## Minnesota Pollution Control Agency

520 Lafayette Road North I St. Paul, MN 55155-4194 I 651-296-6300 I 800-657-3864 I 651-282-5332 TTY I www.pca.state.mn.us

Mr. Bharat Mathur Acting Regional Administrator (AR-19J) U.S. Environmental Protection Agency Region V 77 West Jackson Boulevard Chicago, Illinois 60604

RE: Proposed Amendments to Minnesota's State Implementation Plan (SIP) for Particulate Matter

Dear Mr. Mathur:

The Minnesota Pollution Control Agency (MPCA) hereby submits to the U.S. Environmental Protection Agency (EPA) a revision request for Minnesota's state implementation plan (SIP) for the Childs Road area of Ramsey County. This area was previously in nonattainment with the National Ambient Air Quality Standards (NAAQS) for Particulate Matter less than 10 microns (PM 10).

The facility at 1177 Childs Road, previously owned and operated by J.L. Shiely Company, was found to be a culpable source in the area's non-attainment of the PMIO NAAQS. As J.L. Shiely, the facility was issued an Administrative Order (Amended Findings and Order) to control PMIO emissions on August 25, 1992. The Order has been subsequently amended; the most recent SIP action was approval of Amendment Three, signed on February 21, 1995, and approved into the SIP on April 3, 1998 (63 FR 16435).

Since that submittal, the facility has changed ownership; it is now owned by Aggregate Industries. In addition, the facility has made minor changes to some emission units. No major changes have been made at the facility.

The MPCA has issued Air Emission Permit No. 12300007-002 as a joint Title VFESOP document, containing all the applicable requirements for the source to ensure that the area will continue to maintain the NAAQS.

The MPCA hereby submits Air Emission Permit No. 12300007-002 as a joint document and requests that those conditions labeled "Title I Condition: SIP for PM 1 0" replace the Administrative Order as the SIP enforceable document. This submittal includes a copy of the
new permit and a revocation of the Administrative Order, along with other supporting documents. MPCA did not receive any comments on the SIP revision or permit, or any requests for a public meeting.

St. Paul I Brainerd I Detroit Lakes I Duluth I Mankato I Marshall I Rochester I WillmarMr. Bharat Mathur Page 2

Please contact Catherine Neuschler, of our staff, at 651-757-2607, if you have any questions regarding this submittal.
Sincerely,

# ?J-~~ Paul Eger Commissioner

PE/CN:ale1 Background Information for SIP Revision Aggregate Industries – Yard A Fa cility, Saint Paul, Minnesota
This document provides background information on the submittal of Air Emission Permit No. 12300007-002 as the State Implementation Plan (SIP) enforceable document for the Aggregate Industries – Yard A Facility (Aggregate) at 1177 Childs Road in Saint Paul, Ramsey County, Minnesota.
The facility is an aggregate di stribution and storage facility. It receives aggregate by barge, unloads it, and conveys it to one of several storage piles based on size and material type. The aggregate is stored until it is loaded to truck fo r off-site transport. The facility operates a natural gas-fired aggregate heater that is used between November and April to reduce moisture content and make some materials more easily conveyed. Th e primary emissions from the facility are PM and PM 10 from the process equipment, as well as fugitive emissions from the stockpiles and unpaved roads.

This facility was previously owned and operated by J.L. Shiely Company, and was found to be a culpable source in the Childs Road area’s non-attainment of the PM 10 National Ambient Air Quality Standards (NAAQS). As J.L. Shiely, th e facility was issued an Administrative Order (Amended Findings and Order) to control PM 10 emissions on August 25, 1992. The Order has been subsequently amended; the most recent SIP action was approval of Amendment Three, signed on February 21, 1995 and approved in to the SIP on April 3, 1998 (63 FR 16435).
The Minnesota Pollution Control Agency (MPCA) has issued Air Emission Permit No. 12300007-002 as a joint Title I/FESOP document, cont aining all the applicable requirements for the source to ensure that the area will continue to maintain the NAAQS. At this time, the MPCA is submitting Air Emission Permit No. 12300007-002, to EPA, requesting that those conditions labeled “Title I Condition: SIP for PM10” replac e the conditions from the Administrative Order as the SIP enforceable document.
1. Reasons for Changes and Placing Applicable Conditions into Joint Title I/FESOP Document This SIP revision is necessary for several reason s. First, the facility has changed ownership, becoming Aggregate Industries. Furthermore, as has been documented in previous submittals, the MPCA and EPA have come to an agreement about the process of placing SIP requirements into joint Title I/permit documents and the approp riate citation of such requirements. The MPCA is therefore in the process of replacing all SI P Orders with SIP enforceable joint documents. In addition, the facility request ed clarification of the SIP c onditions and updates to permit language for the aggregate heater. In 1995, the Pe rmittee made changes to the aggregate heater, and asked for a permit change and SIP revision. A SIP revision was not submitted at that time. The changes made included a replacement of the aggregate heater with a new aggregate heater.
Finally, as this facility has not been subject to a SIP revision for many years, this SIP revision will serve to generally update the facility in th e SIP, including any relevant changes to control and process equipment made over the past several years.2 2. Type of Changes Made The changes that are being made in this submittal include:

• Change in ownership of the facility

• Change in enforceable document (Administrative Order to joint document)

• Updating of emission units

• Change to requirements for storage piles

• Removal of lbs/hour PM 10 limit on aggregate heater

The main reason for this SIP revision is the change in ownership of the f acility (from JL Shiely to Aggregate Industries) and to change the enfor ceable document from the Order to a joint Title I/FESOP document.
At the time of the initial issuance of the Order, the facility consisted of three crawler cranes, seven steel loadout bins, eight conv eyor belts, two radial stackers and a rotary aggregate heater. Amendment Two of the Order removed two craw ler cranes and two bins, and added a hopper, diesel backhoe, and belt conveyer. The facility currently consists of one crawler crane, seven loadout bins, eight conveyors, two radial stackers, four hoppers , the diesel backhoe, and the aggregate heater with an associ ated conveyor. Changes to the em ission units at the source were made in the previously amendments to the Order.
However, most of these emission units are not su bject to source specific requirements necessary to show modeled compliance with the PM 10 NAAQS. Instead, they have been subject to general opacity limits based on Minnesota Rules. These op acity limits have been carried forward in the permit, through citations to Minnesota’s opacity rules, many of which are more stringent now than they were when the or iginal Order was issued.
The facility requested a slight change to the requirements for minimizing fugitive dust from the storage piles. The Orders i ndicated that the Company shall not operate the product pile conveyors unless the free fall height from the conve yor to the product pile is less than 10 feet. At the beginning of the season, the facility has depleted the product stor age pile throughout the winter before barges are allowe d to bring product to Yard A. In addition, there are select times during the construction season that the product storag e pile is depleted before barges come to refill the pile. Therefore, during these times it is difficult to maintain the 10 foot free fall height until the storage pile is established. The permit has slightly altered the language so that the free fall height requirement applies only after the product pile is established. Additional language was added to ensure that the less than 10 foot fa ll height should be achieved as expeditiously as possible, and that the fall height cannot be greater than 10 feet for more than six hours. These requirements will ensure that the NAAQS is maintained, while allowing the facility some flexibility in establishing new product piles. Th ere will be no increase in emissions associated with this change because the emission calculati ons for the pile or stack er are not based on free fall height.3 The unit subject to specific control requireme nts necessary to model compliance with the PM 10 NAAQS is EU026 (formerly emission point 5), the aggregate heater. The heater was originally subject to a PM 10 emission limit of 10.2 lbs/hr; th is was raised to 15.1 lbs/hr. 1 The 15.1 lbs/hr limit was coupled with operating restrictions (no more than 16 hours of operation in any 24 hour period) to ensure that the total PM 10 emissions in any 24-hour peri od would not increase, thereby continuing to demonstrate modeled attainment. 2
Since the last SIP revision, in 1995, the facility has changed aggregate heaters. Although the new heater was permitted and a SIP revision was requested by the facility, it does not appear that a SIP revision was submitted. The new heater does not have an exhaust stack, making it difficult to test for the PM 10 limit included in the Administrative Orde r; however, the intent of the design of the new heater is to minimize emissions by keepi ng the air velocity as low as possible in the drum to avoid entrainment of dust.
Therefore, the PM 10 limit has not been includ ed in the permit that the MPCA is requesting to have approved as the joint document. The MPCA is confident that the change in heater and the removal of the PM 10 limit will not jeopardize the NAAQS. First, the new heater runs only on natural gas (the old heater combusted fu el oil) and its potential to emit of PM 10 is 0.119 lbs/hour. The permit maintains the operating restrictions pl aced on the heater when the limit of 15.1 lbs/hr was applied, thereby as suring that 24-hour PM 10 emissions will decrease from those allowable under the current Order.
Replacing the lbs/hr limit, this action adds a re quirement to minimize generation of fugitive dust, and a requirement that the moisture content of materi al leaving the heater be at least two percent. The aggregate heater continues to be subject to operating limits, namely that the heater can only be operated during the winter months (November through April) and no more than 10 hours each day or 16 hours in any 24-hour period.

3. New authorizations No new processes are being authorized in the permit that serves as the joint document.

4. Modeling No modeling was conducted, as the new heater has considerably lower potential emissions than the unit it replaces. The mainte nance of operating hour limitations on the new aggregate heater ensures attainment with the PM 10 NAAQS at a higher PM 10 emission rate than capable by the current heater.

1 The change from 10.2 to 15.1 lbs/hour came in Amendment One to the Amended Findings and Order, but it is not clear that this change was SIP appr oved. Amendment One is not shown on Region V’s SIP webpage; however, subsequent amendmen ts were approved. 2 The 24-hour PM 10 NAAQS was the limiting condition at the facility at the time of the issuance of the Order, and is now the only remaining PM 10 NAAQS.4 5. SIP Revision All conditions necessary for maintaining the NAAQS, including those from the Amendment Three to the Amended Findings and Order, and to be included in the SIP are designated as “Title I Condition: State Implementation Plan for PM 10 ,” making it clear that the term is part of the SIP’s source-specific requirements. In this SIP submittal, MPCA is requesting that only those requirements with the term “Title I Cond ition: State Implementation Plan for PM 10 ” be included into the SIP, and that the Order issued to J.L. Shiely be consequently revoked.
Attachments to Background Document Attachment 1: Permit No. 12300055-004; joint Title I/FESOP document Attachment 2: Permit technical support document Attachment 3: Permit No. 12300055-004; Title I SIP conditions only Attachment 4: Marked Up Findings and Order Attachment 5: Revocation of Findings and Order Attachment 6: Public notice Attachment 8: Completeness Review

This summary was prepared by Catherine Neus chler, Environmental Analysis and Outcomes Division of the MPCA.Attachment 1: Permit No. 12300055-004; joint Title I/FESOP documentPermit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit 1/31/96 updated 2005 001 Major Amendment 9/4/07 002TABLE OF CONTENTS

Notice to the Permittee

Permit Shield
Facility Description
Amendment Description
Table A: Limits and Other Requirements

Table B: Submittals
Appendix: Weather Summary CriteriaNOTICE TO THE PERMITTEE:
Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the Minnesota Pollution Control Agency (MPCA) general information number at:

Metro Area 651-296-6300

Outside Metro Area 1-800-657-3864

TTY 651-282-5332
The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194.
Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above.

PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific pr ovision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION: The facility is an aggregate distribution and storage facility. It receives aggregate by barge, unloads it, and conveys it to one of several storage piles based on size and material type. The aggregate is stored until it is loaded to truck for off-site transport. The facility operates a natural gas-fired aggregate heater that is used between November and April to reduce moisture content and make some materials more easily conveyed. The primary emissions from the facility are Particulate Matter and Particulate Matter smaller than 10 mincrons (PM 10 ) from the process equipment, as well as fugitive emissions from the stockpiles and unpaved roads. Permit action -001 incorporated the applicable Administrative Order (State Implementation Plan) requirements. AMENDMENT DESCRIPTION (M ajor Amendment -002): This major amendment will clarify a Title I Condition regarding a SIP for PM 10 originating from an Administrative Order for the facility issued August 25, 1992. This amendment will also update the permit language for the aggregate heater (EU026) and update opacity limits for GP001 and GP002. SV001 is being removed from the facility description. Total facility permit language was updated to meet current MPCA policy.TABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements.

Subject Item: Total Facility

What to do Why to do it SOURCE-SPECIFIC REQUIREMENTS hdr Permit Appendices: This permit contains an appendix as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendix. Minn. R. 7007.0800, subp. 2

Feed Material Moisture Content: greater than or equal to 1.5 percent Title I Condition: To avoid major source and modification under 40 CFR Section 70.2 and Minn. R. 7007.0200; Minn. R. 7007.0800, subp. 2 Demonstrate feed material moisture content by either 1 or 2 below: 1. Test moisture content of each different feed material source (sampled at an area representative of the feed source and physically capable of being sampled), as follows: a. Use American Society for Testing and Materials (ASTM) method numbers D 2216-92 or D 4643-93 (or equivalent). b. Keep records of each moisture content test summarizing the method used, results, date, time, and initials of person performing test. c. Test weekly, when operating, unless three consecutive tests at the stationary source location show moisture contents of greater than or equal to 1.5 percent after which testing is no longer required until the source of the feed material changes. Title I Condition: To avoid major source and modification under 40 CFR Section 70.2 and Minn. R. 7007.0200; Minn. R. 7007.0800, subp. 2

d. When testing indicates that feed material moisture content is less than 1.5 percent, or in situations where it is infeasible to sample and test, or where the Permittee elects not to sample and test, the Permittee must operate a moisture addition device at or immediately prior to the equipment where unprocessed feed material is being fed to achieve a moisture content greater than or equal to 1.5 percent. Moisture addition during operation shall continue until subsequent moisture content testing demonstrates that feed material moisture content is greater than or equal to 1.5 percent. Daily, when operating, either: (i) keep records of the date, water flow rate, material throughput rate, and initials of the person making the record and the time the record was made; or (ii) conduct moisture content testing daily on the feed material after water application following a. and b. above, and if results show moisture content is less than 1.5 percent, increase water addition to insure moisture CONTINUED: Title I Condition: To avoid major source and modification under 40 CFR Section 70.2 and Minn. R. 7007.0200; Minn. R. 7007.0800, subp. 2

OR 2. Keep records indicating that feed material is being removed from below the water table - or from below the surface of a waterway (e.g., creek, river, lake). Records shall include a description of the source, the corresponding dates, and the initials of the person making the record. CONTINUED: Title I Condition: To avoid major source and modification under 40 CFR Section 70.2 and Minn. R. 7007.0200; Minn. R. 7007.0800, subp. 2

Labeling Requirements: Permanently affix the manufacturer's serial number (or otherwise unique identifying number) to each piece of crushing, screening, transfer operation, and stationary internal combustion engine equipment for tracking purposes within 60 days of permit issuance. The number shall be permanently affixed and maintained so that it is readable and visible at all times from a safe distance at each stationary source. This number shall correspond to the number contained in records regarding the piece of equipment. Minn. R. 7007.0800, subp. 2

SIP REQUIREMENTS hdr
A ctivities Not Requiring A Modification To The SIP: The Permittee is authorized to make changes to the facility without obtaining a modification to the SIP as long as the change does not increase from any emission point, the PM10 emission rates (either lb/hr or gr/dscf) or overall PM10 emissions. A s noted in Part II of the Order, the Permittee may undertake certain changes to the facility without obtaining a modification of the Order. However, if the Permittee does make such a change, and if the change in any way affects PM10 emissions (reduces the amount or changes the concentration, size, character, velocity, direction, or location of PM10 emissions) the Permittee shall notify the AQD Manager in writing at least 30 days prior to undertaking the change. The notification shall describe the change and why it does not require a modification of the SIP. The Permittee must also obtain a permit amendment if required by state or federal law. Title I Condition: State Implementation Plan for PM10TABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-2

A ctivities Requiring A Modification To The SIP: Activities that require a modification to the SIP prior to the Permittee commencing the activity include, but are not limited to: 1. any decrease in stack emissions exit velocity; 2. any decrease in the exit point heat content of stack emissions; or 3. any construction or modification of structures that increase the effective structural dimensions. 4. any changes in operations that increase potential PM10 emissions. Title I Condition: State Implementation Plan for PM10

The Permittee shall demonstrate compliance with applicable conditions of the PM10 SIP, Minnesota and federal statutes, federal regulations and Minnesota rules by the following methods: visually observing the opacity from emission units with opacity limits, in accordance with the testing procedures of 40 CFR pt. 60, A ppendix A, Method 9 as amended in Minn. R. 7005.1860, subp. 7. These records shall be made available when requested by MPCA or EPA. Title I Condition: State Implementation Plan for PM10

Required Records: The following records must be retained at the facility: a. monitoring, testing and other records; b. PM10 emissions and operations records; c. startup, shutdown, bypass and breakdown records; d. excess emissions and noncompliance with operational requirements records Title I Condition: State Implementation Plan for PM10

Permanent Recordkeeping: The Permittee shall permanently maintain the following records: a. Design, Construction and Operation Information. The Permittee shall maintain a file or files of information on the design, construction and operation of each emission source, fuel system, stack, structures pertinent to modeling for downwash, and any other information required to conduct PM10 ambient air quality modeling. The file or files shall include all information required to demonstrate that the equipment identified in this permit is installed and operated as described. If the Permittee makes changes or modifications that do not require amendments to this permit, the file or files shall include a description of that change or modification and all information required to demonstrate that the change or modification did not require a permit amendment. Title I Condition: State Implementation Plan for PM10

Permanent Recordkeeping (continued): b. PM10 Emission and Operational Requirement Compliance Demonstration Plans. The Permittee shall maintain a file at the facility which includes this permit and all attachments or items incorporated by reference, and any plans which upon approval by the MPCA or EPA become integral and enforceable parts of this permit. Title I Condition: State Implementation Plan for PM10 (continued from above)

Recordkeeping: Retain all records at the stationary source and/or corporate office from the date of monitoring, sample, measurement, or report. Records which must be retained at these locations include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Records are required to be retained at the stationary source for 1 year with the remaining records stored at the corporate office for a minimum of six (6) years. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A) unless otherwise noted. Title I Condition: State Implementation Plan for PM10; Minn. R. 7007.0800, subp. 5A

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of PM10. At the time of the notification, the company shall notify the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Title I Condition: State Implementation Plan for PM10

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or a breakdown of process equipment if the process equipment breakdown causes any increase in the emissions of PM10. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. The owner or operator shall notify the Commissioner when the breakdown is over. Title I Condition: State Implementation Plan for PM10

Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements. Performance Test Notification (written): due 30 days before each Performance Tes t Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. Title I Condition: State Implementation Plan for PM10; Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn. R. 7017.2035, subp. 1-2TABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-3

A nnual Reports: The Permittee shall submit to the MPCA once each calendar year, a report that contains the following information: a record of data used in calculating PM10 emissions, and calculations of the PM10 emissions; each startup, shutdown, bypass and breakdown of process and control equipment; and a summary record of excess PM10 emissions, opacity exceedances, hours of operation exceedances and noncompliance with operational requirements (or the Permittee shall state if no exceedances or noncompliance conditions occurred in the year). A nnual reports shall be postmarked or delivered within 60 days following the end of each calendar year. Title I Condition: State Implementation Plan for PM10

The Permittee shall conduct maintenance as necessary to ensure that all equipment is in proper operating condition. Title I Condition: State Implementation Plan for PM10

OPERATIONAL REQUIREMENTS hdr
Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Minn. R. 7011.0020

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Minn. R. 7019.1000, subp. 4

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. Title I Condition: State Implementation Plan for PM10; Minn. R. 7011.0150

Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). Minn. R. 7007.0800, subp. 9(A)
The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in Tables A, B, and/or C. Minn. R. ch. 7017
Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. Minn. R. 7017.2025, subp. 3

RECORDKEEPING hdr Recordkeeping: Retain all records at the stationary source and/or corporate office for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records are required to be retained at the stationary source for 1 year with the remaining records stored at the corporate office up to five (5) years. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007. 1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350 subp. 2), including records of the emissions resulting from those changes. Minn. R. 7007. 0800, subp. 5(B)

If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. For nonexpiring permits, these records shall be kept for a period of five years from the date that the change was made. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. Minn. R. 7007.1200, subp. 4

REPORTING/SUBMITTALS hdrTABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-4

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3.

A t the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.

