should be tempered as the job estimates are a combination of full time, part time and temporary positions.
5. Most of the construction and plant operation positions will be filled by people outside of Itasca County. That number will rise if this is a union construction job. This has direct negative impacts on housing in the area during the construction period.
6. The EIS assumes that there will be an available skilled labor force in the region due to, "...historically persistent higher unemployment rates..." and a decrease in the manufacturing and iron mining industries. It is not at all certain that jobs in iron mining and/or manufacturing are transferable to construction or operation jobs that Mesaba Phase I and II would provide. Continued investment in iron mining and the specter of Minnesota Steel would suggest that there will be a dramatic shortage of skilled labor for construction positions, requiring that more outside skilled labor be hired and housed in Itasca County.
7. The discussion of jobs, wages and employment is occurring in a vacuum. No mention is made of the impact that Minnesota Steel will have on the same population of workers that Mesaba will be trying to hire from. Job competition will be fierce if both are built at the same time. Although this is good news for a few people hired locally with an existing domicile the influx of workers and the shortage of housing will dramatically increase rental and housing costs to the detriment of imported workers through higher rentals, local homeowners through artificially increased property values and taxes and low-income non-skilled individuals and families through increased rental costs and wages that do not keep pace with the increased cost of housing.
8. Most if not all of the discussion in this section references dollars or employment that would be gained if Mesaba Phase I and II are built. Therefore the economic benefits are being overestimated given the scope of the proposed building. The permitting process is asking only for Phase I yet the economic analysis is offering figures for Phase I and II combined. We need to see an EIS that accurately compares all costs and benefits for Phase I, as well as for subsequent phases.
9. The proposed relocation of Itasca County Road 7, the Scenic Highway, is considered to be an act of Itasca County and not the Mesaba Project. Considering the fact that CR7 was recently (within the past 5 years) rerouted and resurfaced from 169 north along its original route at considerable expense it is obvious that an additional rerouting is being done to convenience the Mesaba Project at the expense of Itasca County taxpayers and should be at the very least considered an additional cost of the project.
10. The EIS estimates that, "Perhaps a dozen or more of the other residential properties along CR 7 and Diamond Lake Road closest to the plant site or rail alignment may experience reductions in values or at least slower rates of growth in values." (4.11-7)
11. The EIS states that, "...it is unlikely that residential properties along the proposed new HVTL corridors would experience substantial reduction in property values." Then proceeds to indicate that depending on the route chosen between 4 and 29 residences would be within 500 feet with some as close as 300 feet. I cannot imagine how these residences would not experience a negative impact to their property value. (4.11-7 and 8)
12. The EIS attempts to indicate that housing of temporary construction workers would be easier at the West Range vs. East Range site. This is not necessarily true, especially if Minnesota Steel is being constructed at the same time. (4.11-8)
13. The East Range site impacts fewer homeowners because the East Range site is a true brownfield site with existing infrastructure. This would reduce impacts on housing values due to construction. HVTL corridors would have to be widened and 49 residences are within 500 feet but the EIS states, "...it is unlikely that property values along these corridors would be affected by the additional HVTLs." in part because their values are already being impacted by existing HVTLs.
14. Consider that the economic impact is thought to be a 7 county region, or even throughout Minnesota, but areas that might be adversely affected are considered to be individual blocks within a Census Tract, or just along HVTL corridors and utility ROWs. This is inequitable.
15. Table 4.11.6 Summary of Impacts. This table claims, "Related realignment of CR7 by Itasca County may influence local housing development in vicinity" Here the EIS considers the realignment of CR7 'related' and a benefit yet does not include it as a cost. At the East Range site the lack of construction needed is considered a detriment where it should actually be a benefit.
16. The summary table 4.11.6 is not an accurate summary in that it represents the two sites (West and East Range) as being almost identical with the exception of the relocation of CR7 in the West Range plans and number of residences within rail alignments.
17. The text in section 4.11 points to numerous differences related to impacts to housing values as a result of construction and HVTL corridors, utility ROWs. The text does NOT point out that the East Range site is a brownfield site with existing utility and HVTL infrastructure and therefore more suitable for construction.
18. The socioeconomic analysis is incomplete. The Mesaba Project has to get its product to market and cannot do that without a HVTL that runs from northern Minnesota to the Twin Cities - St. Cloud area where the power is supposedly needed. This analysis does not cover the cost nor the impacts of creating an additional cross-state transmission line.
General Comments Section 4.12 Environmental Justice
- 1. The region of influence for the environmental justice analysis is incredibly narrow and does not match the region of influence used for the socioeconomic analysis. Moreover, my guess is that neither would match the size of the region of influence for the true environmental impact of the Mesaba Project Phase I or Phase I and II combined. To wit, "The regions of influence for environmental justice are determined for each resource area by the potential for minority and low-income populations to bear a disproportionate share of high and adverse environmental impacts from activities within the project area." The EIS then goes on to define the project area as Census Tract 9810 for the West Range and Census Tract 140 for the East Range site. If the economic analysis can be extended to a seven county area why is the environmental justice analysis limited to a singe Census Tract for each site?
2. The environmental region of influence or environmental project area of the Mesaba Project is undoubtedly larger than a single Census Tract (here I am calling the environmental region of influence the geographic area that would receive atmospheric deposition). If this is true then the environmental justice analysis, which is charged with assessing the health effects, risk and rate of hazard exposure and potential cumulative adverse exposures, must take a larger geographic area into consideration.
3. Where is the health report that Excelsior Energy commissioned touting the 'health benefits' of the Mesaba Project. That information was not referenced in either the socioeconomic or environmental justice sections.
4. Northern Minnesota in general and Itasca County in particular is the center for the environmental region of influence. Residents of Itasca County will bear the burden of any increased health effects, any increased health risks or rates, or be affected by cumulative or multiple adverse exposures from environmental hazards. The electricity generated here, will be sent to the Twin Cities metro area where it is needed. Northern Minnesota does not need this electricity but is being asked no required to accept any health burden that its generation would impose. On that basis alone the environmental justice analysis should compare the environmental region of influence, which would include all of Itasca County, with the Twin Cities metro area being the control group. Then the environmental justice analysis can evaluate whether the Proposed Action or alternative would cause disproportionately high and adverse effects on minority or low-income populations in the region of influence.
5. The environmental justice analysis outside of construction sites, HVTL corridors and utility ROWs presented in this EIS is inadequate. The EIS looked at "...the potential for adverse health risks in a wider radius from respective project sites and corridors based on impact analyzed in Section 4.17, Safety and Health, and the assess the potential that an adverse health rise would affect a minority population, low-income population , or American Indian tribe at a higher rate than the general population." The term 'wider radius' was never defined and the only reference made was to effect that additional mercury deposition would have on subsistence fishing on Diamond Lake. There was no effort made to include any other health risks such as particulate matter, VOCs, NOx, SOx or other heavy metal contamination from airborne deposition, nor consider their impact either individually or as cumulative or multiple adverse exposures as required in the Method of Analysis.
6. Somewhere I heard a woman testify that the West Range site is within view of a proposed American Indian retirement home. If this can be substantiated, even if it has not been built but exists only as purchased property with a plan, it may trigger the low-income, minority or American Indian tribe provisions of the analysis.
7. On page 4.12-3 the EIS states that, "Mercury emission in Minnesota declined significantly (about 68 percent) from 1990 to 2000, and there is evidence that concentrations of mercury in Minnesota's fish have declined by about 10 percent, which is considered an encouraging response (MPCA, 2005)." Given this statement why would we want to go backwards towards higher levels of mercury emission? Especially since it appears that even significant declines in emissions have only relatively modest declines in the amount that is actually concentrated in fish. Clearly there is a long lag time between a decrease in mercury emissions and a decrease in mercury concentration in fish. This is consistent with the idea that mercury is a bioaccumulator that is not readily removed from the environment.
Physicians Letter
Citizens Advisory Task Force Comments
HEALTH RISK COMMENTS
JPA Section 7.4.6 p 422-423, and Environmental Supplement Section 3.2.5 III-43
Risk to Human Health and Ecology: These appear to be the only sections that deal with risks to human health. These few pages refer to an Air Emissions Risk Assessment (AERA) and Risk Assessment Screening Spreadsheet (RASS), and describe the carcinogenic and non-carcinogenic hazard indices for air emissions and fish (mercury) ingestion.
This section makes no mention of the Regional Modeling System for Aerosols and Deposition (REMSAD) analysis used by the EPA. REMSAD modeling was previously described in a reported submitted by Excelsior Energy to the MPUC. The final draft of this study is entitled Air Quality and Health Benefits Modeling: Relative Benefits Derived from Operation of the MEP-I/II IGCC Power Station and was prepared by ICF consulting for Excelsior Energy December 14, 2005.
