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 ofthe 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 (PM10) 

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, Missouri

 
2 

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 Natural Resources’ Air Pollution Control Program is 

amending and strengthening the 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 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 nitrates and sulfates), organic chemicals, and soil 

or dust particles. Coarse particles (coarse fraction of PM10) are inhalable and are between 2.5 

and 10 micrometers in diameter. Common PM10 emission sources include windblown dust; dust 

from roadways; agricultural tilling; construction activities; and crushing, quarrying, and grinding 

operations. PM10 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 PM10 NAAQS was set in 1987 at a level of 150 μg/m3 measured 

over 24 hours. An exceedance of the NAAQS is a daily (24-hour average) PM10 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 established in January 1999 as a State or Local Air 

Monitoring Station (SLAMS) site for PM10 NAAQS compliance monitoring. The monitor is 

located very near CCL’s operations as shown in the aerial photograph in Attachment 1. It is a 

continuous Federal Equivalent Method (FEM) PM10 monitor that provides both hourly and 24-

hour integrated PM10 data. 

The Air Program has worked with CCL to address exceedances and violations of the PM10

NAAQS measured at the Carthage monitor dating 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 site, pave entrances, implement usage of chemical 

surfactants, purchase a street sweeper, install wheel wash units, relocate the fine grind scale, 

establish a single roadway to the fine 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 conducted under the agreement addressed the issues at the 

Carthage monitor for several years. 

As discussed above, the PM10 NAAQS is not met if the three-year average number of days per 

year that 150 μg/m3

 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) collected an integrated 24-

hour filter sample every third day. The every-third day schedule is based on requirements in 40 

CFR 58.12. The total number of days that the standard was exceeded each year was estimated 

based on the results from the every-third-day samples. These annual results were then averaged 

over each three-year period. 

The tapered element oscillating microbalance (TEOM) monitor (results shown in red) measured 

the PM10 concentration continuously and reported hourly average results. 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 number of days per year that the standard was 

exceeded was used directly if the sampler operated every day. These annual results were then 

averaged over each three-year period. 

Because of the difference between the operating schedules of the two instruments, the number of 

days that the standard is exceeded can be different between the two instruments, for example if 

relatively high PM10 days are observed with the TEOM but missed by the FRM because of its 

intermittent schedule. The difference for the 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 figure 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 measured 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 standard were observed in 2008 through 2010. 

 
5 

III. Current PM10 NAAQS Violations 

The Carthage monitor again began recording elevated PM10 concentrations from March 2010 

through January 2012. These exceedances are summarized 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 PM10 NAAQS with an 

estimated number of exceedances of 1.7. Preliminary 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 PM10 NAAQS in the 2012-2014 period with a number 

of expected exceedances of 0.6. 

Carthage PM10 AQS Data Validity and Certification Status 

as of 6/30/2013 

Date 

24-hour 

PM10

Exceedance 

(μg/m3

) 

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 Voluntary 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 occurred, a process which can 

take up to 90 days after the quarter in which 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 about data validity for exceedance events can be 

relayed relatively quickly to stakeholders. 

In response to the Air Program’s inquiries about the causes of the recent PM10 NAAQS 

violations, CCL re-evaluated their operations and emission sources and submitted a letter on 
6 

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 short on processing material. The letter also 

indicated that a malfunctioning compressor 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 transition 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 Cedar Rapids Torrit collector with pleated bags 

expected to have better cleaning 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 cooperatively to develop an enforceable consent 

judgment for implementing controls to further reduce PM10 emissions at the facility. CCL 

proactively put several of the controls in place during 2012 and 2013 prior to finalization of the 

consent judgment (e.g., replacing smooth bags with 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 include the installation of dust suppression equipment, 

baghouse and dust collection improvements, adjustments to material transition points, and other 

measures. The agreement sets specific milestones on an expedited schedule in order to address 

the NAAQS violations in a timely manner; all control measures are to be installed and 

operational no later than March 31, 2014. The consent judgment includes additional controls 

referred to as “contingency measures” to be implemented immediately in the event of a future 

monitored PM10 NAAQS exceedance. Within 10 days, CCL is to conduct an investigation and 

submit to the department a detailed report addressing the cause and mitigation of any monitored 

exceedance and a plan for preventing similar exceedances in the future. Further specific 

contingency measures identified in the consent judgment include connecting additional conveyor 

transfer points to the dust collection 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 locations of the controls and contingency measures. 