A t the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected ; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Minn. R. 7019.1000, subp. 1

A pplication for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. Minn. R. 7007.1150 - Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Minn. R. 7007.1400, subp. 1(H)

Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. To be submitted on a form approved by the Commissioner. Minn. R. 7019.3000 - Minn. R. 7019.3100

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 - Minn. R. 7002.0095TABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-5

Subject Item: GP 001 Limits that Apply to Equipment (pre-1969) not Subject to NSPS
Associated Items: EU 001 Crawler Crane
EU 006 Loadout Bin EU 008 Conveyor EU 011 Conveyor EU 014 Conveyor EU 020 Conveyor
EU 021 Loadout Bin EU 025 Stocking Hopper

What to do Why to do it Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0710, subp. 1(A)

Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 33 percent opacity. Minn. R. 7011.0105TABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-6

Subject Item: GP 002 Limits that Apply to Equipment (post-1969) not Subject to NSPS
Associated Items: EU 003 Hopper EU 004 Conveyor
EU 005 Radial Stacker EU 007 Heater Conveyor
EU 009 Loadout Bin
EU 010 Loadout Bin
EU 012 Loadout Bin
EU 013 Loadout Bin
EU 015 Diesel Backhoe EU 016 Hopper EU 017 Hopper EU 018 Conveyor
EU 019 Radial Stacker EU 022 Conveyor EU 023 Conveyor
EU 024 Loadout Bin

What to do Why to do it Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B) and Minn. R. 7011.0110TABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-7

Subject Item: GP 003 SIP Requirements - Storage Piles
Associated Items: FS 001 Stock Piles Sand, Gravel & Limestone Products FS 002 Stock Piles Sand, Gravel & Limestone Products FS 003 Stock Piles Sand, Gravel & Limestone Products FS 004 Stock Piles Sand, Gravel & Limestone Products FS 005 Stock Piles Sand, Gravel & Limestone Products FS 006 Stock Piles Sand, Gravel & Limestone Products FS 007 Stock Piles Sand, Gravel & Limestone Products FS 008 Stock Piles Sand, Gravel & Limestone Products FS 009 Stock Piles Sand, Gravel & Limestone Products FS 010 Stock Piles Sand, Gravel & Limestone Products FS 011 Stock Piles Sand, Gravel & Limestone Products FS 012 Stock Piles Sand, Gravel & Limestone Products FS 013 Stock Piles Sand, Gravel & Limestone Products FS 014 Stock Piles Sand, Gravel & Limestone Products FS 015 Stock Piles Sand, Gravel & Limestone Products FS 016 Stock Piles Sand, Gravel & Limestone Products FS 017 Stock Piles Sand, Gravel & Limestone Products FS 018 Stock Piles Sand, Gravel & Limestone Products

What to do Why to do it Operations: Do not operate the product pile conveyors unless the free fall height from the conveyor belt to the product pile is 10 feet or less after the product pile is established. The free fall height shall not be greater than 10 feet for more than 6 hours. The 10 foot drop height shall be achieved as expeditiously as possible. Title I Condition: State Implementation Plan for PM10

If the steady wind speed exceeds 30 miles per hour, or when wind gusts exceed 45 miles per hour, then the operation of the radial stacker equipment shall be confined to the downwind side of the pile. Title I Condition: State Implementation Plan for PM10

Obtain and record wind measurements from the National Weather Service (St. Paul/Holman Field) or an on-site wind gauge. Minn. R. 7007.0800, subp. 4DTABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-8

Subject Item: EU 026 Heater

What to do Why to do it Operation: Operate the aggregate heater only during the months of November through April. Do not operate this unit on Sundays during the months of November through April. Operate this unit for not more than 10 hours each day that the unit is allowed to operate. Notwithstanding the previous sentence, the unit shall be operated in a manner that prevents the actual total hours of operation from exceeding 16 hours in any 24-hour period from Monday through Saturday in the months of November through April. Title I Condition: State Implementation Plan for PM10

A llowed fuels: Natural gas, no other fuels shall be used. Title I Condition: To avoid major source and modification under 40 CFR Section 70.2 and Minn. R. 7007.0200; Minn. R. 7007.0800, subp. 2 Recordkeeping: Record the following data daily: a. Burner startup and shutdown time to the minute with each burn recorded separately; b. Fuel consumption; c. Approximate amount of material in tons heated by the unit operator; and d. Actual amount of heated materials in tons established based on daily sales records. Title I Condition: State Implementation Plan for PM10; Minn. R. 7007.0800, subp. 5A

Recordkeeping: For each month by the 15th of the following month, summarize the daily data listed above. Title I Condition: State Implementation Plan for PM10; Minn. R. 7007.0800, subp. 5A Operate heater to minimize generation of fugitive dust. Title I Condition State Implementation Plan for PM10 Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0610, subp. 1(A)(1)

Moisture Content: greater than or equal to 2 percent leaving the heater. Test at the beginning of each winter season, when operating. Complete testing until three consecutive tests at the stationary source location show moisture contents of greater than 2% after which testing is no longer required until the next winter season. Title I Condition: State Implementation Plan for PM10

Opacity: less than or equal to 20 percent opacity , this is more stringent than the limit cited in Minn. R. 7011.0610, subp. 1(A)(2). Title I Condition: State Implementation Plan for PM10TABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-9

Subject Item: FS 019 Haul Roads

What to do Why to do it Water unpaved roads located within the property boundaries of the facility. Watering shall be subject to the following conditions: a. Water application rate shall be at least 0.03 gallons for each square foot at least once every 24 hours. b. 0.1 inch or more rainfall during the past 24 hours shall substitute for one daily water application. This shall be measured either by National Weather Service (St. Paul/Holman Field) data or an on-site rain gauge. c. Water application shall not be required when there is snow cover or the ground is frozen. d. Water application shall not be required when there is no traffic on the roads. e. Following any day when water is not applied based on absence of traffic, water shall be applied within 3 hours of the recommencement of traffic. Title I Condition: State Implementation Plan for PM10

Recordkeeping (unpaved roads): Maintain a daily log which shall include the following information:
a. which roads were watered; b. date and time of watering; c. quantity of water used; d. method of application for each application; e. water tank size, total area of roads to be watered and number of fills necessary to accomplish the required application rate; f. records of watering equipment breakdowns and repairs. If water was not applied because the facility was not in operation, there was no traffic on the roads, was frozen or snow covered, or there was rainfall, the log shall note the reason for no watering. The method of rainfall measurement shall be either National Weather Service (St. Paul/Holman Field) data or an on-site rain gauge. Title I Condition: State Implementation Plan for PM10; Minn. R. 7007.0800, subp. 5A

To eliminate track-out of mud onto the paved roads, wash the entire concrete exit driveway at least twice per day in non-frozen conditions. These washings shall be recorded in the road watering log. Title I Condition: State Implementation Plan for PM10

High pressure wash the paved surface of Childs Road (to the side gutters) in front of the facility at least once per day when trucks are hauling from the facility. The washing shall be conducted in both directions to the extent that track-out of sediment from the facility can be seen on Childs Road. Title I Condition: State Implementation Plan for PM10

Recordkeeping (paved roads): Maintain a daily log which shall state the date and time of washing. If water was not applied because trucks were not hauling, the log shall note the reason for no watering. Title I Condition: State Implementation Plan for PM10; Minn. R. 7007.0800, subp. 5AAttachment 2: Permit technical support documentTechnical Support Document, Permit Action Number: 12300007 - 002 Page 1 of 7 Date: 4/24/2009 TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO. 12300007-002
This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set fort h by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit. 1. General Information 1.1 Applicant and Stationary Source Location: Table 1. Applicant and Source Address Applicant/Address Stationary Source/Address (SIC Code: 1442, 1422) Aggregate Industries Inc. 2915 Waters Road Eagan, MN 55121 Aggregate Industries Inc. - Yard A 1177 Childs Road St. Paul, Ramsey County Contact: Patty Christensen Phone: 651-683-8133 1.2 Facility Description Aggregate Industries Inc. - Yard A is an aggreg ate distribution and storage facility. It receives aggregate by barge, unloads it, and conveys it to one of several storage piles based on size and material type. The aggregate is stored until it is loaded to truck for off-site transport. The facility operates a natural gas-fired aggregate heater that is used between November and April to reduce moisture content and make some materials more easily conveyed. The primary emissions from the facility are Particulate Matter (PM) and Particulate Matter less than 10 um in size (PM 10 ) from the processing equipment, as well as fugitive emissions from the stockpiles and unpaved roads. The facility is not eligible for the state non-metallic minerals processing plant general permit because it operates an aggregate heater, and has State Implementation Plan requirements for the PM 10 maintenance area. 1.3 Description of the Activities Allowed by this Permit Action A major amendment application was received September 4, 2007, requesting clarification of a Title I Condition in their permit regarding a State Implementation Plan (SIP) for PM 10 originating from an Administrative Order for the facility issued August 25, 1992. This permit action will amend the Title I Condition in question and update the SIP to reference the latest permit for the Yard A facility instead of the Administrative Order. The Permittee is also requesting to update the permit language for the aggregate heater (EU026). Total facility permit language was updated to meet current MPCA policy. More stringent limits on opacity in GP001 were added to the permit. No emissions increases are associated with this permit action.Technical Support Document, Permit Action Number: 12300007 - 002 Page 2 of 7 Date: 4/24/2009 1.4 Facility Classification: Table 2. Facility Classification Classification Major/Affected Source Synthetic Minor Minor

PSD X Part 70 Permit Program PM 10 PM, SO 2 , NO X , CO, VOC Part 63 NESHAP X 2. Regulatory and/or Statutory Basis New Source Review This facility is a minor source for purposes of NSR/PSD. Part 70 Permit Program The facility is a synthetic minor source under the Part 70 permit program. Fugitive emissions are not factored into the PTE since this facility is not subject to an NSPS. New Source Performance Standards (NSPS) The facility is not subject to NSPS, Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants, because no crushing is performed on-site. National Emission Standards for Hazardous Air Pollutants (NESHAP) There are no National Emission Standards for Hazardous Air Pollutants applicable to the operations at this facility. Compliance Assurance Monitoring (CAM) CAM does not apply to the action allowed in this permit amendment. Environmental Review & AERA Environmental Review and Air Emissions Risk Analysis are not required with this permit action. Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance:

• Minn. R. 7011.0105 Visible Emission Restrictions for Existing Facilities

• Minn. R. 7011.0110 Visible Emission Restrictions for New Facilities

• Minn. R. 7011.0610 Standards of Performance fo r Fossil-Fuel-Burning Direct Heating Equipment

• Minn. R. 7011.0710 Standards of Performance for Pre-1969 Industrial Process Equipment

• Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process EquipmentTechnical Support Document, Permit Action Number: 12300007 - 002 Page 3 of 7 Date: 4/24/2009

