IN THE CIRCUIT COURT OF HOLT COUNTY 

STATE OF MISSOURI 

STATE OF MISSOURI ex rel., )

Attorney General Chris Koster 

and Missouri Department of 

Natural Resources and the Missouri 

Air Conservation Commission, 

)

) 

) 

) 

 )

 Plaintiff )

 )

 v. ) Case No.

 )

Exide Technologies )

)

) 

 Respondent. )

CONSENT JUDGMENT 

Plaintiff State of Missouri, at the relation of Chris Koster, Attorney 

General, the Missouri Department of Natural Resources (MDNR), and the 

Missouri Air Conservation Commission (Commission), and respondent, the 

Exide Technologies Canon Hollow Recycling Facility located 4 miles 

northwest of Forest City, Missouri (Exide), by and through counsel, hereby 

consent to the entry of this Consent Judgment. 

WHEREAS, the State of Missouri, through MDNR, in consideration of 

Exide's agreement to complete the control strategies within the time 

schedules as more fully set forth in the Consent Judgment below, and Exide, 

in consideration of the State of Missouri's agreement to accept the 

implementation of said control strategies as sufficient, under current 
2 

information and belief, to attain and maintain the federal and Missouri 

ambient air quality standard for lead and to accept the time schedules for 

completion of such control strategies as being as expeditious as practicable, 

agree to entry of this Consent Judgment. 

WHEREAS, in 2008, Environmental Protection Agency revised the 

National Ambient Air Quality Standard for lead (2008 Lead NAAQS). 73 Fed. 

Reg. 66,964 (Nov. 12, 2008). The revision reduced the NAAQS for lead from 

1.5 micrograms per cubic meter (μg/m3) to 0.15 μg/m3 over specified 

monitoring and averaging periods. Starting in Spring 2012, some lead air 

quality monitoring results at the MDNR’s recently-installed Forest City / 

Exide levee monitoring site in northwestern Missouri showed violations of 

the 2008 lead NAAQS. Ambient air readings violating a NAAQS may trigger 

State duties to adopt legal requirements to ensure that NAAQS are achieved 

and maintained. 

WHEREAS, MDNR and the Commission are preparing a State 

Implementation Plan (SIP) revision to achieve attainment and maintenance 

of the 2008 Lead NAAQS in the area near the Forest City / Exide levee 

monitoring site, and it is the intent of MDNR and the Commission that this 

Consent Judgment establish the requirements of the SIP applicable to Exide. 

WHEREAS, as part of the 2014 Lead NAAQS Attainment 

Demonstration SIP, MDNR, the Commission, and Exide hereby agree that 
3 

the Court may enter this Consent Judgment, to be binding on the parties, 

providing for a lead emission reduction program which Exide hereby agrees 

to undertake and complete on the schedule set forth in this Consent 

Judgment. The parties, by their signatures hereto, acknowledge that they 

have read and understand the terms of this Consent Judgment and agree to 

be bound thereby. The Court is advised that the parties have consented to 

the terms in this Consent Judgment for settlement purposes only, and that 

their consent is conditioned upon the Court approving the Consent Judgment 

in its entirety. The parties understand and agree that the terms of this 

Consent Judgment are enforceable by further order of this Court, and, to that 

end, the Court retains jurisdiction of the matter in order to enforce the terms 

of this Consent Judgment. 

WHEREAS, this matter comes before the Court on the petition filed by 

the State of Missouri concurrently with this Consent Judgment. 

WHEREAS, by agreeing to the terms of this Consent Judgment, Exide 

does not admit any liability or any violation of law arising from the 

allegations set forth in the State’s Petition. 

NOW THEREFORE, without adjudication or admission of any issue of 

fact and with the consent of the parties, IT IS THEREFORE ORDERED, 

ADJUDGED AND DECREED as follows: 
4 

I. Objectives of the Parties 

1. The objectives of the parties to this Consent Judgment are to 

implement control measures set forth herein in furtherance of the attainment 

and maintenance of the 2008 Lead NAAQS. 

II. Jurisdiction 

2. This Court has jurisdiction over the subject matter herein and of 

the parties consenting hereto pursuant to Section 643.151, RSMo, of the 

Missouri Air Conservation Law. 

III. Parties Bound 

3. The provisions of this Consent Judgment shall be binding upon 

the parties to this action as well as their agents, servants, employees, heirs, 

successors, assigns, and to all persons, firms, corporations, and other entities 

who are, or who will be, acting in concert or privity with, or on behalf of the 

parties to this action or their agents, servants, employees, heirs, successors, 

and assigns. 

IV. Satisfaction 

4. Upon completion of the terms of this Consent Judgment, Exide is 

relieved of liability for violations alleged in the State's Petition. 

