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` ` Mr. Kevin Kain �� Mr. TaMk Hanafy September 10, zo�o Moss & Barnett Page 3 suifide all of whlch makes the technical analysis inCOmplete and tlie assessment most likely erroneous; and (h) the dust and particulate midgation measures related to the alr permit requlre undertaking new modeling w acmunt for the ac[val effidendes in the mtdgation methods. It is tlear that the MPCA lacks adequate background informatlon on both nuisance pollutarns and pollutants that endanger the public health that are generated by these types of projects. M EIS could collect this informatlon. The MPCA's Alr Emission Risk Assessment (AERA) process has made slgnlflcant progress In addressing public risk from pollutants that are rrot on the U.S. Environmental Protectlon Agency's (EPA's) list of hazardous air pollutan[s. Unfortunately, because these pollutants are not on the EPA's list, ihese poflutan[s often lack monitoring data to determine their ambient levels and emissions data to detertnine ffie emfssfon rates of these pollutants from varlous sources. An EIS could address this issue. With so many technical issues and uncertatnties as [o the air quaiiry and pollution factors relatlng to the project, R fs not possible for the MPCA to make a determinadon regarding the lack of adverse environmental effects, or the effectiveness of the contrni technology. Gladstone also believes that an QS is also required to determfne the appropriateness of lowting an asphalt plant In an urban area with already high background levels of noise, odors and air polludon. The fact of industrial zoning does not resoNe the environmental issues. Thfs Is particularly true for the proposed slte due to the proxlmity of office buildings, food processors, �,,,r commercial bufldings, chfld care centers, residences and various recreatlonal amenitles. Fror the reasons that the technical anaysis Is incomplete and fuli of material uncertafntles, we ask the MPCA to deny the permit appllcatlon and order an Environmental Impact Statement (QS). An QS is mquired to protect the public health and the environment. Asphalt Emissions Asphalt plants generate dust from traffic, material handling, processing and storage plles. Material processing generates emissions from combustlon used to generate process heat, from traffic and equipment operation, and material handfing, processi�g and storege. These emissions include both criteria pollutants (sulfur dioxide, particulate matter, volatlle organic compounds, nitrogen oxides, qrbon monoxide and lead) and varlous non-criteria pollutants (hazardous air pollutants and other chemicais of concem such as hydrogen sulfide). Asphaft is a complex mixture derived from petroleum. By weight, it is composed of roughly 80% by Carbon, 10% Hydrogen, up to 6% Sulfur, along with small amounis of Ozygen and Nitrogen and trace amounts of inetals such as Barium, Arsenic, Chromium, Nickei, and Z�nc. The Carbon and Hydrogen in the asphalt are rnmbined with other elements to produce a vartety of polyaromatic hydrocarbons and other org8nic compounds, including many hazardous air pollutants. To keep asphalt from solidlfying during transport, storege and use, it must be kept at temperatures between 400° and 550°F. These elevated temperatures drive off [he I(gh[- ends of the hydrocarbons as odorous vapors, most of which quicldy condense when the organlc vapor/air mixture cools by contacting the surrounding amb(ent air. This condensed vapor �