Mr. Karl Brooks Page Two

Also, due to their size, paper copies of the appendices to the plan are not included in this package. The disk(s) included with this package include an electronic copy of the plan and appendices.

Thank you for your attention to this matter. If you have any questions regarding this submittal, please contact Ms. Wendy Vit with the Missouri Department of Natural Resources' Air Pollution Control Program at P.O. Box 176, Jefferson City, MO 65102 or by telephone at (573) 751-4817.

Sincerely,

AIR POLLUTION CONTROL PROGRAM

# Kyr~;:;**X7/t~** Director

KLM:jwc

Enclosures:

Copy of plan (paper copies of the appendices are not included) Copy of commission signature page certifying Missouri Air Conservation Commission adoption Copy of public hearing notices Copy of public hearing transcript introductory statement Copy of recommendation for adoption Copy of the summary of comments and responses CD with electronic copy of the plan and appendices

c: Missouri Air Conservation Commission File# 1997-03-4-STL-Redesignation

Celebrating 40 years of taking care of Missouri's natural resources. 

### To learn more about the Missouri Department of Natural Resources visit dnr.mo.gov.

## Supplement/Revision to the Redesignation Demonstration and Maintenance Plan for the Missouri Portion of the St. Louis Nonattainment Area for the 1997 8-Hour Ground Level Ozone National Ambient Air Quality Standard

Prepared for the Missouri Air Conservation Commission Adoption: April 24, 2014



## Missouri Department of Natural Resources Division of Environmental Quality Air Pollution Control Program Jefferson City, Missouri

Project Number: 1997-O3-4-STL-Redesignationii 

### TABLE OF CONTENTS

EXECUTIVE SUMMARY ............................................................................................... 1
FOREWORD: EXPLANATION OF RE VISIONS TO THE ORIGINAL DOCUMENT ................................................................................................................ 3
1. BACKGROUND/INTRODUCTION ........................................................................... 5

1.1 N ATIONAL A MBIENT A IR Q UALITY S TANDARD FOR O ZONE ............................................. 5 1.2 G EOGRAPHICAL D ESCRIPTION OF THE S T

. L OUIS N ONATTAINMENT A REA ....................... 6 1.3 S T

. L OUIS O ZONE H ISTORY ............................................................................................... 8 1.4 C URRENT S TATUS / B ACKGROUND S UMMARY : 1997 O ZONE NAAQS ........................... 11


### 2. REDESIGNATION AND MAINTENANC E PLAN REQUIREMENTS ............ 13

2.1 A TTAINMENT OF THE S TANDARD .................................................................................... 13 2.2 I MPLEMENTATION P LAN A PPROVAL ................................................................................ 14 2.3 P ERMANENT AND E NFORCEABLE I MPROVEMENT ............................................................ 15 2.4 M AINTENANCE P LAN R EQUIREMENTS ............................................................................. 15 2.5 S ECTION 110 AND P ART D R EQUIREMENTS ..................................................................... 18


### 3. OZONE MONITORING ........................................................................................... 20

3.1 S T

. L OUIS O ZONE M ONITORING N ETWORK ..................................................................... 20 3.2 A MBIENT A IR M ONITORING D ATA .................................................................................. 21 3.3 S T

. L OUIS O ZONE M ONITORING D ATA A NALYSIS ........................................................... 26 3.4 M ISSING D ATA U NDER THE 1997 8-H OUR O ZONE S TANDARD ........................................ 26 3.5 Q UALITY A SSURANCE P ROGRAM .................................................................................... 27 3.6 C ONTINUED M ONITORING C OMMITMENT ........................................................................ 27 3.7 C LEAN D ATA D ETERMINATION ....................................................................................... 27


### 4. REDESIGNATION REQUEST: EMISSI ON INVENTORY AND CONTROLS FROM 2002 - 2008 ..................................................................................................... 28