V. Injunctive Relief 

5. Exide shall undertake and complete the following lead emission 

reduction program on the schedule set forth below. These control measures 
5 

and the associated schedules are the control measures to be implemented to 

attain and maintain the 2008 Lead NAAQS pursuant to Section 110 of the 

federal Clean Air Act. 

6. Projects Required: Exide shall install the following lead emission 

control measures: 

A. By the date Exide signs this Consent Judgment, Exide has 

installed South baghouse (“Negative Pressure Baghouse 1”) with a 

minimum design flow rate of 315,000 standard cubic feet per minute 

("SCFM") to improve refinery ventilation. 

B. By the date Exide signs this Consent Judgment, Exide has 

installed North baghouse (“Negative Pressure Baghouse 2”) with a 

minimum design flow rate of 315,000 SCFM to improve hygiene 

ventilation. 

C. By the date Exide signs this Consent Judgment, Exide has 

installed Acid Demister stack with a minimum height of 40 feet 

D. By the date Exide signs this Consent Judgment, Exide has 

enclosed all buildings containing the following processes: battery 

breaking, blast furnace, refining and casting, and slag processing. 

Exide shall operate the Negative Pressure baghouses 1 and 2 as needed 

based on furnace operations and the ventilation associated with those 

operations to achieve negative pressure in the operating process 
6 

buildings consistent with the National Emission Standards for 

Hazardous Air Pollutants for Secondary Lead Smelting, 40 C.F.R. 63 

Subpart X (Secondary Lead NESHAP), revised as of January 5, 2012. 

E. Changes may be made to the installed equipment during 

replacement as long as the replacement equipment assures attainment 

of the 2008 Lead and compliance with the Secondary Lead NESHAP. 

7. Required Practices and Procedures. 

A. Baghouse Standard Operating Procedures (SOP): Exide 

has a Baghouse SOP Manual approved by MDNR on August 19, 2013 

pursuant to the Secondary Lead NESHAP, revised as of January 5, 

2012, for sources at the facility subject to the Secondary Lead 

NESHAP. After the applicable deadline for any baghouse projects 

installed pursuant to Paragraph V.6 (Projects Required) or Paragraph 9 

(Projects Required as Contingency Control Measures) and that is not 

otherwise subject to the Secondary Lead NESHAP, any such newly 

installed baghouse(s) shall be subject to the Baghouse SOP, and the 

SOP Manual shall be amended to add procedures applicable to each 

such baghouse. 

B. Baghouse Maintenance or Extended Periods of NonProduction (Shut Downs): Exide may cease the operation of any of the 

ventilation system units used to achieve the appropriate amounts of 
7 

negative pressure as required by paragraph 6.D above in order to 

perform maintenance on the ventilation system, or if all of the lead 

processing units within a given building have been turned off and all 

corresponding production has ceased.

C. Local Exhaust Ventilation (LEV) Operation: Exide shall 

operate LEVs at the following emission units when the units are 

operating: (1) Blast Furnace Charging, (2) Furnace lead and slag 

tapping, and (3) refinery kettles.

D. Fenceline Maintenance: Appendix A indicates the areas 

where modeling has shown the potential for lead levels in ambient air 

to violate the 2008 Lead NAAQS. Appendix A contains a map and 

table of ambient air boundary coordinates as provided in the 2014 Lead 

NAAQS Attainment Demonstration SIP. Exide must preclude public 

access at a minimum distance from the facility as indicated by the 

boundary established in Appendix A. Exide shall notify MDNR of its 

intent to modify the location of any fenceline used to demonstrate 

compliance with this paragraph at least ninety (90) days prior to the 

commencement of construction. 

E. Stack Emission Limits. Exide shall limit lead emissions to 

the atmosphere from certain emission points as set forth in the 

following table: 
8 

Emission 

Point 

Control 

Device 

Emission 

Source / 

Description 

Emission Rate 

(lb/hr) 

AD Acid Demister 

(CD007) 

Battery Break 

Crusher Room 0.024 

EP01 

Wheelabrator 

Air Pollution 

Control System 

Blast Furnace, 

Refinery & 

Casting Process 

Hoods 

0.322 

BH01 

Negative 

Pressure 

Baghouse #1 

(CD005) 

Blast Furnace, 

Refinery & 

Casting Bldg. 

