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.. <br />Mr. Kevin Kain — Bituminous Roadways Rosevil�e Asphait Plani <br />August 11, 2010 <br />Page 8 of 10 <br />-, <br />The HZS emissions esiima[es rely on emissions testing performed by the State of North Carolina and the <br />National Asphalt Pavement Association. This equipmeni may not be the same as that proposed by <br />Bituminous Roadways for this site and does not rely upon the same emission contrals. Bituminous <br />Roadways presumably has equipment similarto equipment at the proposed new plant. Due to <br />uncertainties regarding the HzS data, we request that Bituminous Roadways test existing equipment to <br />verify Hz5 emission rotes prior to EAW approval and permit issuance. The MPCA should closely monitor <br />this testing and as approprlate collect independent samples to veri(y [he results. <br />A fabric filier wiil control air emissions from the asphalt drum/dryer/mixec Air emissions from the drum <br />consist of 6urner combustion produccs, dust and particles from aggregates, and some volatile gases <br />from the liquid asphalt cemeni. Fabric fllters do a good job controlling particulate matter, but they do <br />not do a very good job controiling (or odors and volatile hazardous air pollutants. <br />The Tank farm will store LAC. Tank farm storage will vent to a carbon bed filter [o control HZS <br />emissions. The EAW does not discuss the effectiveness of tarbon bed filters in controlling Hz5 emissions. <br />Carbon bed filter operation and maintenance can have signifcant impacts on i[s effectiveness. 7he EAW <br />should discuss this issue. Approp�iate [erms and conditions related [o carbon bed filter operatlo� and <br />main[enance should be included in tfie afr permit. <br />The HMA/WMA plan[ will control HZS emissions with a fi6er bed filter. The EAW should discuss the <br />effediveness of these filters for tontrolling H=5 emissions and discuss any potential issues with their <br />effectiveness. <br />The EAW indicates that the tank farm wlll store LAC for the proposed site and for o[ber asphalt plants. <br />The EAW and the air permit do not specify the annual LAC throughput through the tank farm. This could <br />have slgnifican[ impac[s on air emissions because tank farm throughput determines the air emission <br />rate and truck traffic. Was the potential LAC tank [hroughput considered in the EAW AERA and odor <br />analysis and [he air permit7 <br />Stormwater <br />Several activities on the proposed project site will impac[ stormwater. Several potential stormwater <br />pollucants are associated with the asphalt Industry. The proposed tacilitWs stormwater permit should <br />require monitoring of discharges to surface water for total suspended solids, total dissolved solids, oll <br />and grease, themical oxygen demand, surfactants, benzene, metals and for substances used to prevent <br />asphalt from adhering to metal surfaces. All storm water detention basins should be equipped with oil <br />skimmers. <br />This proposed project will use steam to heat railway cars prior to unloading. Will the water from <br />steaming rail cars be discharged to the sanitary sewer or to [he stormwater ponds? <br />151 f tYES7BfiANCH DRNL • SUI'fE 200 • h1cLEAN, VA 2I]Ui • TELEPHONE4U12873800 • FAX�703�ZN7�5801 <br />w.elads�onxommerriaLcom 1 www gladstonemmwn'esmm <br />