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,. <br />., <br />odor levels estimated at the rail cars assume that "activated carbon would be used to control <br />the HzS emissions while the railcars are Ueing heated" (pg. 19 of electronic file). Yet, in the <br />EAW, it states, "Due to the portable nature of the rail cars and the small amount of emissions <br />generated, it is not feasible to control the rail cars as they are being heated" (pg. 29). ]-low is it <br />thal they intend to control odor emission with "activated carbon" at the heating railcars? <br />There is no explanation in the memo. <br />With regard to contradictory information in the MPCA presentation, Table 1 of the technical <br />memorandum indicates the "updated" modeled hourly concentration at the HMA plant is 4.4 <br />ug/m3 and at the tank farnt is 6.9 ug/m3. Yet in slide 9 of the MPCA presentation on July 29, <br />2010, the maximum hourly concentrations of HzS at both points are expected to be <br />significandy higher (see below). The tank farm itself would likely have concentrations at or <br />ahove 20 ug/m3, and 1 recall Heather, the MPCA represenlaCive presenting this data that <br />evening, indicating that this was the case at the storage tank facility. Again, there is no <br />explanation or even reference made to an operational change that would warrant such <br />reduced estimates. <br />Modeled Ma�cimum Hourly <br />Hydrogen Sulfde Concentrdtions <br />--.. <br />!\ — � � . <br />� � �� <br />/\ G-� � <br />3! t4I��' uy� <br />� �r� � � 1 �� <br />.. � <br />�, -� ���:� =;_ <br />���; , ,. <br />�� ��G4�'� <br />!-"` ��� <br />,..- <br />.' :1 <br />� . -S <br />"��"1. . _ V S �3* /C • � ... <br />� . .L. . f%Dv>} ( %.1 �.I <br />�, s _ h� -�. ,>s r. �.� <br />P `"�� 1} �' � <br />t t ' G <br />4 �� �r ' " "-� <br />tt <br />I"�:' ` a . _. �av <br />Again, this presents contusing and what seems Co be erroneous data. <br />Prohibited Uses <br />Aside from this, 1 would like to point to specific Roseville zooing ordinances that would <br />prohibit this plant from being built. <br />In the cun-enf und pre-amended (Ord. 1397, 10-11-10) industrial zoning codes, chemicals <br />"involving noxious odors or daoger from fire or explosives" are implicitly prohibited in Table <br />,1� 1007.015, General Requirements (by ivay of the double-negative we're all familiar �vith). <br />Additionally, "noxious" is defined in Chapter 1002 Rules and Definitions as, "material which is <br />capable of causing injury or malaise to living organisms or is capable of causing detrimental <br />effect upon the health or the psychological, social or economic well-being of human beings." <br />(Ord.275,5-12-59) <br />ODOR <br />There are no state standards for odor. However, even using these poten[ially unreliable <br />figures, we can expect that people working and living in the area wil] experience health, <br />^ psychological, and/or economic issues, thereby failing to meet Roseville's standards. <br />