Neg. Pressure 

0.236 

BH02 

Negative 

Pressure 

Baghouse #2 

(CD006) 

Other Building 

Negative 

Pressure 

0.196 

Compliance will be determined via stack testing requirements and on a 

schedule that is consistent with the Secondary Lead NESHAP, revised 

as of January 5, 2012, except as follows. If any test does not show 

compliance with the limits herein, Exide will test the stack that tested 

above the limit within ninety (90) days after the receipt of the stack 

test report or results. If this subsequent test shows compliance, the 

prior exceedance will not be considered a violation of this Consent 

Judgment and compliance testing will return to a schedule consistent 

with the Secondary Lead NESHAP, revised as of January 5, 2012. 
9 

F. Truck Traffic: Frequency and Hours of Operation. Exide 

shall limit truck traffic to the frequency and hours of operation as set 

forth in the following table. 

Group Route 

Description 

Total Trips 

Per Month 

Unrestricted 

Trips Per Month* 

A Cores/Scrap 368 0 Industrials

B 

Furnace Coke

Lime (bulk) 87 4 

Furnace Fluxes

C 

Trash 

Acid (bulk) 61 3 

Plastic Chips

D Cement (bulk) 22 1 Oxygen (liquid)

E Lead Products 260 13 

F Slag Mix to 

Landfill 217 11 

G Service 26 1 

Total 1040 34 

*Note: Restricted trips only use the haul roads 12 hours per day 

(7AM-7PM). Unrestricted trips use the haul roads 24 hours per day. 

G. Recordkeeping and Reporting. Recordkeeping and reporting 

under this Consent Judgment are addressed by the recordkeeping and 

reporting requirements applicable to the facility pursuant to the 

Secondary Lead NESHAP, revised as of January 5, 2012. In addition, 

Exide shall keep records of truck traffic as necessary to demonstrate 

compliance with the hours of operation and monthly frequency limits 

established in this paragraph. 
10 

8. Property Acquisitions in Monitoring Areas 

Exide shall notify MDNR of any real property it acquires or transfers in 

the Forest City area where an MDNR monitor is located or where an 

Exide fenceline required by paragraph V.7.D. to preclude public access 

is located within ninety (90) days of the transaction. This notification 

shall include a copy of the deed or a legal description of the property, 

the interest to be acquired or transferred and the parties to the 

transaction. 

9. Projects required as Contingency Control Measures 

A. Exide shall complete construction or installation, 

commence operation of project and control measures, and achieve 

normal operations within one hundred eighty (180) days of the effective 

date of this Consent Judgment. If the valid and accepted air quality 

data for any rolling three-month average after that date violates the 

0.15 μg/m3 three-month rolling average lead standard, Exide shall 

undertake the Immediate contingency measure specified in the 

following table. 
11 

Facility 

Contingency 

Measure 

Number 

Contingency 

Measure 

Description 

Time Frame 

Canon 

Hollow 1 

Increase the inplant road 

cleaning to 10 

hours each 

working day 

Immediately 

after receipt of 

results 

Additionally, within 180 days from receipt of written or electronic 

notification from MDNR, submit to MDNR an investigative study 

identifying the potential or likely source(s) of emissions principally 

contributing to the exceedance so that a strategy may be developed to 

eliminate the likelihood of another exceedance. The study will list all 

best practices and best available technologies identified from industrial 

smelter or metal manufacturing facilities with similar fugitive 

emissions control challenges, and, for each technology or practice, will 

(i) identify those technologies and/or practices that Exide deems 

technically feasible and cost effective, (ii) quantify associated emissions 

reductions expected to result from the use of the practices or 

technologies, and (iii) provide a time frame for implementation of each 

in a manner that allows attainment of the NAAQS in the most costeffective manner and schedule. Exide will provide justification for any 

projects deemed not to be technically feasible or cost effective or 

necessary for attainment. 
12 

projects deemed not to be technically feasible or cost effective or 

necessary for attainment. 

B. Within 60 days of its receipt of the study, MDNR will 

advise Exide whether the projects and timelines proposed by Exide are 

acceptable and if MDNR agrees that any of the identified technologies 

or practices are not technically feasible or cost effective or necessary. 

Upon approval or after 60 days with no comment, those projects 

identified in the study for completion and the deadlines therein shall 

become a part of this Consent Judgment and fully enforceable 

hereunder as contingency measures and shall be completed pursuant to 

the deadlines. The immediate contingency measure specified above 

need not be a contingency measure proposed under the study if it is not 

selected under the study criteria, and may be halted upon completion of 

the measures specified in the approved study plan. 