4.1 B ASE Y EAR AND A TTAINMENT Y EAR I NVENTORIES ....................................................... 28 4.2 P ERMANENT AND E NFORCEABLE C ONTROLS U SED TO A TTAIN THE S TANDARD ............. 30 4.3 R EASONABLY A VAILABLE C ONTROL T ECHNOLOGY (RACT) ......................................... 34


### 5. MAINTENANCE PLAN DEMONSTRATIO N: EMISSION INVENTORY AND CONTROLS FROM 2008 - 2025 .............................................................................. 36

5.1 B ASE /A TTAINMENT Y EAR I NVENTORY AND F UTURE Y EAR E MISSION P ROJECTIONS ...... 36 5.2 I NTERIM Y EAR E MISSION I NVENTORY : 2017 ................................................................... 41 5.3 F UTURE F EDERAL C ONTROL M EASURES ......................................................................... 42 5.4 N EW S OURCE R EVIEW : P ERMITTING N EW OR M ODIFIED E MISSIONS S OURCES .............. 42 5.5 U PDATE : R ECENT E MISSION R EDUCTIONS 2012 - ........................................................... 43


### 6. TRANSPORTATION CONFORMITY ................................................................. 46

7. CONTINGENCY MEASURES ............................................................................... 48

8. CONCLUSION ........................................................................................................... 52iii 

### L IST OF 

### T ABLES

Table 3-1 2007-2010 St. Louis 8-Hour Design Values

Table 4-1 2002 VOC and NO x Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattainment Ar ea (tons per ozone season day)

Table 4-2 2008 VOC and NO x Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattainment Ar ea (tons per ozone season day)

Table 4-3 Comparison of 2002 and 2008 VOC and NO x Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonatta inment Area (tons per ozone season day)

Table 5-1 2008 VOC and NO x Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattainment Ar ea (tons per ozone season day)

Table 5-2 2025 VOC and NO x Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattainment Ar ea (tons per ozone season day)

Table 5-3 Comparison of 2008 and 2025 VOC and NO x Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonatta inment Area (tons per ozone season day)

Table 5-4 2017 VOC and NO x Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattainment Ar ea (tons per ozone season day)

Table 7-1 Contingency Plan for the Missouri Portion of the 1997 St. Louis 8-Hour Ozone Maintenance Area

Table 7-2 Potential Contingenc y Measures for the Missouri Portion of the 1997 St. Louis 8-Hour Ozone Maintenance Areaiv 

## List of Figures

Figure 1-1 1997 8-Hour Ozone Nonattainment Area for St. Louis (MO-IL) region

Figure 3-1 St. Louis Oz one Monitoring Network

Figure 3-2 2001 – 2010 8-Hour Ozone Design Value Trends – MO

Figure 3-3 2001 – 2010 8-Hour Ozone Design Value Trends – IL

Figure 3-4 2001 – 2003 & 2008 – 2010 Design Value Comparisonv 

## List of Appendices

Appendix A 2002 O 3 Season Day Emissions Inventor y Summary (MO Counties Only)

Appendix B 2008 O 3 Season Day Emissions Inventor y Summary (MO Counties Only)

Appendix C 2017 O 3 Season Day Emissions Inventor y Summary (MO Counties Only)

Appendix D 2025 O 3 Season Day Emissions Inventor y Summary (MO Counties Only)

Appendix E 2008 Base Year Annual Emissi ons Inventory (MO counties only) Appendix E-1 List of Statewide Point Source Emissions by Facility Appendix E-2 Non-road Inventory Documentation Appendix E-3 Nonpoint ICI Combustion Methodology Appendix E-4 MOVES IM Input Development Protocol

Appendix F Retired Unit Exemption Form s for Trigen and Anheuser Busch

Appendix G MEMC Consent Agreement Termination1 

## Executive Summary

The purpose of this SIP revision is to provide the documentation necessary for Missouri's request for redesignation of the Missouri portion of the St. Loui s nonattainment area to attainment for the 1997 ozone National Ambient Air Quality Standard (NAAQS). The plan addresses all of the federal Clean Air Act Amendments of 1990 (CAA) Section 107(d)(3)(E) re designation elements for the area. One of those elements is a mainte nance plan which demonstrates how the area will continue to comply with this NAAQS pursuant to CAA Section 175A. The maintenance plan, contained within this revision, in cludes, among other things, an em issions inventory, future year emissions projections and contingency measures.

