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Mr. Kevin Kain — 8ituminous Roadways Roseville Asphalt Plant Augusi 11, 2010 Page 7 of 10 � The AERA assumes that the whole area is heavy industrial based on the zoning and does not consider the mixed use. The AERA needs to consider the activities that are actuaity being conducted in the buildings adjacent to the proposed asphalt site. Odors Hydrogen sulfide �H=S) is the primary chemical of toncem for evaluating odors from the proposed Bituminous Roadways project. Sensitivity to Hi5 is highly subjective. H=5 odor nuisance thresholds can range from 0.5 parts per billion (ppb) (0.7 µg/m3) to 30 ppb (42 µgJm') based on the individual who is exposed. Typically, an Indivldual's odor threshold will increase wer time as they are exposed. The State of Minnesota has a health based ambien[ air quality standard for H=5 of 30 parts per billion (ppb). In the EAW odor analysis an odor detection threshold level of 8 ppb (11 µg/m3) antl an odor nuisance level of 40 pp6 (56 µg/m3) were used. These are too high and fail to protect occupants of our building and surrounding buildings, workers at nearby loading dotks, parking lots and other sensitive users near the � asphalt plant site. � The odor nuisance level in the EAW is higher than Minnesota's hea�th based sta�dard. The odor detection threshold level is higher than Ihe lowest odor detection level and health based standards used in other states. Other states health based standards are lower than the Minnesota standard and the standard that is referenced in the EAW. for example, Maine has a 1 ppb (2 µg/m�) chronic 1 year avereging time standard for H,S, Michigan's 24 hour ztandard for HzS is 2 µg/m3 and the Wisconsi� 1 hour standard is 14 pgJm3. `� If we are evaluating odor which is subjective and lower than the health based standards, the MPCA should, at a minimum, use lower more proteRive health hased standards to evaluate odor impacts. The EAW odor a�alysis found the one hour maximum concentratlon of 21.SA pg/m' at the northeast comer of the properry, 3.63 ug/m3at the golf course and 2.95 �g/m' at the nearest residence. Assuming the MPCA applies a protective odor standard for H=S is 2 µg/m, this recommended standard will be exceeded for our building and o[her adjacent and nearby commercial buildings. Odor limits woufd also tie exceeded fn nearby residential areas and on the public golf course. Based on our review, the EAW should use an odor standard for Hr5 is 2�µg/m'. The odor analysis results suggests that significant parts of our building and other adjacent b�ildings may exceed the Wisconsin 1 hour standard, [he low range of the odor threshold and the Michigan 24 hour standard for H=S. We helieve that the EAW should take a closer look at tbe odor and other H=5 impacts on adjacent property. The odor analysis considered H=5 emissions from HMA/VJarm Mix Asphalt (WMA) production and liquid asphalt cement (LAC) storage. It does not consider H,S emissions from trucks hauling asphalt and railcars hauling IAC. We believe that the EAW should consider al! Hs5 sources on site and should also consider background conce�trations. 1571 WFSIERANChI DRIVE • S�TfE 200 • McLEAn, VA 22107 •?ELEPHOIJE-703487�i800 • F.V(J01287�5801 .n�wrv qledsron?Mm�ne�gj�p�p I Yi�xm• ¢Indstonettmnart'� mm 1/