C. Exide shall notify MDNR within twenty (20) business days 

of Exide's completion of those contingency projects required by 

paragraph A above. Within 60 days of completion of all required 

contingency projects, Exide shall propose additional contingency 

measure(s) and a proposed timeframe for completion to be added to this 

Consent Judgment. In proposing the additional contingency 

measure(s), Exide shall revisit any of the best practices and best 
13 

available technologies that were identified in the study above and 

previously deemed not to be technically-feasible or cost effective. Upon 

approval by MDNR, the additional contingency measure(s) shall 

become a part of this Consent Judgment and be fully enforceable 

hereunder If Exide identifies and demonstrates to MDNR's satisfaction 

alternative control measure(s) that would achieve attainment with the 

NAAQS, Exide may substitute the new measure(s) for the contingency 

measure(s) identified above, upon approval of the MDNR’s Director of 

the Air Pollution Control Program. Any substitute contingency 

measure shall be implemented under a reasonable time frame to be 

established with the approval of the State as a modified contingency 

schedule. 

D. Nothing in this agreement shall prevent Exide from 

implementing the contingency measures prior to receiving notification 

from MDNR. 

VI. Stipulated Penalties and Force Majeure 

10.

A. If Exide fails to complete construction of the control 

measures set out in this Consent Judgment by the dates specified, 

Exide may be subject to stipulated penalties according to the following 

schedule. The penalties are per day, per violation, and may be assessed 
14 

by MDNR beginning with the first day of violation after the scheduled 

deadline date. 

Period of Noncompliance Penalty per Day of 

Violation 

First through 30th day of 

noncompliance 

$500.00 

31st through 60th day of 

noncompliance 

$2,000.00 

61st through 90th day of 

noncompliance 

$3,000.00 

91st day of noncompliance and 

beyond 

$5,000.00 

B. If a performance test conducted under the requirements of 

Paragraph 7.E of this Consent Judgment fails to demonstrate 

compliance with the emission limits stated therein, Exide may be 

subject to stipulated penalties according to the following schedule: 

First test failure - $1,000 

Second test failure - $2,000 

Third test failure - $3,000 

Fourth (and beyond) test failure – $5,000 

C. If Exide fails to comply with any other requirements of this 

Consent Judgment, Exide may be subject to stipulated penalties 

according to the following schedule. The penalties are per day, per 
15 

violation, and may be assessed by MDNR beginning with the first day 

of violation after the scheduled deadline date. 

Period of Noncompliance Penalty per Day of 

Violation 

First through 30th day of 

noncompliance 

$200.00 

31st through 60th day of 

noncompliance 

$400.00 

61st through 90th day of 

noncompliance 

$600.00 

91st day of noncompliance and 

beyond 

$800.00 

11. If any violation is enforceable under more than one provision of 

this Consent Judgment or regulatory requirement, MDNR will only seek to 

enforce the Stipulated Penalties under this Consent Judgment , but not both, 

against Exide. 

12. All penalties assessed shall be paid within forty-five (45) days of 

the date of receipt of notification of the assessment of a stipulated penalty 

from MDNR unless Exide challenges the penalty pursuant to the Dispute 

Resolution procedure outlined in Section VII. If the penalty is challenged, it 

shall be paid thirty (30) days after the Commission's determination that 

Exide owes the stipulated penalty, and that Exide has failed to use, or has 

exhausted, its rights to review the Commission's decision. If Exide exercises 
16 

its right to appeal a decision of the Commission, payment will be due thirty 

(30) days after a final decision on appeal. 

13. All penalties shall be paid by check made payable to the State of 

Missouri (Holt County Treasurer), and delivered to the Collections Specialist, 

Attorney General of Missouri, P.O. Box 899, Jefferson City, Missouri 65102-

0899. 

14. The penalties set forth herein shall not apply in the event of a 

force majeure, as defined in this section. For the purposes of this Consent 

Judgment, force majeure shall be defined as any event arising from causes 

beyond the control of Exide or its contractors and of any entity controlled by 

Exide or its contractors, which delays or interferes with the performance of 

any obligation under this Consent Judgment notwithstanding Exide’s best 

efforts to avoid such an event and fulfill the obligation. The requirement that 

Exide exercise "best efforts to avoid such an event" includes using best efforts 

to anticipate any potential force majeure event and best efforts to address the 

effects of any force majeure event (1) as it is occurring, and (2) following the 

force majeure event such that the adverse effect or delay is minimized to the 

greatest extent practicable. Examples of events that are not force majeure 

events include, but are not limited to, increased costs or expenses of any work 

to be performed under this Consent Judgment, changed financial 

circumstances, or other financial or budgetary issues. Failure to apply for a 
17 

required permit or approval, or to provide in a timely manner all information 

required to obtain a permit or approval necessary to meet the requirements 

of the Consent Judgment, are not Force Majeure events. 

