Mr. Karl Brooks Page Two

Resources' Air Pollution Control Program at P.O. Box 176

, Jefferson City, MO 65102 or by telephone at (573) 751-4817.

Sincerely,

AIR POLLUTION CONTROL PROGRAM 

# ;t"/lJ!JVvL

Kyra L. Moore Director

KLM:wvc

Enclosures:

Copy of plan Copy of commission signature page certifying Missouri Air Conservation Commission adoption Copy of public hearing notices Copy of public hearing transcript introductory statement Copy of recommendation for adoption Copy of the summary of comments and responses

c: Missouri Air Conservation Commission File# 1987-PM-6 Carthage

Celebrating 40 years of taking care of Missouri's natural resources. To learn more about the Missouri Department of Natural Resources visit dnr.mo.gov.

# Missouri State Implementation Plan Revision

________________ Americold Logistics, LLC 24-Hour Particulate Matter (PM 10 

## ) National Ambient Air Quality Standard (NAAQS) Consent Judgment



# ________________
Adoption March 27, 2014

Prepared for the Missouri Air Conservation Commission

Missouri Department of Natural Resources Division of Environmental Quality Air Pollution Control Program Jefferson City, Missouri2 I. Purpose

As required by Section 110(a) of the Clean Air Act, Missouri’s State Implementation Plan (SIP) must ensure attainment and maintenance of all National Ambient Air Quality Standards (NAAQS). The Missouri Department of Natura l Resources’ Air Pollution Control Program is amending and strengthening the Missouri SIP to address violations of the 24-hour coarse particulate matter (PM 10 ) NAAQS of 150 micrograms per cubic meter (μg/m 3 ) near the Americold Logistics, LLC’s Carthage Crushe d Limestone (CCL) facility. The SIP revision consists of a consent judgment with CCL for measures intended to reduce PM 10 emissions at the facility, all of which are scheduled for installation and operation by March 31, 2014.

II. Background and History

Particulate Matter is a mixture of extremely small solid particles and liquid droplets made up of a variety of components, including acids (such as nitr ates and sulfates), orga nic chemicals, and soil or dust particles. Coarse pa rticles (coarse fraction of PM 10 ) are inhalable and are between 2.5 and 10 micrometers in diameter. Common PM 10 emission sources include windblown dust; dust from roadways; agricultural til ling; construction activities; a nd crushing, quarrying, and grinding operations. PM 10 poses health problems because these particles can bypass the body’s natural defense mechanisms and affect both the heart and lungs.

EPA’s current health-based PM 10 NAAQS was set in 1987 at a level of 150 μg/m 3 measured over 24 hours. An exceedance of the NAAQS is a daily (24-hour average) PM 10 concentration that is above the level of the standard. A violation of the NAAQS occurs when an exceedance occurs more than once per year on average over three years.

CCL is a limestone quarry operation located near Carthage, Missouri in Jasper County. The Carthage Air Quality monitoring site was establ ished in January 1999 as a State or Local Air Monitoring Station (SLAMS) site for PM 10 NAAQS compliance monitoring. The monitor is located very near CCL’s operations as shown in the aerial photograph in A ttachment 1. It is a continuous Federal Equivalent Method (FEM) PM 10 monitor that provides both hourly and 24- hour integrated PM 10 data.

The Air Program has worked with CCL to address exceedances and violations of the PM 10 NAAQS measured at the Carthage monitor datin g back to 2001. In October 2003, all parties entered into a settlement agreement containing measures for reducing CCL’s fugitive particulate matter emissions. Under the agreement, CCL was required to purchase an 8,000 gallon water truck, relocate the dust collector at the rail si te, pave entrances, implement usage of chemical surfactants, purchase a street sweep er, install wheel wash units, relocate the fine grind scale, establish a single roadway to the fi ne grind plant, and improve the grind feed transfer system, all by December 31, 2004. In addition, CCL was to implement dust collection at truck loadout points by August 2005. Activities c onducted under the agreement a ddressed the issues at the Carthage monitor for several years.

As discussed above, the PM 10 NAAQS is not met if the three- year average number of days per year that 150 μ g/m 3 was exceeded is greater than one day per year. Figure 1 shows this number of days for 1999 through 2013 based on measurements at the State’s Carthage monitoring site.3 Exceedance days shown in the figure are queried from the Environmental Protection Agency (EPA) Air Quality System (AQS) ( EPA AQS AMP488 Report, 02/25/2014 ).

The federal reference method (FRM) sampler (results shown in blue) collect ed an integrated 24- hour filter sample every third day. The every-th ird day schedule is based on requirements in 40 CFR 58.12. The total number of days that the st andard was exceeded each year was estimated based on the results from the ever y-third-day samples. These annua l results were then averaged over each three-year period.

The tapered element oscillating microbalance (TEOM) monitor (results show n in red) measured the PM 10 concentration continuously a nd reported hourly average result s. The total number of days that the standard was exceeded each year was estimated based on 24-hour block averages if the monitor did not operate every day, or the numb er of days per year that the standard was exceeded was used directly if th e sampler operated every day. These annual results were then averaged over each three-year period.