Table 3. Regulatory Overview of Units Affect ed by the Modification/Permit Amendment Level* Applicable Regulations Comments: GP 001 Minn. R. 7011.0105 Restricting the limits on opacity based on Administrative Order and State Implementation Plan (SIP) for PM 10 GP 002 Minn. R. 7011.0715, subp. 1(B); Minn. R. 7011.0110 Citing the Minn. R. setting opacity limits in the Administrative Order and SIP for PM 10 GP 003 (FS001- FS018) Title I Condition: State Implementation Plan for PM 10 Title I Condition updated to reference the facility permit instead of the Administrative Order and State Implementation Plan (SIP) issued August 25, 1992 EU 026 Title I Condition: State Implementation Plan for PM 10 Replacing PM 10 limit of < 15.1 lb/hr with a requirement to operate the heater to minimize fugitive dust and add a Moisture Content limit of > 2% leaving the aggregate heater. *Where the requirement appears in the permit (e.g., EU, SV, GP, etc.). 3. Technical Information Aggregate Industries Inc. is requesting to update permit language in the Yard A current state permit (12300007-001) to match the actual operating scenario at the facility. The updated language addresses the free fall height from the product pile conveyors to the product pile at the Yard A facility. At the beginning of the season (i.e. Spring) the facility has depleted the product storage pile throughout the winter before barges are allowed to bring product to Yard A. In addition, there are select times during the construction season (Spring, Summer and Fall), that the product storage pile is depleted before barges come to refill the pile. Therefore, during these times it is difficult to maintain the 10 foot free fall height until the storage pile is established. Aggregate Industries requests to update the facility permit to allow for this temporary operating condition. There will be no increase in emissions associated with this change because the emission calculations for the pile or stacker are not based on free fall height. The condition that is proposed to be amended is currently part of Aggregate Industries permit and is also part of an Administrative Order (AO) that is part of the State Implementation Plan (SIP) for the area for maintenance of compliance with the PM 10 National Ambient Air Quality Standard (NAAQS). The Permittee is requesting that along with this permit action, that the permit be made to replace the AO and therefore, future changes are not required to be made separately to the AO/SIP and the permit. The Permittee is also requesting to update permit language for the aggregate heater (EU026). The PM 10 limit for EU026 of less than or equal to 15.1 lb/hr is being replaced with a requirement to minimize generation of fugitive dust. The old aggregate heater at the facility was a Madsen Rotary dryer manufactured in 1958. This heater was replaced in 1995 with an ADM heater added in action -001. The new heater does not have an exhaust stack making it difficult to test for the existing PM 10 limit in the permit. The stack associated with the Madsen heater was not removed in permit action -001 and this correction is being made in this permit action (-002). The intent of the design of the ADM heater is to minimize emissions by keeping the air velocity as low as possible in the drum to avoid entrainment of dust. The ADM heater runs on natural gas whereTechnical Support Document, Permit Action Number: 12300007 - 002 Page 4 of 7 Date: 4/24/2009 the Madsen heater combusted fuel oil. The Permittee is also adding a moisture content limit of greater than or equal to 2% leaving the heater. Opacity limits are also being restricted to what is stated in Minn. R. 7011.0105 and Minn. R. 7011.0110 as enforced by the Administrative Order dated August 25, 1992. The cover page of permit action -001 listed the facility with limits to avoid Pt. 70 and limits to avoid PSD/NSR while the Technical Support Document listed the facility as a true minor source for PSD/NSR and no citations of 40 CFR Section 52.21 in the permit. This error is being corrected in this permit action. Also the Emission Calculations spreadsheet for permit action 001 had an incorrect link in the summary tab for uncontrolled PM and PM 10 emissions. These corrections are shown in the attached revised emissions calculations to this TSD. There are no emissions increases involved with this permit action. Table 4. Title I Conditions / SIP for PM 10 Changes Citation Old Requirement (PER 001) New Requirement (PER 002) Title I Condition: State Implementation Plan for PM 10 (for GP003) Operations: Do not operate the product pile conveyors unless the free fall height from the conveyor belt to the product pile is 10 feet or less. Operations: Do not operate the product pile conveyors unless the free fall height from the conveyor belt to the product pile is 10 feet or less after the product pile is established. The free fall height shall not be greater than 10 feet for more than 6 hours. The 10 foot drop height shall be achieved as expeditiously as possible Title I Condition: State Implementation Plan for PM 10 (for EU026) Particulate Matter < 10 micron: less than or equal to 15.1 lbs/hour (PTE is 11.37 lb/hr) Operate heater to minimize generation of fugitive dust.

Title I Condition: State Implementation Plan for PM 10 (for EU026) none Moisture Content: greater than or equal to 2% leaving the heater. Test at the beginning of each winter season, when operating. Complete testing until three consecutive tests at the stationary source location show moisture contents of greater than or equal to 2% after which testing is no longer required until the next winter season. Minn. R. 7011.0710, subp. 1(B) Minn. R. 7011.0105 (for GP001) Opacity: less than or equal to 20 percent opacity shall be permissible for four minutes in any 60-minute period and 40 percent opacity shall be permissible for four additional minutes in any 60-minute period Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 33 percent opacity.

Minn. R. 7011.0715, subp. 1(B) & Minn. R. 7011.0110 (for GP002) Opacity: less than or equal to 20 percent opacity Opacity: less than or equal to 20 percent opacity
Note: Other Title I Conditions are being added to the permit to replace those represented in the AO.Technical Support Document, Permit Action Number: 12300007 - 002 Page 5 of 7 Date: 4/24/2009 3.1 Periodic Monitoring In accordance with the Clean Air Act, it is the re sponsibility of the owner or operator of a facility to have sufficient knowledge of the facility to cer tify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considers the following:

• The likelihood of violating the applicable requirements;

• Whether add-on controls are necessary to meet the emission limits;

• The variability of emissions over time;

• The type of monitoring, process, maintenance, or control equipment data already available for the emission unit;

• The technical and economic feasibility of possible periodic monitoring methods; and

• The kind of monitoring found on similar units elsewhere. Table 5 summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate. Table 5. Periodic Monitoring EU Requirement (basis) Additional Monitoring Discussion

EU026 Title I Condition: State Implementation Plan for PM 10 Recordkeeping: Daily burner operation time, fuel use, material heated Requirements referenced by the facility permit for the State Implementation Plan (SIP) for PM 10 rather than the administrative order.

3.2 Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be tracked (e.g., limits, submittals, etc.), should be in Table A or B. The main reason is that the appendices are word processing sections and are not part of the tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these. 3.3 Comments Received Public Notice Period: March 22, 2009 – April 20, 2009 No comments were received from the public or from EPA during the public notice period. No changes to the permit were made, however the potential-to-emit (PTE) calculations for the heater (EU026) were corrected to 1560 hours/year rather than 8760 hours. This correction was made toTechnical Support Document, Permit Action Number: 12300007 - 002 Page 6 of 7 Date: 4/24/2009 the attached calculation spreadsheets and the facility description. Since there is no control equipment associated with the heater, the uncontrolled and controlled PTE in the spreadsheet are equal. The unrestricted PTE in the facility description however is based on 8760 hours/year and the limited PTE is based on 1560 hours/year. 4. Conclusion Based on the information provided by Aggregate Industries Inc. Yard A Facility, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 12300007-002 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Tarik Hanafy (permit writer/engineer) Brent Rohne (enforcement) Catherine Neuschler (SIP) Chris Buntjer (peer reviewer)
AQ File No. 54D; DQ 1641
Attachments: 1. Facility Description and CD-01 Forms 2. Revised Emissions Calculations 3. Amendment Findings and Order to J.L. Shiely CompanyAttachment 3: Permit No. 12300055-004; Title I SIP conditions onlyPermit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit 1/31/96 updated 2005 001 Major Amendment 9/4/07 002TABLE OF CONTENTS

Notice to the Permittee

Permit Shield
Facility Description
Amendment Description
Table A: Limits and Other Requirements

Table B: Submittals
Appendix: Weather Summary CriteriaNOTICE TO THE PERMITTEE:
Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the Minnesota Pollution Control Agency (MPCA) general information number at:

Metro Area 651-296-6300

Outside Metro Area 1-800-657-3864

TTY 651-282-5332
The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194.
Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above.

PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific pr ovision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION: The facility is an aggregate distribution and storage facility. It receives aggregate by barge, unloads it, and conveys it to one of several storage piles based on size and material type. The aggregate is stored until it is loaded to truck for off-site transport. The facility operates a natural gas-fired aggregate heater that is used between November and April to reduce moisture content and make some materials more easily conveyed. The primary emissions from the facility are Particulate Matter and Particulate Matter smaller than 10 mincrons (PM 10 ) from the process equipment, as well as fugitive emissions from the stockpiles and unpaved roads. Permit action -001 incorporated the applicable Administrative Order (State Implementation Plan) requirements. AMENDMENT DESCRIPTION (M ajor Amendment -002): This major amendment will clarify a Title I Condition regarding a SIP for PM 10 originating from an Administrative Order for the facility issued August 25, 1992. This amendment will also update the permit language for the aggregate heater (EU026) and update opacity limits for GP001 and GP002. SV001 is being removed from the facility description. Total facility permit language was updated to meet current MPCA policy.TABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements.

Subject Item: Total Facility

What to do Why to do it SOURCE-SPECIFIC REQUIREMENTS hdr

SIP REQUIREMENTS hdr
A ctivities Not Requiring A Modification To The SIP: The Permittee is authorized to make changes to the facility without obtaining a modification to the SIP as long as the change does not increase from any emission point, the PM10 emission rates (either lb/hr or gr/dscf) or overall PM10 emissions. A s noted in Part II of the Order, the Permittee may undertake certain changes to the facility without obtaining a modification of the Order. However, if the Permittee does make such a change, and if the change in any way affects PM10 emissions (reduces the amount or changes the concentration, size, character, velocity, direction, or location of PM10 emissions) the Permittee shall notify the AQD Manager in writing at least 30 days prior to undertaking the change. The notification shall describe the change and why it does not require a modification of the SIP. The Permittee must also obtain a permit amendment if required by state or federal law. Title I Condition: State Implementation Plan for PM10TABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-2

A ctivities Requiring A Modification To The SIP: Activities that require a modification to the SIP prior to the Permittee commencing the activity include, but are not limited to: 1. any decrease in stack emissions exit velocity; 2. any decrease in the exit point heat content of stack emissions; or 3. any construction or modification of structures that increase the effective structural dimensions. 4. any changes in operations that increase potential PM10 emissions. Title I Condition: State Implementation Plan for PM10

The Permittee shall demonstrate compliance with applicable conditions of the PM10 SIP, Minnesota and federal statutes, federal regulations and Minnesota rules by the following methods: visually observing the opacity from emission units with opacity limits, in accordance with the testing procedures of 40 CFR pt. 60, A ppendix A, Method 9 as amended in Minn. R. 7005.1860, subp. 7. These records shall be made available when requested by MPCA or EPA. Title I Condition: State Implementation Plan for PM10

