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�.. Mr. Kevin Kain - Bituminous Raadways Roseville Asphalt Plant August 11, 2010 Page 3 of 10 .� Specifiwlly, it would 6e helpful to see a maps or figures acwrately identifying where the residential, commercial and industrial receptors are in the odor, notse and modeling analysis and in the Air Fmissioru Risk Assessment (AFRAJ. Gublic comments by Bitumfnous Roadways and information in tfle EAW indicate that crushing operations wiil be limited to between 6 AM and 8 PM. Public documents contain referentes to operations 6e[ween 7 AM ro 7 PM. Will other opera[ions also be iimited to this time period or will the facility operate 24 hours per day? Likewise, Bituminous Roadways notes that its operations are seawnal and not year round. The restrictions vn daily operations and annual operations have the effect of concentroting emissions. The EAW states that the proposed facility is restricted to less than or equal to 589,231 tons of hot mix asphalt (NMA) on an annual basis. Whereas 589,231 tons per year spread over 8760 hours is 67.26 [ons per hour, using 16 hours per day from April through fJovem6er results ln an average of 153.A5 tons per hour, This wncentretion of activity has over twice the hourly impact of the scenarlo [hat assumes that there are not seasonal fluctuations. Was this considered in the EAW, the AERA and the air permi[? Does the permit have limits on hovdy operatfons? Newspaper reports on the recent public mee[ing state that the MPCq staff Indicated Chat Agency staff wo�ld conduct inspectlons of the plant to ensure compliance with all set guidelines. How ohen will MPCA staff be conduct(ng Inspect�ons? Will these inspections include inspections of hours of operation, odors, noise, and other operatlonal permit [erms and conditions. What equipment will the MPCA utilize to conduct these inspections? Noise The failure of the EAW to consider the actual uses of the property adjatent to and nearby the proposed asphalt plant site has signiflcan[ impacts on the EAW noise analysis. The EAW estimates noise levels off the projectsite at nearby "indusvfal properties" to be 72.5 tl8(A) which (s within [he MPCA standards for industrial aceas. We believe that the agency should use the commercial noise standard for adJacent property rother than the Indus[rial s[andard: Land Use Code Residenlial NAC•1 .__. __ _.__ .. Commercial NAG2 . Industrial .NAC-3 _....__..____._.'-----'--._--'----_._._.. ___ ._--.. __. . ..._ .._ _. �. Minnesota PolWtion Control Agency Stata Nolee Standards � . . _.__..___. .. . _.._ .. .. _ .._ ___,._: Day {7.00 a.m 10:00 p.m.) Night (10:00 p m. - 7:00 a.m.) dBA dBA ._ ,.._. __.--.._. _._..._ _� L'10 of 65 ; L50 of 60 ' L10 of 55 L50 0150 - � - - - . .. ..._.. _. ��..._ . _._: L10 of 70 ' L50 of 65 � � 1.10 0( 70 � L50 of 65 � _... .. _ -- -- --_- -.._. . _ __ . ._.: L1D oF 80 i L50 of 75 L10 of 80 ' L50 of �5 �� The EAW Noise analysis uses test data from one crusher and the location of [hat crusher on the site is uncleac From reading the EAW and the air permit, crushing may occur at any location on the proposed 1527 WFSTHRAKCH DRIVE • SUITE 200 • McLEAN, VA 22102 • TELEPHONE�7034878800 • FAX�903�28:�5801 www gladslonmimmer6al mm I www,pladstonemmnanies mm � �..i `r