Because of the difference between the operating sche dules of the two instruments, the number of days that the standard is exceeded can be differe nt between the two instru ments, for example if relatively high PM 10 days are observed with the TEOM but missed by the FRM because of its intermittent schedule. The difference for th e 2001-2003 and 2002-2004 periods results primarily from the number of observed exceedance days in 2002 for the TEOM being higher than that for the FRM.

The significant features of the fi gure are that the standard was not met for the first four periods, was met or nearly met for the next seven periods , and then was not met for the two most recent overlapping three-year periods.4 Figure 1

*The average number of exceedance days meas ured by the TEOM for 2008-2010 is labeled as not valid in the AMP488 report, possibly because only 3 quarters of valid data were reported for 2010. However, no exceedances of the st andard were observed in 2008 through 2010.5 III. Current PM 10 NAAQS Violations

The Carthage monitor again began recording elevated PM 10 concentrations from March 2010 through January 2012. These exceedances are summ arized in the chart below along with data validity and certification status in EPA’s Air Quality System (AQS). Based on validated air quality data for the 2009-2011 period, the monitor is in violation of the PM 10 NAAQS with an estimated number of exceedances of 1.7. Pre liminary 2012 monitoring data, which has been quality-assured through June 30, 2013, indicates an estimated number of exceedances of 2.3 for the 2010-2012 period. Validated data through June 30, 2013 projects a number of expected exceedances of 2.0 for the 2011-2013 period. Assuming no additional exceedances are monitored, the site is expected to meet the PM 10 NAAQS in the 2012-2014 period with a number of expected exceedances of 0.6.

Carthage PM 10 AQS Data Validity and Certification Status as of 6/30/2013

Date 24-hour PM 10 Exceedance

(μg/m 3 ) Data Validated in AQS (Yes/No) Data Certified in AQS (Yes/No)*

3/18/2010 151 Yes Yes 6/23/2011 174 Yes Yes

9/9/2011 159 Yes Yes 9/26/2011 258 Yes Yes 11/30/2011 192 Yes Yes

1/16/2012 222 Yes Yes

*The data for calendar year 2012 is certified in the Environmental Protection Agency’s (EPA) Air Quality System (AQS) as of May 1, 2013.

IV. 2014 Consent Judgment and Vo luntary Alarm System

The Air Program initiated assistance discussions with CCL in January 2012 and conducted an on-site assistance visit on February 1, 2012. As a result of these discussions, the Air Program worked with CCL to establish a protocol to provide preliminary near-real-time ambient air monitoring data directly to CCL staff for episode analysis. Former practice for handling ambient air monitoring data was to wait until monitoring data had been validated and reported to AQS prior to reporting that an ‘official’ exceedance or violation had occurr ed, a process which can take up to 90 days after the quarter in whic h the monitoring data was collected. Recent advances in technological and management practices for handling near-real time ambient air monitoring data has improved to the point where obvious equipment malfunctions can be determined relatively quickly and evaluations ab out data validity for exceedance events can be relayed relatively quickly to stakeholders.

In response to the Air Program’s inqui ries about the causes of the recent PM 10 NAAQS violations, CCL re-evaluated their operations and emission sources and submitted a letter on6 June 8, 2012 to the Air Program proposing additional control measures. As summarized in their letter, CCL determined that excessive emissions occurred when the haulage equipment malfunctioned and the Telsmith Crusher ran shor t on processing material. The letter also indicated that a malfunctioning co mpressor for the Chip Plant, Cedar Rapids Dryer and Collector had been repaired, which was expected to reduce visible emissions from this equipment. In addition, a newly designed transi tion and bin top was expected to address excessive emissions from the Cedar Rapids Long Lime Belt Discharge. Another significant measure identified in the letter was replacing the smooth bags in the Ceda r Rapids Torrit collectorwith pleated bags expected to have better cleani ng efficiency, fewer bag failures, and a reduction in the number of start-up and shut-down operations. With these and other measures in the letter as a starting point, the Air Program and CCL worked coopera tively to develop an enforceable consent judgment for implementing controls to further reduce PM 10 emissions at the facility. CCL proactively put several of the controls in pl ace during 2012 and 2013 prior to finalization of the consent judgment (e.g., replacing smooth bags wi th pleated bags in two bag houses, the Cedar Rapids Torrit Dust Collector and the Line #1 BHA West Dust Collector).

The 2014 consent judgment being submitted to the EPA for incorporation into the Missouri SIP is in Attachment 2. The control measures incl ude the installati on of dust suppression equipment, baghouse and dust collection improvements, adjustme nts to material transi tion points, and other measures. The agreement sets specific milestone s on an expedited schedule in order to address the NAAQS violations in a timel y manner; all control measures are to be installed and operational no later than March 31, 2014. The c onsent judgment includes additional controls referred to as “contingency measures” to be impl emented immediately in the event of a future monitored PM 10 NAAQS exceedance. Within 10 days, CCL is to conduct an investigation and submit to the department a detailed report addr essing the cause and mitigation of any monitored exceedance and a plan for preventing similar ex ceedances in the future . Further specific contingency measures identified in the consent judgment include connecting additional conveyor transfer points to the dust colle ction system, enhancing the wet suppression system, and reducing the use of compressed air for cleaning certain equipment. The aerial photograph of CCL’s operations in Attachment 1 illustrates the locati ons of the controls a nd contingency measures.