Required Records: The following records must be retained at the facility: a. monitoring, testing and other records; b. PM10 emissions and operations records; c. startup, shutdown, bypass and breakdown records; d. excess emissions and noncompliance with operational requirements records Title I Condition: State Implementation Plan for PM10

Permanent Recordkeeping: The Permittee shall permanently maintain the following records: a. Design, Construction and Operation Information. The Permittee shall maintain a file or files of information on the design, construction and operation of each emission source, fuel system, stack, structures pertinent to modeling for downwash, and any other information required to conduct PM10 ambient air quality modeling. The file or files shall include all information required to demonstrate that the equipment identified in this permit is installed and operated as described. If the Permittee makes changes or modifications that do not require amendments to this permit, the file or files shall include a description of that change or modification and all information required to demonstrate that the change or modification did not require a permit amendment. Title I Condition: State Implementation Plan for PM10

Permanent Recordkeeping (continued): b. PM10 Emission and Operational Requirement Compliance Demonstration Plans. The Permittee shall maintain a file at the facility which includes this permit and all attachments or items incorporated by reference, and any plans which upon approval by the MPCA or EPA become integral and enforceable parts of this permit. Title I Condition: State Implementation Plan for PM10 (continued from above)

Recordkeeping: Retain all records at the stationary source and/or corporate office from the date of monitoring, sample, measurement, or report. Records which must be retained at these locations include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Records are required to be retained at the stationary source for 1 year with the remaining records stored at the corporate office for a minimum of six (6) years. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A) unless otherwise noted. Title I Condition: State Implementation Plan for PM10; Minn. R. 7007.0800, subp. 5A

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of PM10. At the time of the notification, the company shall notify the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Title I Condition: State Implementation Plan for PM10

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or a breakdown of process equipment if the process equipment breakdown causes any increase in the emissions of PM10. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. The owner or operator shall notify the Commissioner when the breakdown is over. Title I Condition: State Implementation Plan for PM10

Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements. Performance Test Notification (written): due 30 days before each Performance Tes t Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. Title I Condition: State Implementation Plan for PM10; Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn. R. 7017.2035, subp. 1-2TABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-3

A nnual Reports: The Permittee shall submit to the MPCA once each calendar year, a report that contains the following information: a record of data used in calculating PM10 emissions, and calculations of the PM10 emissions; each startup, shutdown, bypass and breakdown of process and control equipment; and a summary record of excess PM10 emissions, opacity exceedances, hours of operation exceedances and noncompliance with operational requirements (or the Permittee shall state if no exceedances or noncompliance conditions occurred in the year). A nnual reports shall be postmarked or delivered within 60 days following the end of each calendar year. Title I Condition: State Implementation Plan for PM10

The Permittee shall conduct maintenance as necessary to ensure that all equipment is in proper operating condition. Title I Condition: State Implementation Plan for PM10

OPERATIONAL REQUIREMENTS hdr

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. Title I Condition: State Implementation Plan for PM10; Minn. R. 7011.0150

PERFORMANCE TESTING hdr

RECORDKEEPING hdr

REPORTING/SUBMITTALS hdrTABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-7

Subject Item: GP 003 SIP Requirements - Storage Piles
Associated Items: FS 001 Stock Piles Sand, Gravel & Limestone Products FS 002 Stock Piles Sand, Gravel & Limestone Products FS 003 Stock Piles Sand, Gravel & Limestone Products FS 004 Stock Piles Sand, Gravel & Limestone Products FS 005 Stock Piles Sand, Gravel & Limestone Products FS 006 Stock Piles Sand, Gravel & Limestone Products FS 007 Stock Piles Sand, Gravel & Limestone Products FS 008 Stock Piles Sand, Gravel & Limestone Products FS 009 Stock Piles Sand, Gravel & Limestone Products FS 010 Stock Piles Sand, Gravel & Limestone Products FS 011 Stock Piles Sand, Gravel & Limestone Products FS 012 Stock Piles Sand, Gravel & Limestone Products FS 013 Stock Piles Sand, Gravel & Limestone Products FS 014 Stock Piles Sand, Gravel & Limestone Products FS 015 Stock Piles Sand, Gravel & Limestone Products FS 016 Stock Piles Sand, Gravel & Limestone Products FS 017 Stock Piles Sand, Gravel & Limestone Products FS 018 Stock Piles Sand, Gravel & Limestone Products

What to do Why to do it Operations: Do not operate the product pile conveyors unless the free fall height from the conveyor belt to the product pile is 10 feet or less after the product pile is established. The free fall height shall not be greater than 10 feet for more than 6 hours. The 10 foot drop height shall be achieved as expeditiously as possible. Title I Condition: State Implementation Plan for PM10

If the steady wind speed exceeds 30 miles per hour, or when wind gusts exceed 45 miles per hour, then the operation of the radial stacker equipment shall be confined to the downwind side of the pile. Title I Condition: State Implementation Plan for PM10TABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-8

Subject Item: EU 026 Heater

What to do Why to do it Operation: Operate the aggregate heater only during the months of November through April. Do not operate this unit on Sundays during the months of November through April. Operate this unit for not more than 10 hours each day that the unit is allowed to operate. Notwithstanding the previous sentence, the unit shall be operated in a manner that prevents the actual total hours of operation from exceeding 16 hours in any 24-hour period from Monday through Saturday in the months of November through April. Title I Condition: State Implementation Plan for PM10

Recordkeeping: Record the following data daily: a. Burner startup and shutdown time to the minute with each burn recorded separately; b. Fuel consumption; c. Approximate amount of material in tons heated by the unit operator; and d. Actual amount of heated materials in tons established based on daily sales records. Title I Condition: State Implementation Plan for PM10; Minn. R. 7007.0800, subp. 5A

Recordkeeping: For each month by the 15th of the following month, summarize the daily data listed above. Title I Condition: State Implementation Plan for PM10; Minn. R. 7007.0800, subp. 5A Operate heater to minimize generation of fugitive dust. Title I Condition State Implementation Plan for PM10

Moisture Content: greater than or equal to 2 percent leaving the heater. Test at the beginning of each winter season, when operating. Complete testing until three consecutive tests at the stationary source location show moisture contents of greater than 2% after which testing is no longer required until the next winter season. Title I Condition: State Implementation Plan for PM10

Opacity: less than or equal to 20 percent opacity , this is more stringent than the limit cited in Minn. R. 7011.0610, subp. 1(A)(2). Title I Condition: State Implementation Plan for PM10TABLE A: LIMITS AND OTHER REQUIREMENTS 04/23/09 Aggregate Industries Inc - Yard A
12300007 - 002 Facility Name:
Permit Number: A-9

Subject Item: FS 019 Haul Roads

What to do Why to do it Water unpaved roads located within the property boundaries of the facility. Watering shall be subject to the following conditions: a. Water application rate shall be at least 0.03 gallons for each square foot at least once every 24 hours. b. 0.1 inch or more rainfall during the past 24 hours shall substitute for one daily water application. This shall be measured either by National Weather Service (St. Paul/Holman Field) data or an on-site rain gauge. c. Water application shall not be required when there is snow cover or the ground is frozen. d. Water application shall not be required when there is no traffic on the roads. e. Following any day when water is not applied based on absence of traffic, water shall be applied within 3 hours of the recommencement of traffic. Title I Condition: State Implementation Plan for PM10

Recordkeeping (unpaved roads): Maintain a daily log which shall include the following information:
a. which roads were watered; b. date and time of watering; c. quantity of water used; d. method of application for each application; e. water tank size, total area of roads to be watered and number of fills necessary to accomplish the required application rate; f. records of watering equipment breakdowns and repairs. If water was not applied because the facility was not in operation, there was no traffic on the roads, was frozen or snow covered, or there was rainfall, the log shall note the reason for no watering. The method of rainfall measurement shall be either National Weather Service (St. Paul/Holman Field) data or an on-site rain gauge. Title I Condition: State Implementation Plan for PM10; Minn. R. 7007.0800, subp. 5A

To eliminate track-out of mud onto the paved roads, wash the entire concrete exit driveway at least twice per day in non-frozen conditions. These washings shall be recorded in the road watering log. Title I Condition: State Implementation Plan for PM10

High pressure wash the paved surface of Childs Road (to the side gutters) in front of the facility at least once per day when trucks are hauling from the facility. The washing shall be conducted in both directions to the extent that track-out of sediment from the facility can be seen on Childs Road. Title I Condition: State Implementation Plan for PM10

Recordkeeping (paved roads): Maintain a daily log which shall state the date and time of washing. If water was not applied because trucks were not hauling, the log shall note the reason for no watering. Title I Condition: State Implementation Plan for PM10; Minn. R. 7007.0800, subp. 5AAttachment 4: Marked Up Findings and Order1

## Summary of Comments on JL_Shiely Order.pdf Page: 2

Number: 1 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:19:51 PM -06'00' This limit has been removed, as the aggregate heater has been replaced and no longer has an associated stack. Therefore, there would be no method of complying with the limit. The change in fuel type makes the limit obsolete1

2

3

### Page: 3

Number: 1 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:22:43 PM -06'00' All emission units are still subject to opacity limits that are derived from Minnesota's SIP-approved opacity rules and have be come more stringent since this Order was written. The limits were NOT cited as Title SIP conditions on most emission units because the original limitation basis did not show tha t they were necessary to maintain NAAQS compliance. Number: 2 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:20:17 PM -06'00' This has been retained as a Title I SIP Condition on EU026. Number: 3 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:23:00 PM -06'00' Limitation maintained on EU0261

2

3

4

5

6

7

### Page: 4

Number: 1 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:23:48 PM -06'00' These requirement were maintained, on page A9 of the joint document for FS 019. Number: 2 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:24:50 PM -06'00' This was modified slightly to clarify that water is not required when the ground is frozen or there is snow cover. Number: 3 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:25:05 PM -06'00' These requirement were maintained, on page A9 of the joint document for FS 019. Number: 4 Author: cneusch Subject: Cross-Out Date: 2/20/2009 1:25:18 PM -06'00'

Number: 5 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:25:34 PM -06'00' Changed in later amendment Number: 6 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:26:23 PM -06'00' Requirement is on GP003, page A7. Requirement was modified slightly to clarify that this takes effect once the product pile is established. Number: 7 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:26:41 PM -06'00' Continued for GP003, page A71