As specified in section XII, the 2014 consent judgment will terminate if CCL ceases operation of 

PM10 emission units or elements in Exhibit A, Compliance Plan, are imposed in a permit or 

permit amendment. In the event the 2014 consent judgment is terminated, the Air Program 

would incorporate applicable contingency 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 additional Emissions Inventory Questionnaire (EIQ) 

reporting requirements. Per 10 CSR 10-6.110, CCL is required to submit periodic emission 

inventory data to the Air Program. Upon review of their 2008 emission year report (EIQ), the 

Air Program determined that the nomenclature and calculations used in the EIQ did not match 

those used in the issued permits and the facility was not using the current emission estimation 

equations. Because this issue was never resolved, 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 voluntarily agreed to participate in a near-realtime PM10 concentration alarm notification system for monitored hourly PM10 levels that exceed 

150 μg/m3. The notification consists of an automated email to the department and CCL from the 

department’s data acquisition system when this hourly threshold is exceeded. Although the nearreal-time data is preliminary, the notification allows CCL to investigate elevated levels early to 

determine what emissions sources could be contributing and to take corrective actions, if needed, 

to prevent a 24-hour exceedance. The department also posts the hourly PM10 and on-site wind 

speed and wind direction data to the department’s webpage to provide immediate information 

about whether or not the prevailing winds are out of the direction of the facility’s emission 

sources. Since the inclusion of CCL into the automated alarm system, staff at the facility has 

been able to identify causes for elevated PM10 concentrations that are likely attributable to 

facility emission sources and have communicated their 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 PM10 concentration alarm notification system is strictly 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 all permanent and enforceable control 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 1,000 square feet of unpaved/untreated 

surface area, as required by Construction Permits 062005-013 and 062005-014. The 2013 

consent judgment builds on and complements existing measures at the CCL facility to ensure 

continued compliance with the PM10 NAAQS. 

The recently implemented control measures, plus 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 severe 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 PM10 NAAQS occurred during these conditions gives further support to 

the effectiveness of CCL’s efforts. Full implementation of the control measures outlined in the 

consent judgment, along with any contingency measures if triggered, is expected to further 

reduce PM10 emissions at the facility and ensure continued maintenance of the 24-hour PM10

NAAQS in the future. 

V. Public Participation 

In accordance with Section 110(a)(2) of the CAA, 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 other 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 revision was posted on the Department of Natural 

Resources’ Air Pollution Control Program 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 Conference 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 these 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 proactive approach, including early 

implementation of several control measures and participation 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 PM10 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 continued compliance with the 24-hour PM10 NAAQS. 

 
9 

Attachment 1 

Carthage Monitoring Site AQS# 29-097-0003 

530 Juniper, Carthage, MO 64836

MDNR 

PM10 Monitor 

Carthage 

Crushed 

Limestone 

Facility 

Telsmith & 

Crusher area 

Haul 

Road to 

Telsmith 

& mine 

areas 

PM Control Measures as outlined 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 transfer points to the dust collection system. 

PM control 

measures 1 & 2 

PM control measures 

3, 4, 5, & 6. 

