pf09-010 - Laserfiche WebLink

Home

�. Mr. Kevin Kain Mr. Tarik Hanafy September 10, 201� Page 9 0 ��♦� Moss & Barnett The calculatlons atso assume 95% contral for the categories total organic compounds, totai hazardous air pollutants (HAPS), and total non vofatlle organic compound (VOC)/non-HAP. Each of ti�ese categorles indude chemicals that the manufacturer has identified as either not condensing at filter bed operating temperatures or may not candense at fliter bed operating temperatures. The calculations and any modeting and tox(cs analysis based on these calculations should be revised to refled the actual control efficiendes or these ptegories. Modeling Gladstone`s concems wfth the modeling Involve the use of background data and t�e implications of the modeling results on the AERA. The modefing is at best incomplete. It does not consider all the relevant pollutants and background conditions. Additionally, and crftically for the location of the proposed plant, it fails to consider features of the Giadstone building and the complete and detafled consideratlon of the other uses and improvements in tfie immediate area. Additional work is required before the modeling can be relied on for the MPCA to issue the air permit or for the project to proceed. Non-criteria Pollutant Emissions The modeling uses MPCA defaults for badcground concentrations and assumes that background data should account for emissions for non-criteria pollutants because emissions from petroleum handling and combustion are ubiquitous. These assumptions provide the basls for the risk catculations in the AERA. Emissions from the nearby facllitfes, in particular the Magellan PipeNne (a major VOC source) and the Valero tank farms (a state regulated air emission source}, should be added to assumed background levels. In addition, the modeling and the AERA sfiould account for emissions from other nearby combusGon sources, exfsting traffic emtssions on local streets and interstate 35W and Trunk Highway 3b, and emfss)ons from increased trafflc due to the proposed project. l�i�e table below lists several non-criteria poilutar� emitted by the proposed Bituminous Roadways project and indicates (f they are also expected to be emitted from natural gas combustion, petrochemica) storage, gasoline engir�e operatlan or dlesel engine operation. As the table shows, there is considerable overlap. Non- Criteria Pollutant Emissfons from Bituminous Natural Gas Petrochemical Gasollne Diesel CAS Roadways Plant Combustion Storage Engine En ine 91-57-6 2•Methylnaphthalene X 83-32-9 Acena hthene X X 208-96-8 Acenaphthylene X X 534-15-6 Acetaldehyde X X X 67-64-1 Acetone X 107-OZ-8 Acrolien X X 120-12-7 Anthracene X X �..- � �