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Mr. Kevin Kain <br />Mr, Tarik Hanafy <br />September 10, 2010 <br />Page 13 <br />��i�i <br />Moss & Barnett <br />serious pubilc health concems for certain populations. 7he permit application shows poteniial <br />emisslons of 39.16 tons of particulate matter with approximately half of this composed of larger <br />particulate matter. How much of thts material wili se[tle on our building, building air intakes, <br />vehlGes In parking lots and on the buildings, air intakes and parking lots of our neighbors? The <br />modeling overlooks these specific physicai features of the area. It fails to consfder In a detailed <br />way the nuisance a�d pubifc health concerns relating to the proposed project and the slte. A <br />proper analysis would not gloss over the spetifics of the area by making broad assumpYrons of <br />the nature of the uses and improvements in the immedlate area, including the Gladstone <br />building and others. M EIS is required to gather more data and more effectively evaluate the <br />ImpacLs of d�st on the area near the proposed asphalt plant. <br />Hydrogen Sulfide <br />The AERA shows significant hydrogen sulfide impacts at the properry Iine. We have two <br />concerns with this. First, as dfscussed above, we are not comfortabie with using North Carolina <br />test data to predict emissions for a fadlity that may or may not share design, material <br />specificaUon and operetlng parameters wliich can Influence hydrogen sulflde emissions and <br />control technology effictency. This uncertainty needs to be addressed. Changes in control <br />efficiency of a few percent can signlfica�tly extend the area where hydrogen sulfide <br />concentrations exceed odor thresholds. Given the proximity of our building, within several <br />hundred feet, of hydrogen sulfide sources, direct impacts are a strong possibillty. Second, we <br />are concerned about the hydrogen sulflde concentratlons from fhe proposed facility on our roof <br />where our air intakes are located. <br />The analysis of hydrogen sulfide impacts also does not consider background concentratlons. <br />Backg�ound levels of hydrogen sulflde are unknown In Minnesota. According to the Malne <br />Department of Health & Human Services, the amounts of hydrogen sulfide found natu�aly in <br />the air ranges from 0.11-.033 ppb (0.15-0.46 ug/m3). <br />The Minnesota Environmental Quality Board's GeneNcEnvlronmenla/lmpadS(atement (GEIS) <br />A1rQua//tyandOdorlmpacts, noted that :°...ambient monftoring data would be helpful in <br />estaWishing proper "background" levels of hydrogen sulfide.' For example: <br />"Considerable effort has been devoted to measuring hydrogen sulfide concentrations <br />downwind of animal agriculture facilities; however, collection of arnbient hydrogen <br />sulflde concenUatlon data in a variety of locations would help to estabiish a <br />'badcground' level and help determine the contribuGon of feedlots to that <br />background level." <br />Thls issue should be explored tn greater detall in an EIS. Prfor to permitting asphalt plants in a <br />dense commerclal and residential areas such as this, the MPCA should consider monitoring of <br />the amblent air In the Immediate vicinity of the proposed asphait plant to determine background <br />levels of hydrogen sulflde. <br />� <br />� <br />� <br />