21-CV-21-678

Filed in District Court

State of Minnesota
4/22/2021 10:57 AM

STATE OF MINNESOTA DISTRICT COURT

COUNTY OF DOUGLAS SEVENTH JUDICIAL DISTRICT

Case Type: Civil Other/Misc.

State of Minnesota by its Minnesota Pollution Court File No. ____________

Control Agency,

Plaintiff,
SUMMONS
vs.

Joe Wagner,

Defendant.

THIS SUMMONS IS DIRECTED TO JOE WAGNER, through his attorney, Matthew Berger,
Gislason & Hunter, 2700 South Broadway Street, New Ulm, MN 56073.

1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The
Plaintiff’s Complaint against you is attached to this summons. Do not throw these papers away.
They are official papers that affect your rights. You must respond to this lawsuit even though it
may not yet be filed with the Court and there may be no court file number on this summons.

2. YOU MUST REPLY WITHIN 20 DAYS TO PROTECT YOUR RIGHTS.

You must give or mail to the person who signed this summons a written response called an
Answer within 20 days of the date on which you received this Summons. You must send a copy
of your Answer to the person who signed this summons located at: Christina Brown, Office of
the Minnesota Attorney General, 445 Minnesota Street, Suite 900, St. Paul, Minnesota 55101-
2127.

3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written

response to the Plaintiff’s Complaint. In your Answer you must state whether you agree or
disagree with each paragraph of the Complaint. If you believe the Plaintiff should not be given
everything asked for in the Complaint, you must say so in your Answer.

4. YOU WILL LOSE YOUR CASE IF YOU DO NOT SEND A WRITTEN

RESPONSE TO THE COMPLAINT TO THE PERSON WHO SIGNED THIS
SUMMONS. If you do not Answer within 20 days, you will lose this case. You will not get to
tell your side of the story, and the Court may decide against you and award the Plaintiff
everything asked for in the complaint. If you do not want to contest the claims stated in the
complaint, you do not need to respond. A default judgment can then be entered against you for
the relief requested in the complaint.
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5. LEGAL ASSISTANCE. You may wish to get legal help from a lawyer. If you
do not have a lawyer, the Court Administrator may have information about places where you can
get legal assistance. Even if you cannot get legal help, you must still provide a written
Answer to protect your rights or you may lose the case.

6. ALTERNATIVE DISPUTE RESOLUTION. The parties may agree to or be

ordered to participate in an alternative dispute resolution process under Rule 114 of the
Minnesota General Rules of Practice. You must still send your written response to the
Complaint even if you expect to use alternative means of resolving this dispute.

Dated: March 15, 2021 KEITH ELLISON

Attorney General
State of Minnesota

/s/ Christina Brown

CHRISTINA BROWN
Assistant Attorney General
Atty. Reg. No. 0391019

445 Minnesota Street, Suite 900

St. Paul, Minnesota 55101-2127
(651) 757-1471 (Voice)
(651) 297-4139 (Fax)
christina.brown@ag.state.mn.us

ATTORNEY FOR PLAINTIFF MINNESOTA

POLLUTION CONTROL AGENCY

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STATE OF MINNESOTA DISTRICT COURT

COUNTY OF DOUGLAS SEVENTH JUDICIAL DISTRICT

Case Type: Civil Other/Misc.

State of Minnesota by its Minnesota Pollution Court File No. ____________

Control Agency,

Plaintiff,
COMPLAINT
vs.

Joe Wagner,

Defendant.

This is an action by Plaintiff, State of Minnesota by the Minnesota Pollution Control

Agency (MPCA), against Defendant Joe Wagner, to recover civil penalties and award injunctive

relief pursuant to Minnesota Statutes section 115.071, subdivisions 3 and 4. Wagner operates a

National Pollution Discharge Elimination System (NPDES) permitted feedlot in Douglas

County. In violation of his NPDES permit and applicable state rules, Wagner expanded the

number of cattle at his feedlot and constructed unauthorized animal holding pens; created illegal

manure stockpiles; and contributed to manure-laden discharges to waters of the state, both

ground and surface waters. MPCA, for its Complaint against Defendant, hereby states and

alleges as follows:

PARTIES

1. MPCA is an executive agency of the State of Minnesota with responsibility for

the administration and enforcement of statutes and rules related to air, water, and land pollution.

