ELMER'S CRANE AND DOZER, INC.

ELMER'S CRANE AND DOZER, INC. ( ELMER'S ) OWNS THREE PORT- ABLE NONMETALLIC MINERAL PROCESSING PLANTS (THE PLANTS ) (COMMONLY KNOWN AS SAND AND GRAVEL CRUSHING PLANTS) IN LEELANAU COUNTY AND GRAND TRAVERSE COUNTY, MICHIGAN. THE THREE PLANTS CONSIST OF THE FOLLOWING: (1) THE CEDARAPIDS 1274 PLANT ( CEDARAPIDS PLANT ) IN MAPLE CITY, MICHIGAN; (2) THE 103-VSI IMPACT SERVICE CORPORATION PLANT ( 103-VSI PLANT ) IN MAPLE CITY; MICHIGAN; AND (3) THE 66 SPOKANE - VSI PLANT ( 66 SPOKANE PLANT ) WERE INSTALLED AND COMMENCED OPERATIONS ON SEPTEMBER 20, 1994, AUGUST 11, 1995, AND NOVEMBER 1, 1992, RESPECTIVELY. EACH OF THE THREE PLANTS WAS INSTALLED AND OPERATED WITHOUT AIR USE PERMITS REQUIRED PURSUANT TO THE MICHIGAN STATE IMPLEMENTATION PLAN ( SIP ). IN ADDITION, ELMER'S FAILED TO PROVIDE REQUIRED WRITTEN NO- TIFICATIONS OF CONSTRUCTION AND OPERATION OF THE PLANTS TO U.S. EPA. ELMER'S ALSO FAILED TO TIMELY CONDUCT PERFORMANCE TESTS AT EACH OF THE PLANTS. SUBSEQUENT ATTEMPTS AT COMPLI- ANCE WITH PERFORMANCE TEST REQUIREMENTS FAILED TO FOLLOW REQUIRED TEST METHODOLOGIES AND CONDITIONS. WRITTEN NOTIFI- CATIONS, PERFORMANCE TESTS AND CORRESPONDING TEST METHODS AND CONDITIONS ARE REQUIRED BY NEW SOURCE PERFORMANCE STAN- DARDS ( NSPS ), 40 CFR PART 60, SUBPARTS A AND 000, PROMUL- GATED UNDER SECTION 111 OF THE CLEAN AIR ACT, 42 U.S.C. SEC. 7411. ELMER'S PERFORMANCE TESTS DID NOT INDICATE VIOLATIONS OF OPACITY LIMITS. HOWEVER, U.S. EPA