Contingency PM 

control measures 1 

& 2 
2014 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

Crushers
SL01DOCS\4011219.6 

Attachment 2 – Missouri State Implementation Plan Revision 

2014 Consent Judgment for Americold Logistics, LLC for 24-Hour Particulate Matter 

(PM10) National Ambient Air Quality Standard (NAAQS) 
rthage - May 05, 2014 - 11:07 AM 
rthage - May 05, 2014 - 11:07 AM
rthage - May 05, 2014 - 11:07 AM
rthage - May 05, 2014 - 11:07 AM
rthage - May 05, 2014 - 11:07 AM
rthage - May 05, 2014 - 11:07 AM
rthage - May 05, 2014 - 11:07 AM
rthage - 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 (PMIO) Consent Judgement 

~~~~~t------,;}LJ.~C.:::======= -=- , Chairman 

('---/ 

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

, Member 


_________________,Member 

__________________,Member 

_________________, Member 
Jay Nixon, Governor 

Sara Parker Pauley, Director

Air Pollution Control Program

State Plan Actions                                                                    

On Public Notice | Proposed for Adoption

On Public Notice 

Supplement/Revision to the Redesignation Demonstration 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, the 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 Conservation 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 corrections to the emissions inventories included 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. 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 provisions of the Clean Air Act, section 107;

•

Concurrently, EPA approve the associated maintenance plan as a revision to the State 

Implementation Plan (SIP) meeting the requirements of the Clean Air Act, section 

175A;

•

That EPA approve the 2008 base year inventory as meeting the requirements under 

Clean Air Action section 172(c)(3); and

•

Approve the Motor Vehicle Emissions Budgets (MVEBs) for the years 2008 and 2025 

pursuant to Clean Air Act Section 176(c).

•

State Plan Actions on Public Notice - DNR Page 1 of 3

http://www.dnr.mo.gov/env/apcp/stateplanrevisions.htm 12/24/2013
Proposed Supplement/Revision to the Redesignation Demonstration 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 this plan action on January 30, 2014. Comments about 

this plan action will be accepted through the close of business on February 6, 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

The initial maintenance plan for the St. Louis 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 after 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 subsequent violation of 

the CO NAAQS, additional control 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 seven years and an updated emission inventory for 

average winter day CO emissions in the St. Louis area.   

Proposed Revision to Limited Maintenance Plan for the St. Louis Nonclassifiable 

Maintenance Area for the 8-Hour Carbon Monoxide National Ambient Air Quality Standard

Appendices A and B

Submit Comments

A public hearing for this plan action will be held on Jan. 30, 2014. Comments about this 

plan action will be accepted through the close of business on Feb. 6, 2014. 

Missouri State Implementation Plan Revision - Americold Logistics, LLC 24-Hour Particulate Matter (PM10) 

National Ambient Air Quality 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 Natural Resources’ Air Pollution Control 

Program is proposing to amend and strengthen the 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 are scheduled for installation and operation by 

March 31, 2014. 

State Plan Actions on Public Notice - DNR Page 2 of 3

http://www.dnr.mo.gov/env/apcp/stateplanrevisions.htm 12/24/2013
Proposed CCL PM10 SIP Revision 

Attachment 2 – Proposed CCL Consent Judgment 

Exempt Equipment List

Submit Comments

A public hearing for this plan action will be held on Jan. 30, 2014. Comments about this 

plan action will be accepted through the close of business on Feb. 6, 2014. 

Proposed for Adoption

None at this time. 

Back to top

State Plan Actions on Public Notice - DNR Page 3 of 3

http://www.dnr.mo.gov/env/apcp/stateplanrevisions.htm 12/24/2013
1

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 Notices Update - Missouri Air Conservation 

Commission Public Hearing, Jan. 30, 2014

This is a courtesy copy of an email 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 CONSERVATION COMMISSION 

WILL HOLD PUBLIC HEARING 

JEFFERSON CITY, MO -- The Missouri Air Conservation Commission will hold a public hearing on 

Thursday, January 30, 2014 beginning at 9 a.m. at the Elm Street Conference Center, 1730 East Elm Street, 

Lower Level, Bennett Springs Conference Room, Jefferson City, Missouri. The commission will hear 

testimony related to the following proposed action(s): 

* 10 CSR 10-6.200 (amendment) Hospital, 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 start-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 inclusion 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 Measures May be Required When 

Sources Are Clustered in a Small Land Area 

 
2

This proposed rescission will remove an outdated rule originally written in 1967, prior to the federal 

Clean Air Act. This rule was intended to provide the Missouri Air Conservation Commission 

authority to regulate particulate matter and sulfur dioxide emissions from concentrated sources in the 

St. Louis area. Given that section 643.050, RSMo provides the commission authority to promulgate 

regulations necessary to enforce the 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 (amendment) Ambient Air Quality Standards 

 

This proposed amendment will update the standards for ambient air quality throughout Missouri in 

order to reflect recent changes in the National Ambient Air Quality Standards (NAAQS) for fine 

particulate matter (PM2.5), nitrogen dioxide (NO2), and sulfur dioxide (SO2); reorganize the standards 

table for clarity; and update the rule purpose statement to more accurately reflect the rule. The Clean 

Air Act requires periodic reviews of the air quality criteria, the science upon which the standards are 