As specified in section XII, the 2014 consent judg ment will terminate if CCL ceases operation of PM 10 emission units or elements in Exhibit A, Compliance Plan, are imposed in a permit or permit amendment. In the ev ent the 2014 consent judgment is terminated, the Air Program would incorporate applicable co ntingency measures into a new consent judgment or into a permit/permit amendment and submit to EPA for inclusion in the Missouri SIP.

The consent judgment also includes additi onal Emissions Inventory Questionnaire (EIQ) reporting requirements. Per 10 CSR 10-6.110, CCL is required to submit periodic emission inventory data to the Air Progr am. Upon review of their 2008 emission year report (EIQ), the Air Program determined that the nomenclature an d calculations used in the EIQ did not match those used in the issued permits and the facil ity was not using the current emission estimation equations. Because this issue was never resolv ed, the consent judgment requires Americold to submit a full EIQ for calendar year 2012 by February 1, 2014.7 In addition to installing control measures, CCL vol untarily agreed to participate in a near-realtime PM 10 concentration alarm notificati on system for monitored hourly PM 10 levels that exceed 150 μg/m 3 . The notification cons ists of an automated email to the department and CCL from the department’s data acquisition system when this hourly threshold is exce eded. Although the nearreal-time data is preliminary, the notification allo ws CCL to investigate elevated levels early to determine what emissions sources could be contri buting and to take correc tive actions, if needed, to prevent a 24-hour exceed ance. The department also posts the hourly PM 10 and on-site wind speed and wind direction data to the department ’s webpage to provide immediate information about whether or not the prevai ling winds are out of the direct ion of the facility’s emission sources. Since the inclusion of CCL into the au tomated alarm system, staff at the facility has been able to identify causes for elevated PM 10 concentrations that are likely attributable to facility emission sources and have communicated thei r findings, in detail, to the department in a timely manner. These voluntary investigations by CCL have been useful in understanding how equipment performance and best management practices may affect monitored particulate concentrations. The PM 10 concentration alarm notif ication system is stri ctly voluntary; the Air Program is not submitting requirements for CCL to participate in the alarm notification system for inclusion in the Missouri SIP.

CCL will continue to implement a ll permanent and enforceable contro l measures in place prior to the 2014 consent judgment. In particular, CCL will maintain all best management practices, including application of 100 gallons of water per day per 1,00 0 square feet of unpaved/untreated surface area, as required by Construc tion Permits 062005-013 and 062005-014. The 2013 consent judgment builds on and complements exis ting measures at the CCL facility to ensure continued compliance with the PM 10 NAAQS.

The recently implemented control measures, pl us CCL’s attentiveness to elevated hourly readings via the voluntary alarm system have resulted in a positive impact on the Carthage monitor. No exceedances have been recorded at the monitor since January 16, 2012. It is important to note that Missouri experienced se vere drought conditions during the summer and fall of 2012, which would tend to exacerbate fugitive particulate matter emissions. The fact that no exceedances of the PM 10 NAAQS occurred during these cond itions gives further support to the effectiveness of CCL’s efforts. Full implemen tation of the control meas ures outlined in the consent judgment, along with any contingency meas ures if triggered, is expected to further reduce PM 10 emissions at the facility and ensure continued maintenance of the 24-hour PM 10 NAAQS in the future.

V. Public Participation

In accordance with Section 110(a)(2) of the C AA, the Missouri Air Conservation Commission is required to hold a public hearing prior to adoption of this plan and the subsequent submittal to the EPA. The department notifies the public and othe r interested parties of an upcoming public hearing and comment period thirty (30) days prior to holding such hearing for this SIP revision as follows:8  Notice of availability of the SIP revisi on was posted on the Department of Natural Resources’ Air Pollution Control Pr ogram website on December 30, 2013: http://www.dnr.mo.gov/env/apcp /stateplanrevisions.htm

 The public hearing was held on January 30, 2014 beginning at 9:00 a.m. at the Elm Street Conference Center, in Bennett Springs C onference Room, 1730 East Elm Street, Jefferson City, MO 65101.

 The public comment period for the plan opened when it was posted on the Department of Natural Resources’ Air Pollution Control Program website on December 30, 2013, and closed on February 6, 2014, seven days after the public hearing.

VI. Conclusion

The Air Program is submitting a consent judgment with CCL for incorporation into the Missouri SIP in order to strengthen the SIP and make th ese requirements federally enforceable. The consent judgment includes a number of controls designed to reduce fugitive particulate matter emissions at this facility on an expedited schedule. CCL’s pr oactive approach, including early implementation of several control measures and part icipation in a near real-time alarm system on a voluntary basis, is already yielding positive results at the Carthage monitor, which has not measured an exceedance of the PM 10 NAAQS since January 16, 2012. The Air Program expects complete implementation of all measures in the 2014 consent judgment, along with continuation of best management practices as required by the facility’s permanent and enforceable construction permits, will ensure c ontinued compliance with the 24-hour PM 10 NAAQS.9 Attachment 1

Carthage Monitoring Site 

### AQS# 29-097-0003 530 Juniper, Carthage, MO 64836

MDNR PM 10 Monitor

Carthage Crushed Limestone Facility Telsmith & Crusher area

Haul Road to Telsmith & mine

areas

PM Control Measures as outlin ed in the Consent Judgment: 1. Wet suppression system for crushers. 2. Eliminate screen, OR, reduce free fall distance of rock & use wet suppression system. 3. Install new compressor on baghouse controlling the dryer. 4. New drop point transition to improved seal at conveyor transfer point. 5. New bin top on west lime hopper. 6. New drop point transitions to improved seals at conveyor transfer points.