As part of these duties, MPCA regulates feedlots through the issuance of National Pollution
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Elimination System (NPDES) permits and enforcement of applicable state laws and rules. Minn.

Stat. §§ 115.03 and 116.07, subd. 7c and Minn. R. chs. 7020, 7050, and 7060.

2. Defendant Joe Wagner is an individual who owns and operates a registered

feedlot, number 041-66885, located in the SW ¼ of Section 12, Millerville Township, Douglas

County, Minnesota (feedlot).

JURISDICTION AND VENUE

3. This Court has subject matter jurisdiction to impose civil penalties and award

injunctive relief pursuant to Minnesota Statutes section 115.071 for violations of Minnesota

feedlot regulations and NPDES permit requirements.

4. Venue is proper in this district under Minn. Stat. § 542.02 because the injured

property is located in Douglas County. Venue is also proper in this district under Minn. Stat.

§ 542.09 because Wagner resides in Douglas County and the cause of action arose there.

HISTORICAL BACKGROUND

5. MPCA enforces state laws aimed at preventing pollution of “waters of the state.”

Minn. R. 7020.0300, subp. 26; see also Minn. Stat. § 115.03, subd. 1(a). MPCA monitors for

and prevents potential water pollution through its Feedlot Program (Program). The Program has

two main tasks. First, the Program ensures the proper “storage, transportation, disposal, and

utilization of animal manure and process wastewaters.” Minn. R. 7020.0200. Second, the

Program manages “application[s] for and issuance of permits for construction and operation of”

systems for managing, disposing, or utilizing animal manure. Id.

6. One of the ways the Program ensures proper management of animal manure is

through the oversight of animal feedlots. Animal feedlots (also referred to as “feedlots”), are

defined as

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a lot or building or combination of lots and buildings intended for the confined
feeding, breeding, raising, or holding of animals and specifically designed as a
confinement area in which manure may accumulate, or where the concentration of
animals is such that a vegetative cover cannot be maintained within the enclosure.

Minn. R. 7020.0300, subp. 3.

7. The Program requires owners of feedlots containing a certain number of animal

units to register with MPCA and, if applicable, their respective county feedlot program. Minn.

R. 7020.0350. If a feedlot is large enough, the owner may need to obtain a NPDES permit to

further control discharges to state waters. Minn. R. 7020.0405, subp. 1(A).

8. Since 2006, MPCA has worked with Wagner to maintain and/or bring his

operations into compliance with state feedlot regulations.

9. Despite MPCA’s efforts, Wagner has demonstrated significant difficulties

maintaining compliance with applicable regulations. Prior to the events at issue in this case,

MPCA conducted 24 inspections of Wagner’s operations, 7 of which were in response to

MPCA’s receipt of approximately 27 citizen complaints. MPCA’s inspections have documented

21 violations of state feedlot regulations, 16 of which were deemed “major” violations.

10. The documented violations have resulted in the issuance of 1 administrative

penalty order (APO), 3 stipulation agreements, and 1 administrative order from May 1, 2012 to

July 16, 2020.

11. On February 11, 2021, MPCA issued a Notice of Violation after its most recent

inspection of the feedlot at issue in this case and other Wagner sites, documenting 2 violations, 1

of which were “major” violations.

FACTUAL BACKGROUND

12. Wagner owns and operates a cattle feedlot in Douglas County. Historically, the

feedlot’s production area consisted of a series of open lots, with and without runoff controls,

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covering an area measuring approximately 1,500’ x 600’. The feedlot housed 970 head of beef

feeder cattle, for a total of 679 animal units (AU). The feedlot also consisted of two feed storage

areas without runoff controls, as well as a settling basin that directed manure contaminated

runoff from a portion of the open lots to a 2.6 acre vegetative infiltration area.

