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On the Need for an Environmental Assessment Worksheet Findings of Fact Bituminous Roadways, Inc. Hot Mix Asphalt Plant Project Conclusions of Law Columbus, Minnesota And Order 9 Pollutant Title V Permit Threshold State Air Permit Threshold (tpy) (tpy) PM 100 100 PM10 100 25 PM2.5 100 100 SO2 100 50 NOx 100 100 CO 100 100 VOC 100 100 Lead NA 0.5 Single HAP 10 10 Combined HAPs 25 25 tpy – tons per year NOx – Nitrogen Oxides PM – Particulate Matter CO – Carbon Monoxide PM10 – Particulate Matter less than 10 µm (micrometers) in size VOC – Volatile Organic Compound PM2.5 – Particulate Matter less than 2.5 micrometers in size HAPs – Hazardous air pollutants SO2 – Sulfur Dioxide 49. Bituminous must comply with federal New Source Performance Standards and Standards of Performance for Hot Mix Asphalt Facilities (40 CFR pt. 60, subp. I), which contain limits for PM and opacity. Bituminous must conduct performance tests on the hot mix asphalt plant and submit the results to the MPCA Air Program for review. MPCA must make the determination Bituminous’ equipment meets the performance requirements before Bituminous may use the equipment. 50. The state of Minnesota also regulates air emissions from hot mix asphalt plants. See Minn. R. subp.7011.0900 through 7011.0922. Most hot mix asphalt plants in Minnesota receive permit coverage under MPCA’s Option D Registration Permit (Minn. R. 7007.1130), or receive an individual air permit. The Option D Registration Permit restricts emissions to 50% of the Title V permit thresholds listed in the table above. 51. Bituminous is applying for an MPCA Option D Permit and must meet the emission restrictions in Minn. R. 7011.0900-0922. Bituminous must install and operate equipment, including the asphalt plant production and control equipment and tanks, according to the manufacturer’s specifications. Bituminous must also monitor, inspect and calibrate equipment and provide MPCA with an annual calculated actual emissions report from the Project. If Bituminous discovers any deviations, it must report them to the MPCA. 52. Bituminous’ consultant, Wenck, in a letter dated August 9, 2017, (Attachment 5) provided MPCA with air modeling information on both the Project as well as traffic emissions. MPCA is not using the Wenck Letter information as a formal air modelling data submittal. However, the MPCA believes the information does provide a reasonable example of emissions from a similar type of facility, as well as expected air emissions from trucks hauling materials.