Volume IV
Administrative Record and Supporting Documents
Submitted in Connection with Both Petitions
Proposed Asphalt Operation · 50 Roelker Road · Wright City, Missouri
Compiled July 20, 2026 · Updated August 15, 2026 to add the Aug 6, 2026 records production
Table of Contents
Exhibit Index3
Exhibit A — June 11, 2026 Minutes and Approval Conditions4
Exhibit B — Ordinance No. 1108 and §410.010(G)5
Exhibit C — Relevant Planning and Zoning Commission Minutes6
Exhibit D — Site Plan and Plan Sheets7
Exhibit E — Sunshine Law Requests and Responses8
Exhibit F — Recorder of Deeds Correspondence9
Exhibit G — The Six Parcels and Conceptual Lots 1–510
Exhibit H — Missouri DNR Stormwater/Air-Permit Documents11
Exhibit I — Public Water Supply / Utility Approval Documents12
Exhibit J — 41 Roelker Road Comparison Records (Ordinance No. 1104)13
Exhibit K — Other Directly Relevant Records14
Exhibit L — School District & MoDOT Records, Petition Drafts15
Exhibit M — Aug 6, 2026 Records Production (July 31 Consolidated Request)16
Exhibit N — DNR Air Permit Record: Fuel Oil Tanks (9B) and Diesel Storage17
Exhibit Index
This Volume IV index (A–N) is the administrative-record set. The broader, running Master Exhibit Index (A–L) covers the full case file, including the site/parcel and public-statement exhibits referenced throughout both petitions.
| Exhibit | Description | Status |
| A | June 11, 2026 Board of Aldermen minutes and approval conditions | On file |
| B | Ordinance No. 1108 and §410.010(G) | On file |
| C | Relevant Planning and Zoning Commission minutes | On file |
| D | Site plan and plan sheets relied upon by the City | On file |
| E | City Clerk Sunshine Law requests and responses | On file |
| F | Warren County Recorder of Deeds correspondence | On file |
| G | Records concerning the six parcels and conceptual Lots 1–5 | On file |
| H | Missouri DNR stormwater/air-permit documents | On file |
| I | Public water supply / utility approval documents | On file |
| J | 41 Roelker Road comparison records, including Ordinance No. 1104 | On file |
| K | Other directly relevant records cited in either petition | On file |
| L | School district & MoDOT records, and petition drafts | On file |
| M | Aug 6, 2026 production on the July 31 consolidated request (Items 1–17) | On file (added Aug 15, 2026) |
| N | DNR air permit record — Fuel Oil Tanks (9B), diesel generators, ULSD conditions | On file (added Aug 16, 2026) |
N
DNR Air Permit Record — Fuel Oil Tanks (9B) and On-Site Diesel Storage
The operator's own state filings for this address identify fuel-oil tanks and diesel generators as plant equipment, and the issued authorization requires ultra-low sulfur diesel and per-shipment fuel records. The City-approved site plan (Exhibit D) identifies liquid asphalt tanks but no fuel-oil or diesel tank, capacity, containment, or fueling area. Analysis: Findings Memo — Fuel Storage Omission and Expired Site Authorization. The authorization also states on its face that authority to operate at this site expired April 1, 2026.
- 2/24/2025 Portable Source Relocation Request — Magruder Paving LLC, PORT-0658 (5 pp.) — cover letter from the operator’s environmental consultant requesting relocation from Eldon (Miller County S35, T42N, R15W) to 50 Roelker Road (Warren County S21, T47N, R1W) at a proposed 3,500 tons/day for MoDOT and commercial projects; form signed by the operator’s Environmental Manager, listing G&M Concrete and Asphalt Co., Inc. as owner and an estimated one year at the new location. Page 2 answers “Yes” to “Is this a new site for this equipment?”, which triggers the form's instruction to attach a map and “Show locations and orientation of all portable equipment. Show haul roads and storage piles.” Page 3 is the Form 1.1 Process Flow Diagram for Plant No. 0658, numbering the equipment: AC Tank (9A), Fuel Oil Tanks (9B), Asphalt Oil Heater (5), Diesel Generators (10), Dryer (4), Crusher (11), Stockpiles (2), haul-in and load-out steps, and the note “See also attached sketches.” Page 4 is a handwritten equipment sketch grouping the AC tank with tanks labeled Fuel #5 and Fuel #2. Page 5 is the submitted site map, showing only haul distances (1,720′ in, 1,620′ out, 200′ stockpiles to plant) and a single plant rectangle — no individually located tanks, generators, heater, or dryer.
- 3/12/2025 DNR Authorization — Permit No. 032010-001AK, Project No. 2025-03-002 (11 pp.) — letter from the DNR Permits Section Chief authorizing relocation of PORT-0658 to 50 Roelker Road subject to conditions, including that the equipment be operated “in accordance with your existing permit,” and stating that authority to operate at this site expires April 1, 2026. Special Condition 4.A requires the drum dryer's baghouse to operate “as specified in the permit application” — establishing DNR's reliance on an underlying application not reproduced in these pages. Special Condition 5 requires exclusively ultra-low sulfur diesel (≤0.0015 wt%, 15 ppm) in the drum dryer (EU-4) and the asphalt heater (EU-7), vendor sulfur records for each shipment of fuel received, kept with the unit. Special Condition 6 bars operation at the site longer than 12 consecutive months to preserve nonroad-engine status under 40 CFR 1068.30. The Technical Review states a maximum design rate of 400 tons per hour, a 120 MMBtu/hr diesel-fired drum dryer, a 3.5 MMBtu/hr diesel-fired asphalt heater, 1.5 acres of storage piles, and that the plant is powered by a diesel engine; project emissions were based in part on the plant's 2024 Emissions Inventory Questionnaire.
- Not disclosed in either filing: tank capacity in gallons, aboveground/underground configuration, tank location on the parcel, secondary containment, overfill protection, fill or delivery-truck location, fuel piping and dispensing layout, aggregate petroleum storage capacity, or any SPCC plan. Records sought: equipment/emission unit 9B tank capacities and specifications; the existing permit governing PORT-0658; the full construction-permit application and attachments; the 2024 EIQ; and any Wright City Fire Marshal review of fuel storage at this address.