**SL01DOCS\4011219.6** EXHIBIT A COMPLIANCE PLAN

A. REQUIRED PARTICULATE MATTER EMISSION CONTROL MEA SURES
**The following requirements shall be implemented in accordance with the schedule set forth**  **herein. Equipment acquired or used by Americold sh all be approved by the Department before**  **installation unless already installed.**
**1.Telsmith Primary and Secondary Crushers: Americol d installed and is operating a wet**  **suppression system designed to control fugitive par ticulate matter emissions from the Telsmith**  **primary and secondary crushers. The wet suppression system consists of installing at least four**  **spray heads on the primary crusher, three spray hea ds on the secondary crusher, and four spray**  **heads on the splitter. Each spray head consists of at least seven fogging nozzles. The wet**  **suppression system was installed and operating by N ovember 1, 2012. This system will be**  **maintained and operated in good working order.**
**2. Chip Plant, Pre-1983 Tyler Screen: Americold eli minated use of the Tyler screen in December**  **2012.**
**3. Cedar Rapids Dryer and Collector: Americold shal l purchase and install a 40 horsepower 100**  **CFM compressor for the baghouse controlling the Ced ar Rapids dryer. The compressor was**  **installed and operating by August 31, 2013. This s ystem will be maintained and operated in**  **good working order.**
**4. Cedar Rapids Long Lime Belt Discharge: Americold completed temporary means to control**  **emissions including sealing the transition point an d any leaks by January 1, 2014. Americold**  **shall design and install a new drop point/transitio n at the drop point from the Cedar Rapids long**  **lime conveyor belt (COCR-06) to the West Lime Hoppe r. The new drop point/transition shall be**  **installed by January 31, 2014. Americold shall subm it verification of installation to the**  **Department within 30 days of the completion of the installation. This system will be maintained**  **and operated in good working order.**

**5. West Lime Hopper: Americold shall install a new bin top on the West Lime hopper. The new**  **bin top shall be installed by January 31, 2014. Ame ricold shall submit verification of installation**  **to the Department within 30 days of the completion of the installation. This system will be**  **maintained and operated in good working order.**

**6. Line #1 C5 Belt: Americold implemented a tempora ry measure to seal the drop point between**  **C5 #1 belt and the C5 Elevator by December 1, 2012. Americold shall also fabricate a new**  **transition on the C5 elevator (Elev-L1-03) head whe re it drops onto the tail of the line #1 CS**  **conveyor belt (Conv-L1-05). Americold shall also in stall a new head house and boot that seals to**  **the C5 elevator (Elev-Ll-03). This permanent equipm ent shall be installed and operating by**  **January 31, 2014. Americold shall submit verificati on of installation and operation to the**  **Department within 30 days of the completion of the installation. This system will be maintained**  **and operated in good working order. SL01DOCS\4011219.6** 

**7. Water Truck for Haul Roads: Americold shall modi fy an existing CAT 769 haul truck and**  **rebuild it into an 8,000 gallon water truck for the haul roads. The rebuilt water truck shall be in**  **service by March 31, 2014. Americold will submit ve rification to the Department within 30 days**  **of the rebuilt water truck being placed into servic e. The water truck currently used by Americold**  **for this purpose shall be kept in good working orde r until the rebuilt water truck is in service and**  **shall be kept available as a backup in the event th e rebuilt water truck becomes inoperable. Both**  **water trucks shall be maintained and operated in go od working order.** 

**8. Waste Fines Haul Truck: Americold will enclose t he bed of the D350 haul truck that hauls**  **waste fines to the stock pile area. This project wa s completed on December 1, 2012. The**  **enclosure system and haul truck will be maintained and operated in good working order.** 

**9. Operation and Maintenance Plan: Americold shall develop an operation and maintenance**  **(O&M) plan, and shall submit this plan to the Depar tment on or before January 31, 2014, for**  **Department review and approval. Implementation of t he plan must commence immediately upon**  **acceptance of the plan by the Department and any ch anges must be reviewed in advance and**  **approved by the Department. This O&M plan must addr ess, at a minimum, the following:** 
**a. Baghouses and dust collectors including, but not limited to, continuing to use the**  **pleated dust collector bags in the Cedar Rapids Tor rit dust collector and the Line #1 BHA**  **West dust collector The bags must be capable of ac hieving 99.5% control, as certified by**  **the manufacturer. The pleated dust collector bags in the Cedar Rapids Torrit dust**  **collector and the Line #1 BHA West dust collector s hall be replaced as necessary and**  **those particular dust collector systems shall be ma intained and operated in good working**  **order.**
**b. Wet suppression systems**

