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� Mr. Kevin Kain Mr. Tarik Hanafy September 10, 2010 Page 12 ��i�i Moss & Barnett 24-hr 8.8 26 34.8 35 99.6% 7Mzs Tler 3 Mnual 2.6 10 12.6 15 84.2% 1-hr 1033 83 186.3 188 99.196 pp� 7fer 3 Annua! 15.1 17 32.1 100 32.146 1-hr 1,044.5 3,565 4,609.5 �� 11.5% CO (35,000) (13.2%) Tier 1 8-hr 373.4 2,760 3,133.4 50,000 31.33% Vehfcle trafflc can be a significant source of these four criteria pollutants. Based on our review of the permft materlals we cannot determine whether the modeling consider ex(sting traffic emissions on local streets and Interstate 35W and Trunk Hfghway 36, and emisslons from increased traffic due to tlie proposed project, We request that the proposed facility be remodeled to include emissions from trafflc. ^ Nthough we requested the modeling report on August i6, 2010, we did not get the report until September 8, 2010 and have not had tlme to fully evaluate It. If, as we suspect, the modeling did not consider the air Intakes on our roof and on other nearby bulldings as receptors, the modeling must be revised. We are concemed that the concentretions of these pollutants may be higher on the roof of our building and other nearby buildings. It is critical to account for air intakes on the roofs of nearby buildings to detertnine the Impacts of the proposed project on building ocapants. Meteorological Data The modeling uses meteorological data from tlie 1986-1990 perfod, We understand that more recent meteorological data is available. This data should also be reviewed and incorporated in emissions modeiing for the proposed plant. Nuisance Dust For fugitive dust emissions from wind erosion the Bituminous Roadways permit appllcaUon uses a Total Suspended Particulate emissions calculation fw asphalt rooflng from 1983. Gladstone believes that Ute most recent emissions factors should be used espedaily when tonsidering the high particulate concentrations that are revealed in the modeling. The MPCA regulates fine partculate (PM,a) and particulate known to cause resplratory and cardlovascular disease (PMz.$)• The emissions calculations suggest that proposed facility will also create a signiflcanY quantiry of larger par[iculate matter which will settie out of the air a short distance from the proposed facility. These fugitive emissions are a nufsar�ce and Qeate