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� -�. Mr. Kevin Kaln �� Mr, Tarik Hanafy September 10, zo�o Moss & Barnett Page 4 creates octremely fine aerosol particies which results in a vlsible plume often referred to az 'blue haze' or'biue smoke.' This condensed aerosol is hazardous when tnhaled, wats nearby equipment and machinery, can create a fire hazard and often has an unpleasant odor. This phenomenon occurs in severel asphalt production, storage and transport applicaUOns, including tank and tanker loading and unloading, blending, processing and sto2ge tanks, which will be employed by Bltuminous Roadways at this site. Glads[one is particulaHy concemed about the levels of pardculate matter, nitrogen oxides, carbon monoxide, hazardous air pollutants and pollutan[s of concem such as hydrogen sulfide generated by the proposed Bituminous Roadways Roseville project. Hydrogen sulfide fs of particular concern due its low odor threshold and due to a growing body of evidence showin9 long term chronic effec[s at low expasure levels. In additlon to the errvironmental impacts of the proposed asphalY piant and storege terminal, Gladstone believes that the EAW does not adequately address the potential of odors, noise and pollutfon from trucks transporting asphalt and other materials to and from the proposed site. The emisslons from the proposed facilfty are also of concem due to high levels of background concentratlons from road treffic — especially on Interstate 35W and Trunk Highway 36, other nearby sources that emtt similar pollutants (Magellan and Nu Star Tank Farms), and generally high badcground concentratlons of hazardous poilutants found in tlie Twin Ctles Metropolitan area. The users of the Gladstone building wlll be as sensitive to the emisslons as any others In tlie community. As we previously noted, the actual users in the area of the project are also generally and in some instances highly sensitive to these matters. It is noY posslble to gloss over the speclflc detalls of the area by broadly categorizing the area as Industrial, and tlierefore reladvely insensitive to matters such as hydrogen sulflde and pardculates. The fact that there are uses in the area that mtght be less sensitive or even sources themselves does not ailow anyone to condude that the entire area Is Iike that. We belleve for these reasons, and uncertainHes re9arding estimates of the impact of the proposed Bituminous Roadways Project, that this project warrants an Environmental Impad Statement (QS). AP-42 Factors The EAW's conclusions about air pollution emission factors at the proposed plant rely on test data hom other facllities that cannot be reliably extrapolated to the project without doser analysis of the mul�tude of factors relevant to the test data results and their applicatlon to the proposed ptant. The EPA compiles representative air pollu[ion emission factors to allow estimatlon ot tlie amount of pollutlon released to the air by an activity or process. These factors allow predic-�ng a process' emfsslons by multlplying the process throu9hput by the publtshed emisslon factor.