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EXHIBIT A 

COMPLIANCE PLAN

A. REQUIRED PARTICULATE MATTER EMISSION CONTROL MEASURES 

The following requirements shall be implemented in accordance with the schedule set forth 

herein. Equipment acquired or used by Americold shall be approved by the Department before 

installation unless already installed. 

1.Telsmith Primary and Secondary Crushers: Americold installed and is operating a wet 

suppression system designed to control fugitive particulate 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 heads 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 November 1, 2012. This system will be 

maintained and operated in good working order. 

2. Chip Plant, Pre-1983 Tyler Screen: Americold eliminated use of the Tyler screen in December 

2012. 

3. Cedar Rapids Dryer and Collector: Americold shall purchase and install a 40 horsepower 100 

CFM compressor for the baghouse controlling the Cedar Rapids dryer. The compressor was 

installed and operating by August 31, 2013. This system 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 and any leaks by January 1, 2014. Americold 

shall design and install a new drop point/transition at the drop point from the Cedar Rapids long 

lime conveyor belt (COCR-06) to the West Lime Hopper. The new drop point/transition shall be 

installed by January 31, 2014. Americold 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. 

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. Americold 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 temporary 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 where it drops onto the tail of the line #1 CS 

conveyor belt (Conv-L1-05). Americold shall also install a new head house and boot that seals to 

the C5 elevator (Elev-Ll-03). This permanent equipment shall be installed and operating by 

January 31, 2014. Americold shall submit verification 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. 
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7. Water Truck for Haul Roads: Americold shall modify 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 verification to the Department within 30 days 

of the rebuilt water truck being placed into service. The water truck currently used by Americold 

for this purpose shall be kept in good working order until the rebuilt water truck is in service and 

shall be kept available as a backup in the event the rebuilt water truck becomes inoperable. Both 

water trucks shall be maintained and operated in good working order. 

8. Waste Fines Haul Truck: Americold will enclose the bed of the D350 haul truck that hauls 

waste fines to the stock pile area. This project was 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 Department on or before January 31, 2014, for 

Department review and approval. Implementation of the plan must commence immediately upon 

acceptance of the plan by the Department and any changes must be reviewed in advance and 

approved by the Department. This O&M plan must address, 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 Torrit dust collector and the Line #1 BHA 

West dust collector The bags must be capable of achieving 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 shall be replaced as necessary and 

those particular dust collector systems shall be maintained 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 and silos 

10. Emissions Inventory Questionnaire: Americold will 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 Exceedance: 

Americold shall conduct the following evaluation when preliminary ambient air monitoring data 

recorded by the Carthage ambient air monitor located 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 PM10 NAAQS may have occurred: 
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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 exceedances. If Americold wants to claim 

that an exceedance was caused by a startup, shutdown of malfunction, then 

Americold shall follow the requirements of 10 CSR 10-6.050 “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 Departments’ discretion. 

3. For purposes of this provision, “Exceedance” for PM10 means a daily value that is 

above the level of the 24-hour standard after rounding to the nearest 10 μg/m3 (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/m3

), 24 hour average concentration (See 40 CFR 

50.6). The standards are attained when the expected number of days per calendar 

year with a 24-hour average concentration above 150 μg/m3

, as determined in 

accordance with appendix K to 40 CFR Part 50, is equal to or less than one. 

Further Contingency Measures: 

If, after execution of this Consent Judgment and implementation of all measures in Section A of 

this Compliance Plan, Americold has a validated exceedance of the PM10 NAAQS recorded by 

the Ambient Monitor and the validated exceedance resulted from Americold’s operations, 

Americold shall initiate implementation of the contingency measures listed below within thirty 

days of receiving notification of the validated exceedance. For purposes of this provision, 

“Validated” means Monitoring data that has undergone 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 but not later than 90 days after the calendar 

quarter in which the monitoring data was measured. 

Implementation of a subset of these contingencies may 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 described above. In the event that alternate 

Contingency Measures are identified through the investigation process for any specific 

exceedance, Americold shall propose, within the report of the investigation, additional or 

alternate Contingency Measures for Department review and approval. 

Americold shall submit verification of completion of these contingency measures or a request for 

extension for completion to the Department within 60 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. 
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2. Line #1 and Line #2 of the Fine Grind plant: Americold 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 install (an) additional wet suppression 

system(s), or enhance the existing wet suppression systems, in order to further reduce 

fugitive particulate matter emissions from the processing 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 external cleaning of the crushers, dust 

collectors, duct work, or other process equipment at the facility. Compressed air will 

only be used for the maintenance of the internal workings of the crushers and dust 

collectors and duct work identified on the attached list.