15. If any event occurs that is likely to delay or interfere with the 

performance of an obligation under this Consent Judgment, whether or not 

caused by a force majeure event, Exide shall notify MDNR by telephone 

within five (5) business days of Exide becoming aware of such event. Within 

ten (10) business days thereafter, Exide shall provide in writing to the State 

an explanation and description of the reasons for the delay; the anticipated 

duration of the delay; all actions taken or to be taken to prevent or minimize 

its effects; a schedule for implementation of any measures to be taken to 

mitigate the event; and a statement as to whether, in the opinion of Exide, 

such an event may cause or contribute to the endangerment of public health, 

public welfare, or the environment. Exide shall include with any notice all 

available documentation supporting the claims that the delay was 

attributable to a force majeure. Failure to comply with these requirements 

shall preclude Exide from asserting any claim of force majeure. 

16. If the State agrees that the delay or anticipated delay is 

attributable to a force majeure event, then the State may agree to extend the 

time for Exide to perform the obligation(s) under this Consent Judgment that 

is affected by the force majeure event for the time necessary to complete 
18 

these obligations. The State will notify Exide in writing of the length of the 

extension, if any, for performance of the obligations affected by the force 

majeure event. An extension of the time for performance of the obligations 

affected by the force majeure event shall not, by itself, extend the time for 

performance of any other obligation. 

17. If the State does not agree that a force majeure event has 

occurred, or does not agree on the length of any time extension sought by 

Exide, Exide may seek review of the State’s decision on the issue pursuant to 

the Dispute Resolution procedures set forth in Section VII of this Consent 

Judgment. In any such proceeding, to qualify for a force majeure defense 

Exide shall have the burden of demonstrating by a preponderance of the 

evidence that the delay or noncompliance has been or will be caused by a 

force majeure event, that its duration was or will be warranted under the 

circumstances, that Exide exercised or is exercising due diligence by using its 

best efforts to avoid and mitigate its effects, and that Exide complied with the 

requirements of Paragraphs 15-16 above. Should Exide carry the burden set 

forth in this section, the delay or noncompliance at issue shall be deemed not 

to be a violation of the affected obligation of this Consent Judgment. 

VII. Dispute Resolution

18. Any dispute that arises with respect to the meaning, application 

or implementation for any provision of this Consent Judgment may be subject 
19 

to dispute resolution as provided herein, unless the Consent Judgment 

provision provides that dispute resolution is not available. Any dispute 

which arises with respect to the meaning, application or implementation of 

this Consent Judgment shall in the first instance be the subject of informal 

negotiations between Exide and MDNR. Notice of a dispute shall be given by 

the party alleging the dispute, shall be addressed in writing to the MDNR 

Director, and copied to the opposing party. Such notice shall state the specific 

grounds for the dispute, including any supporting documentation and the 

relief requested. 

19. The MDNR and Exide shall have thirty (30) days from the receipt 

of the notice of the dispute to resolve the dispute. If agreement is reached, the 

resolution shall be reduced to writing and this Consent Judgment modified, if 

appropriate. If the parties to the dispute are unable to reach agreement 

within the thirty (30) day period and this period is not extended in writing by 

mutual agreement of the parties, the matter will be submitted to the 

Commission. The opposing party may file suggestions in opposition and 

include any documentation relevant to deciding the dispute. Said suggestions 

and documentation shall be submitted within fourteen days of submission of 

the matter to the Commission. The Commission will issue a written decision 

following its review of the record submitted by the parties. 
20 

20. The parties will then be entitled to judicial review pursuant to 

Section 536.140, RSMo. The filing of a notice of dispute shall not 

automatically extend, postpone, or affect any party's obligations under this 

Consent Judgment with respect to the disputed issue. This provision shall 

not be construed to prevent either party from requesting a stay of the party's 

obligations under this Consent Judgment. 

IX. Reservations 

21. Nothing in this agreement shall be construed as a waiver of any 

obligation of Exide or as a permit to Exide under any other environmental 

laws applicable to Exide. 

X. Modifications 

22. This Consent Judgment may be modified or amended only by 

written modification between the parties and with the approval of the Court. 

23. In the event Exide ceases operation of lead emission units subject 

to this Consent Judgment, Exide shall notify MDNR and will be relieved of 

the injunctive relief or other required practices that were for the purpose of 

reducing lead emissions from the subject unit. 