**c. Water truck**

**d. Cold weather operations**

**e. Stockpile areas**

**f. Level and overflow sensors/indicators for bins a nd silos** 
**10. Emissions Inventory Questionnaire: Americold wi ll submit a full EIQ for calendar year 2012**  **by February 1, 2014.**

B. CONTINGENCY PARTICULATE MATTER EMISSION CONTROL MEASURES
**Initial investigation of a monitored PM10 Exceedanc e:** 
**Americold shall conduct the following evaluation wh en preliminary ambient air monitoring data**  **recorded by the Carthage ambient air monitor locate d off of Juniper Road east of the Americold**  **facility and operated by the State of Missouri (the “Ambient Monitor”) indicates that an**  **exceedance of the PM 10**  **NAAQS may have occurred: SL01DOCS\4011219.6** 

**1. Any exceedance shall be immediately investigated and addressed to the extent**  **possible in a timely manner. Americold will submit, to the Department, a detailed**  **report addressing the cause of the exceedance, the mitigation of the exceedance and**  **the plan for prevention of future similar exceedanc es. If Americold wants to claim**  **that an exceedance was caused by a startup, shutdow n of malfunction, then**  **Americold shall follow the requirements of 10 CSR 1 0-6.050 “Start-up, Shutdown**  **and Malfunction Conditions” at a minimum.**

**2. The report shall be submitted to the Department within 10 days. Extensions to the**  **reporting deadline may be granted at the Department s’ discretion.** 

**3. For purposes of this provision, “Exceedance” fo r PM**  **10 means a daily value that is**  **above the level of the 24-hour standard after round ing to the nearest 10 μg/m**  **3 (i.e.,**  **values ending in 5 or greater are to be rounded up) . The level of the national primary**  **and secondary 24-hour ambient air quality standards for particulate matter is 150**  **micrograms per cubic meter (μg/m 3**  **), 24 hour average concentration (See 40 CFR 50.6). The standards are attained when the expecte**  **d number of days per calendar year with a 24-hour average concentration above 150**  **μg/m 3**  **, as determined in accordance with appendix K to 40 CFR Part 50, is eq** **ual to or less than one.**
**Further Contingency Measures:**
**If, after execution of this Consent Judgment and im plementation of all measures in Section A of**  **this Compliance Plan, Americold has a validated exc eedance of the PM**  **10 NAAQS recorded by**  **the Ambient Monitor and the validated exceedance re sulted from Americold’s operations,**  **Americold shall initiate implementation of the cont ingency measures listed below within thirty**  **days of receiving notification of the validated exc eedance. For purposes of this provision,**  **“Validated” means Monitoring data that has undergon e comprehensive evaluation of quality**  **control results and has been reported to EPA’s Air Quality System (AQS). Validated data may be**  **reported to AQS by the Department weeks or months b ut not later than 90 days after the calendar**  **quarter in which the monitoring data was measured.**
**Implementation of a subset of these contingencies m ay be approved at the Department’s**  **discretion if a definitive cause of the exceedance has been determined in the initial exceedance**  **investigation and provided within the report as des cribed above.**  **In the event that alternate Contingency Measures are identified through the inv**  **estigation process for any specific exceedance, Americold shall propose, within the rep**  **ort of the investigation, additional or alternate Contingency Measures for Department revie**  **w and approval.**

**Americold shall submit verification of completion o f these contingency measures or a request for**  **extension for completion to the Department within 6 0 days of notification of the exceedance.** 

**1. Connect Line #1 C5 Belt (Conv-L1-05) Tail to the Dust Collection System:**  **Americold will connect the transfer point from the C5 elevator (Elev-L1-03) head to**  **the line #1 C5 conveyor belt (Conv-L1-05) tail, to the existing dust collection system.** **SL01DOCS\4011219.6**

**2. Line #1 and Line #2 of the Fine Grind plant: Ame ricold will review other drop points**  **of Line #1 and Line #2 of the Fine Grind plant that could be connected to the existing**  **dust control systems.**
**3. Wet Suppression System(s): Americold will instal l (an) additional wet suppression**  **system(s), or enhance the existing wet suppression systems, in order to further reduce**  **fugitive particulate matter emissions from the proc essing of non-metallic minerals.**  **This system, upon installation, shall be maintained and kept in good working order.** 

**4. Cessation of the use of compressed air to clean certain equipment: Americold will**  **discontinue the use of compressed air for the exter nal cleaning of the crushers, dust**  **collectors, duct work, or other process equipment a t the facility. Compressed air will**  **only be used for the maintenance of the internal wo rkings of the crushers and dust**  **collectors and duct work identified on the attached list.**