2 3

4

### Page: 5

Number: 1 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:27:09 PM -06'00' Compliance testing completed. Number: 2 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:29:36 PM -06'00' Any exceedances of the opacity limitations are required to be reported in the SIP Annual Report requirement shown on Page A2. Number: 3 Author: cneusch Subject: Highlight Date: 4/21/2009 12:15:00 PM

Number: 4 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:30:12 PM -06'00' Maintained under "Activities not Requiring a Modification to the SIP" on page A-11

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Number: 1 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:30:43 PM -06'00' Maintained under "Activities not Requiring a Modification to the SIP" on page A-1 Number: 2 Author: cneusch Subject: Highlight Date: 4/21/2009 12:15:22 PM

Number: 3 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:32:37 PM -06'00' This condition was not included because the area did attain the PM10 NAAQS by the specified date.1

2

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Number: 1 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:37:10 PM -06'00' Page A2 Number: 2 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:37:43 PM -06'00' page A21

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Number: 1 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:38:24 PM -06'00' Page A9, FS 019 Number: 2 Author: cneusch Subject: Highlight Date: 4/21/2009 12:15:41 PM

Number: 3 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:39:19 PM -06'00' Page A2 Number: 4 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:39:49 PM -06'00' Page A21

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Number: 1 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:39:46 PM -06'00' Page A2 Number: 2 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:40:20 PM -06'00' Required under Minnesota's general SIP-approved compliance and enforcement rules. Number: 3 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:40:41 PM -06'00' page A21

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Number: 1 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:41:34 PM -06'00' Page A21

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Number: 1 Author: cneusch Subject: Highlight Date: 2/20/2009 1:42:11 PM -06'00'

Number: 2 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:42:55 PM -06'00' Page A2 Number: 3 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:43:16 PM -06'00' Page A21

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Number: 1 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:44:01 PM -06'00' Page A1, Activities Requiring a Modification to the SIP. Number: 2 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:44:27 PM -06'00' No longer relevant. Offset rule approved.

## Summary of Comments on JL_Shiely_Am2.pdf This page contains no comments1

2

### Page: 2

Number: 1 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:51:36 PM -06'00' Page A9, FS 019 Number: 2 Author: cneusch Subject: Sticky Note Date: 2/20/2009 1:51:44 PM -06'00' Page A2

### STATE OF MINNESOTA MINNESOTA POLLUTION CONTROL AGENCY



### In the Matter of J. L. Shiely Company Proceedings to Develop 

### AMENDMENT THREE and Implement a State Implementation TO AMENDED Plan for the Ramsey County PM- 10 FINDINGS Nonattainment Area to Demonstrate, 

### AND ORDER Attain and 

### Maintain Compliance with the National Ambient Air 

### Quality Standards for particulate matter as Required by Sections 1 10,172 and 189 of the Clean Air Act, 42 U.S.C. 

## $9 7410,7502 and 7513a

The Minnesota Pollution Control Agency (MPCA), being fully advised in the premises and with the consent of J.L Shiely Company, hereby adopts this Amendment Three to the Amended Findings and Order (hereinafter Original Order) that was 

### issued to J.L Shiely Company on August 25, 1992. The Original 

### Order was issued to J.L Shiely Company and is part of Minnesota's State Implementation Plan (SIP) to control emissions of particulate matter 

### in Ramsey County. The SIP, including the 

### Original Order, has been approved by the U.S. Environmental Protection Agency (EPA). Amendment One to the Original Order was submitted to EPA on March 9, 1994. Amendment Two to the Original Order was submitted to EPA on December 22, 1994. The MPCA intends to submit this Amendment Three to the EPA for approval as part of the SIP.



### In making the changes, underline denotes additions and strikethrough denotes deletions to the original language.

### 1. 

### Amendment Three authorizes the following revision tocPart 

### I.A.2. of the Original Order:

Part 

### I.A.2.: The Company shall not exceed the opacity limits 

### as specified in the table below:

Emission Point Nos. Emission Limit Limitation Basis

4-4 

### 20% opacity; except that a 

### maximum of 

### Min.. Rules pt. WE.! ! 

### 19 

### 3-4 40% opacity shall be permissible for four 

### 701 

### 1 .0105 minutes 

### in any 

### 60 minute period



### 5 20% opacity 

### Minn. 

### SIP modeled PM 

### 10 ambient air standard compliance



### W-4 20% opacity; except that a 

### maximum of 

### Minn. Rules pt. 3885.1 ! 

### 13 6-9. 12-14, 40% opacity shall be permissible for four 

### 7- minutes 

### in any 

### 60 minute period


### 15,16 20% opacity 

### Minn. Rules pt. 

### 388W 

# m

17 20% opacity; except that a 

### maximum of 

### Minn. Rules pt. 

### X5. ! ! ! 

### 9 

### 40% opacity shall be permissible for four 

### 701 1.0105 minutes in 

### any 

### 60 minute period



### 18 20% opacity 

### Minn. Rules pt. 

### 3885.: 128 

### 7011.0110

19 

### 20% opacity; except that a 

### maximum of 

### Minn. Rules pt. 7-W

### 40% opacity shall be permissible for four 

### 701 1.0105 minutes 

### in any 

### 60 minute period

### 2. 

### Amendment Three authorizes the following revision to the table in Part I.B. of the Original Order: Compliance Emission Determination 

### Minimum Testing Point Pollutant Method Frequency Procedures

5 

### PMlO [no change] [no change] [no change]

1 through 19 

### 3-9.12-22 Opacity [no change] [no change] [no change]

3. 

### Amendment Three authorizes revisions to Exhibit 1 of the Original 

### Order as Attachment 1 

### to this Amendment Three.

Amendment Three shall become effective on the date it is executed by the MPCA Air 

### Quality Division Manager. Except as expressly amended herein, all 

### provisions of the Original Order and Amendment One remain unchanged and in 

### fdl force and effect.

IT IS SO ORDERED BY 

### THE MINNESOTA POLLUTION CONTROL AGENCY:

8 

### 9. 

### Lisa 

### 3'. Tho& Y 

# 4 Air 

### Quality bivision Manager

, 

### Minnesota Pollution Control Agency

Date: 

### 2/11/45

I

### ATTACHMENT 

### 1

Exhibit 

### 1 Facility Description



### I. Overview

J.1. 

### Shiely Company operates an aggregate storage and distribution 

### facility (Yard 

### A) on Chile Road 

### in St. Paul. Aggresate fiom the Permittee's Nelson and Larson facilities is transported by barge to this yard.

Yard A is not subject to any New Source Performance Standards (NSPS) under 40 CFR
.
. 

### Part 60, Subpart 

### 000. Yard A is not defined 

### as a "nonmetallic mineral proc~ssing plant" under 

### 40 CFR Part 

### 60, Subpart 

### 000 

### 60.671 since there is no equipment to perform crushing or grinding.



### . 11. 

### Emission 

### Units and Pollution Control Equipment

The emission units, 

### air pollution control equipment and monitoring equipment at the

, 

### .- 

### emission facility described above include the following:

### Emission Point No. 

### 3 ' 

### Facility I. 

### D. Conveying to Product Piles

Emission Unit- Type: Belt conveyor Mfi.: Barber Green Date Manufactured: 1958 Date Installed: 1958 Size: 24 inches wide x 

### 127 feet long

Control Equipment- Type: None Monitoring Equipment- Type: None

Stack Parameters- Height: NIA

Emission Point No. 4 

### Facility I. D. Conveying to Product Piles

Emission Unit- - 

### Type: Radial stacker 

### M.: Barber Green Date Manufactured: 195 8 Date Installed: 1958 Size: 24 inches wide x 

### 150 feet long

Control Equipment- Type: None Monitoring Equipment- Type: None

Stack Parameters- Height: NIA

Emission Point No. 

### 5 Facility I. D. Aggregate Heater

. 

### Emission Unit- Type: Rotary heater Mfi.: 

### Madsen Date Manufactured: 1958 Date Installed: 1958 Model: 25048 Fuel Permitted to Burn: No. 1 diesel Rated Heat Input: 6 million 

### Btuh

### Control Equipment- Type: 

### Mi?.: Model:
Monitoring Equipment- Type:

Stack Parameters- Height: Inside Exit Diameter: Exhaust 

### Gas Flow Rate: Exhaust 

### Gas Exit Temperature: Cyclone Iowa Manufacturing Company CH-80A

None

30 feet 2 feet 15,000 acfm 200°F

Emission Point No. 

### 6 Facility I. D. Conveying to Loadout Bins

Emission Unit- Type: Belt conveyor M.: 

### J.L. Shiely Company Date Manufactured: 1958 Date Installed: 1958 Size: 24 inches wide 

### x 23 1 feet long Control Equipment- Type: None Monitoring Equipment- Type: None Stack Parameters- Height: NIA

Emission Point No. 7 

### Facility I. D. Conveying to Loadout Bins Emission Unit- Type: Belt conveyor 

### M.: J.L. Shiely Company Date Manufactured: 1958 Date Installed: 1958 Size: 24 inches wide 

### x 217 feet long

, 

### Control Equipment- Type: None Monitoring Equipment- Type: None Stack Parameters- Height: NIA

### Emission Point No. 

### 8 Facility 

### I. 

### D. Conveying to Loadout Bins

Emission Unit- Type: Belt conveyor Mfr.: J. 

### L. Shiely Company Date Manufactured: 1958 Date Installed: 1958 Size: 24 inches wide 

### x 300 feet long

Control Equipment- Type: None Monitoring Equipment- Type: None

Stack Parameters- Height: NIA

Emission Point No. 9 

### Facility 

### I. D. 

### Loadout Bins

Emission Unit- Type: Three steel 

### bins Mfk.: J. 

### L. Shiely Company Date Manufactured: 

### 1 95 8 Date Installed: 

### 1 958 Model: 80 ton capacity per bin


### Control Equipment- Type: None Monitoring Equipment- Type: None

Stack Parameters- Height: NIA

### Emission Point No. 12 

### Facility 

### I. D. Conveying to Product Piles

Emission Unit- Type: Belt conveyor 

### Mfr.: Barber Green Date Manufactured: 1 95 8 

### Date Installed: 1958 

### Size: 24 

### inches wide x 127 

### feet long

Control Equipment- Type: None Monitoring Equipment- Type: None

Stack Parameters- Height: N/A



### Emission Point No. 13 

### Facility 

### I. D. Conveying to Product Piles

Emission Unit- Type: Radial stacker 

### Mfi.: Barber Green Date Manufactured: 1958 r 

### Date Installed: 1958 

### Size: 24incheswidex150feetlong Control Equipment- Type: None Monitoring Equipment- Type: None

Stack Parameters- Height: N/A

### Emission Point No. 

### 14 

### Facility 

### I. D. Conveying to Loadout Bins



### - Emission Unit- Type: Belt conveyor 

# m.: J. L. Shiely Company Date Manufactured: 1958 Date Installed: 195 8 Size: 36 inches wide 

### x 165 feet long

Control Equipment- Type: None Monitoring Equipment- Type: None Stack Parameters- Height: NIA

Emission Point No. 15 

### .Facility I. D. Conveying to Loadout Bins

Emission Unit- Type: Belt conveyor Mfi.: J. 