XI. Contacts 

24. All notices, reports, submissions, correspondence, or 

communications on requirements of this Consent Judgment shall be directed 

by mail or electronic mail as follows: 
21 

If to the State: 

To the Missouri Department of Natural Resources: 

Planning Section Chief 

Air Pollution Control Program 

Missouri Department of Natural Resources 

1659 East Elm Street 

Jefferson City, Missouri 65101With copies to 

Chief Counsel 

Agriculture and Environment Division 

Missouri Attorney General’s Office 

P.O. Box 899 

Jefferson City, MO 65102 

If to Exide: 

Plant Manager 

25102 Exide Drive 

Forest City, MO 64451 

With copies to 

Frederick Ganster 

Exide Technologies 

3000 Montrose Avenue 

Reading, PA 19605 

XII. Termination 

25. In the event the specific control requirements, emission 

standards, or record keeping and monitoring requirements are incorporated 

into other federally enforceable documents such as construction permits or 

regulations that have been approved by the U.S. Environmental Protection 
22 

Agency as part of Missouri’s SIP, the parties may terminate the 

corresponding provisions of this Consent Judgment by written agreement. 

The parties agree to meet and discuss measures to allow for the substitution 

of enforceable requirements in other documents and the termination of this 

agreement upon the request of either party. 

XIII. Effective Date 

26. This Consent Judgment is effective upon entry by the Court. 

 
SIGNATURES 

EXIDE TECHNOLOGIES 

DATE: 


MISSOURI DEPARTMENT OF NATURAL RESOURCES 

BY:~L in.. Lean e Tippett Mosby, ~ DIrector 

JO Division of Environmental Quality 

DATE: 0./5/'1 

MISSOURI AIR CONSERVATION COMMISSION 

BY: 6 '0 J?%,,--,-­

~i76nffiel'man, Chairperson 

fu''l j)e.t\der:g f::)...S5 

DATE: cB- 2S~ i4­

ATTORNEY GENERAL OF MISSOURI 

Chris Koster, Attorney General 

BY~~ Assistant Attorney General 

DATE: 


23 

 

APPENDIX A 

Zone of Public Access Preclusion Map & Coordinates 

(per Paragraph V.7.D. of the Consent Judgment) 
Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX,

Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community

DRAFTED BY: hthompson DATE: 5/2/2014

Figure

P:\Exide Technologies\Canon Hollow, MO\GIS\arcview\MXD\Figure 1. Site Location. 5.1.14.mxdt

LEGEND

EXISTING FENCE

PROPOSED FENCE

APPROXIMATE PROPERTY BOUNDARY

0 125 250 500

Meters

07-21624C

1

SITE LOCATION MAP

EXIDE TECHNOLOGIES FOREST CITY, MO
Fenceline Receptor Coordinates (UTM)

(Approximately 10 meter spacing between receptors)