This report should be included in the JPA as air quality and health impacts are of significant local concern, and the information is missing from the JPA. The following issues should be addressed by Excelsior Energy:
- 1. The above referenced study was prepared/modeled for the West Range Site. Provide similar modeling for the East Range Site.
2. The "health benefits" modeled are compared to a Super Critical Pulverized Coal Plant in Central Minnesota. Placing the modeled SCPC plant near a higher density population makes the expected health implications appear to have a substantially greater impact (and thus MEP would have a greater "benefit") than would otherwise be the case. The modeling should compare health risk of both plants in the same location in order to assess the actual differences in adverse air quality and health impact.
3. A SCPC plant would not be the only alternative to IGCC. If the air emission and health impact comparison between IGCC and SCPC is to be made, the company should also model other forms of power production including alternative energy sources, especially given that this project is labeled an innovative energy project and has received renewable energy funding.
4. REMSAD modeling uses PM2.5, not PM10 (emissions of approximately 440 tons/year) as is listed in the emissions data of the JPA. With regard to particulates, PM2.5 is thought to have the most significant adverse impact on human health. What are the average and maximum emissions of PM 2.5 from MEP I/II? Give data for both East and West Range Sites.
5. Chapter three of this study indicates that individuals with asthma, COPD (emphysema), chronic bronchitis, and heart disease are at greatest risk from particulates. "There will be a measurable effect on air quality up to 70-80 km from the plant, and a peak effect near the plant location with lesser impacts surrounding the plant in all directions." "Areas with higher proportions of older residents will have higher estimated risks owing to their higher background' mortality risks.
- A. The company should describe the specific increase in health risk for people in nearby communities as well as individuals with co-morbidities and the elderly.
B. In addition, the company should address health impacts/risk for Native American elders with regard to the senior housing facility and interpretative center planned just off Hwy 169 near the Scenic Highway.
6. Compared to a hypothetical SCPC plant, the Mesaba Energy Project is expected to result in 1.5 fewer deaths per year in Minnesota for phase I, and 6.4 fewer deaths nationally. The report assumes doubling of this death rate in phase II. The information appears to indicate that MEP I/II would be responsible for 10.7 deaths nation wide, with 24% of those deaths occurring in Minnesota. Additionally, the report states that "It can be seen that mortality risks associated with the IGCC Power Station are both somewhat lower and more concentrated around the facility than the estimated risks associated with the Alternative SCPC plant". The company should quantify the "somewhat lower and more concentrated" risk in the area around the facility, and how this risk increases for nearby residences and municipalities.
7. The study is modeled on the original stack height. The current planned stack height has been lowered by about 100 ft for "aesthetic reasons" according to the Baxter testimony to the MPUC. Describe the aesthetic improvement for both the stack and the emissions plume, and contrast this with the increase in adverse local air quality and health impacts.
8. Morbidity (non-fatal health effects) related to particulate matter are described in the ICF Consulting study. Data is given for morbidity related to PM2.5 (cases per year in Minnesota) including:
| Acute bronchitis | 1.6 |
| Non-fatal MI (heart attack) | 1.9 |
| Asthma exacerbation | 100 |
| ER visits for asthma | 1.3 |
| Lower respiratory illness | 19 |
| Minor restricted activity days | 791 |
| Work loss days | 18,313 |
The company should:
- A. Give the range expected for these morbidities in a given year, and adjust for seasonal variation.
B. Give the expected number and range of clinic or urgent care visits, and factor this in to projected costs both to the State, and to local health care facilities and health insurance plans such as Itasca Medical Care (IM Care).
C. Explain the apparent discrepancy between low numbers of minor respiratory illness, significant number of minor restricted activity days, and the seemingly out of proportion number of work loss days.
D. Describe the cost of these 18,000 work loss days to the average family affected, as well as the affect on employers needing to cover for sick workers.
9. Secondary formation of particulate matter can have a significant impact on human health.
- A. The JPA should address air quality modeling and adverse health consequences, both local and regional, with regard to secondary particulates.
B. Provide similar analysis of secondary particulate matter health impacts for the general population, individuals with co-morbidities, and the elderly.
10. Ground level ozone health concerns and formation of smog need to be addressed by Excelsior Energy. Nitrous oxides contribute to formation of secondary particulate matter, and also play a major role in formation of ground level ozone. Volatile organic compounds (VOC) and nitrous oxides (NOx) combine in the presence of light and heat to form ozone. The Minnesota Department of Health indicates ozone exposure can lead to respiratory infections and inflammation and that one third of healthy adults are sensitive to the effects of ozone.
The Minnesota Department of Health also states that on hot sunny days, ozone concentrations can rise to unhealthy levels, and ozone transport can cause elevated levels in rural areas. MEP I/II will emit approximately 2700 tons of NOx/yr and 152 tons of VOC/yr. Because this will increase levels of ground level ozone, Excelsior Energy should address the following:
- A. Estimate the increase in risk for developing childhood asthma
B. Estimate risk attributable to ozone exposure for people with co-morbidities, including children, individuals with lung disease, and the elderly. Provide details on average risk as well as risk on hot sunny days.
C. Estimate the health risk for healthy individuals and children exercising outdoors on hot sunny days.
11. The Excelsior commissioned study indicates that 7,780 women of child-bearing age reside in the mercury deposition impact zone of MEP I. The phase I mercury impact zone encompasses 720 lakes in which 487,000 fish are harvested. The company should:
- A. Provide a clear detailed analysis of how lakes in this impact zone will be affected by additional mercury deposition.
B. Provide details and analysis of this plant's mercury speciation. Clearly chart/graph the local lake impact over time given emissions of elemental mercury, methyl-mercury, and secondary methylation of elemental mercury.
C. Provide information regarding which of these 720 lakes have been tested and how many have fish consumption advisories for mercury.
D. Provide details of health risk analysis for women of childbearing age who live in this mercury impact zone.
12. The Excelsior commissioned study states "Recent research has indicated that low-level chronic exposure to methyl-mercury via fish consumption may be linked with a higher risk of serious cardiovascular impacts in men, including MI, coronary artery disease, and other cardiovascular disease." Estimate the public's adverse health risk given increasing mercury concentrations over time with respect to the MEP.
JPA Environmental Supplement Section 3.4 Water resources
Section 3.4.1.1F describes the possibility of reducing water levels of the Canisteo Mine Pit under conditions of extreme drought to the point where land bridges would be exposed.
How would exposing land bridges affect the availability of process water?
How low would water levels need to drop before affecting the function and capacity of the pump stations and caisson intake?
How much of a drop in surface level is "significant"?
Are there any other competing uses for the process water that may make this situation more likely?
Exposing land bridges would provide a smaller volume of water into which the cooling tower blowdown would discharge, increasing concentrations of mercury, hardness, total dissolved solids, etc at a faster rate. Describe and graph how this would be anticipated to occur at such surface water levels, as well as the long term plan to deal with this situation.
Provide details of how the addition of Zero Liquid Discharge on the cooling tower blowdown at the West Site would affect the availability of process water with regard to total water use needs. The addition of ZLD is necessary at the West Site to prevent pollution of Canisteo Lake and the future reality of dealing with these polluted waters when the MEP is no longer operational.
JPA Environmental Supplement Section 3.4 Water resources: Section 3.4.4 p III-117
West range site. This page states, "There is the potential to impact municipal water supply wells within the cities of Marble and Calumet as a result of significantly reducing the water levels in the HAMP".
- 1. The company should provide details of how such impacts will be prevented and at what reduction of water levels is it possible that this will occur. If this situation does occur, how will the company and municipalities be affected and deal with this situation?
2. In this situation, how such water level reductions or even lesser reductions of water levels affect Coleraine and Bovey water supplies as these wells are not nearly as deep, and may receive recharge from more superficial layers above the ore body?
The Joint Permit Application is incomplete in that it does not address the cumulative environmental and socio-economic impacts related to the planned MSI direct reduction steel mill scheduled to be built just north of the proposed West Range Site.
Verbal Comments at Public Hearing
in Taconite, November 27, 2007
For the past two weeks, CAMP has been reviewing the DEIS, and our overall reaction is disappointment. We're disappointed in the agencies that produced this document, and we're extremely disappointed in the process by which you have led us to believe that public input is important.
The DEIS is far from complete. The purpose of the scoping was supposed to ensure that the EIS is complete and to identify areas of local concern. Instead, it appears that the overall objective of this document is to minimize the adverse environmental impacts, push a federal policy for "clean coal", and facilitate a project that has no hope of ever realizing the DOE objectives outlined in the Clean Coal Power Initiative.
Many people in this room have spent inordinate amounts of time reading the JPA, researching the issues, and submitting comments during the scoping process. Agencies such as the Army Corps of Engineers, MPCA, and the MN DNR also submitted numerous comments over a wide variety of issues. These issues included Excelsior's unverified claims of need for power, site selection, water discharge and mercury deposition, air emissions, and the plant's impact on the CMP trout fishery and local recreation. Most of the comments have not been addressed at all, and others have been addressed inadequately.
