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� <br />Mr. Kevi� Kain — Bituminous Roadways Roseville Asphalt Plant <br />August 11, 2010 <br />Page 6 of SO <br />Concrete rubble F <br />Crushed concre[e <br />Rail car � <br />516 752 <br />665 906 <br />569 816 <br />876 1118 <br />606 1125 <br />470 1215 <br />886 1126 <br />� <br />1115 956 <br />1265 991 <br />1175 970 <br />1425 973 <br />1177 990 <br />1A85 937 <br />907 976 <br />1066 976 <br />979 976 <br />1297 976 <br />1019 976 <br />1406 976 <br />1304 976 <br />Modeling discussed in the EAW shows maximum predicted 24 hour average PMi.s impacts within 0.2 <br />µg/m� of the National Ambient Air Quality S[andard jNAAQS). The maximum predicted PM�o impacts <br />are 70%of the annual average NAAQS. Were receptors such as the air intakes on our roof and the air <br />intakes on the roofs of other adjacent buildings considered in che air modeling? <br />A review of the Miscellaneous Emfssions factors n AP 42 13Z4-4 indicates that total particulate <br />emisstons from the storoge pites, haul roads, crushers, and o[her activities wiil be signiflcantly higher <br />than the maximum predicted PMZ,Sand PM�o emissions. Although there is not a NAAQS for dust <br />particles larger than 10 microns, shouldn't. the EAW consider the impacts of nuisance dust on properties <br />adjacent to the proposed project? <br />The EAW indicates that all traffic areas will be paved in order to reduce dust from truck treffic. We <br />request that the air permit also indude requirements ro sweep the roadways and other paved areas. <br />Air Emissions Risk Assessment <br />Asphalt is considered a potential carcinogen due to the fact that it rypically may contain many <br />carcinogenit compounds, including many PAHs. Asphalt plants emit chemicals like hexane, phenol, <br />polycylit organit matter, formaidehyde and toluene. Concerns have been raised at asphal[ plants over <br />benzene and various metals such as chromium, cadmium and arsenic. Given the serious public concern <br />the MPCA shoutd conduct a careful and thorough review of the Bliuminous Roadways proposal. <br />Did [he Air Emissions RiskAssessment (AERA) considcr background concen[rations From tra�c on <br />Interstate 35W, Highway 36, local truck traffic on Walnut Street a�d Terminal Road and from the nearby <br />tank farms7 This Is important as many of the constituents of vehfcle emisslons are the same as the <br />emisslons from the proposed asphalt pfant. <br />The AERA does not include tail pipe emissions from truck traffic moving on the property nor from <br />inereased truck traffic on local streets as a result of this projecL Increased truck traffic wuld have a <br />sigoificant impact [he AERA results. <br />1571 WESf6RANCH DRIVE • SU17E Z00 • McLEAN, VA 4YIW • TELEPHO\�E403467�i800 • FA&703Q87•SSOl <br />-H� $IaAstonxvmmere"uil.rom 1 w�n�.•_¢�aAsronemmoan'¢y cvm <br />