A‐1

Receptor Easting  Northing

1 309300 4433352

2 309299 4433362

3 309298 4433372

4 309297 4433382

5 309296 4433392

6 309295 4433402

7 309294 4433412

8 309293 4433422

9 309292 4433432

10 309291 4433442

11 309290 4433452

12 309289 4433462

13 309289 4433472

14 309289 4433482

15 309289 4433492

16 309289 4433502

17 309292 4433511

18 309294 4433521

19 309297 4433531

20 309299 4433540

21 309302 4433550

22 309304 4433560

23 309307 4433569

24 309309 4433579

25 309312 4433589

26 309317 4433598

27 309321 4433607

28 309325 4433616

29 309329 4433625

30 309333 4433634

31 309337 4433643

32 309341 4433652

33 309345 4433662

34 309349 4433671

35 309352 4433677

36 309351 4433696

37 309354 4433700

38 309355 4433710

39 309356 4433720

40 309356 4433730

41 309357 4433740

42 309358 4433750

43 309359 4433760

44 309359 4433770

45 309362 4433779

46 309367 4433788

47 309371 4433797

Receptor Easting  Northing

48 309375 4433807

49 309380 4433815

50 309386 4433823

51 309392 4433831

52 309398 4433839

53 309405 4433846

54 309414 4433851

55 309423 4433855

56 309433 4433856

57 309443 4433857

58 309453 4433857

59 309463 4433857

60 309473 4433856

61 309483 4433855

62 309493 4433854

63 309503 4433853

64 309512 4433851

65 309522 4433850

66 309532 4433849

67 309542 4433847

68 309552 4433846

69 309562 4433845

70 309572 4433844

71 309582 4433844

72 309592 4433846

73 309601 4433848

74 309611 4433846

75 309620 4433841

76 309629 4433837

77 309638 4433834

78 309648 4433830

79 309657 4433827

80 309666 4433823

81 309676 4433820

82 309685 4433818

83 309692 4433810

84 309702 4433807

85 309711 4433806

86 309721 4433805

87 309731 4433803

88 309741 4433802

89 309751 4433801

90 309761 4433799

91 309771 4433798

92 309781 4433796

93 309791 4433795

94 309801 4433794

Receptor Easting  Northing

95 309810 4433792

96 309820 4433791

97 309830 4433790

98 309840 4433788

99 309850 4433787

100 309860 4433786

101 309869 4433782

102 309878 4433777

103 309886 4433772

104 309895 4433767

105 309903 4433761

106 309912 4433756

107 309920 4433751

108 309929 4433746

109 309937 4433740

110 309946 4433735

111 309954 4433730

112 309963 4433725

113 309971 4433719

114 309980 4433714

115 309988 4433709

116 309992 4433701

117 309991 4433691

118 309990 4433681

119 309990 4433671

120 309989 4433661

121 309989 4433651

122 309988 4433641

123 309987 4433631

124 309985 4433621

125 309983 4433611

126 309981 4433602

127 309979 4433592

128 309977 4433582

129 309975 4433572

130 309973 4433562

131 309971 4433553

132 309969 4433543

133 309967 4433533

134 309965 4433523

135 309963 4433514

136 309960 4433504

137 309958 4433494

138 309956 4433484

139 309954 4433474

140 309952 4433465

141 309950 4433455
Fenceline Receptor Coordinates (UTM)

(Approximately 10 meter spacing between receptors)

A‐2

142 309945 4433446

143 309940 4433438

144 309934 4433430

145 309929 4433421

146 309923 4433413

147 309918 4433404

148 309912 4433396

149 309907 4433388

150 309901 4433379

151 309896 4433371

152 309890 4433363

153 309885 4433354

154 309879 4433346

155 309874 4433338

156 309868 4433329

157 309863 4433321

158 309857 4433313

159 309852 4433304

160 309846 4433296

161 309841 4433288

162 309835 4433279

163 309830 4433271

164 309824 4433262

165 309819 4433254

166 309813 4433246

167 309808 4433237

168 309802 4433229

169 309797 4433221

170 309791 4433212

171 309786 4433204

172 309780 4433196

173 309775 4433187

174 309765 4433187

175 309755 4433188

176 309745 4433188

177 309735 4433188

178 309725 4433189

179 309715 4433189

180 309705 4433189

181 309695 4433190

182 309685 4433190

183 309675 4433190

184 309665 4433191

185 309655 4433191

186 309645 4433191

187 309635 4433192

188 309625 4433192

189 309617 4433186

190 309610 4433180

191 309610 4433170

192 309610 4433160

193 309608 4433150

194 309604 4433141

195 309601 4433131

196 309598 4433122

197 309593 4433117

198 309585 4433123

199 309576 4433128

200 309568 4433134

201 309560 4433140

202 309552 4433146

203 309544 4433151

204 309536 4433157

205 309528 4433163

206 309519 4433169

207 309511 4433175

208 309503 4433180

209 309495 4433186

210 309487 4433192

211 309479 4433198

212 309470 4433204

213 309462 4433209

214 309454 4433215

215 309446 4433221

216 309438 4433227

217 309430 4433233

218 309422 4433239

219 309414 4433245

220 309407 4433252

221 309399 4433258

222 309391 4433264

223 309383 4433271

224 309376 4433277

225 309368 4433283

226 309360 4433290

227 309353 4433296

228 309345 4433303

229 309337 4433309

230 309330 4433316

231 309322 4433322

232 309315 4433329

233 309308 4433336

234 309301 4433343

235 309278 4433358

236 309281 4433368

237 309280 4433378

238 309280 4433388

239 309279 4433393

240 309279 4433398

241 309278 4433408

242 309277 4433418

243 309276 4433428

244 309275 4433438

245 309274 4433448

246 309273 4433458

247 309272 4433468

248 309272 4433478

249 309272 4433488

250 309273 4433498

251 309275 4433507

252 309277 4433517

253 309279 4433527

254 309279 4433535

255 309269 4433538

256 309263 4433543

257 309266 4433552

258 309269 4433562

259 309272 4433570

260 309282 4433567

261 309290 4433567

262 309292 4433576

263 309295 4433586

264 309299 4433595

265 309302 4433605

266 309306 4433614

267 309310 4433623

268 309314 4433632

269 309318 4433641

270 309322 4433650

271 309326 4433660

272 309330 4433669

273 309334 4433678

274 309338 4433687

275 309342 4433696

276 309345 4433706

277 309346 4433716

278 309347 4433726

279 309347 4433736

280 309348 4433746

281 309350 4433756

282 309351 4433766

283 309352 4433776

284 309355 4433785

285 309358 4433795
Fenceline Receptor Coordinates (UTM)

(Approximately 10 meter spacing between receptors)

