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Mrs. Deborah R. Pile, Director <br />November 7, 1984 <br />Page Three <br />(2) Item 7: Construction Costs. The EAW estimates the construction <br />cost at $5, 00,0 . Correspondence from MRC's attorney attached as Exhibit A <br />indicates the cost will be $6,000,000. Other information we have been <br />provided indicates that the cost for acquisition of the property and con- <br />struction of the facility together could be in excess of S6,000,000. The cost <br />of the facility obviously directly affects its economic viability. If the <br />facility is not economically viable, it will not be adequately constructed or <br />operated. Therefore, it is important that the true cost of the facility be <br />ascertained. The information contained in the EAW appears to be incorrect. <br />(3) Item 12 (A): Land Use Ordinance. The EAW states that this project <br />is not inconsistent with any adopted land use ordinance. That statement is <br />incorrect. The proposal is inconsistent with the Roseville zoning code. The <br />City of Roseville has not amended its zoning code to permit this activity. <br />(4) Item 13: Surrounding Development. Apparently describing the Boise <br />Cascade Corrugated Container Plant, the EAW referes to "forest products <br />manufacturing" as a neighboring activity. This description substantially <br />misrepresents the nature of the activities at the Boise Cascade facility. <br />As previously stated, the facility manufactures packaging material over 50% <br />of which is used to package food. The nature of this activity may be incon- <br />sistent with the activities proposed to be conducted by MRC. The EAW de- <br />scription of surrounding activities is, in this respect, inaccurate. <br />(5) Item 15: Soil Types. According to the EAW, "nearby well logs" <br />indicate "clay and sand gravel surfaces with area characterized by clay <br />to 12 feet." Soil composition is critical to this project in view of the <br />hazardous waste handling which will take place and the potential for spills. <br />In our experience, well logs are extremely unreliable for determining soil <br />composition. Soil borings should be 'taken to accurately assess soil composi- <br />tion. The discussion of soil type, although critically important in review of <br />the environmental effects of the project is inadequate and possibly inaccurate. <br />(6) Item 17: Ground Water Depth. According to the EAW, there is a <br />140 foot average static water level at this site. We believe that this <br />statement is in error and that the ground water level (surface of the <br />saturated zone) is more likely of 30 to 40 feet and could be shallower. <br />Again, the depth of the ground water is extremely critical in assessing the <br />potential for ground water contamination from hazardous wastes spills at the <br />site. Again, we believe the EAW is factually incorrect. <br />(7) Item 21: Effect on Water Quality. The EAW states that the project <br />will have no effect on the quality of either surface or ground water. This <br />statement ignores the obvious. A significant portion of the hazardous wastes <br />in the State of Minnesota at any one time will likely be concentrated at this <br />site. There is a potential for serious hazardous waste spills at this site. <br />Any such spills would substantially impact surface and ground water quality. <br />Failure of the EAW to acknowledge the potential for adverse water quality <br />impacts has resulted in a failure to address measures to mitigate such <br />impacts. The EAW is inaccurate in stating that there will be no water <br />quality impact. <br />