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m T q Ms. Deborah R. Pile, Director November 7, 1984 Page Two 1) The accuracy and completeness of the material contained in the EAW; 2) Potential impacts that may warrant further investigation before the major project is commenced; and 3) The need for and EIS on the proposed project. (Minn. Rules, Sec. 4410.1600). A. Accuracy of EAW. (1) Item 5: Project Description. The description of the MRC project in Item 5 of the LAW and Attachment A to the EAW seriously misstates the actual nature of the project and overlooks one of its most important components. The cover letter from the MPCA dated September 28, 1984 refers to the project as a "proposed metal waste central treatment and recovery facility" and states that this EAW is "essentially a reissuance of a prior EAW." It further characterizes as a "slight project change" the addition of a feature to the project whereby organic wastes would be handled at the MRC facility. In Attachment A, a 14 page description of the facility prepared by MRC and submitted with the EAW, the metal waste processing function of the facility is described in great detail. In sharp contrast, there is no discussion of the organic waste handling function at all. Although the EAW discusses the metal waste treating activities at the facility, it virtually ignores the organic waste handling at the facility. The organic waste component of this facility appears to be that which is most likely to create adverse environmental impacts but there is almost no dis- cussion in the EAW of this activity at the site. The EAW mischaracterizes the facility in its description by concentrating on the metal waste handling component but ignoring the organic waste component. MRC has asked the City of Roseville to amend its zoning code to authorize a special use permit for MRC's facility. A copy of a letter from MRC's counsel describing that amendment is attached as Exhibit A. Under the proposed amendment, the following category of special use permits is established: "(11) The collection, processing, treatment and dis- tribution of industrial wastes consisting of metal compounds, solutions, and sludges and organic and inorganic liquids." Under the terms of this proposed ordinance amendment, MRC would be permitted to collect, process, treat, and distribute organic wastes at this facility. However, the description of the project in Item 5 of the EAW does not deal with this aspect of the proposal in any significant way. Item 5 of the EAW is erroneous and misleading in that it ignores organic hazardous ►,aste handling component of the project.