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� � � Mr. Kevin Kain Mr. Tarik Hanafy September 10, 2010 Page 14 ��i�i Moss & Barnett Gladstone is one of several users near the proposed fadlity that will be direcTiy effected by hydrogen sulfide emissions. The EAW analysis fails to consider those effects in detall or with spedficity. It again assumes that the receptors are of a type that are intended to tolerate nufsance odor Ievels, which evidences an incompiete analysis. Coupled with uncertafnty regarding the application of the test results from other settings and the uncertainty as to the meaning and appropriateness of odor and hydrogen sulflde standards, more study is needed. Permit Issues The air permit fndudes ten different operatlng scenarios based on dffferent combinatlons of raw material handling (crushing), number of aggregate Vucks, aushing dust mitigatlon, and asphalt productlon. The scenarbs involve different sweeping/fiushing requirements on 14 roadway segments and dlfferent crusher dust midgatlon requirementr. We Rnd these scena�ios confusin9 and belleve that they will be difficult to monitor, track and enforce. Much of the large particulate, depending on wind speed, will settle on the site. Trucks wili tradc material onto and off the site. wnd and storm water runoff wlll aiso deposit particulate on the site and on the haul roads. We estlmate that there are 0.4 miles of roads on the proposed Bituminous Roadways site. Eigln, a major street sweeper manufatturer recommends a street sweeper speed of 5 miles per hour. At the recommended speed, It would take a relativey short period of time to sweep all of the roadways. Tests conducted by the United States Geologipl Service (USGS) found that the efficiency of street sweepe�s range from 20% to 31% for mechan(cal sweepers and from 60°/o to 929'o for vacuum sweepers. Tests conducted by Elgin, a major street sweeper manufacturer, on its vacuum sweepers found they achleved efficlendes renging from Bl% to 97.5% depending on the type of sweeper. The type of sweeper obviously makes a big dlfference. The permit should spedry a type of sweeper and sweeper efficiency. The modeling and emissions calculaUons should be revised to reflect actual levels of efficiency of the equlpment. Certain mechanical sweepers can generate slgniflcant air emissions. If BiWminous Roadways intends to use a mechanical sweeper, the emissions calcutations should reflect the lower efficiencies of inechanical sweepers and account for the alr emisslons caused by mechanfCal sweeping. The permit does not specify water sprays for the portable cru�ing equipment. Due to the fact that particulate concent2tlons from tlie proposed project are extremely close to the NAAQS, the permit should specify [he most stringent par[iculate controls on the wshing equlpmenG The permtt applicatlon states that the City of Rosevilie will restrict avsher operetion to a maximum of two 3-week periods per year separated by a minimum of 12D days. The permit should include this requiremenC