A corresponding plan, submitted by the Illinois E nvironmental Protection Agency, has already been approved by the U.S. Environmental Prot ection Agency (EPA) for the Illinois or MetroEast portion of the St. Louis nonatt ainment area. As a result, th e Metro-East portion has already been designated attainment for the 1997 ozone standard.

Ozone air quality has dramatically improved in th e St. Louis region as a result of implementation of State and Federal control measures sin ce the designation of the St. Louis area as nonattainment in 2004. On June 9, 2011, EPA issued a “Clean Data Determination” that the entire St. Louis nonattainment area achieved at least three consecutive ozone seasons (2008- 2010) of complete, quality assured ambient air qu ality monitoring data demonstrating attainment with the 0.080 parts per million (ppm) 8-hour ozone NAAQS promulgated in 1997 [76 FR 33647]. The air quality monitoring data for the most recent years of 2011-2013 also shows compliance with the 1997 NAAQS. These air qual ity improvements are due to permanent and enforceable emission control measures.

This maintenance plan provides for continued at tainment of the 1997 8-hour ozone air quality standard for the St. Louis nonattainment area for a period of ten years after the EPA has formally redesignated the area to attainment. The plan al so provides assurances that, in the event of a subsequent violation of the air quality standar d, additional control options listed in this plan, called contingency measures, can quickly be implem ented to prevent any future violations. In addition, this plan demonstrates that the area attained the st andard based on permanent and enforceable emissions reductions. This plan also includes an emissions inventory analysis of the ozone precursors - Nitrogen Oxides (NO x ) and Volatile Organic Compounds (VOCs) – for both the redesignation demonstration period (2002- 2 008) and the maintenance plan period (2008 – 2025).

The State’s efforts to improve ozone air quality in the St. Louis area by no means end with the area’s redesignation to attainment under the 1997 8-hour ozone NAAQS. Re visions to the ozone NAAQS are ongoing and continuous. On Marc h 27, 2008, the EPA released a revised 8-hour ozone standard [73 FR 16436]. This revision lowers the ozone standard to 0.075 ppm (or 75 ppb). Similarly, a potentially even more stringent revision to the ozone standard is expected in 2015. For the 2008 ozone NAAQS revision, the St. Louis area was designated nonattainment area and classified as marginal [77 FR 30088]. Marginal nonattainment areas have until December 31, 2015 to attain the 2008 Oz one NAAQS [40 CFR 51.1103]. The Missouri Department of Natural Resources’ Air Pollution Control Program (Air Program) is currently2 developing a plan to address th e area’s marginal nonattainment obligations under the 2008 ozone NAAQS.

By redesignating the Missouri po rtion St. Louis area to attainme nt under the 1997 standard through this plan, the Air Program is es tablishing contingency measures a nd anti-backsliding levels. Since the implementation rule for the 2008 NAAQS propos es to revoke the 1997 NAAQS, the approval of this plan will conclude any obligations under the 1997 standard pr ior to its proposed revocation. This will allow the state to focus its resources on addressing the newly-revised and more protective standard(s).3 

## Foreword: Explanation of Revisi ons to the Original Document

On November 27, 2011, the Missouri Air Cons ervation Commission (MACC) adopted the Redesignation Demonstration and Maintenance Plan for the Missouri Portion of the St. Louis Nonattainment Area for the 1997 8-Hour Ozone Na tional Ambient Air Quality Standard. The plan was then submitted to the EPA on November 28, 2011 for inclusion in the Missouri State Implementation Plan (SIP). The plan was not ap proved at that time due to litigation surrounding the federal interstate air pollution transport ru les: Clean Air Interstate Rule (CAIR) & its successor, Cross State Air Po llution Rule (CSAPR).