Contingency PM Control Measures 1 & 2 both entail connecting additional conveyor tran sfer points to the dust collection system. PM control measures 1 & 2

PM control measures 3, 4, 5, & 6. Contingency PM control measures 1 & 22014 Consent Judgment Attachment ‐ Exempt Equipment List

MODNR ID Description
1 CRUSHER

‐ TS

‐ 01 Telsmith 4856 Horizontal Impact Crusher
2 CRUSHER

‐ TS

‐ 02 Telsmith 5263 Horizontal Impact Crusher
3 CRUSHER

‐ CR

‐ 01 El

‐ Jay RC

‐ 54 Cone Crusher
4 TORN

‐ CR

‐ 01 Tornado Vertical Shaft Impact Crusher at Cedar Rapids plant

5 TORN

‐ L1

‐ 01 Tornado Vertical Shaft Impact Crusher at Line #1
6 TORN

‐ L2

‐ 01 Tornado Vertical Shaft Impact Crusher at Line #2

MODNR ID Description
7 COLLECTOR

‐ CR

‐ 01 American Air Filter collector on the Cedar Rapids Dryer and all connected duct work.
8 COLLECTOR

‐ CR

‐ 02 American Air Filter Collector on the high frequency screen, drop points, and all connected duct work.
9 COLLECTOR

‐ CR

‐ 04 Torit collector on the Cedar Rapids Tornado and Elevator and all connected duct work.
10 COLLECTOR

‐ RM

‐ 01 BHA Collector for Roller Mill System and all connected duct work.
11 COLLECTOR

‐ L1

‐ 01 BHA Collector for Screen and Drop points on Line #2 and all connected duct work.
12 COLLECTOR

‐ L1

‐ 03 Mack Collector for Line #1 Load out tunnel and all connected duct work.
13 COLLECTOR

‐ L2

‐ 01 BHA Collector for the Retractable Rail Loadout spout and all connected duct work.
14 COLLECTOR

‐ L2

‐ 02 BHA Collector for Screen and Drop points on Line #2 and all connected duct work.
15 COLLECTOR

‐ L2

‐ 03 Mack Collector for Line #2 Load out tunnel and all connected duct work. Collectors CrushersSL01DOCS\4011219.6 Attachment 2 – Missouri State Im plementation Plan Revision 2014 Consent Judgment for Americold Logist ics, LLC for 24-Hour Particulate Matter (PM 10 ) National Ambient Air Quality Standard (NAAQS)Electronically Filed - Jasper County - Carthage - May 05, 2014 - 11:07 AM14AP-CC00036Electronically Filed - Jasper County - Carthage - May 05, 2014 - 11:07 AMElectronically Filed - Jasper County - Carthage - May 05, 2014 - 11:07 AMElectronically Filed - Jasper County - Carthage - May 05, 2014 - 11:07 AMElectronically Filed - Jasper County - Carthage - May 05, 2014 - 11:07 AMElectronically Filed - Jasper County - Carthage - May 05, 2014 - 11:07 AMElectronically Filed - Jasper County - Carthage - May 05, 2014 - 11:07 AMElectronically Filed - Jasper County - Carthage - May 05, 2014 - 11:07 AM

### The Missouri Air Conservation Commission ADOPTS 

### the following action

on this 27th day of March, 2014:

Missouri State Implementation Plan Revision

- Americold Logistics, LLC Particulate Matter (PM IO ) 

### Consent Judgement

# ~~**~~~t------,;}LJ. ~C.:::===** **== ==** **-=- ,**  Chairman ('---/

# _,c....~_---=-=::..::...~_----'L-----!Io,~""-=:::.....- ______ , Vice Chairman



### , Member

_________________ ,Member

__________________ ,Member

_________________ , MemberJay Nixon, Governor Sara Parker Pauley, Director 

## Air Pollution Control Program

State Plan Actions

On Public Notice | Proposed fo r Adoption

On Public Notice

Supplement/Revision to the Redesignation De monstration and Maintenance Plan for the Missouri Portion of the St. Louis Nonattainment Area for the 1997 Annual Fine Particulate Matter National Ambient Air Quality Standard
Based on monitoring data from 2007-2009, th e St. Louis nonattainment area achieved attainment of the 1997 annual fine particulate matter (PM2.5) national ambient air quality standard (NAAQS). In August 2011, the Missouri Air Co nservation Commission adopted the Redesignation Demonstration and Maintenance Plan for the Missouri Portion of the St. Louis Nonattainment Area for the 1997 Annual PM2.5 NAAQS. This plan was then submitted to the U.S. Environmental Protection Agency for inclusion in the Missouri State Implementation Plan. The Missouri Department of Natural Resources Air Pollution Control Program has developed a technical supplement/revision to this plan. The technical supplement/revision to this plan makes correctio ns to the emissions in ventories included in the plan, includes emissions inve ntories and a discussion on cont rols for the Illinois portion of the nonattainment area, an d changes the future year of the plan from 2022 to 2025. This technical supplement also establishes mo tor vehicle emissions bu dgets to be used in regional transportation conformity determinat ions for the base year (2008) and the future year (2025) of the plan. Through this SIP submittal, the Missouri Department of Natural Resources Air Pollution Control Program is requesting that:
EPA redesignate the Missouri Portion of the St. Louis 1997 PM2.5 nonattainment area to attainment pursuant to the provis ions of the Clean Air Act, section 107; •