13. On October 6, 2016, MPCA issued Wager an individual NPDES permit, number

MN0070866. The permit authorized construction of the following components:

a. One series of open lots with runoff controls covering an area measuring

2,400’ x 200’ for housing 1,000 head of beef slaughter cattle (1,000 AU) and 1,000 head

of beef feeder cattle (700 AU), for a total of 2,000 head of cattle (1,700 AU).

b. One 400’ x 30’ partial confinement barn associated with a portion of the

open lots described above.

c. One 1,000’ x 104’ total confinement barn for housing 1,850 head of beef

feeder cattle (1,295 AU).

d. One 600’ x 104’ total confinement barn for housing 1,150 head of beef

feeder cattle (805 AU).

e. Two 432’ x 100’ total confinement barns, with a 432’ x 116’ x 12’ poured

concrete liquid manure storage area located beneath each barn, for housing 1,500 head of

beef slaughter cattle in each barn (3,000 AU).

f. One 100’ x 50’ working barn.

g. One 400’ x 200’ x 8’ geo-synthetic clay lined (GCL) liquid manure

storage area for collecting open lot and feed storage area runoff.

h. One 800’ x 200’ x 7’ GCL liquid manure storage area for collecting open

lot and feed storage area runoff.

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i. One 670’ x 280’ impervious feed storage area with runoff controls.

j. One 120’ x 64’ commodity building.

k. One 24’ x 16’ commodity building.

l. One 25’ x 30’ dead animal management area.

14. Only upon completion of construction of the aforementioned components, as well

as the closure of open existing lots, earthen settling area, vegetative infiltration area, and any

feed storage areas without runoff controls, the NPDES permit authorized Wagner to expand from

970 head of beef feeder cattle (670 AU) to 6,800 beef slaughter cattle (4,000 AU) and 4,000 beef

feeder cattle (2,800 AU) for a total of 10,800 head of cattle (6,800 AU).

15. On November 20, 2018, MPCA issued Wagner a modification to the permit that

allowed Wagner to change the dimensions of two bars with liquid manure storage areas and to

replace two previously-approved land application fields with four new ones. The modification

kept the same restrictions in place from the original permit that limited Wagner’s ability to

expand beyond 970 head of cattle (679 AU) until completion of all required construction and

closures.

16. On July 1, 2019, MPCA staff received photographic documentation from a

Douglas County Feedlot Officer that indicated Wagner had illegally exceeded the number of

permitted cattle at the feedlot and installed unauthorized components.

17. On July 10, 2019, MPCA staff, together with the Douglas County Feedlot Officer

and Land and Resource Management Director, conducted a compliance inspection of the feedlot.

Wagner was present for the inspection. During the inspection, MPCA staff observed that none

of the new components authorized under the NPDES permit were under construction or

completed, and documented the following violations:

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a. Unauthorized Animal Numbers. Wagner was using ten open lots to

house cattle and he stated that these open lots currently held approximately 2,581 head of

cattle, each weighing over 1,000 pounds (2,581 animal units). The permit prohibited an

increase in animal units beyond 970 head (679 AU) until all existing facility components

were closed and the new approved barns, runoff controls, and liquid manure storage areas

were constructed and made operational. Aerial photographs taken by the Douglas

County Feedlot Officer on May 2, 2019 and provided to MPCA on July 1, 2019 showed

the presence of approximately 3,673 head of cattle.

b. Unauthorized Feedlot Components. Present at the feedlot were two

newly constructed, unauthorized open lots. The first, known as “Pen 6,” was

approximately 200’ x 300’ in size. The second, known as “Pen West,” was

approximately 809’ x 618’ and located within close proximity to Lorsung Lake. Both

unauthorized pens were devoid of vegetation, included feedbunks, and had manure

accumulation present. Wagner stated to MPCA staff and the Douglas County Feedlot

Officer and Land and Resource Management Director that both pens had been in use

since mid-to-late 2018.

c. Non-Compliant Manure Stockpiles. Also present were several non-

compliant “short-term” manure stockpiles located within three distinct areas.

i) “Manure Stockpile 1” was located between Pen 6 and Pen West,

within a gravel pit, and approximately 350’ long by 75’ wide. It contained

manure stockpiles up to 15’ tall. Wagner informed MPCA staff this stockpile had

been in use since April 2019.

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ii) “Manure Stockpile 2” was located south of Pen West and within

close proximity to Lorsung Lake. The stockpile was approximately 200’ x 200’

and 3’ deep. Wagner informed MPCA staff this stockpile had been in used since

April 2019.

iii) “Manure Stockpile 3” was located within a low area that is

between Pen 6 and the gravel pit and contained multiples piles of manure ranging

from 10; x 15’ to 15’ x 25’ and were all approximately 2’ deep. Wagner

informed MPCA staff this stockpile had been in use since the winter of 2018-

2019.

d. Discharges to Surface Water. Present at the time of the inspection were

three separate discharges to surface waters. Two of the discharges originated from

Manure Stockpiles 1 and 2. The third originated in what Wagner referred to as “Pen 1.”