The District of Columbia Circuit Court ruled to vacate CSAPR and directed EPA to continue implementing CAIR while awaiting an acceptable replacement rule. Since CAIR remains in effect until the Supreme Court makes a decision or a satisfactory replacement rule is enacted, the emission reductions from CAIR are permanent and enforceable.

As a result, this document is an update to the maintenance plan submitted in 2011 (2011 plan). The Missouri Department of Natural Resources’ Ai r Pollution Control Program (Air Program) is now proposing a technical supplement/revision to the 2011 plan. This re vision will make the following updates and correc tions to the 2011 plan:

 The future year in the maintenance plan has been changed from 2022 to 2025. All references to emissions in 2022 throughout the plan and appendices ha ve been revised to refer to emissions in the new future year (2025).

 Emissions inventories and appendices have b een updated to account for recent changes:

o Appendix H was created to supply the Emission Inventories for the Illinois portion of the nonattainment area;

o The point source emissions inventories fo r the interim year (2017) have been adjusted so that the Clean Air Interstate Rule (CAIR) is the control strategy used to control electric generati ng units’ emissions as opposed to the Cross State Air Pollution Rule (CSAPR). The new future ye ar in the plan (202 5) also relies on CAIR to control these emissions. The pl an and appendices have been updated to accurately characterize a ll of these revisions;

o The on-road mobile source inventories included for the base year (2008) and interim year (2017) of the plan have been revised to incorporate the actual inspection/maintenance (I/M) program in place in the St. Louis area. For VOC emissions, the Stage II refueling emissions have been removed from the mobile source inventory and added to the area source inventory. For the interim year (2017) emissions inventory, the stage II control program was removed from the mobile model in calculating the Stage II area source emissions to account for a current SIP development to remove these re quirements as a result of wide spread use of on-board vapor recovery equipment. The new future year (2025) emissions inventory in the plan al so accounts for the removal of Stage II controls and4 incorporates the appropriat e I/M input in the mobile model. The plan and appendices have been updated to accurate ly characterize all of these revisions;

o The non-road source emissions inventories for the base year (2008) and interim year (2017) will be revised to account for e rrors that were discovered in the inputs to the NONROAD model used to develop the inventories. Additionally, it was discovered that aircraft takeoff a nd landing emissions were not properly accounted for in the original plan for the base year (2008) and interim year (2017), and revisions have been made to correctly add these emissions to these inventories included in the plan. In this plan, non-road source NO x emissions are lower than the 2011 plan because the Air Program used the newer version of the 2008 National Emissions Inventory (NEI vers ion 3) in this plan. Commercial marine NO x emissions decreased when compared to the 2011 plan because they were found to be overestimated in the 2008 NEI version 2. The new future year (2025) non-road emissions inventory incl uded in this document was calculated using the appropriate modeli ng inputs and properly account s for air craft take offs and landings. The plan and appendice s have been updated to accurately characterize all of these revisions.

 On May 21, 2012, the EPA revoked the 1997 8-hour ozone standard for the purposes of Transportation Conformity [77 FR 30160]. Ch apter 6 has been revised accordingly.

 For the purposes of increased clarity, e.g. th e plan was updated to better show which CAA redesignation request & maintenance pl an requirements are addressed by which sections of the document.

 Minor changes and corrections have been ma de throughout the plan and appendices to fix typographical errors, revise references, a nd to ensure the plan and appendices are reflective of the updates that have been made.