Concurrently, EPA approve the associated main tenance plan as a revision to the State Implementation Plan (SIP) meeting the requ irements of the Clean Air Act, section 175A; •

That EPA approve the 2008 base year inventory as meetin g the requirements under Clean Air Action section 172(c)(3); and •

Approve the Motor Vehicle Emissions Bu dgets (MVEBs) for th e years 2008 and 2025 pursuant to Clean Air Act Section 176(c). • Pa g e 1 of 3 State Plan Actions on Public Notice - DN R

12/24/2013 htt p ://www.dnr.mo. g ov/env/a p c p /state p lanrevisions.htmProposed Supplement/Revision to the Redesignation Demonstr ation and Maintenance Plan for the Missouri Portion of the St. Louis Nonattainment Area for the 1997 Annual Fine Particulate Matter National Ambient Air Quality Standard Appendices A through L

Submit Comments
A public hearing is scheduled for th is plan action on January 30, 2014. Comments about this plan action will be accepted throug h the close of business on February 6, 2014.

Missouri State Implementation Plan Revision - Limited Main tenance Plan for the St. Louis Nonclassifiable Maintenance Area for the 8-Hour Carbon Monoxide National Ambient Air Quality Standard

The initial maintenance plan for the St. Lo uis nonclassifiable Carbon Monoxide (CO) maintenance area ensured attainment of the CO NAAQS through 2008. Pursuant to Section 175A(b) of the Clean Air Act, the State must submit a subsequent plan revision for maintaining the standard for an additional 10 year period afte r the expiration of the first maintenance period. The Air Program has developed a second maintenance plan that provides for continued attainment of the 8- hour CO NAAQS for the St. Louis area from 2008 through 2018. The plan provides assurances that, in the event of a subseq uent violation of the CO NAAQS, additional co ntrol options, called contingency measures, can quickly be implemented to prevent any future violations. In addition, this plan includes CO ambient air quality monitoring data from the last seve n years and an updated emission inventory for average winter day CO emissi ons in the St. Louis area.
Proposed Revision to Limited Maintenanc e Plan for the St. Louis Nonclassifiable Maintenance Area for the 8-Hour Carbon Mono xide National Ambient Air Quality Standard Appendices A and B

Submit Comments
A public hearing for this plan acti on will be held on Jan. 30, 2014. Comments about this plan action will be accept ed through the close of bu siness on Feb. 6, 2014.

Missouri State Implementation Plan Revision - Ameri cold Logistics, LLC 24-Hour Particulate Matter (PM10) National Ambient Air Quality St andard (NAAQS) Consent Judgment

As required by Section 110(a) of the Clean Ai r Act, Missouri’s State Implementation Plan (SIP) must ensure attainment and maintena nce of all National Ambient Air Quality Standards (NAAQS). The Missouri Department of Natura l Resources’ Air Pollution Control Program is proposing to amend and strengthen th e Missouri SIP to address violations of the 24-hour coarse particulate matter (PM10) NAAQS of 150 micrograms per cubic meter (μg/m3) near the Americold Logistics, LLC’s Carthage Crushed Limestone (CCL) facility. The SIP revision consists of a consent judgment with CCL for measures intended to reduce PM10 emissions at the facility, all of which ar e scheduled for installa tion and operation by March 31, 2014. Pa g e 2 of 3 State Plan Actions on Public Notice - DN R

12/24/2013 htt p ://www.dnr.mo. g ov/env/a p c p /state p lanrevisions.htmProposed CCL PM10 SIP Revision Attachment 2 – Proposed CCL Consent Judgment Exempt Equipment List

Submit Comments
A public hearing for this plan acti on will be held on Jan. 30, 2014. Comments about this plan action will be accept ed through the close of bu siness on Feb. 6, 2014.

Proposed for Adoption

None at this time.
Back to top Pa g e 3 of 3 State Plan Actions on Public Notice - DN R

12/24/2013 htt p ://www.dnr.mo. g ov/env/a p c p /state p lanrevisions.htm1 Bechtel, Cheri

From: Missouri DNR <MODNR@public.govdelivery.com> Sent: Tuesday, December 24, 2013 8:33 AM To: Bungart, Renee; Archer, Larry; Beydler, Van; Lovejoy, Victoria; Moore, Kyra; Vit, Wendy; Bechtel, Cheri; Crawford, Betsy Subject: Courtesy Copy: Missouri DNR Air Public No tices Update - Missouri Air Conservation Commission Public Hearing, Jan. 30, 2014

This is a courtesy copy of an em ail bulletin sent by Cheri Bechtel.