All three discharges flowed into a type 3 protected wetland that is hydrologically

connected to Lorsung Lake, waters of the state.

e. Discharges to Groundwater. Also present at the time of the inspection

were three discharges of manure and manure contaminated water to groundwater. Two

of the discharges originated from Manure Stockpiles 1 and 2. Both of these stockpiles

were located on top of loam soil types that are conducive to drainage and allow easy

infiltration to groundwater. The third originated in Pen West and pooled in an area that

contained a surface tile intake.

18. On July 17, 2019, Wagner, through his attorney, sent a letter to the Attorney

General’s Office regarding the July 10 inspection. Without admitting any violation of applicable

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regulations of permits, Wagner submitted a proposed plan for removing the unauthorized manure

stockpiles and cattle.

19. On August 12, 2019, MPCA sent Wagner an Alleged Violations Letter that

formally required Wagner to immediately do the following:

a. Begin or continue to remove all of the manure within the unpermitted

manure storage areas and either land apply or stockpile the manure in accordance with

applicable laws.

b. Begin or continue to reduce the number and type of cattle to 970 head of

feeder cattle (679 AU).

c. Take any and all actions necessary to stop the runoff of manure and

manure contaminated runoff from the unpermitted animal holding and manure storage

areas to waters of the state.

d. Begin or continue to provide MPCA with a weekly report on the amount

of manure removed from unpermitted manure storage areas and the number of cattle

removed until such time that all of the manure from the unpermitted manure storage areas

is removed and the number and type of cattle are reduced to 970 head of feeder cattle

(679 AU).

20. Between mid-July of 2019 and November 13, 2019, Wagner provided periodic

updates regarding his progress in removing the unauthorized manure stockpiles and reducing the

number of unauthorized cattle, as well as his compliance with the AVL’s directives.

21. On November 14, 2019, MPCA staff conducted a site inspection of the feedlot.

MPCA staff confirmed that Wagner had completed removal of the unauthorized cattle and

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manure stockpiles and that runoff of manure and manure contaminated runoff from the

unpermitted animal holding and manure storage areas to water of the state had ceased.

22. Prior to the July 2019 inspection, Wagner had a significant history of

noncompliance. Since 2012, MPCA and Wagner have executed three settlement agreements and

MPCA has issued Wagner an Administrative Penalty Order for similar alleged violations.

23. The violations observed and documented in July 2019 demonstrate an escalating

pattern of noncompliance with and willful disregard for Minnesota regulations and permits

governing feedlots.

COUNT I

Unauthorized Discharges to Surface Waters

(Minn. R. 7050.0210, subps. 2 and 13; NPDES Permit No. MN0070866, Part 13.2.2)

24. MPCA re-alleges all prior paragraphs of the Complaint.

25. Minnesota Rule 7020.0300 defines “discharge” as follows:

Subp. 9c. Discharge. "Discharge" means the addition of a pollutant to waters of

the state, including a release of animal manure, manure-contaminated runoff or
process wastewater from an animal feedlot, a manure storage area, or an animal
manure land application site by leaking, pumping, pouring, emitting, emptying,
dumping, escaping, seeping, leaching, or any other means. Discharge includes
both point source and nonpoint source discharges.

26. The discharges of manure and manure contaminated runoff violate Minnesota

Rule 7050.0210, which prohibits the creation of nuisance conditions and discharges of other

waste into state waters.

27. Section 13.2.2 of Wagner’s NPDES prohibits the discharge of manure and

manure contaminated water to surface waters absent a precipitation event and full compliance

facility, operational, and recordkeeping requirements.

28. As documented on July 10, 2019, Wagner caused illegal discharges to surface

waters.

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29. Unauthorized manure stockpile 1 discharged manure and manure contaminated

runoff within the gravel pit where the stockpile was located.

30. The discharge left the gravel pit through a channel that flowed out of the pit’s

south side and into a type 3 protected wetland adjacent and hydrologically connected to Lorsung

Lake.

31. The discharged manure and manure contaminated runoff were discolored, foamy

in places, and had a strong manure odor.

