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<br />e <br /> <br />e <br /> <br />e <br /> <br />Mr. Steven Rohlf <br />Page 2 <br /> <br />Ve would like to note that Elk River is within a region of the state, north <br />of the Twin Cities along the Mississippi River Valley, in which the MPCA hopes <br />to improve ambient ground water quality monitoring. In particular, well <br />igwb0010, at 19861 Gary Street in Elk River, may be included in this network; <br />this well seems to be down gradient of the mining district and may be a useful <br />reference point in the future to track potential impacts of development, mining <br />and non-mining, on the local ground water. <br /> <br />Ve are pleased to see that the EIS addresses in detail the Pollution Prevention <br />Plans required by the National Pollutant Discharge Elimination System (NPDES) <br />storm water permit program. It is not clear from MPCA records, however, whether <br />each of the active mining and aggregate production operations in the Elk River <br />mining district indeed has prepared and begun to implement their respective <br />plans. In particular, we question the status of these plans for Barton, Bauerly <br />Brothers, Elk River Bituminous, Midwest Asphalt, and Plaisted at their respective <br />Elk River facilities. Ve recommend that you contact each firm and request to <br />review each of their plans, and then indicate in the final EIS where the city <br />believes each firm is with respect to storm water compliance. This would be <br />helpful in better meshing the city's water quality management efforts, which <br />appear to be well planned, with state and federal storm water permitting <br />requirements. The MPCA staff expects each of the mining companies, as well <br />as other industrial facilities like AME Ready Mix and Shiely Masonry, to fully <br />comply with the requirements of the NPDES storm water program so as to protect <br />local waters from runoff impacts. <br /> <br />Page 3-53 of the EIS discusses chemical treatment as a means of dust suppression. <br />Vhile this is a generally accepted method to control fugitive dust, we recommend <br />that chemical application be discouraged whenever there are feasible alternatives, <br />so as to minimize surface and ground water contamination by the chemicals. <br /> <br />Regarding air quality matters, we note that the air quality section of the EIS, <br />specifically pages 3-44 to 3-47 and table 3.5-2, gives emission factors for the <br />various operations and total expected emissions from the facilities, but does not <br />give the facility basis for each site. MPCA thus has no way of verifying that the <br />totals given are correct. It also appears that some of the emission factors used <br />may have been extracted from the wrong reference. John V. Ferman of the MPCA Air <br />Quality Division (296-7600) should be contacted to discuss this matter. <br />