This bulletin was sent to the following groups of people:

Subscribers of Air Public Notices (535 recipients)

Having trouble viewing this email? View it as a Web page

.

MISSOURI AIR CONSER VATION COMMISSION WILL HOLD PUBLIC HEARING
JEFFERSON CITY, MO -- The Missouri Air Conser vation Commission will hol d a public hearing on Thursday, January 30, 2014 beginning at 9 a.m. at th e Elm Street Conference Ce nter, 1730 East Elm Street, Lower Level, Bennett Springs Conference Room, Jefferson City, Missouri. The commission will hear testimony related to the fo llowing proposed action(s):
* 10 CSR 10-6.200 (amendment) Hospit al, Medical, Infectious Waste Incinerators

This proposed amendment will remove language from the compliance and performance testing provisions that provide an exemption to the emission limits for hospital, medical, and infectious waste incinerators (HMIWI) during star t-up, shutdown, or malfunction conditions. In addition, the hierarchy of definitions will clearly state that the applicable definitions in the Code of Federal Regulations take precedence over those in 10 CSR 10-6.020 Definitions and Common Reference Tables. At the same time, EPA test method references in the state rule will be revised to match how these methods are referred to in the federal HMIWI regulations.

The above rule action will not be submitted for incl usion in the Missouri State Implementation Plan but will be submitted for inclusion in the plan established under Clean Air Act Section 111(d) covering existing sources of noncriteria pollutants.

* 10 CSR 10-5.240 (rescission) Additional Air Quality Control Measur es May be Required When Sources Are Clustered in a Small Land Area2 This proposed rescission will remove an outdated ru le originally written in 1967, prior to the federal Clean Air Act. This rule was intended to pr ovide the Missouri Air Conservation Commission authority to regulate particulate ma tter and sulfur dioxide emissions from concentrated sources in the St. Louis area. Given that section 643.050, RSMo pr ovides the commission au thority to promulgate regulations necessary to enforce th e provisions of the Clean Air Act, this rule is no longer necessary.

The above rule action will be submitted to the U. S. Environmental Protection Agency for removal from the Missouri State Implementation Plan.

* 10 CSR 10-6.010 (amend ment) Ambient Air Quality Standards

This proposed amendment will update the standard s for ambient air quality throughout Missouri in order to reflect recent changes in the National Ambient Air Qua lity Standards (NAAQS) for fine particulate matter (PM 2.5 ), nitrogen dioxide (NO 2 ), and sulfur dioxide (SO 2 ); reorganize the standards table for clarity; and update the rule purpose statemen t to more accurately reflect the rule. The Clean Air Act requires periodic reviews of the air quality criteria, th e science upon which the standards are based, and the NAAQS themselves. As a result of fe deral review, the U.S. Environmental Protection Agency has recently updated the PM 2.5 , NO 2 , and SO 2 NAAQS, and this rulemaking would revise these values in the state rule for consistency.

* Missouri State Implementation Plan Revision – Supplement/Revision to the Redesignation Demonstration and Maintenance Plan for the Missour i Portion of the St. L ouis Nonattainment Area for the 1997 Annual Fine Particulate Matter National Ambient Air Quality Standard

In August 2011, the Missouri Air Conserva tion Commission adopted the Redesignation Demonstration and Maintenance Plan for the Missour i Portion of the St. L ouis Nonattainment Area for the 1997 Annual Fine Particulate Matter Nationa l Ambient Air Quality Standard. This plan was then submitted to the U.S. Environmental Prot ection Agency on August 26, 2011 for inclusion in the Missouri State Implementation Plan. The Missouri Department of Natural Resources Air Pollution Control Program has developed a technical supp lement/revision to this plan. The technical supplement/revision to this plan ma kes corrections to the emissions inventories in cluded in the plan, includes emissions inventories and a discussion on controls for the Illinois portion of the nonattainment area, and changes the future year of the plan from 2022 to 2025. This technical supplement also establishes motor vehicle emissions budgets to be used in regional transportation conformity determinations for the base year ( 2008) and the future year (2025) of the plan.

* Missouri State Implementation Plan Revisi on – Americold Logistics, LLC 24-Hour Particulate Matter (PM 10 ) National Ambient Air Quality Sta ndard (NAAQS) Consent Judgment

As required by Section 110(a) of the Clean Air Act, Missouri’s Stat e Implementation Plan (SIP) must ensure attainment and maintenance of all Nationa l Ambient Air Quality Standards (NAAQS). The Missouri Department of Natural Resources’ Air Pollution Control Pr ogram is proposing to amend and strengthen the Missouri SIP to address violatio ns of the 24-hour coarse particulate matter (PM 10 ) NAAQS of 150 micrograms per cubic meter (μg/m 3 ) near the Americold Logistics, LLC’s Carthage Crushed Limestone (CCL) facility. The SIP revision consists of a consent judgment with CCL for measures intended to reduce PM 10 emissions at the facility, all of which are scheduled for installation and operation by March 31, 2014.