For example; the JPA describes how the Canisteo Mine Pit (CMP) would be closed to recreational use and that the water and trout fishery will be ruined by concentrated discharge of cooling water. The DEIS does not acknowledge that the CMP is a trout fishery or even that it is used for recreation.
As the CMP becomes polluted, private wells and the municipal water supply for Coleraine and Bovey are at risk. The MDH Wellhead Protection study that describes the hydrologic connection between the municipal wells and CMP is not mentioned in this document.
Numerous comments were submitted regarding human health, and most of these comments came directly from a study commissioned by Excelsior in 2005. In Feb 2007, the NEJM published an excellent study showing that each 10 mcg/m3 increase in PM 2.5 increases the risk of heart attack and stroke by 70%. A large majority of physicians and nurse practitioners in Itasca County have submitted a letter expressing opposition to this project and concern for our patient's health and well-being. Excelsior's study clearly reveals the expected increase in illness and premature death due to Mesaba's air emissions, and those numbers are low given recent research in this field.
In contrast, the DEIS describes Electro-Magnetic Field (EMF) effects and gives a brief summary of cancer and non-cancer health hazard indices. But the majority of this text talks about rates of obesity, hypertension, smoking, and drinking among people in MN, Itasca County, and St. Louis County. None of the important health issues are discussed in the DEIS. Excelsior actually did a better job of describing the adverse health impacts of their project than you have. In this area again, the DEIS is grossly inadequate.
These are just a few examples, and CAMP's formal comments will be submitted prior to the January 11th deadline.
Although we believe the DOE's objectives related to their Clean Coal Power Initiative are misdirected, they do appear to be clear. The DOC objectives are not quite as clear. The DOC mission statement includes "ensuring equitable commercial and financial transactions, reliable utility services, and advocating the public's interest before the PUC". The Mesaba Project does not meet any of the DOE & DOC objectives by any stretch of the imagination. We certainly don't feel that the DOC is advocating in the public's interest. This is the wrong project, and it's in the wrong place. The people here today deserve to have you take their concerns and comments seriously. We hope you'll show us that you really do value public input, and demonstrate that in the Final EIS.
Canisteo Mine Pit Comments
These comments are in regard to the economic and recreational value of the Canisteo Mine Pit (CMP). The CMP is currently one of four lakes in Itasca County managed by the DNR for lake trout. It is the second largest of these lakes which include Caribou, Bluewater, and Trout, and it is growing in popularity. The CMP is a unique and heavily used recreational fishery and brings great value to Itasca County. The loss of this lake to recreational use would result in a negative economic impact and is not in the public interest.
The lake data regarding recreational use of the CMP in Excelsior's Joint Permit Application is not accurate and appears to be taken from the DNR website Lake Finder. According to DNR fisheries personnel, the current surveys are not on Lake Finder and are described below. Since 1997 the CMP has been stocked with over 35,000 lake trout fingerlings. The initial annual stocking is now reduced to every other year because of natural reproduction. The DNR has invested more than $75,000 in management of the CMP including fixed transportation costs, hatchery costs, and DNR staff assessment/lake management planning. Closing the CMP leaves little to no return on this public dollar investment.
Although the CMP is not classified as protected water, it is a valuable local resource. Excelsior Energy proposes to take this resource away from the general public, but this does not need to be the case. The company has the ability to establish "Zero Liquid Discharge" (ZLD) for non-contact cooling water thus protecting water quality as well as the fishery, and should stabilize the water level to maintain recreational use access. Excelsior has cited the cost of ZLD as being prohibitive, but would in fact be required if this plant were to be placed at the alternative East Range site. The cost of ZLD for non-contact cooling water and the cost of maintaining water levels consistent with safe recreational use access need to be considered in this proceeding. Alternatively, if Excelsior Energy manages the CMP as planned, the total cost to the public regarding the loss of this lake needs to be assessed and added to the total cost of the project. These costs are outlined below.
DNR aerial survey data show heavy recreational use of this water system. The 2001 summer average was 3,360 angling hours, with winter use of 2,830 angler hours. Additional non-angling recreational use was estimated at 376 hours for a total of 6,566 annual recreational use hours. The Minnesota DNR report "Economic Impact and Social Benefits Study of Coldwater Angling in Minnesota, June 2002"* details the economic benefits of a coldwater fishery. The economic impact of anglers using inland lakes and streams in Region 2 (Northeast MN) is calculated at over $38 million in sales, over $24 million in income, and supports over 790 jobs. The economic impact tends to be highly concentrated within this region as there are few resources within the state for coldwater angling. Grand Rapids is one of these areas. The report lists average daily spending of $33.20 (summer) and $25.97 (winter) for anglers in their home area; $72.01 and $55.42 for anglers away from home. Assuming an average 5 hour fishing day and that 75% of these anglers live locally, the estimated economic impact would total $47,939 annually. The authors state that these estimates are felt to be highly conservative because they do not take into account other related expenses, such as durable equipment like vehicles and boats, snowmobiles, transportation, etc. These estimates also do not include any value for consumer surplus. "Using consumer surplus or other non-market evaluation technique would significantly raise total economic impact."* With the exception of Trout Lake, the other coldwater lakes in the Grand Rapids region are quite small, and it would be reasonable to assume that removing the Canisteo Mine Pit from recreational use would place additional burden on these smaller lakes, and would decrease the overall recreational experience and diversity of the Grand Rapids area coldwater fishery.
A less conservative approach to quantifying the economic impact of the Canisteo Mine Pit is to use data outlined in a 2003 publication of the North American Lake Management Society.** The local economic impact from 10 lakes in the Turtle Lake watershed has been estimated at $1,494 per acre per year creating 16.5 jobs per 1000 acres of fishable water. By this estimate, the 1300 acre CMP would contribute 21.45 jobs and $1.94 million of direct and indirect economic impact to the local economy.
Another cost not under consideration relates to the water quality of another Trout Lake (Coleraine). The DNR and Western Mesabi Mine Planning Board are working to stabilize the CMP near the 1300ft-msl elevation with a siphon to Trout Lake. This would allow permanent access facilities to be established on the south shore near Coleraine, Bovey, and/or Taconite with resulting improvement in the water quality of Trout Lake and increased access to recreational use of CMP. Stable high CMP levels are also felt to influence Trout Lake by keeping water levels from dropping significantly in dry years, maintaining flow, and maintaining water clarity.
CMP water is of extraordinary clarity and is low in phosphorous. This siphon is expected to improve the water clarity of Trout Lake, which will subsequently increase lakeshore property values. A study published by the Mississippi Headwaters Board quantifies expected property value changes due to changes in water clarity.** This study shows that a one meter increase in water clarity would increase the frontage foot value of Prairie Lake property by $4.20 and Pokegama Lake by $29.53. Trout Lake has 13.5 miles or 71,280 feet of shoreline. Using this data, the range of total property value increase for Trout Lake if the Canisteo siphon provides just one meter of increased water clarity would be $299,376 to $2,104,898. Alternatively, should Trout Lake water clarity decrease (which could happen if CMP levels drop and groundwater outflow decreases) by one meter, the frontage foot value would drop by $7.75 to $36.29 (Prairie and Pokegama lakes estimates). Total Trout Lake property value would then decrease $552,000 to $2,586,000. The total lake property value difference between one meter of water clarity increase and one meter of water clarity decrease could be as high as $4,690,898.
What is the value of a 1300 acre lake with extraordinary water clarity? This type of cold, clear, deep lake with a self-sustaining lake trout population is rare in Itasca County and has significant intrinsic value. The Minnesota DNR has made a considerable investment in the management of the CMP; and the economic impact and recreational value of the Canisteo Mine Pit is substantial. Property owners on Trout Lake will not realize the dollar increase related to improved water clarity, and may see property values decrease if water clarity is adversely affected. This translates into millions of dollars Excelsior Energy needs to be held accountable for if they will not commit to ZLD and surface water level stabilization. Loss of the Canisteo Mine Pit to public use will result in a negative economic impact and is not in the public interest.
*Gartner, et al, Economic Impact and Social Benefits Study of Coldwater Angling in Minnesota, June 2002
**Dziuk, H and Heisky, S. 2003. Local Economic Impact of Healthy lakes, Lakeline 23(3): North American Lake Management Society
***Lakeshore Property Values and Water Quality: Evidence from Property Sales in the Mississippi Headwaters Region. Mississippi Headwaters Board, June 2003.
Citizens Advisory Task Force
Comments on Completeness, Accuracy,
and other Issues on the JPA that Need
to be Addressed in the EIS
Certificate of Need
I am concerned about the waiver from Certification of Need Environmental Supplement Section 1.2.4.1). While I realize that this waiver is authorized by legislation, questions remain about the actual "Need" for this addition to the overall power grid, particularly since the power generated is not slated for consumption within the TTRA. The waiver not withstanding, I think a thorough purpose and need section needs to be in the final EIS. This would then also address the additional impacts for HVTL from the POI to end users (Presumably the Metro area).