32. Unauthorized manure stockpile 2 discharged manure and manure contaminated

runoff into a type 3 protected wetland that is hydrologically connected to Lorsung Lake.

33. Manure and manure contaminated runoff were also discharged from Pen 1 into

waters of the state.

34. The discharge from Pen 1 flowed into an area that was previously a gravel pit.

The gravel pit area sloped to the south, where a significant amount of manure and manure

contaminated runoff pooled before it exited the gravel pit area and into a type 3 protected

wetland that is hydrologically connected to Lorsung Lake.

35. Wagner did not construct and operate the feedlot in accordance with permitted

design standards such that a discharge to surface waters would have been permissible.

36. Wagner violated Minnesota rules and the terms of his NPDES Permit, both of

which protect surface waters from illegal discharges. This Court has jurisdiction to assess a civil

penalty under Minnesota Statutes section 115.071, subdivision 3.

COUNT II

Unauthorized Discharges to Groundwater

(Minn. R. 7060.0600, subp. 2; NPDES Permit No. MN0070866, Part 13.4)

37. MPCA re-alleges all prior paragraphs of the Complaint.

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38. Minnesota Statutes section 115.01 defines “other waste” as:

Subd. 9. Other wastes. "Other wastes" mean garbage, municipal refuse,

decayed wood, sawdust, shavings, bark, lime, sand, ashes, offal, oil, tar,
chemicals, dredged spoil, solid waste, incinerator residue, sewage sludge,
munitions, chemical wastes, biological materials, radioactive materials, heat,
wrecked or discarded equipment, rock, cellar dirt or municipal or agricultural
waste, and all other substances not included within the definitions of sewage
and industrial waste set forth in this chapter which may pollute or tend to
pollute the waters of the state.

39. Minnesota Rule 7060.0600 prohibits the discharge of other waste to the

unsaturated zone as well as the deposition of other wastes in such a place, manner, or quantity,

which may pollute underground waters.

40. Section 13.4 of Wagner’s NPDES permit prohibits discharges of manure, manure

contaminated runoff, and processed wastewater to a sinkhole, fractured bedrock, well, surface

tile intake, mine, quarry, or other natural or constructed channels that convey fluids to

groundwater.

41. As documented on July 10, 2019, Wagner caused illegal discharges to

groundwater from both unauthorized manure stockpiles and an unauthorized holding pen.

42. Unauthorized manure stockpile 1 was located in a gravel pit and sat upon

Sandberg gravelly sandy loam, which is classified as an excessively drained soil and contributes

to the potential to infiltrate and pollute groundwater.

43. It also discharged manure and manure contaminated runoff to a type 3 protected

wetland. The area where the discharge entered the wetland was located on Urness mucky silt

loam, which has a depth to the water table of 0 inches and contributed to the potential to pollute

groundwater.

44. Unauthorized manure stockpile 2 discharged manure and manure contaminated

runoff to a type 3 protected wetland that is hydrologically connected to Lorsung Lake. The area

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where the discharge entered the wetland was also located on Urness mucky silt loam and

contributed to the potential to pollute groundwater.

45. Manure and manure contaminated runoff also discharged from Pen West, an

unauthorized feedlot component. The discharge flowed out to the west and pooled in a low area

that also contained a surface tile intake.

46. Wagner violated Minnesota rules and the terms of his NPDES Permit, both of

which protect groundwaters from illegal discharges. This Court has jurisdiction to assess a civil

penalty under Minnesota Statutes section 115.071, subdivision 3.

COUNT III

Unauthorized Numbers of Animal Units and Construction of Unauthorized Feedlot

Components in Violation of Wagner’s NPDES Permit
(Minn. R. 7020.0405, subp. 5; NPDES Permit No. MN0070866, Parts 3 and 14)

47. MPCA re-alleges all prior paragraphs of the Complaint.

48. Section 3.1 of Wagner’s NPDES permit prohibited Wagner from expanding

beyond 970 head of cattle (679 AU) until he completed all requirements set forth in paragraphs 6

and 7 of this Complaint.

49. Both Section 14 of the permit, as well as Minnesota Rule 7020.0405, prohibit

modifications to a permitted feedlot without first obtaining approval from MPCA.