* Missouri State Implementation Plan Revision – Limited Maintenance Plan For The St. Louis Nonclassifiable Maintenance Area For The 8-Hour Carbon Monoxide National Ambient Air Quality Standard (NAAQS)3 The initial maintenance plan for the St. Louis nonclassifiable Carbon M onoxide (CO) maintenance area ensured attainment of the CO NAAQS thr ough 2008. Pursuant to Section 175A(b) of the Clean Air Act, the State must submit a subsequent plan revision for maintaining the standard for an additional 10 year period after the expiration of the first maintenance period. The Air Program has developed a second maintenance plan that provide s for continued attainment of the 8-hour CO NAAQS for the St. Louis area fr om 2008 through 2018. The plan provi des assurances that, in the event of a subsequent violation of the CO NAAQS, additional c ontrol options, called contingency measures, can quickly be implemented to prevent any future violations. In addi tion, this plan includes CO ambient air quality monitoring data from the la st seven years and an updated emission inventory for average winter day CO emi ssions in the St. Louis area.

If the Commission adopts these action(s ), it will be the Department’s intention to submit the action(s) to the U.S. Environmental Protection Agency to be incl uded in Missouri’s State Implementation Plan unless otherwise noted above.

Documents for the above item(s) will be available for review at the Missour i Department of Natural Resources, Air Pollution Control Progr am, 1659 Elm Street, Jefferson City, (573) 751-4817 and in the Public Notices section of the program web site http://dnr.mo.gov/env/apcp/publicnotices.htm. This information will be available at least 30 days prior to the public hearing date.
The Department will accept written or email comments for the record until 5 p.m. on February 6, 2014. Please send written comments to Chief, Air Quality Planning Section, Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102-0176. Email comments may be submitted via the program web site noted above. All written and email comments and public hear ing testimony will be equally considered.

Citizens wishing to speak at the public hearing should notify the secretary to th e Missouri Air Conservation Commission, Missouri Department of Natural Resour ces, Air Pollution Control Program, P.O. Box 176, Jefferson City, Missouri 65102-0176, or telephone ( 573) 526-3420. The Department requests persons intending to give verbal presenta tions also provide a wr itten copy of their testimony to the commission secretary at the time of the public hearing.

Persons with disabilities requiring special services or accommodations to attend the meeting can make arrangements by calling the Program di rectly at (573) 751-4817, the Divisi on of Environmental Quality's toll free number at (800) 361-4827, or by writing two weeks in advance of the meeting to: Missouri Department of Natural Resources, Air Conservation Commissi on Secretary, P.O. Box 176, Jefferson City, MO 65102. Hearing impaired persons may contact the program through Relay Missouri, (800) 735-2966.

You are subscribed to the Air Publ ic Notices topic for Missouri DNR. Th is information has recently been updated, and is now available at the link below. Tha nk you for your interest in the Air Public Notices.

http://dnr.mo.gov/env/apcp/stateplanrevisions.htm

Update your subscriptions, modify your password or email address, or st op subscriptions at any time on your Subscriber Preferences Page . You will need to use your email addre ss to log in. If you have questions or
p roblems with the subscription service, please contact subscriberhelp.govdelivery.com

.4 This service is provide d to you at no charge by Missouri DNR

.HEARING 1/30/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334 MIDWEST LITIGATION SERVICES Page 1

1

MISSOURI DEPARTMENT OF NATURAL RESOURCES'

2 AIR CONSERVATION COMMISSION MEETING

3 PUBLIC HEARING

THURSDAY, JANUARY 30, 2013

4

5

REPORTED BY SUSAN M. FIALA

6 CERTIFIED COURT REPORTER

REGISTERED PROFESSIONAL REPORTER

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25HEARING 1/30/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334 MIDWEST LITIGATION SERVICES Page 3

1 PROCEEDINGS

2 CHAIRMAN PENDERGRASS: The hearing will

3 come to order. Let the record show the

4 following Commissioners are present: Jack

5 Baker, Mark Garnett, Gary Pendergrass, and David

6 Zimmerman.

7 The Air Conservation Commission of the

8 State Of Missouri has called this public hearing

9 pursuant to Section 643.070, Revised Statutes of

10 Missouri; EPA promulgated rule 40 CFR 51.102,

11 for the purpose of hearing testimony related to:

12 Missouri State Implementation Plan

13 Revision - Supplement/Revision to the

14 Redesignation Demonstration and Maintenance Plan

15 for the Missouri Portion of the St. Louis

16 Nonattainment Area for the 1997 Annual Fine

17 Particulate Matter National Ambient Air Quality

18 Standard.

19 Missouri State Implementation Plan

20 Revision - Americold Logistics, LLC Particulate

21 Matter (PM10) Consent Judgment.

22 Missouri State Implementation Plan

23 Revision - Limited Maintenance Plan for the St.

24 Louis Nonclassifiable Maintenance Area for the

25 8-hour Carbon Monoxide National Ambient AirHEARING 1/30/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334 MIDWEST LITIGATION SERVICES Page 13
1 next item is Missouri State Implementation Plan

2 Revision - Americold Logistics, LLC Particulate

3 Matter Consent Judgment.

4 Wendy Vit.

5 WENDY VIT,

6 being first duly sworn to tell the truth, the

7 whole truth and nothing but the truth deposes

8 and says as follows:

9 MS. VIT: Chairman, members of the

10 Commission, my name is Wendy Vit. I am employed

11 with the Air Pollution Control Program as Air

12 Quality Planning Section Chief. I work at 1659

13 East Elm Street, Jefferson City, Missouri, and

14 I'm here today to present testimony on a

15 Missouri State Implementation Plan, or SIP,

16 revision consisting of a consent judgment with

17 Americold Logistics, LLC. The information can

18 be found starting on Page 99 of your briefing

19 document.