Recreation Impacts
What does it mean that access to the CMP will be restricted (closed?) and what impact will this have on the local residents? What are the safety, security, and operational reasons that will require this and how will non-authorized access then be prevented and maintained?
Partial Exemption for the proposed pipeline route permit
On what basis is the request for a partial exemption from the requirement of a detailed environmental analysis for all proposed pipeline routes on the West Range Site justified?
Compensation & Eminent Domain
Are there compensation mechanisms available to people whose property values are negatively impacted by either proximity to the plant or to the various right of ways required regardless of site?
The EIS does not indicate whether and how many times eminent domain will be used to obtain land and whether the company or local authority will be exercising it.
How many and what specific instances is the company going to use eminent domain or will a local authority be required to use eminent domain for this project?
When are binding contracts between the proposed consortium members expected and could this alter the contents of this document in terms of the environmental impact assessment and projections?
Comments on the Comparison Table in the JPA
The comparison tables are not complete/ correct as shown:
- Aesthetics - "the West Range HVTL is shorter" this is not true as additional transmission lines will be required at the West Site.
- Public Services - the new infrastructure could be able to serve other businesses at the east site as well.
- Tourism - any benefit from the lower levels in the lake may be offset by the deterioration in Water Quality over time. This table needs to reflect all aspects and impacts.
- Air Quality - the table says that the West site will have less impact on the BWCA since it is further away, however due to prevailing winds being from the west and south west, the West site may have a much more significant impact on the BWCA since emissions may travel in this direction more of the time. The EIS needs to provide wind direction as a function of time for each site and also by season in order to be able to determine exactly what the level of emissions are for each site and to be able to make an accurate comparison.
- Electric Transmission "the West Range HVTL is shorter" this is not true as additional transmission lines will be required at the West Site. The EIS needs to reflect the impact of all transmission lines required by this project.
- Railroad/ Truck The table does not mention that the East Site has existing railroad right of way adjacent to the site. The West site will require a number of miles of railroad right of way including some crossings of residential property.
- Energy Efficiency The table is not complete. The table does not mention the additional transmission line losses at the West Site that result from the POI to the users at Xcel Energy vs. the East Site.
- The table also mentions the additional energy required to run the ZLD system at the East Site but does not address the energy required to pump water to the West Site. The Table should reflect all parasitic energy uses correctly.
Section 1.8.3.2 Environmental Supplement I-201
This section states that the IGCC Power Station will play an important long term role at the West Range Site in regard to flood prevention of the CMP waters, and will be an important "pollution prevention feature." This paragraph is inaccurate in that:
- 1. The project plan as described will direct cooling tower blowdown (CTB) discharge water to the Canisteo Mine Pit which currently has clarity to depths of over 50 ft. The CTB discharge water will result in increasing levels of mercury, sulfates, TDS, etc. If the company's statement is to be accurate, they need to commit to ZLD on the CTB.
2. Flood control of the Canisteo water will be accomplished through a planned siphon independent of the MEP. This siphon will be built regardless of if the MEP is approved or not. Trout Lake water quality will benefit from the discharge of low phosphorous CMP water to Trout Lake. The Trout Lake Association is on record as being in support of receiving water from this siphon, and a recent survey cited by lake association members revealed Trout Lake residents to be in favor of siphoning CMP to Trout Lake by an 8:1 vote.
Section 1.8.2.1.4 Environmental Supplement pI-178 Sanitary Discharges
This section gives options for sanitary water discharges including MEP building its own WWTF vs. use of Bovey/Coleraine/Taconite WWTF.
The B/C/T WWTF already has problems with excess flow. Since 1999 there have been six separate events resulting in discharge to prior Cleveland Cliffs basins and Holman Lake. The MEP would further burden a system in need of attention and upgrade. If Excelsior dismisses building a WWTF in favor of using B/C/T:
- 1. How and when will this WWTF be updated?
2. This is a local issue in that there will be a direct financial impact on the local municipalities. What technology upgrades need to be evaluated if the local municipal WWTF is utilized for the MEP. What is the cost of this upgrade directly attributable to the MEP, and how does this compare to potential cost shifting to the public at the East Range Site?
Section 1.6.5.3 Environmental Supplement: I-135
This section describes mercury removal and appears to state that 90% of the mercury will be removed from the solid IGCC feed stock.
- 1. If the Eastman process has been shown to remove 95% of mercury, why does this section state only 90%?
This section describes NG pipeline preferred routes and alternatives. The information is deficient in that:
- 1. The proposed routes do not detail or compare the number of properties on existing corridors vs. new corridors.
2. There is an existing NG pipeline (Northland?) from Virginia and Hibbing that currently goes to the MSI site, and is much closer to the proposed MEP West Range Site. This route would appear to have significantly less impact on landowners and would follow an existing corridor. Why is this route (with the required upgrade) not included as an alternative to the routes proposed?
Issues of local concern include:
- 1. Alternative 3 appears to have the least impact on undisturbed land, is the shortest route, and has more existing corridor than the preferred option. How many property owners are in the new corridor vs. existing corridor for this proposal?
2. Alternative 2 is the longest route, but has over 10 miles of existing corridor and 5 affected property owners. How many property owners are in the new vs. existing corridor for this route?
3. Explain why, in light of the above questions, Alternative 1 is preferred.
Section 1.8.2.2.4 page I-195 Environmental supplement: waste water discharge.
This section states that key water quality constituents associated with Outfall 001 and 002 discharges will be mercury, TDS, and hardness. It also states that the mass of mercury discharged to Holman Lake through Outfall 002, combined with the mass of mercury discharged to Panasa Lake from the HAMP will not exceed the mass of mercury currently permitted to be discharged to Panasa Lake under existing NPDES Permit No. MN0030198 currently held by the Minnesota DNR. Panasa and Holman Lake are tributary to the Swan River and Mississippi.
The next statement, "Therefore, this system will not contribute additional pollutants to the Swan River watershed." is inaccurate and misleading.
To correct this, the company needs to:
- 1. Acknowledge that additional mercury, sulfates, phosphorus, dissolved solids, and suspended solids will be present in this discharge stream, leading to an overall increase of these constituents in the Swan River/Mississippi tributary system.
2. Accurately and completely describe the makeup and amounts of the constituents described above.
3. Quantify the current mass or concentration of mercury discharged to Panasa Lake from the HAMP under NPDES permit No.MN0030198.
4. Address increased concentrations of phosphorus to this discharge stream (JPA Appendix 6 Section 5) and how this relates to the Annondale-Maple Lake Court Decision (currently under appeal) which does not currently allow for any new source NPDES/SDS permits above Lake Pepin.
5. Address the ability to use NDPES permit No MN0030198 vs. the need for a new permit.
6. Address and completely describe the relationship and impact of mercury and sulfur with regard to increased methyl-mercury formation and discharge limits on methyl-mercury to the Swan River system.
7. Thoroughly address the discharge of mercury and sulfur to wetlands and the anaerobic conditions of this environment leading to formation of methyl mercury.
8. Address the potential for discharge limits for methyl mercury (including secondary formation in the above environments) in addition to a total mercury discharge limit.
9. Thoroughly address the above issues with regard to increasing levels of sulfur, mercury, TDS, etc in the source water over time due to operation of the plant at the west site.
10. Quantify the average and maximum amount of dissolved solids due to concentration of TDS in this discharge stream, and identify subsequent impact on Holman Lake, Swan River, and the Mississippi River.
11. Address how adjustments of water discharged directly to Holman Lake ("every 5 years, or as needed during Phase I and II operation, to limit the mass of mercury discharged") will further impact quality of the Canisteo waters.
To correct these important issues of local concern, Excelsior Energy would need to incorporate a Zero Liquid Discharge system for the cooling tower blowdown at the West Range Site, similar to what has been proposed for the East Range Site.
Section 1.12.4.2.2A(1) Water Sources Existing Information, CMP Complex I-343:
This section is inaccurate and incomplete in that it does not adequately address pollution of Canisteo Lake and potential for municipal water supply contamination as explained below.
The MPUC JPA proposes drawing process water from four sources and sending discharge water to Canisteo Lake with a minor restricted flow to Holman Lake. Most of the process water will be lost to evaporation in the cooling towers. The remaining discharge waters will have increased levels of mercury, phosphorus, sulfate and other dissolved solids. This results in a continuous increase in the contamination of Canisteo Lake as documented in Appendix 6 of the JPA.
The south wall of the old Canisteo pit cuts through all geological layers above the iron ore body. The upper layer is glacial deposits from the last Ice Age. Studies by USGS (Water-Resources Investigations Report 02-4198) show a south flow of ground water from Canisteo Lake to Trout Lake. The municipal wells for Bovey and Coleraine draw water from aquifers in this glacial layer.
