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� <br />� <br />opernte�f that no noise resulti»gfi�a� snid opera�ion rv/lich would conslitufe n nuisance <br />is perceptible beyond the premises. This does �iot npply to incider:ta! trrrffrc, parking <br />n�trt off-street locrding operatio►:s. <br />As indicated in the EAW at pages 29-31, noise attributable to the propased asphalt piant <br />would extend beyond the premises. Mauy of us li��ing in nearby neighborhoods believe <br />the F,AW seriously understates the noise levels associated with the proposed plant, and in <br />pariicular the crushin� operation. Both the operation of the proposed plant itself, and in <br />particular the crushing operation, are likely to praduce greater noise levels than used in <br />the EA W analysis. <br />Furtlier, �ve must not cotlfiise the MPCA noise standards and findings in the EAW with <br />the Roseville Code. MpCA noise standards apply to the exterior of particular land uses, <br />e.g. the yard of a residence. The language in Roseville Performance Standard 1 relates to <br />the noise Ievel essentially at the property line of the noise generator, that is "beyond the <br />preinises." I'here is no doubt that nuisance level i�oise �vould extend beyond the premises <br />of the proposed asphalt plant. <br />Yerforn�nnce Sta�rdard 2. S»:oke And Particulate Matter: Tlie enrission of snroke or• <br />parliculnte mntter is prohrbrted where such eniission is perceptible heyond the p�•e�nises <br />to the �legree as to constitute a nuisance. <br />There should be no doubt that the proposed plant could not meet the standard found <br />above. Data in the EAW, at pages 19-22, sho«� the proposed plant would produce readil_y <br />detectible particulate emissions beyond the premises. Further, as acknowledged in the <br />public meeting at Roseville in August, MPCA staff indicated that emission control <br />technology at the proposed plani have not yet been used in similar facilities, making the <br />emissions information suspect and possibly understating dle imUact. <br />Further, tlle proposed site will have huge stockpiles of material, see Figure 4 of the <br />EA��I�. These eight separate piles include aggregate, uncrushed asphalt and concrete <br />rubble, crushed asphalt and concrete, aggregate, sand, shingles, asphalt millings, and <br />sand. The proposed site would contain more than 112,000 square feet of ground area <br />containing piles of exposed rnaterial. Iv�ore importantly, these are three dimensional <br />piles, each of ��hich is 30 or more feet in height. Thei•efore; the surface area of exposed <br />rubble and crushed material containing fine particulate is substantially greater tlian the <br />11?,4U0 sq. ft. These piles would be exposed to wind 12 months a year, regardless of <br />whether the plant would be operating or not. As shown on Figt►re 4 of the EAW these <br />piles are in close proaimity to the proposed site boundaries, indeed both the concrete <br />rubble and asphalt rubble piles are shown di�•ectly adjacent to the property lines. <br />There can be no doubt that the proposed asphalt plant «�auld result in particulate matter <br />bein� perceptiUle beyond the premises to the degree as to constitute a nuisance. <br />