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Ms. Deborah R. Pile, Director November 7, 1984 Page Four (8) Item 24: Air Pollution. According to this item, the project will generate neither air pollution nor odors. Although it is stated that the project will not generate air pollution, the EAW further states that the need for an air quality permit will be assessed at a later date. An air emissions control equipment permit may also be required. The fact that such permits may be required establishes that, contrary to the EAW, there is a potential for air pollution at the site. Additionally, we believe that the cyanide treatment process proposed in the facility has the potential for generating hydrogen cyanide or hydrogen sulfide if combined with acids stored at the site. There is no discussion of the air quality impact of this or other treatment methods at the facility. In regard to odor, it seems clear that the mixing and batching of solvents could generate odors. Again, the EAW states there will be no odor impact. We believe this conclusion is incorrect. (9) Item 25: Description of Waste. The EAW states that only "small quantities of organic waste" will be collected at the site. However, it also states that the drum storage area will be capable of holding a maximum of 1,500 drums at one time with an expected average of 1,000 drums stored for an average of 30 days. If such predictions are met, the MRC site will store 3,000 tons of hazardous wastes in drums per year. This is a substantial amount of hazardous wastes. Only 12 tons of stored hazardous waste a year is required to trigger an EAW. Again, the EAW substantially minimizes the impact of the storage of organic wastes at the site. (10) Item 29: Traffic -Impact. According to the EAW, it is estimated that there will be approximate y 5 incoming truck trips per day. However, according to the September 6, 1984 letter from Benshoof and Associates which is attached to the EAW, "it is expected that the proposed development would generate approximately 100 truck trips in per day -- 50 arriving at the site and 50 departing from the site." The EAW is in error in claiming only 15 incoming trucks per day. B. Potential Impacts. (1) Orgnaic Waste. The EAW's discussion of the organic waste collect- ing, handling, mixing, and distribution activities at the site is limited to a single paragraph on page 10. Such a discussion is wholly insufficient for an activity with such serious potential environmental effects. An EIS should be required to establish the types of organic waste proposed to be handled, how much organic waste will be handled, how long the wastes will be kept in the facility, how the wastes will stored and segregated, how the wastes will be mixed and combined, and how the hazardous waste will be tested and moni- tored. The failure of the EAW to deal with the organic waste component of this proposal is its single greatest failing. The handling of such large quantities of hazardous waste has a potential for many and severe environ- mental effects which have not been addressed.