50. As documented on July 10, 2019, Wagner illegally expanded the number of cattle

present at the feedlot, as well as constructed unauthorized feedlot components, in violation of his

NPDES permit and Minnesota rule.

51. Without completing the requirements set forth in paragraphs 6 and 7, Wagner

expanded the number of cattle at the feedlot to 3,673 head of cattle, 2,703 beyond the permitted

970 head of cattle.

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52. Wagner also constructed unauthorized feedlot components without first obtaining

permission from MPCA through a permit amendment.

53. Wagner violated the terms of his NPDES Permit and Minnesota Rule 7020.0405.

This Court has jurisdiction to assess a civil penalty under Minnesota Statutes section 115.071,

subdivision 3.

COUNT IV

Unauthorized Manure Stockpiles

(Minn. R. 7020.2125, subps. 1-2; NPDES Permit No. MN0070866, Part 8.3.1 )

54. MPCA re-alleges all prior paragraphs of the Complaint.

55. Minnesota Rule 7020.2125, subpart 1 sets forth general requirements for manure

stockpiles. These include a 3-to-1 horizontal-to-vertical ratio, a solids content of at least 15%,

and soils less coarse than a sandy loam, as well as a prohibition against the placement of manure

stockpiles in gravel pits.

56. Subpart 2 prohibits the placement of manure stockpiles on land with slope

percentages between 2 and 6 percent unless the clean water diversions and erosion control

practices are installed. It also prohibits manure stockpiles on certain soil types.

57. Part 8.3.1 of Wagner’s NPDES permit only allows manure stockpiles on a short

term basis. The permit prohibits the placement of manure stockpiles anywhere for longer than

10 consecutive days and no more than 6 times per year.

58. As documented on July 10, 2019, Wagner illegally stockpiled manure in

violation of both his permit and Minnesota rules. Wagner admitted to MPCA staff that the

manure stockpiles at issue had been in place since the 2018/2019 winter season.

59. In addition to the manure stockpiles exceeding the 10-day maximum, they lacked

a 3-to-1 horizontal-to-vertical ratio and were placed on land with slopes between two and six

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percent that did not have clean water diversions and erosion controls in place. The stockpiles

were also placed on soil types prohibited by Minnesota rules and one stockpile was located

within a gravel pit.

60. Wagner violated Minnesota rules and the terms of his NPDES Permit through the

storage and placement of illegal manure stockpiles. This Court has jurisdiction to assess a civil

penalty under Minnesota Statutes section 115.071, subdivision 3.

RELIEF

WHEREFORE, MPCA respectfully asks this Court to:

1. Enter judgment against Wagner for his violations of Minnesota rules and his

NPDES permit in an amount to exceed $50,000;

2. Issue an injunction against Wagner that prohibits him from expanding beyond 970

head of cattle (679 AU) until he completes all requirements set forth in paragraphs 6 and 7 of this

Complaint;

3. Award costs, disbursements, and reasonable attorneys’ fees to MPCA;

4. Award pre- and post-judgment interest to MPCA; and

5. Grant such other relief as this Court deems just and proper.

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Dated: March 15, 2021 KEITH ELLISON

Attorney General
State of Minnesota

/s/ Christina Brown

CHRISTINA BROWN
Assistant Attorney General
Atty. Reg. No. 0391019

445 Minnesota Street, Suite 900

St. Paul, Minnesota 55101-2127
(651) 757-1471 (Voice)
(651) 297-4139 (Fax)
christina.brown@ag.state.mn.us

ATTORNEY FOR PLAINTIFF MINNESOTA

POLLUTION CONTROL AGENCY

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MINN. STAT. § 549.211

ACKNOWLEDGMENT

The party on whose behalf the attached document is served acknowledges through its

undersigned counsel that sanctions, including reasonable attorney fees and other expenses, may

be awarded to the opposite party or parties pursuant to Minn. Stat. § 549.211.

Dated: March 15, 2021 __________ /s/ Christina Brown

CHRISTINA BROWN
Assistant Attorney General
Atty. Reg. No. 0391019

445 Minnesota Street, Suite 900

St. Paul, Minnesota 55101-2127
(651) 757-1471 (Voice)
(651) 297-4139 (Fax)
christina.brown@ag.state.mn.us

ATTORNEY FOR PLAINTIFF MINNESOTA

POLLUTION CONTROL AGENCY

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