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Ms. Deborah R. Pile, Director November 7, 1984 Page Six C. Need for EIS. Under Minn. Stat., Sec. 116D.04, subd. 2A, an environmental impact statement is required "where there is a potential for significant environmental effects." A review of this project conclusively indicates that there is the potential for serious and significant environmen- tal effects. Further, it is clear that those effects have not been antici- pated or discussed in the EAW. One of those environmental effects is contamination of surface and ground water by the hazardous waste collected, and handled at the facility. An EIS is needed in order to establish likely impacts on water quality from this activity. The control measures specified in the EAW are inadequate and the EIS is needed to determine likely water impacts and what spill control measures would be appropriate for this facility. There is a clear potential for air pollution which has not been dis- cussed. The EIS should determine those potential effects and review what control measures are required to prevent air pollution in the treatment processes. Of particular concern is the potential for air pollution by volatile organic compounds. A major concern should be the toxic fumes which could be generated in case of a fire at the facility. The fire suppression measures described in the EAW are inadequate for this type of facility. There is no indication that surrounding fire departments have the abilities to cope with the types of fires which could develop at the facility. The EIS should review the fire danger. Just the sheer scope and size of the project indicates the need for an EIS. Under the EAW rules, an EIS is required to be prepared if the facility will handle in excess of 1,000 kilograms per year or approximately 12 tons per year of hazardous waste. The EAW estimates that MRC will be storing an average of 1,000 barrels at a time for no longer than an average of 30 days. On a yearly basis, MRC will thus accept 12,000 barrels or 3,000 tons per year of barrels. Additionally, MRC therefore expects to receive approx- imately 3,000 to 20,000 tons per year of hazardous metal processing wastes. MRC will be receiving 6,000 to 23,000 tons of hazardous waste per year while the cut off requirement for preparation of an EAW is only 12 tons per year. MRC will be processing 500 to 1,900 times the amount of hazardous waste considered significant enough to require an EAW. This substantial impact alone should be enough to indicate the need for an EIS. Under the applicable rules regarding decision on the need for an EIS (Minn. Rule Sec. 441M700, subp. 8 and subp. 9), "related" or "phased" actions are required to be considered in determing the need for an EIS. MRC is purchasing an eight acre site of which only four acres will be used for its project. The additional four acres will be used for resale "to an industrial user which would benefit by proximity to the facility." (Attach- ment A). The identity of that industrial user is not known. However, this statement indicates that the activity of MRC is related to an activity which it anticipated will be conducted on the adjacent site. The combined impact of these two related projects must be investigated in determining the environ- mental impact of the whole project.