### L. Shiely Company Date Manufactured: 1 988 Date Installed: 1988 Size: 36 inches wide 

### x 225 feet long
Control Equipment- Type: None Monitoring Equipment- Type: None Stack Parameters- Height: NIA

Emission Point No. 

### 16 Facility 

### I. D. Conveying to Loadout Bins

Emission Unit- Type: Belt conveyor Mfi.: Marco Date Manufactured: 1 988 DateInstalled: 1988 Size: 3 6 inches wide 

### x 1 50 feet long

Control Equipment- Type: None Monitoring Equipment- Type: None

Stack Parameters- Height: N/A- 

### Emission Point No. 

### 1'7 Facility 

### I. D. Loadout Bins

Emission Unit- Type: Steel bin M.: 

### J. L. Shiely Company Date Manufactured: 

### 1958 Date Installed: 

### 1958 Model: 

### 80 ton capacity Size: 

### 10 foot diameter

Control Equipment- Type: None Monitoring Equipment- Type: None

- 

### Stack Parameters- Height: NIA



### Emission Point No. 

### 18 Facility 

### I. D. Loadout Bins

Emission Unit- Type: Steel bin 

### M.: MSM Charter Date Manufactured: 

### 1988 Date Installed: 

### 1988 Model: 

### 100 ton capacity Control Equipment- Type: None Monitoring Equipment- Type: None

Stack Parameters- Height: NIA



### Emission Point No. 

### 19 Facility 

### I. D. Barge Unloading

Emission Unit- Type: Crawler Crane 

### M.: American Date Manufactured: 

### 195 8 Date Installed: 

### 195 8 Model: 

### 7250L#65 15562 Control Equipment- Type: None Monitoring Equipment- Type: None

Stack Parameters- Height: N/A

### Emission Point No. 20 

### . . acilitv 

### I. D. Hw

Tne: 

### MXt!q2my ufactured: 1995 

### Date Installed: A~prox. April. 

### 1995 Model: YAHI Capacity: 

### 700 tons horn

Tee: None

Stack Pmeters- Height: N/A



### . 

## . . . mlsslon Point No. 21 

### acilitv 

### I. 

### D. Directional 

### Convevor



### TF~: Relt Conveyor



### . . 

### Su~erior Date Manufactured: Unknown

Model: YAI 

### 700 tons per how

Monito- Eauaent- Tv~e: None

Parameters- Height: N/A

22 

## . . Emission Point No. acihtv 

### I. D. D~esel Backhoe

. 

### Mfr. : 

### CAT
, 

### ufactured: 1995 

## DateInstalled: A~nl 1995 

### Model: 244 

### BT Fuel Burned: Diesel fuel Type: None

None

Stack Parameters- Heigbt: NIAAttachment 5: Revocation of Findings and OrderSTATE OF MINNESOTA MINNESOTA POLLUTION CONTROL AGENCY

In the Matter of J. L. Shiely Company Proceedings to Develop and Implement REVOCA nON OF
a State Implementation Plan for the AMENDED FINDINGS Ramsey County PM -10 Maintenance AND ORDER Area to Demonstrate, Attain and Maintain Compliance with the National Ambient Air Quality Standards for PM IO as required by Sections 110, 172, and 189 of the Clean Air Act, 42 U.S.c. § § 7410, 7502, and 7513a.
Whereas, the Amended Findings and Order (hereinafter Order) was issued to IL. Shiely Company located at 1177 Childs Road in Saint Paul, Ramsey County, on August 25, 1992 and subsequently amended on January 12, 1994, December 21, 1994, and February 21, 1995;

Whereas the Order and subsequent amendments were approved by the U.S. Environmental Protection Agency (EPA) as revisions of Minnesota's State Implementation Plan (SIP) to control emissions of particulate matter (PM\o) in Ramsey County;

Whereas Aggregate Industries now owns and operates the facility at 1177 Childs Road;

Whereas Aggregate Industries was issued an air quality permit (Air Emission Permit No. 12300007- 002) on April 23, 2009, which includes and identifies those Title I SIP conditions that are included in the Order;

Whereas the issuance of the Air Emission Permit with Title I SIP Conditions renders the Order unnecessary and duplicative;
NOW, THEREFORE, the MPCA revokes the Amended Findings and Order and subsequent amendments issued to J.L. Shiely Company (now Aggregate Industries)

This Revocation shall become effective on the date that EPA approves Air Emission Permit No. 12300007-002 into Minnesota's State Implementation Plan and removes the Order from the SIP. All conditions of the Order remain federally enforceable until Air Emission Permit No. 12300007-002 into the SIP.

IT IS SO ORDERED BY THE MINNESOTA POLLUTION CONTROL AGENCY:

Dated: 

## S J I 

### S 

# I 

# 01
Paul Eger Commissioner Minnesota Pollution Control AgencyAttachment 6: Public NoticeMINNESOTA POLLUTION CONTROL AGENCY PUBLIC NOTICE ON DRAFT/PROPOSED AIR EMISSION FACILITY PERMIT

NOTICE IS HEREBY GIVEN , that the Commissioner of the Minnesota Pollution Control Agency (MPCA) proposes to issue Air Emission Permit No. 12300007-002 to Aggregate Industries Inc - Yard A for their facility located at 1177 Childs Rd, St. Paul, Ramsey County, Minnesota. In addition, NOTICE IS HEREBY GIVEN that the Commissioner has determined that the State Implementation Plan (SIP) conditions for this facility should be amended. This permit incorporates Title I requirements for Aggregate Industries, Inc. – Yard A, that are included in an Administrative Order (Order) issued to the facility (then known as J.L. Sh iely Company) in 1992 and subsequently amended. The Order is included in Minnesota’s SIP and cont ains conditions that are necessary to demonstrate compliance with the National Ambient Air Quality Standards (NAAQS) for particulate matter less than 10 microns (PM 10 ). Under its Title I authority, the MPCA is revising the SIP conditions and will be formally requesting that the U.S. Environmental Protection Agency (EPA) amend Minnesota’s SIP to include the new revised Title I SIP conditions from Air Emissions Permit No. 12300007-002, which will serve as a joint Title I SIP/FESOP document. These Title I Conditions do not expire. 1) Proposed Permit The permit action is for operation of the facility

. The permit action is a major amendment to a state operating permit; therefore, the draft/proposed permit has been placed on public notice. This major amendment will clarify a Title I Condition regarding a State Implementation Plan (SIP) for PM 10 originating from an Administrative Order for th e facility issued August 25, 1992. This amendment will also update permit language for the aggregate h eater (EU026) and also update opacity limits for GP001 and GP002. SV001 is being removed from the f acility description. Total facility permit language is being updated to meet current MPCA policy. There are no emissions increases of any criteria pollu tants associated with this major amendment.

Pollutant PM PM 10 PM 2.5 SO 2 NO X VOCs CO Lead Total Facility PTE 83* 42* NA 0.04 6.9 0.4 5.8 0 Facility Emissions (2008) 32.34 11.96 NA 0 0.06 0 0.05 0

PM = Particulate Matter PM 10 = PM smaller than 10 microns PM 2.5 = PM smaller than 2.5 microns SO 2 = Sulfur Dioxide NO X = Nitrogen Oxides VOCs = Volatile Organic Compounds CO = Carbon Monoxide *: Totals do not include fugitives The Permittee is not required to submit a pollution prevention progress report pursuant to Minn. Stat. § 115D.08. 2) Proposed SIP Changes This permit incorporates Title I requirements for Aggregate Industries that are currently included in an Order issued to J.L. Shiely Company that is part of Minnesota’s SIP. This SIP revision is intended to update the ownership of the facility in the SIP and replace the Order by incorporating all applicable requirements into this permit, which will serve as a joint Title I/FESOP document. This SIP revision also requests changes to the requirements for the aggregat e heater (EU026) and generally updates the facility in the SIP. Aggregate Industries is located in a maintenance area for PM 10 . The MPCA believes that the changes proposed in this notice will not have an adverse im pact on compliance with the NAAQS for this pollutant.3) Public Participation The preliminary determination to issue the air emi ssion permit and submit the SIP revision is tentative. There are four formal procedures for public particip ation in the MPCA’s consideration of the permit application and SIP revision. Interested persons may (1) submit written comments on the proposed permit and SIP revision; (2) request that the MPCA hold a public information meeting; (3) request the MPCA hold a contested case hearing; and/or (4) submit a petition to the Commissioner requesting that the MPCA Board consider the permit and SIP revision matter. The decision whether to issue the permit and submit the SIP revision and, if so, under what terms, will be presented to the MPCA Board for decision if: (1 ) the Commissioner grants the petition requesting the matter be presented to the MPCA Board; (2) an MPCA Board member requests to hear the matter prior to the time the Commissioner makes a final decision on the permit; or (3) a request for a contested case hearing is pending. Otherwise, the Commissioner will make the decision. Persons who submit comments or petitions to the MPCA must state (1) their interest in the permit application or the draft permit and proposed SIP revi sion; (2) the action they wish the MPCA to take, including specific references to the section of the dr aft permit and proposed SIP revision they believe should be changed; and (3) the reas ons supporting their position, stated with sufficient specificity as to allow the MPCA to investigate the merits of the position. As described in Minn. R. 7000.1800, persons who submit requests for a contested case hearing must also state the issues they propose to address in a contested case hearing, the specific relief requested or resolution of the matter, and the reasons (which ma y be in the form of proposed findings) supporting an MPCA decision to hold a contested case hearing. Failure to comply with these rules exactly may result in a denial of the request. The decision whether to hold a contested case hearing will be made under Minn. R. 7000.1900. Most public libraries throughout the state have copies of the current Minnesota Rules. They are also available on the Internet at www.revisor.leg.state.mn.us