Section 2.5.2.3 JPA Environmental Supplement II-116 describes the nearby public water supplies for Bovey and Coleraine as having a possible hydrologic connection between groundwater captured by wells and local surface waters. The Minnesota Department of Health has found high tritium concentrations in groundwater pumped from these public water supply wells indicating that the water supply is more sensitive to land surface activity and more vulnerable to potential contamination.
These municipal wells appear to recharge fairly quickly, and because the iron ore body at the south end of Canisteo Lake slopes southward toward Bovey/Coleraine, gravitational flow of subsurface water would also be in this direction. Thus it appears that these aquifers are at risk for contamination as Canisteo Lake is polluted.
Section 5 JPA Appendix 6 shows that over time, (approximately 30 years), Canisteo Lake process water will have significantly increased levels of mercury, sulfates, and hardness. Water discharge will eventually exceed the mercury water quality standard of 6.9 ng/L. Canisteo water will exceed water quality standards for hardness and total dissolved solids (TDS) necessitating treating the power station effluent or further reducing the cycles of concentration. Mercury concentrations in Canisteo Lake will rise from 0.9 ng/L to 2.2 ng/L. There only a vague plan in Appendix 6 Section 5.2.2.1.1 for dealing with this problem.
This same scenario is taking place at Minntac now whereby the process water supply has become heavily polluted over the life of the plant. This water now has super-high levels of sulfates and hardness causing heavy scaling and makes water discharge issues extremely difficult and complex.
This issue is perhaps the most important local cause for concern. Polluting Canisteo Lake puts municipal wells at risk for contamination, will make Power Station use of this water inefficient, and will eventually make this water difficult if not impossible to discharge. The life of a power plant is not forever, and at some time in the future, we will need to deal with the issue of discharging polluted Canisteo water as surface levels rise. How will this be accomplished if the water exceeds quality standards, especially if future mercury standards for Swan River and Mississippi River are lowered similar to Lake Superior standards?
At this time, we have the potential for using Canisteo water to improve the water quality in Trout Lake. If the MEP is built on the West Range Site, we lose this opportunity, and we also lose the opportunity to keep and continue to develop an excellent recreational lake and lake trout fishery.
Excelsior Energy needs to address the problems defined above as it would be irresponsible for the company to ignore the future reality of this important issue. Committing to Zero Liquid Discharge on cooling tower blowdown discharge water from day one of operation appears to be the only way to prevent this situation from occurring.
Section 1.12.4.2.2(A)1 Environmental Supplement I-344; Section 7.6.1 JPA p 443 Water Resources and Water Quality Canisteo Mine Pit
These sections are inaccurate in that they minimize the recreational importance of Canisteo Lake. Canisteo Lake is a super clear 5 mile long oligotrophic lake. The lake experiences more than "occasional" recreational use as described in the JPA, although "occasional use" is not defined. This report also describes low amounts of nutrients and biota, but this would be expected in any oligotrophic system, and the report is inaccurate in that it describes the lake as a "resulting poor fishery". The fish survey report used in the JPA appears to have been taken prior to the occurrence of lake trout stocking, and from personal experience and local anecdotal reports this lake has developed into an excellent lake trout and crappie fishery.
Fish in Canisteo Lake, especially lake trout as they are a fatty fish, will bioaccumulate increasing levels of mercury over time due to cooling tower blowdown discharge as described in JPA Appendix 6 Section 5. Excelsior Energy should address how this will affect fish consumption advisories over time. In addition, lowering water levels, especially over the winter, could expose lake trout eggs on shoals and negatively impact the fishery. In addition, introducing Prairie River water into Canisteo Lake could accelerate eutrophication due to much higher levels of phosphorous in the Prairie River.
Excelsior Energy also proposes to remove the MDNR Buckeye Mine Pit boat launch and close Canisteo Lake to recreational use for "safety, security, and operational reasons". The DNR and Western Mesabi Mine Planning Board are working to stabilize Canisteo Lake near the 1300ft-msl elevation with a siphon to Trout Lake. This would allow permanent access facilities to be established on the south shore near Coleraine, Bovey, and/or Taconite with resulting improvement in the water quality of Trout Lake and increased access to recreational use of Canisteo Lake.
Excelsior Energy should avoid introducing higher phosphorous water into Canisteo Lake, and commit to maintaining the Canisteo Lake level within a range compatible with fish reproduction and permanent recreational use facilities.
Section 1.6.6.3.2 Environmental supplement I-141:
Cooling tower blowdown sludge from the proposed East Range ZLD system is "expected to be non-hazardous and will be tested to confirm such condition." The company should address the following questions:
- 1. How will this testing be performed, and how will the dry cake be stored prior to transport offsite?
2. How will storage containment measures and offsite transport be accomplished or change if the materials tested are found to be hazardous?
Section 1.8.2.3 Environmental Supplement East Range I-196: This section quantifies the amounts of solids requiring disposal from the proposed East Range cooling tower blowdown ZLD system. The amount of solids requiring disposal is listed at 109 tons/day at peak flows and 73 tons/day annual average. There is no comparison to a similar system on the West Range Site. The company should address the following questions:
- 1. Quantify the maximum and average amounts of solids discharged to Holman Lake and Canisteo Lake in the absence of a ZLD system on the West Site.
2. Quantify the maximum and average amounts of solids requiring disposal with a ZLD system for cooling tower blowdown at the West Range Site.
3. Address appropriate disposal of these solids, and where this landfill would be located.
4. Address any potential environmental impact from this landfill.
Section 1.3.3 Environmental Supplement I-24:
This section refers to improvements upon the Wabash River plant. The paragraph describes DOE funded studies of potential performance and technological upgrades but does not list the studies referenced. The company should:
- 1. Give citations of the DOE referenced studies.
2. Describe the performance upgrades that Wabash River required to meet discharge permit criteria for selenium, arsenic, and cyanide.
3. Submit data from Wabash River proving subsequent ability of that plant to meet these discharge permit limits.
Section 2.5.2.1 Environmental Supplement I-27 and I-61:
This section describes high groundwater levels in the soils in the vicinity of the West Range Site footprint, and states that the site may require permanent water table control measures. Given that over 300 acres of wetland exist on the West Range Site and adjacent utility corridors the company should:
- 1. Provide details on the acres and types of wetlands that will be affected.
2. Provide detail on how extensive these water table control measures would be, and how such measures would be accomplished.
3. Describe in detail how loss of wetlands will be mitigated.
Figure 1.5-14 West Range Plan HVTL and pages I-45 to I-50: This plan shows HVTL route proposals from the plant site to the Blackberry substation. There is significant local concern regarding these routes, as well as the needed upgrades beyond Blackberry. The information is incomplete in that:
- 1. The preferred route selection and alternatives do not list the amount of existing right of way vs. need for new property easements along each proposed route.
2. A list of affected landowners is not included, nor have landowners been notified.
3. HVTL routes should include information on landowners already affected by existing right of way, and separately identify landowners who will be affected by new right of way.
4. Identify the necessary upgrades required beyond Blackberry as well as the landowners affected by these upgrades.
The Joint Permit Application is incomplete in that it does not address the cumulative environmental and socio-economic impacts related to the planned MSI direct reduction steel mill scheduled to be built just north of the proposed West Range Site.
Section 1.8.2.2.4 page I-195 Environmental supplement: waste water discharge.
This section states that key water quality constituents associated with Outfall 001 and 002 discharges will be mercury, TDS, and hardness. It also states that the mass of mercury discharged to Holman Lake through Outfall 002, combined with the mass of mercury discharged to Panasa Lake from the HAMP will not exceed the mass of mercury currently permitted to be discharged to Panasa Lake under existing NPDES Permit No. MN0030198 currently held by the Minnesota DNR. Panasa and Holman Lake are tributary to the Swan River and Mississippi.
The next statement, "Therefore, this system will not contribute additional pollutants to the Swan River watershed." is inaccurate and misleading.
To correct this, the company needs to:
- 1. Acknowledge that additional mercury, sulfates, phosphorus, dissolved solids, and suspended solids will be present in this discharge stream, leading to an overall increase of these constituents in the Swan River/Mississippi tributary system.
2. Accurately and completely describe the makeup and amounts of the constituents described above.
3. Quantify the current mass or concentration of mercury discharged to Panasa Lake from the HAMP under NPDES permit No.MN0030198.
4. Address increased concentrations of phosphorus to this discharge stream (JPA Appendix 6 Section 5) and how this relates to the Annondale-Maple Lake Court Decision (currently under appeal) which does not currently allow for any new source NPDES/SDS permits above Lake Pepin.
5. Address the ability to use NDPES permit No MN0030198 vs. the need for a new permit.
6. Address and completely describe the relationship and impact of mercury and sulfur with regard to increased methyl-mercury formation and discharge limits on methyl-mercury to the Swan River system.
