Public Comment Period Open on Mercer-Fraser Asphalt Batch Plant in Dinsmore
Mercer-Frasier has published notice to the public that the company applied to the North Coast Unified Air Quality Management District (NCUAQMD) for a permit to operate “hot mix asphalt plant,” generally referred to as a ‘batch plant,’ in Dinsmore, CA.
Patty Clary, the Executive Director of California for Alternatives to Toxics, is concerned about NCUAQMD issuing permanent approval. Clary argues that because Dinsmore sits in a small and deep valley, where the mountains soar a thousand feet above the valley floor that is only a half mile wide, that this location may be more prone to air quality degradation than most places. Clary expressed fear for the air quality of people living there and said similar operations in places such as Hoopa and Longvale have led such poor air quality that residents were forced to avoid outdoor activity.
Mercer-Frasier is a general engineering contracting firm established in Humboldt County in the 1870’s. Mercer-Fraser is known for engineered construction projects such as bridges, sea walls and roads. It owns many quarries and other industrial properties. The application currently on file with the air quality district relates to their site on the Van Duzen River east of the Dinsmore Market, just yards into Trinity County on Highway 36.
Speaking with Jason Davis, Permits & Planning Division Manager, at the NCUAQMD, he explained that Mercer-Frasier has had a batch plant on that site that runs an average of three or four months in every two year period, and that the batch plant has been there for at least two decades. Davis explained that Mercer-Frasier upgraded their equipment in a manner that triggered the need for a new Best Available Control Technology (BACT) permit for Stationary Source emissions.
To meet State recommendations, Mercer-Fraser’s batch plant at Dinsmore will now include ground tires, referred to by the industry as “crumb rubber.” Using crumb rubber is strongly encouraged by CalTrans. CalTrans’ Office of Pavement Programming has two primary functions: to implement the Ten Year State Highway System Management Plan and to prepare the Annual Crumb Rubber Usage Report. CalTrans promotes the crumb rubber to divert several million tons of used tires away from landfills. Although CalTrans does not appear to study the safety differences of pavement in which crumb rubber has been used for a portion of the aggregate, acadamic papers such as A Review on Using Crumb Rubber in Reinforcement of Asphalt Pavement by Nuha Salim Mashaan, et al published in the Scientific World Journal in 2014 shows rubberized pavement does offer additional benefits such as reducing damage to pavement caused by freezing and reducing the danger to drivers from hydroplaning and skidding.
According to industry journals, getting the asphalt and the rubber to bond to one another means adding polymer class chemicals, that were previously unnecessary, to the asphalt mixture while heating it to 375 degrees, well past the boiling point at 212 degrees, which encourages atmospheric release of chemicals and odors.
Davis said Mercer- Frasier has been running a hot batch operation on the property under a temporary permit and this filing will make it a permanent arrangement according to Davis.
Clary, the Executive Director of California for Alternatives to Toxics, acknowledged the benefits of adding rubber to the pavement mix, however, she argues that since batch plant operations are only needed occasionally when the local roads are being resurfaced, temporary permitting by NCUAQMD would better ensure that Mercer Frasier did not use inadequate or under-performing equipment, but instead would be obligated to invest in the latest technology for keeping the air resources clean. Clary said, “They need to spend and invest in our air quality even if it means cutting into their bottom line.”
Davis, at the NCUAQMD said that he had not yet checked in with the enforcement department at the NCUAQMD and could not say offhand whether there have been air quality complaints made to his agency since Mercer-Fraser began using the new batch plant equipment under the temporary permit on Highway 36. Davis did say the analysis by Trinity County Planning Department indicated this application by Mercer-Fraser would not require an “ambient air quality dispersion analysis” because the batch plant is considered a “minor source” of air pollution that is unlikely to “significantly degrade” air quality.
Davis explained that if the NCUAQMD were to consider having Mercer Fraser prepare the asphalt in Fortuna or another site, that the air quality impacts of trucking the mix would have to be added to the list of factors impacting the air. And he also said that thermal inversion layers that cause air to be trapped in valleys tend to happen in cold weather whereas paving activity needs to happen in warm weather to prevent the asphalt from solidifying in the equipment before it can be applied to the road.
The North Coast Unified Air Quality Management District Board is accepting letters from the public until 5pm on Wednesday, December 12th. The public notice includes the following instructions for submitting public comment, “To be considered, written comments must be received prior to 4:00 p.m.December 12, 2018
The Board “will review and consider all comments prior to taking final action on the application for a permit. Documents are available for inspection at the District offices during normal business hours -Monday through Friday 9:00 a.m. to 12:00 p.m. and 1:00 p.m. to 4:00 p.m. Information is also posted on the District website at www.ncuaqmd.org. Should you have a question or require additional information contact Jason Davis at (707) 443-3093 or firstname.lastname@example.org.
Public comments concerning this permit may be submitted to:
North Coast Unified Air Quality Management District
Attn: Mercer-Fraser ATC#001063-1
707 L Street
Eureka, CA 95501”
Jason Davis added that the District really values feedback and emphasized that all comments are read and considered in the decision making process.