. The public comment period commences March 22, 2009, and terminates April 20, 2009. Comments must be received in writing at the MPCA by 4:30 p.m. on April 20, 2009. The request that the MPCA hold a public information meeting must be received in writing at the MPCA by 4:30 p.m. April 20, 2009. Evidence of timely receipt includes a date/time stamp imprinted on the first page of the written comments by the first floor information and reception area of the MPCA or by the Industrial Division support staff, or receipt by fax. Persons interested in requesting a contested case hearing on the proposed permit must submit their request during the public comment period est ablished in this notice. Requests for a contested case hearing must satisfy the criteria established in Minn. R. 7007.1800. A public information meeting will only be held if one is requested during the public comment period. If such a meeting is requested, it will be held from 3:00 p.m. to 4:00 p.m. on Thursday, April 23, 2009, at the MPCA St. Paul Office, 520 Lafayette Road Nort h, St. Paul, Minnesota. To find out if a public meeting will be held, please call Catherine Neusch ler at 651-757-2607, after the close of the public comment period. The public information meeting will provide information, receive public input, and answer questions about both the proposed permit and SIP revision.Comments, requests, and petitions should be sent to: Permit: Tarik Hanafy, Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155, Phone 651-757-2404, Fax 651-296-8717 SIP Revision: Catherine Neuschler, Minnesota Po llution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155, Phone 651-757-2607, Fax 651-297-8324

A copy of the draft/proposed permit w ill available on the MPCA’s website at http://www.pca.state.mn.us/news/data/index.cfm?PN=1 , or will also be mailed to any interested person upon the MPCA's receipt of a written request. Inform ation on the SIP revision will be available on the MPCA’s website at http://www.pca.state.mn.us/air/sip.html . Additional materials relating to the issuance of this permit are available for inspection by appoi ntment at the Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155, phone 651-757-2404, between the hours of 8:00 a.m. and 4:30 p.m., Monday through Friday. All MPCA offices may be reached by calling 1-800-657-3864.
DATED: March 12, 2009

Don Smith, P.E., Manager Air Quality Permits Section Industrial DivisionAttachment 7: Completeness Review
A. Administrative Materials (40 CFR pt. 51, Appendix V, Part 2.1)
The EPA’s Criteria for Determining the Comple teness of Plan Submittals, published at 40 CFR pt. 51, Appendix V (2001), requires st ates to provide the basic documents that show that the State has properly followed th e administrative requirements called for by the CAA for the adoption of SIPs. The requirements, and how this SIP revision complies with these requirements, are discussed here:
1) Formal Letter of Submittal:

“A formal letter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof.”
Attached to this SIP revision request is a formal letter of submittal from the MPCA Commissioner, Paul Eger, to the EPA Region V Acting Administrator, Bharat Mathur. The office of the Commissioner of the MPCA is statutorily created at Minnesota Statute § 116.03, subd. 1 (a) (2000). The Commissioner is appoin ted by the Governor, and the duties of the position include acting as the state agent to “apply for, receive, and disburse federal funds made available to the state by federa l law or rule and regulations promulgated thereunder for any purpose related to the power and duties of the MPCA or the Commissioner. The Commissioner shall comply with any and all re quirements of such federal law or such rules and regulations promulgated thereunder to facilitate application fo r, receipt, and disbursement of such funds.” Minn. Stat. § 116.03 subd. 3 (2000).
2) Evidence of State Adoption of Plan and Issuance of Orders in Final Form
“Evidence that the State has adopted the plan in the State code or body of regulations; or issued the permit, order, consent agreement (hereafter ‘document’) in final form. That evidence shall include the date of adoption or fi nal issuance as well as the effective date of the plan, if different from the adoption/issuance date.”
This SIP revision request is based on the Administra tive Orders previously issued to the facility. As J.L. Shiely, the facility was issued an Ad ministrative Order (Amende d Findings and Order) to control PM 10 emissions on August 25, 1992. The Order has been subsequently amended; the most recent SIP action was approval of Amen dment Three, signed on February 21, 1995 and approved into the SIP on April 3, 1998 (63 FR 16435).
In a letter dated June 15, 2006, EPA approved a pr ocess for placing SIP conditions in permits, resulting in joint Title I/perm it documents, and MPCA has ensured that this permit clearly follows the guidance in that letter for serving as a joint document. Therefore, the joint Title I/permit document includes relevant SIP conditi ons, labeled “Title I Condition: SIP for PM10 NAAQS.” All Title I conditions are non-expiring. Attachment 4 shows where all the relevant conditions from the Administrative Order were placed into the joint document.The permit has been subsequently amended, becoming permit No. 03700015-002, without any changes to the Title I SIP conditions. SIP condi tions are changing in this joint document, but will not become effective until permit N o. 03700015-004 is approved into the SIP by EPA.
Attached to this document (Att achment 1) is a copy of the re levant permit, which became effective at the state level as soon as it was signed by the Commissioner.
3) Legal Authority Documentation:
“Evidence that the State has the necessary le gal authority under St ate law to adopt and implement the plan.”
This SIP revision request is based on the MPCA’s PM 10 SIP revision submitted to the EPA in 1992, which contained an Administrative Order for th e J.L. Shiely facility. Attachment 1 of Appendix C of the original July 1992 submittal documents MPCA’s legal authority to adopt ambient air quality standards for PM 10 , issue orders to sources to control their emissions, and to enforce those rules and orders.
On May 2, 1995, EPA approved MPCA’s revised ope rating permit program as a SIP revision (60 FR 21447). MPCA submitted the operating permit pr ogram for inclusion in the SIP in part so that permits issued under the program could be considered federally enforceable vehicles for imposing emissions limitations on culpable s ources located in nonattainment areas.
Attachment B of MPCA’s November 4, 1998 submittal of a PM 10 SIP revision for Olmsted County (approved on March 9, 2001 in 66 FR 14087) further documents MPCA’s legal authority to issue, modify or revoke permits, as well as to enforce those permits.
EPA’s conclusion that MPCA has the authority to issue permits with non-expiring Title I SIP conditions in order to replace Admi nistrative Orders has been further documented in an April 4, 1997 letter from Michael Sandusky of the MPCA to David Kee of EPA Region 5, a July 3, 1997 letter from David Kee of EP A Region 5 to Michael Sandusky of the MPCA and in a June 15, 2006 letter from Jay Bortzer of EPA Region 5 to David Thornton of the MPCA. Copies of these letters have been included in other recent SIP revisions.
4) Compliance with State Procedures:
“Evidence that the state followed all of the pr ocedural requirements of the State’s laws and constitution in conducting and completi ng the adoption/issuance of the plan.”
MPCA complied with all relevant state procedures for issuing the permit as well as the SIP revision.
5) Public Notice:
“Evidence that public notice was given of the pr oposed change consistent with the procedures approved by the EPA, including the date of the publication of the notice.”The public notice for the permit and associatedSIP revision was published in the St. Paul Pioneer Press on March 21, 2009, with the pub lic comment period commencing on March 22, 2009 and ending on April 20, 2009. The St. Paul Pi oneer Press is a newspaper with general circulation in Ramsey PM 10 area. During the public commen t period, a copy of the permit and SIP revision request was made available at the MPCA office lo cated in St. Paul and on the MPCA’s website. A copy of the public notice is attached. (Attachment 6).
6) Public Hearing Certification
“Certification that public hearin g(s) were held in accordance w ith the information provided in the public notice and the State’s laws and constitution, if applicable.”
The public notice states: “A public information m eeting will only be held if one is requested during the public comment period. If such a meeting is requested, it will be held from 3:00 p.m. to 4:00 p.m. on April 23, 2009, at the MPCA St . Paul Office, 520 Lafayette Road North, Minnesota. To find out if a public meeting will be held, please call Catherine Neuschler at 651- 757-2607, after the close of the public comment period. The public information meeting will provide information, receive public input, and an swer questions about both the proposed permit and SIP revision.”
No public meeting was requested.
7) Public Comments and State Response:
“Compilation of the public comments and State’s response thereto.”
The MPCA did not receive any comments during th e public notice period for the SIP revision.
B. Technical Support:
1) Pollutants Regulated:
“Identification of all regulated po llutants affect by the plan.”
The regulated pollutant subject to this SIP revision request is PM 10 . 2) Source Identification

“Identification of the locations of affected so urces including the EPA attainment/nonattainment designation of the locations and the state of the Attainment Pl an for the affected area(s).”

The affected source within the former Childs Road PM 10 nonattainment area is the Aggregate Industries Yard A facility. Further informati on on the facility is included in the attached Technical Support Document.3) Emissions Quantification:
“Quantification of the changes in the plan; allowable emission s from the affected sources; estimates of changes in current actual emissions from affected sources or, where appropriate, quantification of the cha nges in actual emissions through calculations of the differences between certain baseline levels and allowable emissions anticipated as a result of the revision.”
The changes in this SIP do not increase emi ssions from the facility (shown in the permit Technical Support Document). The change to the a ggregate heater is likely to result in decreased emissions, as the new heater has a lower poten tial to emit but the permit maintains emission limitations established to ensure NAAQS complian ce for a heater with higher hourly emissions. Further details on emissions can be f ound in the permit TSD, Attachment 2.
4) NAAQS Protections:

“The State’s demonstration that the NAAQS, prevention of signifi cant deterioration increments, reasonable further progress demonstration, and visibi lity, as applicable, are protected if the plan is approved and implemented.”
As stated above, this SIP revision results in mini mal changes. The changes are likely to result in decreased emissions, thereby ensuring th at the NAAQS will be protected.
5) Modeling Information
“Modeling information required to support the proposed revision, including input data, output data, models used, justification of the mode l selections, ambient monitoring data used, meteorological data used, justifi cation for use of off-site data (where used), modes of models used, assumptions, and other information relevantto the determination of adequacy of the modeling analysis.”
Modeling was not performed due to the minimal changes in the SIP revision.
6) Continuous Emission Reduction
“Evidence, where necessary, that emission limitations are based on continuous emission reduction technology.”
These requirements are included in the permit a nd joint Title I/permit document issued to the source. This document is attached as Attachment 1.
7) Emission Level Assurance
“Evidence that the plan contains emissi on limitations, work practice standards and recordkeeping/requirements, where nece ssary, to ensure emissions levels.”Again, the above requirements are addressed in th e permit and joint Title I/Title V document as shown in Attachment 1.
8) Compliance/Enforcement
“Compliance and enforcement strategies, incl uding how compliance will be determined in practice.”
The above requirements are addressed in the perm it and joint Title I/Title V document as shown in Attachment 1.
9) Special Economic and Tec hnological Justifications:
“Special economic and technological justifications required by a ny applicable EPA policies, or an explanation of why such justifications are not necessary.”
This requirement does not apply to this submittal.

Conclusion
The MPCA expects that the Childs Road PM 10 area will continue to remain in compliance with the NAAQS, as this revision results in lower ambi ent impacts from this facility, and requests approval of this SIP revision.