7. Thoroughly address the discharge of mercury and sulfur to wetlands and the anaerobic conditions of this environment leading to formation of methyl mercury.
8. Address the potential for discharge limits for methyl mercury (including secondary formation in the above environments) in addition to a total mercury discharge limit.
9. Thoroughly address the above issues with regard to increasing levels of sulfur, mercury, TDS, etc in the source water over time due to operation of the plant at the west site.
10. Quantify the average and maximum amount of dissolved solids due to concentration of TDS in this discharge stream, and identify subsequent impact on Holman Lake, Swan River, and the Mississippi River.
11. Address how adjustments of water discharged directly to Holman Lake ("every 5 years, or as needed during Phase I and II operation, to limit the mass of mercury discharged") will further impact quality of the Canisteo waters.
To correct these important issues of local concern, Excelsior Energy would need to incorporate a Zero Liquid Discharge system for the cooling tower blowdown at the West Range Site, similar to what has been proposed for the East Range Site.
Section 1.12.4.2.2A(1) Water Sources Existing Information, CMP Complex I-343:
This section is inaccurate and incomplete in that it does not adequately address pollution of Canisteo Lake and potential for municipal water supply contamination as explained below.
The MPUC JPA proposes drawing process water from four sources and sending discharge water to Canisteo Lake with a minor restricted flow to Holman Lake. Most of the process water will be lost to evaporation in the cooling towers. The remaining discharge waters will have increased levels of mercury, phosphorus, sulfate and other dissolved solids. This results in a continuous increase in the contamination of Canisteo Lake as documented in Appendix 6 of the JPA.
The south wall of the old Canisteo pit cuts through all geological layers above the iron ore body. The upper layer is glacial deposits from the last Ice Age. Studies by USGS (Water-Resources Investigations Report 02-4198) show a south flow of ground water from Canisteo Lake to Trout Lake. The municipal wells for Bovey and Coleraine draw water from aquifers in this glacial layer.
Section 2.5.2.3 JPA Environmental Supplement II-116 describes the nearby public water supplies for Bovey and Coleraine as having a possible hydrologic connection between groundwater captured by wells and local surface waters. The Minnesota Department of Health has found high tritium concentrations in groundwater pumped from these public water supply wells indicating that the water supply is more sensitive to land surface activity and more vulnerable to potential contamination.
These municipal wells appear to recharge fairly quickly, and because the iron ore body at the south end of Canisteo Lake slopes southward toward Bovey/Coleraine, gravitational flow of subsurface water would also be in this direction. Thus it appears that these aquifers are at risk for contamination as Canisteo Lake is polluted.
Section 5 JPA Appendix 6 shows that over time, (approximately 30 years), Canisteo Lake process water will have significantly increased levels of mercury, sulfates, and hardness. Water discharge will eventually exceed the mercury water quality standard of 6.9 ng/L. Canisteo water will exceed water quality standards for hardness and total dissolved solids (TDS) necessitating treating the power station effluent or further reducing the cycles of concentration. Mercury concentrations in Canisteo Lake will rise from 0.9 ng/L to 2.2 ng/L. There only a vague plan in Appendix 6 Section 5.2.2.1.1 for dealing with this problem.
This same scenario is taking place at Minntac now whereby the process water supply has become heavily polluted over the life of the plant. This water now has super-high levels of sulfates and hardness causing heavy scaling and makes water discharge issues extremely difficult and complex.
This issue is perhaps the most important local cause for concern. Polluting Canisteo Lake puts municipal wells at risk for contamination, will make Power Station use of this water inefficient, and will eventually make this water difficult if not impossible to discharge. The life of a power plant is not forever, and at some time in the future, we will need to deal with the issue of discharging polluted Canisteo water as surface levels rise. How will this be accomplished if the water exceeds quality standards, especially if future mercury standards for Swan River and Mississippi River are lowered similar to Lake Superior standards?
At this time, we have the potential for using Canisteo water to improve the water quality in Trout Lake. If the MEP is built on the West Range Site, we lose this opportunity, and we also lose the opportunity to keep and continue to develop an excellent recreational lake and lake trout fishery.
Excelsior Energy needs to address the problems defined above as it would be irresponsible for the company to ignore the future reality of this important issue. Committing to Zero Liquid Discharge on cooling tower blowdown discharge water from day one of operation appears to be the only way to prevent this situation from occurring.
Section 1.12.4.2.2(A)1 Environmental Supplement I-344; Section 7.6.1 JPA p 443 Water Resources and Water Quality Canisteo Mine Pit
These sections are inaccurate in that they minimize the recreational importance of Canisteo Lake. Canisteo Lake is a super clear 5 mile long oligotrophic lake. The lake experiences more than "occasional" recreational use as described in the JPA, although "occasional use" is not defined. This report also describes low amounts of nutrients and biota, but this would be expected in any oligotrophic system, and the report is inaccurate in that it describes the lake as a "resulting poor fishery". The fish survey report used in the JPA appears to have been taken prior to the occurrence of lake trout stocking, and from personal experience and local anecdotal reports this lake has developed into an excellent lake trout and crappie fishery.
Fish in Canisteo Lake, especially lake trout as they are a fatty fish, will bioaccumulate increasing levels of mercury over time due to cooling tower blowdown discharge as described in JPA Appendix 6 Section 5. Excelsior Energy should address how this will affect fish consumption advisories over time. In addition, lowering water levels, especially over the winter, could expose lake trout eggs on shoals and negatively impact the fishery. In addition, introducing Prairie River water into Canisteo Lake could accelerate eutrophication due to much higher levels of phosphorous in the Prairie River.
Excelsior Energy also proposes to remove the MDNR Buckeye Mine Pit boat launch and close Canisteo Lake to recreational use for "safety, security, and operational reasons". The DNR and Western Mesabi Mine Planning Board are working to stabilize Canisteo Lake near the 1300ft-msl elevation with a siphon to Trout Lake. This would allow permanent access facilities to be established on the south shore near Coleraine, Bovey, and/or Taconite with resulting improvement in the water quality of Trout Lake and increased access to recreational use of Canisteo Lake.
Excelsior Energy should avoid introducing higher phosphorous water into Canisteo Lake, and commit to maintaining the Canisteo Lake level within a range compatible with fish reproduction and permanent recreational use facilities.
Section 1.6.6.3.2 Environmental supplement I-141:
Cooling tower blowdown sludge from the proposed East Range ZLD system is "expected to be non-hazardous and will be tested to confirm such condition." The company should address the following questions:
- 1. How will this testing be performed, and how will the dry cake be stored prior to transport offsite?
2. How will storage containment measures and offsite transport be accomplished or change if the materials tested are found to be hazardous?
Section 1.8.2.3 Environmental Supplement East Range I-196:
This section quantifies the amounts of solids requiring disposal from the proposed East Range cooling tower blowdown ZLD system. The amount of solids requiring disposal is listed at 109 tons/day at peak flows and 73 tons/day annual average. There is no comparison to a similar system on the West Range Site. The company should address the following questions.
- 1. Quantify the maximum and average amounts of solids discharged to Holman Lake and Canisteo Lake in the absence of a ZLD system on the West Site.
2. Quantify the maximum and average amounts of solids requiring disposal with a ZLD system for cooling tower blowdown at the West Range Site.
3. Address appropriate disposal of these solids, and where this landfill would be located.
4. Address any potential environmental impact from this landfill.
Section 1.3.3 Environmental Supplement I-24: This section refers to improvements upon the Wabash River plant. The paragraph describes DOE funded studies of potential performance and technological upgrades but does not list the studies referenced. The company should:
- 1. Give citations of the DOE referenced studies.
2. Describe the performance upgrades that Wabash River required to meet discharge permit criteria for selenium, arsenic, and cyanide.
3. Submit data from Wabash River proving subsequent ability of that plant to meet these discharge permit limits.
Section 2.5.2.1 Environmental Supplement I-27 and I-61:
This section describes high groundwater levels in the soils in the vicinity of the West Range Site footprint, and states that the site may require permanent water table control measures. Given that over 300 acres of wetland exist on the West Range Site and adjacent utility corridors the company should:
- 1. Provide details on the acres and types of wetlands that will be affected.
2. Provide detail on how extensive these water table control measures would be, and how such measures would be accomplished.
3. Describe in detail how loss of wetlands will be mitigated.
Figure 1.5-14 West Range Plan HVTL and pages I-45 to I-50:
This plan shows HVTL route proposals from the plant site to the Blackberry substation. There is significant local concern regarding these routes, as well as the needed upgrades beyond Blackberry. The information is incomplete in that:
- 1. The preferred route selection and alternatives do not list the amount of existing right of way vs. need for new property easements along each proposed route.
2. A list of affected landowners is not included, nor have landowners been notified.
3. HVTL routes should include information on landowners already affected by existing right of way, and separately identify landowners who will be affected by new right of way.
