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-. -. Mr. Kevin Kain �� Mr. Tarik Hanafy September 10, zo�o Moss & Barnett Page 2 of documenis until September 8"'. ConsequenUy, we have not had adequate tlme to review the file documents. Based on our consultanYs review of the proposed permlt, Environmental ASSessment Worksheet {EAW), appllcaUOns, and related documents from MPCA Flies, we have concems about the effect of the propased Bltuminous Roadways asphalt plant on Gladstone's building, tenants and adjacent properties. The emissions from the proposed plant need more study. Our review of the material has identified seve2l areas of uncertainty that may signtfipntly affect the environmental impacts of the proposed pro]ect. Because we have serious concems about the effectiveness of the control technology, the impact of background emissions, and the needs and Interests of the project's neighbors, Gladstone asks the MPCA to deny the permit application and order an Environmental Impact Sratement (EIS). An ETS is required to protect the public health and the environment To be certaln that we have communicated to you tfie specffic items of wncem, we draw your attention to the fotlowing summary of tlie technical discussion of this letter. That dfscussion shows that the analysis to date is not adequate for the MPCA to make a decision other than to pursue further study of the proJec[ through an EIS. The MPCA needs to consider all of the items listed below in add(Gon to the commeMS we previously made and tliose from oth� interested members of the community. We summarize the rema(nder of this comment letter as follows: (a) the emisslons hom the asphalt plant are of critiwl concem and [he estlmates regarding the impad are uncertain; (b) the AP-42 Factor analysis relles on test results where the wide variation in the underlying factors is relevant to those results and there is inadequate analysis for extrapolatlng those results to the analysis of the project; (c) the carbon bed/carbon filter technology proposed for the proJeQ is critical for the controlling U�e environmental Impact but the technical analysis of the technology is Incomptete and needs additional examinatlon before making a decision whether the technology is adequate; • (d) the aspiialt plant wili rely on a fiber bed filter to reduce VOC's and condensable PM but the calculations regarding the ePficacy of the eqWpment need to be reworked; (e) the modeling of non-criteria and criteria pollutant emfssions is incomplete and inadequate when consfdered with respect to an accu2te and complete analysis of the relevant conditions induding the uses and receptors in the area of the project; (fj the analysis of nuisance dust suffers from the same problems as the modeling of the emissions; and (g) the analys(s of hydrogen sulfide relies on test data that we conclude may not be adequate for e�Rrepoladon to this fadlity and also fails to consider the specific features and nature of the nearby receptors, including our bufldfng a�d other uses, that are sensitive to the hydrogen