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Ms. Deborah R. Pile, Director November 7, 1984 Page Five (2) Fire Control. Storage of wastes of the nature described in the EAW present a significant potential for fire and toxic fumes resulting from fire. However, the fire protection measures described in the EAW are clearly inadequate. The EAW proposes to handle fires by a sprinkler system augmented by hand held extinguishers. Such a system would be inadequate to handle the type of fire likely to develop at this facility. The types of fire likely to develop could best be fought using light water or fo&m. Further, there is no discussion of whether the Roseville Fire Department could adequately handle the fire potential for this facility. The environmental effects of a fire at the facility should be addressed so mitigative measures could be adopted. (3) Sewer Capacity. In a letter dated June 21, 1983 from Pope -Reid Associates, Inc., attached to the EAW, it is stated that the existing sewer connection is inadequate. There is no discussion in the EAW of the impact of MRC's sewer utilization on future industrial development in the area. It is certainly conceivable that the sewer capacity requied by the MRC facility would preclude future industrial development in the area. (4) Spills. The containment method for spills of hazardous wastes described in response to Item 21 is inadequate. According to the EAW, drainage from the truck parking and unloading area will connect directly to the storm water drainage system of the City of Roseville. Such a direct connection presents a serious possibility of hazardous waste contamination in the case of a spill. The gates and traps system proposed to divert liquids in case of a spill is inadequate. (5) Air Pollution. The proposed facility presents a significant risk of air pollution, toxic fumes and adverse odors. There is no discussion in the EAW of methods for abating, mitigating or controlling odor toxic fumes or other air pollution. There are no air quality criteria for emission of volatile organic compounds. The potential of this facility for emitting volatile organics should be examined. (6) Financing. The proposed facility will only be successful if it adequately financed. There is no indication as to whether the project is economically feasible. It is critical that the economic feasibility of the project be determined initially in order to insure that the facility is not abandoned or neglected in the event it fails to be profitable. Further, requirements in the nature of a bond or letter of credit should be adopted to insure cleanup of the site if it is abandoned. (7) Management. Also critical to the success of this project is the nature o the management personnel who will be operating the facility. We understand that MRC will be contracting with other individuals or companies to operate the facility. Further, we understand that MRC has or will enter into joint venture or partnership agreements with entities other than those listed in the EAW. The MPCA should make some determination as to whether those persons are capable and competent enough to operate such a highly technical facility with such a serious potential for adverse environmental impact.