4. Identify the necessary upgrades required beyond Blackberry as well as the landowners affected by these upgrades.
There are some small farms in the region which are not mentioned in the Environmental Supplement, the Environmental Supplement should be amended to include all known farms in the area.
A study entitled Air Quality and Health Benefits Modeling: Relative Benefits Derived from Operation of the MEP-1/II IGCC Power Station, prepared by ICF consulting for Excelsior Energy and dated December 14, 2005 should be included in the JPA. In addition:
- The above reference study should be prepared/modeled for the East Range Site.
The modeling should compare health risk of a Super Critical Pulverized Coal Plant in the same location as the IGCC facility in order to assess the actual differences in adverse air quality and health impacts.
The company should also model other forms of power production including alternative energy sources.
Emissions of PM2.5 should be evaluated. What are the average and maximum emissions of PM 2.5 from MEP I/II? Provide data for both the East and West Range sites.
The EIS should indicate how, when, and where will the level of mercury in the Swan River watershed be measured. (This may be more of a permit condition with the MPCA)
Is there general agreement that the benefit to the State relative to the draw down of the Hill-Annex State Park is significant? If so, has this benefit been documented and quantified in terms of cost, tourism potential, etc?
Is there a net recreational/tourism impact, positive or negative, on the West Range Site due to the restricting of the CMP and to the upgrades to the Hill-Annex Park?
Explain how the addition of Zero Liquid Discharge on the cooling tower blowdown at the West Site would affect the availability of process water with regard to total water use needs.
By what level is the concentration of mineral constituents expected to be reduced, if any, in the CMP? Over what range of elevation will the pit water be maintained for both safety and water quality considerations?
Plans for either site allow for the operation of up to two generating units over the life of the project. What is the expected life of the project and are there any decommissioning issues associated with eventual shutdown that should be addressed up front? If so, what are they and would they possibly vary by site? The document mentions starting at 230kv and changing to 345 later on to minimize capital costs and impacts. This is will not be true if the extra autotransformers will add to the cost of the project over installing one set of 345kv transformers at the outset.
Section 3.4.4 p 111-117 ...There is the potential to impact municipal water supply wells within the cities of Marble and Calumet as a result of significantly reducing the water levels in the HAMP.
- The company should provide details of how such impacts will be prevented and at what reduction of water levels is it possible that this will occur. If this situation does occur, how will the company and municipalities be affected and deal with this situation?
In this situation, how do such water level reductions or even lesser reductions of water levels affect Coleraine and Bovey water supplies as these wells are not nearly as deep, and may receive recharge from more superficial layers above the ore body?
What impact might the potential need for permanent groundwater table control have upon the West Range Site?
CAMP work-group/DEIS review
REVIEW of the DEIS
Chapters 1 & 2
Chapter One
| Page | Error | Comment |
|---|---|---|
| 1-8 | Provide 3000-6000 MW of needed generation in Minnesota. | Where is this number derived from? Xcel, the largest utility in the state has indicated that it will need far less capacity and it can get this from wind and renewable. |
| 1-8 | Bottom of page: economic benefit. The Economic Impact Analysis completed by the Bureau of Business and Economic Research at the University of Minnesota, Duluth (BBER, 2006) was a purely theoretical study based upon project cost. | The study is not relevant or accurate as it ignored the inputs to the project, namely coal, gas and specialized maintenance costs and services which must come from outside of Minnesota. The real ongoing economic impact will be less than $15 million per year in NE Minnesota. |
| 1-23 | Citizens Advisory Task Force is discussed. | The concerns about the project raised by many of the Task Force are not mentioned. |
Chapter Two
| Page | Error | Comment |
|---|---|---|
| All | General There are many errors and statements that are not entirely accurate or misrepresent what will really happen. | Is this a consistent pattern of minimizing the downsides of the project and promoting the upsides, often in an inaccurate manner? |
| 2-6 | Table CO2 should be 10,600,000 / 9,400,000 (off by a factor of a million tons per year!) | Is this part of the pattern of minimizing the downsides of the project ? |
| 2-21, 2-22 | CO2 capture Pipelines of: 265 miles to saline formations in Eastern ND and; 405 miles to sequestration areas mentioned | This underestimates the length of pipe required. The route to saline formations in Eastern ND would more likely be closer to 400 miles
and the route to the old oil fields 550 to 750 miles (if it is required to go up to Saskatchewan to handle the volume of CO2. Further, the DEIS assumes a direct route following a road or railroad. A CO2 pipeline would most likely be more circuitous as it may not be allowed near residences due to the danger from the heavier than air odorless poisonous gas CO2. |
| 2-21, 2-22 | CO2 capture | Many details are not included about the CO2 capture, energy required, energy required to pump the CO2 from 400 to 750 miles, etc. Further, if CO2 Capture is not required, Mesaba will be the second largest source of CO2 in the state. It will increase rather than solve the problem. |
| 2-8 | 2.1.2.1 West Range site has lower electrical losses | This is only to the connection substation. Further this cannot be stated as a line loss study has not been done. |
| 2-39, 2-49 | Petroleum Coke is mentioned as a fuel source 50/50 with sub-bituminous coal | Petroleum Coke contains many toxic metals (including Vanadium and others), that are not listed in the EIS here or elsewhere, If burned at a 50/50 blend, these metals and the resulting compounds, e.g. harmful Vanadium Pentaoxide and others) could be part of the air, water and land emissions and should be considered in the EIS. The EIS should include all toxic emissions expected from the operation. |
Air Quality Comments on DEIS
4.3 Air Quality and Climate (including Greenhouse Gases)
I. Assumptions built in to modeling, and data used: As citizens, reviewing the data and analysis of the affect of Mesaba I/II on air quality and climate is difficult as only the results are presented, and not the modeling assumptions or data used to come up with the results. This is like a math teacher getting a sheet of answers and telling the student, "but show me your work...How did you come up with these numbers?"
Right off we noticed that MN Steel, a "reasonably foreseeable future action in the project vicinity," was not included as a major source input in the description of Mesaba's Predictive Modeling Approach. (4.3-2). We discovered that MN Steel data is included in chapter 5 in the cumulative affects section, but we wondered what is the affect on modeling without including MN Steel's data? This led us to turn to MN Steel's Final EIS and compare their section on affect on air quality to Mesaba's DEIS. We found what we think are discrepancies in the data presented regarding the quality of the existing air, and even differences in the standards used for analysis. It also triggered more questions about how reflective the results of the modeling are of the on-the-ground reality.
For example, regarding Particulate Matter, which has been found to be detrimental to health, the PSD increment standard for PM10 in Mesaba's DEIS is 37 (p. 4.3-18). But the standard in MN Steels' FEIS is stated as 30 (FEIS, p. 4-103). Mesaba says it will emit PM10 at a rate of 23.5 in a 24 hour period. MN Steel says it will emit PM10 at 26 ug/m3 in a 24 hour period. The total of the two emission rates is 49.5 in a 24 hour period which exceeds even Mesaba's higher standard rate of 37.
Mesaba's DEIS did not include wet or dry depletion/deposition in the modeling" (4.3-1). Why not? MN Steel's FEIS did include this. An EPA document explains that, "Wet and dry deposition are important processes in indirect exposure modeling because they account for the movement of constituent mass from the atmosphere to soil, water, and vegetation" (p. 5-28).1
And why use such old data? Appendix B in Mesaba's DEIS states, "The meteorological data are based upon Hibbing, Minnesota hourly surface weather observations for the years 1972 through 1976" (B.1-1) Mesaba's DEIS (4.3-3) states that upper air data from two stations were used: St. Cloud and International Falls for 1990 and 1992; and Minneapolis and International Falls for 1996. More current data is available. The US EPA site has links to the "Radiosonde Data of North America (RDNA)" which is a standard upper air database provided by NCDC, containing data through 1997 data. Another data bas has hourly and synoptic type data for approximately 12,000 global stations are available for 1995-2005. Upper air data for 1990-present are also available. We also found what we think are discrepancies and deficiencies in data in Mesaba's DEIS when compared with MN Steel's FEIS. For example:
In the analysis of the affect on air quality in the Class II area:
- -Mesaba shows an existing background of Sulphur Dioxide (SO2) at 10 ug/m3 in 1 hour, while MN Steel shows 90.
-Mesaba shows background Nitrogen Oxide (NOx) being 5 annually, while MN Steel shows it as being 12.
(MNSteel page 4-91, Mesaba page 4.3-11).
Regarding the Class I area (Federally Protected areas like the Boundary Waters):
- -Mesaba does not include Isle Royale.
-Mesaba does not include wet or dry deposition information for sulfur and nitrogen, or ozone concentrations info.
-MN Steel shows that the maximum allowed SO2 concentrations in 3 hr period in the BWCAW is 10.8, but Mesaba's DEIS indicates it's 1.5.
(MNSteel page 4-92, Mesaba 4.3-13).