based, and the NAAQS themselves. As a result of federal review, the U.S. Environmental Protection 

Agency has recently updated the PM2.5, NO2, and SO2 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 Missouri Portion of the St. Louis Nonattainment Area 

for the 1997 Annual Fine Particulate Matter National Ambient Air Quality Standard 

 

In August 2011, the Missouri Air Conservation Commission adopted the Redesignation 

Demonstration 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. This plan was 

then submitted to the U.S. Environmental Protection 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 supplement/revision to this plan. The technical 

supplement/revision to this plan makes corrections to the emissions inventories included 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 Revision – Americold Logistics, LLC 24-Hour Particulate Matter 

(PM10) National Ambient Air Quality 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 Natural Resources’ Air Pollution Control Program is proposing to amend and 

strengthen the 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 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 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 after 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 subsequent violation of the CO NAAQS, additional control 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 seven years and an updated emission inventory 

for average winter day CO emissions 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 included in Missouri’s State Implementation Plan unless 

otherwise noted above. 

 

Documents for the above item(s) will be available for review at the Missouri Department of Natural 

Resources, Air Pollution Control Program, 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 hearing testimony will be equally considered. 

 

Citizens wishing to speak at the public hearing should notify the secretary to the Missouri Air Conservation 

Commission, Missouri Department of Natural Resources, 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 presentations also provide a written 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 directly at (573) 751-4817, the Division 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 Commission 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 Public Notices topic for Missouri DNR. This information has recently been 

updated, and is now available at the link below. Thank 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 stop subscriptions at any time on your 

Subscriber Preferences Page. You will need to use your email address to log in. If you have questions or 

problems with the subscription service, please contact subscriberhelp.govdelivery.com. 
4

This service is provided to you at no charge by Missouri DNR. 
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MISSOURI DEPARTMENT OF NATURAL RESOURCES'

2 AIR CONSERVATION COMMISSION MEETING

3 PUBLIC HEARING

 THURSDAY, JANUARY 30, 2013

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 REPORTED BY SUSAN M. FIALA

6 CERTIFIED COURT REPORTER

 REGISTERED PROFESSIONAL REPORTER

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MIDWEST LITIGATION SERVICES

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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 Air
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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 amend
1

RECOMMENDATION FOR ADOPTION ON 

PROPOSED REVISION TO 

MISSOURI STATE IMPLEMENTATION PLAN — 

AMERICOLD LOGISTICS, LLC 

24-HOUR PARTICULATE MATTER (PM10) 

NATIONAL AMBIENT AIR QUALITY 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 Natural Resources’ Air Pollution Control Program is 

strengthening the 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’ 

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 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 proposed 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 Department of Natural Resources’ Air 

Pollution Control Program, 1659 East Elm Street, 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 intention 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 (PM10) 

NATIONAL AMBIENT AIR QUALITY STANDARD (NAAQS) 

CONSENT JUDGMENT 

The public comment period for the proposed revision to the Missouri State Implementation Plan 

(SIP) entitled Americold Logistics, LLC 24-Hour Particulate Matter (PM10) National Ambient 

Air Quality Standard (NAAQS) Consent Judgment opened on December 30, 2013 and closed on 

February 6, 2014. Revisions to the proposed plan were made as a result of comments.

The following is a summary of comments received and the Missouri Department of Natural 

Resources’ Air Pollution Control Program’s (Air Program’s) corresponding responses. Any 

changes to the proposed plan are included in the response to comments. 

SUMMARY OF COMMENTS: During the public comment period for the proposed plan, the 

Air Program received four comments from two sources: 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 Cave LLP commented on behalf of Americold 

Logistics. He suggested revisions to item 2 in the list of required particulate matter control 

measures in Exhibit A, Compliance Plan, of the consent judgment in order to clarify that the 

Americold’s Carthage Crushed Limestone (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, Compliance Plan, of the consent judgment as suggested. 

COMMENT #2: EPA suggested adding monitoring 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 PM10 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 

PM10 NAAQS. 

RESPONSE AND EXPLANATION OF CHANGE: As a result of this comment, the Air 

Program clarified in Section IV. of the main SIP document when CCL was originally contacted 

regarding the most recent PM10 NAAQS violation. 
COMMENT #4: EPA requested clarification on what happens to the contingency measures in 

the consent judgment if the judgment is terminated per paragraph 20. Specifically, EPA asked if 

the contingency measures would be incorporated 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 judgment 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.