20 As required by Section 110(a) of the

21 Clean Air Act, Missouri's SIP must ensure

22 attainment and maintenance of all National

23 Ambient Air Quality Standards, or NAAQS. The

24 Missouri Department of Natural Resources' Air

25 Pollution Control Program is proposing to amend1 RECOMMENDATION FOR ADOPTION ON

PROPOSED REVISION TO

MISSOURI STATE IMPLEMENTATION PLAN — AMERICOLD LOGISTICS, LLC 24-HOUR PARTICULATE MATTER (PM 10 ) NATIONAL AMBIENT AIR QU ALITY STANDARD (NAAQS) CONSENT JUDGMENT

As required by Section 110(a) of the Clean Air Act, Missouri’s State Implementation Plan (SIP) must ensure attainment and maintenance of all National Ambient Air Quality Standards (NAAQS). The Missouri Department of Natura l Resources’ Air Pollution Control Program is strengthening the Missouri SIP to address viol ations of the 24-hour coarse particulate matter (PM 10 ) NAAQS of 150 micrograms per cubic meter (μg/m 3 ) near the Americold Logistics’ Carthage Crushed Limestone (CCL) facility. The SIP revision consists of a consent judgment with CCL for measures intended to reduce PM 10 emissions at the faci lity, all of which are scheduled for installation and operation by March 31, 2014.

A summary of comments received and the Air Program’s corresponding responses is included on the following page. Revisions were made to the pr oposed plan as a result of comments received.

The revised plan has not been reprinted in the briefing document due to its volume. The entire revised plan is available for review at the Missouri Departme nt of Natural Resources’ Air Pollution Control Program, 1659 East Elm St reet, Jefferson City, Missouri, 65101, (573)751- 4817. It is also available online at http ://dnr.mo.gov/env/apcp/stateplanrevisions.htm.

The Air Program recommends the commission adopt the plan as revised. If the commission adopts this plan, it will be the department’s inten tion to submit this plan to EPA for inclusion in the Missouri State Implementation Plan.COMMENTS AND RESPONSES ON

PROPOSED REVISION TO

MISSOURI STATE IMPLEMENTATION PLAN — AMERICOLD LOGISTICS, LLC 24-HOUR PARTICULATE MATTER (PM 10 ) NATIONAL AMBIENT AIR QU ALITY STANDARD (NAAQS) CONSENT JUDGMENT

The public comment period for the proposed revisi on to the Missouri State Implementation Plan (SIP) entitled Americold Logistics, LLC 24-Hour Particulate Matter (PM 10 ) National Ambient Air Quality Standard (NAAQS) Consent Judgment opened on December 30, 2013 and closed on February 6, 2014. Revisions to the proposed pl an were made as a result of comments.

The following is a summary of comments recei ved and the Missouri Department of Natural Resources’ Air Pollution Control Program’s (A ir Program’s) corresponding responses. Any changes to the proposed plan are incl uded in the response to comments.

SUMMARY OF COMMENTS: Duri ng the public comment period for the proposed plan, the Air Program received four comments from two s ources: one comment from an attorney with Bryan Cave LLP and three comments from the U.S. Environmental Protection Agency (EPA).

COMMENT #1: The attorney with Bryan Ca ve LLP commented on behalf of Americold Logistics. He suggested revisi ons to item 2 in the list of requ ired particulate matter control measures in Exhibit A, Compliance Plan, of the consent judgment in order to clarify that the Americold’s Carthage Crushed Li mestone (CCL) facility has eliminated the use of the Tyler

screen. RESPONSE AND EXPLANATION OF CHANGE: As a result of this comment, the Air Program revised item 2 in Exhibit A, Complianc e Plan, of the consent judgment as suggested.

COMMENT #2: EPA suggested adding monitori ng data dating back to 2004, as well as a discussion about monitoring data trends, to Section II. of the main SIP document. RESPONSE AND EXPLANATION OF CHANGE: As a result of this comment, the Air Program added Figure 1 to illustrate the PM 10 monitoring data trends dating back to 1999 along with discussion of the trends in the main SIP document.

COMMENT #3: EPA suggested adding to Section IV. of the SIP document a reference to the date that the Air Program originally contacted CCL regarding the most recent violation of the PM 10 NAAQS. RESPONSE AND EXPLANATION OF CHANGE: As a result of this comment, the Air Program clarified in Section IV. of the main SI P document when CCL was originally contacted regarding the most recent PM 10 NAAQS violation.COMMENT #4: EPA requested clar ification on what happens to the contingency measures in the consent judgment if the j udgment is terminated per paragraph 20. Specifically, EPA asked if the contingency measures would be in corporated into a permit or SIP. RESPONSE AND EXPLANATION OF CHANGE: In the event the consent judgment is terminated based on the conditions in paragraph 20, the intention is to incorporate applicable contingency measures into a new consent judgm ent or permit/permit amendment and submit to EPA for approval into the SIP. The Air Program has added language to the main SIP document to clarify this.