II. Air Pollutant Emissions Significantly Above Thresholds:
No matter what data was used in the modeling, it still turns out that Air Pollutant Emissions from the proposed Mesaba I/II facilities are significantly above threshold levels. Mesaba Energy will emit 9 of the 10 Air Pollutants at levels significantly above the threshold level.
For example, Mesaba will emit 2,872 tons/per year of nitrogen oxide and the threshold is 40 tons per/year. This is in addition to the 59,701 tons/year of Nitrogen Oxides (NOx) emitted from regional facilities that currently exist,2 and MN Steel's planned addition of 1,505 tons/year of Nitrogen Oxides. Mesaba will emit 1,390 tons/year of Sulphur Dioxide and the threshold is 40 tons/year. This is in addition to the 36,491 tons a year that are already emitted from regional sources, and MN Steel's facility will add yet another 421 tons/year to our air.
| Pollutant | PSD Significance Threshold (TPY) | Plantwide Potential to Emit (TPY) |
|---|---|---|
| Carbon Monoxide (CO) | 100 | 2,539 |
| Nitrogen Oxide (NOx) | 40 | 2,872 |
| Sulphur Dioxide (SO2) | 40 | 1,390 |
| PM | 25 | 503 |
| PM10 | 15 | 493 (West) |
| O3 as VOC (Volatile Organic Compound) | 40 | 197 |
| Sulfuric Acid-mist | 7 | 130 |
| Hydrogen Sulfide | 10 | 17 |
Nitrogen oxides and ozone:
Nitrogen oxides and ozone play a major role in formation of particulate matter and ground level ozone (smog). Ozone causes respiratory illness and lung inflammation. On high ozone days there is a marked increase in hospital admissions and emergency room visits for asthma and other respiratory illness.3 Ozone forms in the presence of nitrous oxides, volatile organic compounds, light, and heat. The Mesaba plant would produce 2,872 tons/yr of nitrous oxides and 197 tons/yr of volatile organic compounds.
Particulate Matter:
With regard to particulates, PM2.5 is thought to have the most significant adverse impact on human health. Secondary formation of particulate matter can also have a significant impact on human health. In Mesaba's analysis, PM10 and SO2 exceed the threshold monitoring concentrations, but all Mesaba says that it will do about this about this is make application requesting a waiver of the preconstruction monitoring requirements (Mesaba 4.3-12). Not only has Excelsior Energy been exempted from demonstrating need for the entire project altogether, or whether it's the least cost alternative, they want to be exempted from monitoring requirements, as well.
III. Understatement of affects of Mercury:
Mesaba I/II will release up to 54 lbs of mercury per year. But Mesaba's DEIS only presented information for area within a 3 kilometer radius (4.3-26). A report of the mercury impact zone includes 720 lakes over 320 square km.4 487,000 fish are annually harvested from these lakes and 7,780 women of child-bearing age and children live here. Chronic mercury exposure in a developing fetus can cause mental retardation, growth deformity, seizures, blindness, deafness, and severely delayed development. Chronic mercury exposure of infants and small children can cause impaired reflexes, delayed motor development, impaired attention, impaired memory, and impaired language. Low level mercury exposure from fish consumption may lead to heart attack, and hardening of the arteries, especially in adult males.
The effects of mercury are well-known. A March 2007 report from the Pollution Control Agency stated that "MPCA scientists calculate that mercury emissions will have to be reduced 93 percent from 1990 levels for fish mercury levels to be reduced to safe levels. The MPCA has established a goal of reducing Minnesota mercury emissions by 93 percent, to 789 pounds per year, and is working with the U.S. Environmental Protection Agency to address out-of-state sources."5 Amidst these efforts to reduce mercury in the environment, why add another 54 lbs a year when the need for this electricity has not even been shown?
IV. Acid Rain:
As a utility generating unit greater than 25 MW, Mesaba also exceeds allowable emissions that contribute to acid rain. To deal with this, all they write is that they are required to obtain and comply with a Phase II Acid Rain Permit "in a manner consistent with EPA's overall efforts to reduce emissions of acids precursors" (4.3-24).
V. Major Greenhouse Gas Producer/Adding to Global Warming:
Mesaba will emit 9.4-10.6 million tons/year of CO2, a major greenhouse gas that contributes to global warming ( 4.3-25). Mesaba discusses its plan for Carbon Capture & Sequestration (CCS) in Appendix A and states that CCS would reduce emissions by 30%. But it is very expensive to actually do CCS, and the technology is not yet proven. So, this DEIS was careful to include a statement about what more they will ask for to implement CCS: "upon approval of a modification to the proposed power purchase agreement that would allow for Excelsior to be compensated at a reasonable cost of capital for the necessary capital investments, and to be made whole on the other costs associated with the CCS program" (A-1). Translation: without major additional taxpayer money, there is no plan to reduce CO2.
VI. Affect on Class I area Visibility and Regional Haze:
Mesaba would cause regional haze in Class I areas like the Boundary Waters Wilderness Canoe Area, and in its own words, "Project-related impacts occurring during periods of natural visibility degradation would have added effect" (4.3-29).
MPCA's July 2007 draft "Concept Plan for Addressing Major Point Sources in Northeastern Minnesota"6 states, "Concerns have been raised by Federal Land Managers (FLM) and others about the impact of new and existing sources in NE Minnesota on visibility in the Class I areas due to both proximity and high emissions" (p. 2). The MPCA has to submit a Regional Haze Plan to the EPA by December 2007. MPCA's plan calls for a 30 percent reduction in combined sulfur dioxide (SO2) and nitrogen oxides (NOX) emissions in Northeastern Minnesota. Again, why add more sources of pollution?
Back to our questions about the modeling technique used: Mesaba's DEIS states that "CALPUFF is the approved long-range transport model" (4.3-2). But an EPA document: "CALPUFF Analysis in Support of the 2005 changes to the Regional Haze Rule, published in June 15, 2005,7 provided this further explanation of the limitations of using CALPUFF. The report states that, "The challenge we encountered is that CALPUFF has not been fully tested for secondary formation and thus is not fully approved for applications in PSD permitting and NAAQS attainment demonstrations (i.e., it is approved for primary particulates, but not for secondarily-formed particulates)" (p. 1).
A report prepared for the DOE assessing reliability of CALPUFF the modeling used for visibility stated that: "CALPUFF is primarily a multi-source plume model that treats transport downwind and dispersion along the transport path. The representation of gas phasechemistry is highly simplified. These simplifications are likely to be deficient when applied to situations in which complex chemistry dominates the processes responsible for formation of secondary air pollutants. Such secondary air pollutants are an important source of visibility degradation." The report further stated that, "The agreement between measured and estimated aerosol concentrations using this [CALPUFF] approach is random and poor. Thus, we are concerned that the simplistic approach to aerosol formation may produce significant errors"8
Expert testimony provided to the state of Washington on a similar matter found: "The CALPUFF model used in this analysis represents a simplified treatment of visibility and haze. It does not account for the effect of secondary organic aerosol formed as a byproduct of VOC emissions and does not account for the effect of gaseous pollutants, NO2 in particular, which may lead to a modest underestimation of the impact on visibility. It also does not fully account for the contribution to particulate matter made by NH3 emissions."9
Even accepting CALPUFF as the best means there is of modeling, Mesaba uses old data. For example, Mesaba used data from 1990, 1992, 1996 (Mesaba 4.3-20), while for the same calculations MNSteel's FEIS used data from 2002, 2003, and 2004 (MNSteel page 4-107). Mesaba's DEIS (using the older data) states that it will "reduce visibility in the BWCAW by more than [the unacceptable rate of] 10% from 40-70 days a year" (4.3-20) This would be in addition to existing regional source contributions...
Further, Mesaba's DEIS states that "PM10 concentrations at the Boundary Waters over a 24-hour averaging period exceeds the SIL," and that "at the West Range site, SO2 impacts are above the SIL" (page 4.3-18). Data in MNSteel's FEIS, which was not included in this section of Mesaba's DEIS stated that MNSteel's contribution to PM10 in the Class I area would range from 4.83 to 7 days for the 3 years modeled. The increment standard is 8 µg/m3 for Class I Areas. It appears the combination of Mesaba and MNSteel's emission of PM10 exceeds the increment standard.
Deposition of Nitrogen and Sulphur in Class I Area:
MNSteel's FEIS explains the affects on plant and animal species of deposition of nitrogen and sulphur, "In evaluating potential adverse effects to flora and fauna, lichen species are generally used as a threshold indicator of potential air pollution damage because they are especially susceptible to air pollution and show adverse effects before other plant species and animal species. If pollutant concentrations in a Class I area are sufficiently low that no damage occurs to native lichens, then it can reasonably be concluded that all other flora and fauna species are protected. The most sensitive lichen species are only present when annual average SO2 concentrations are less than 40 µg/m3" (MNSteel 4-104).
Mesaba's DEIS does not provide contextual explanations like this, but does state that the maximum annual deposition of S and N from Mes