A‐3

286 309362 4433804

287 309367 4433813

288 309372 4433821

289 309378 4433829

290 309384 4433837

291 309389 4433846

292 309395 4433854

293 309402 4433860

294 309411 4433865

295 309421 4433868

296 309431 4433867

297 309441 4433867

298 309451 4433866

299 309461 4433866

300 309471 4433865

301 309481 4433864

302 309490 4433863

303 309500 4433862

304 309510 4433861

305 309520 4433860

306 309530 4433858

307 309540 4433857

308 309550 4433856

309 309560 4433855

310 309570 4433854

311 309580 4433853

312 309590 4433855

313 309598 4433860

314 309606 4433866

315 309611 4433874

316 309614 4433884

317 309617 4433893

318 309618 4433903

319 309619 4433913

320 309620 4433923

321 309621 4433933

322 309622 4433943

323 309624 4433953

324 309625 4433963

325 309626 4433973

326 309627 4433983

327 309627 4433993

328 309623 4433998

329 309613 4433999

330 309603 4433999

331 309593 4433999

332 309583 4434000

333 309573 4434000

334 309563 4434000

335 309553 4434001

336 309543 4434001

337 309533 4434002

338 309523 4434002

339 309513 4434002

340 309503 4434003

341 309493 4434003

342 309483 4434003

343 309473 4434004

344 309463 4434004

345 309453 4434004

346 309443 4434005

347 309433 4434005

348 309423 4434005

349 309413 4434006

350 309403 4434006

351 309393 4434006

352 309383 4434007

353 309373 4434007

354 309363 4434008

355 309353 4434008

356 309343 4434008

357 309333 4434009

358 309323 4434009

359 309313 4434009

360 309303 4434010

361 309293 4434010

362 309283 4434011

363 309273 4434011

364 309263 4434012

365 309253 4434012

366 309243 4434013

367 309233 4434013

368 309223 4434014

369 309213 4434014

370 309203 4434014

371 309193 4434014

372 309183 4434015

373 309173 4434015

374 309163 4434015

375 309153 4434015

376 309143 4434015

377 309133 4434015

378 309123 4434015

379 309113 4434016

380 309103 4434016

381 309093 4434016

382 309083 4434016

383 309073 4434016

384 309063 4434016

385 309053 4434016

386 309043 4434017

387 309033 4434017

388 309023 4434017

389 309013 4434017

390 309003 4434017

391 308993 4434017

392 308983 4434018

393 308973 4434018

394 308963 4434018

395 308953 4434018

396 308943 4434018

397 308933 4434018

398 308924 4434018

399 308914 4434019

400 308904 4434019

401 308894 4434019

402 308884 4434019

403 308874 4434019

404 308864 4434019

405 308854 4434019

406 308844 4434020

407 308834 4434020

408 308824 4434020

409 308814 4434020

410 308804 4434020

411 308804 4434014

412 308809 4434005

413 308814 4433996

414 308818 4433987

415 308823 4433979

416 308828 4433970

417 308833 4433961

418 308837 4433952

419 308842 4433943

420 308847 4433934

421 308852 4433926

422 308856 4433917

423 308861 4433908

424 308866 4433899

425 308869 4433890

426 308873 4433880

427 308876 4433871

428 308880 4433862

429 308883 4433852
Fenceline Receptor Coordinates (UTM)

(Approximately 10 meter spacing between receptors)

A‐4

430 308885 4433843

431 308888 4433833

432 308890 4433823

433 308892 4433813

434 308894 4433804

435 308897 4433794

436 308899 4433784

437 308901 4433774

438 308903 4433765

439 308906 4433755

440 308908 4433745

441 308909 4433735

442 308909 4433725

443 308909 4433715

444 308909 4433705

445 308909 4433695

446 308909 4433685

447 308913 4433677

448 308920 4433670

449 308927 4433663

450 308934 4433656

451 308941 4433649

452 308948 4433642

453 308955 4433635

454 308962 4433628

455 308970 4433621

456 308977 4433614

457 308984 4433607

458 308991 4433600

459 308998 4433593

460 309005 4433586

461 309012 4433579

462 309019 4433572

463 309027 4433565

464 309034 4433558

465 309041 4433551

466 309049 4433544

467 309056 4433538

468 309064 4433532

469 309072 4433526

470 309080 4433519

471 309088 4433513

472 309095 4433507

473 309103 4433500

474 309111 4433494

475 309119 4433488

476 309126 4433481

477 309134 4433475

478 309142 4433469

479 309150 4433463

480 309157 4433456

481 309165 4433450

482 309173 4433444

483 309181 4433437

484 309189 4433431

485 309196 4433425

486 309204 4433419

487 309212 4433412

488 309220 4433406

489 309227 4433400

490 309235 4433393

491 309243 4433387

492 309251 4433381

493 309258 4433374

494 309266 4433368

495 309274 4433362