Although this document is an update to the 2011 plan, it is stand- alone and therefore substantially restates the conten ts of the 2011 plan except for the changes mentioned above. The original 2011 plan submittal may be found at http://www.dnr.mo.gov/env/ap cp/docs/stl-ozonemaintplan-redesig.pdf

.5 

## 1. Background/Introduction

1.1 National Ambient Air Quality Standard for Ozone Congress first enacted the Clean Air Act (CAA) in 1970. It was last amended in 1990. The CAA requires the U.S. Environmental Protection Agency (EPA) to set National Ambient Air Quality Standards (NAAQS) for pollutants cons idered harmful to public health and the environment. There are two categories of NA AQS that are set by the EPA. The primary standards are health-based standard s and are designed to establish lim its to protect public health. The secondary standards are commonly referred to as “welfare-based standards” and are meant established to protect public we lfare. These limits are intende d to protect against decreased visibility, and damage to crops, animals, and bu ildings. Currently there are six pollutants with established primary level NAAQS. These polluta nts are carbon monoxide, lead, total suspended particles, sulfur dioxide , nitrogen oxide, and ozone. These pol lutants are referred to as “criteria” pollutants. The EPA establishes a standard for e ach criteria pollutant. If an area is found to exceed this value, it is classifi ed as a nonattainment area for that specific pollutant. The states and/or tribes responsible for th e affected area must then develop and carry out strategies and measures to attain the NAAQS. The goal for any areas designated as “nonattainment” is to be reclassified by the EPA to atta inment for the pollutant.

The CAA requires that the EPA car ry out a periodic review of the NAAQS. This review must include the scientific basis for (1) changing or reaffirming the NAAQS and (2) implementing the NAAQS. As required by the CAA, the EPA reviewed the one-hour NAAQS for ozone in the 1990’s and determined that a new standard was need ed. This new standard was finalized in July of 1997. The replacement of the ozone NAAQS was pur suant to subpart 1 of the CAA, Title I, Part D.

The 1997 ozone standard is based on an eight-hour averaging period. This standard defines an area as in attainment of the 8-hour ozone standa rd when the three-year average of the annual fourth highest daily maximum 8-hour ozone concen tration is less than or equal to 0.08 parts per million (ppm) (or 80 parts per billion (ppb)). Due to rounding conventions in the 1997 standard, an 8-hour average ozone concentration above 0.085 ppm is considered an exceedance of standard. When the three-year average value is 0.085 ppm or greater, a violation of the ozone NAAQS has occurred. A violati on of the eight-hour standard is determined on a per monitor basis. Monitor readings (and ex ceedances) at one location do not have any effect on the readings at another.

The EPA was challenged in court on the new 8- hour standard, and the one-hour standard was reinstated. The Supreme Court uph eld the constitutionality of 8-hour standard, but ruled that the EPA could not implement the new standard under subpart 1 of the CAA w ithout considering the CAA’s subpart 2 requirements. Subpart 2 spec ifies area classification for nonattainment areas with additional control strategy requirements fo r each classification. The rule was remanded to the EPA in order to develop a reasonable approach to implement the new standard while considering the roles of subparts 1 and 2 in the implementation.

Phase I of the Final Rule to Implement th e 8-Hour Ozone National Ambient Air Quality Standard was released on April 30, 2004 [69 FR 23951] and became effective on June 15, 2004.6 Phase II of the rule was published on November 29, 2005 [70 FR 71612] and became effective on January 30, 2006. These two rules provided specific obligations for state ozone plan revisions. Under these rules, the St. Louis 8- hour Ozone Nonattainment Area was subject to a number of obligations.


### 1.2 Geographical Description of th e St. Louis Nonattainment Area
The St. Louis Ozone Area is a bi-state nonattai nment area that violated the 1997 8-Hour Ozone Standard (see Figure 1-1). In April 2004, EPA designated the St. Louis area as nonattainment with a classification of m oderate [69 FR 23858]. For more information on the NAAQS designation process, see paragraph 1.3.2 of this document. The following is a list of the counties contained in the St. Louis Missouri-Illinois 8-hour ozone nonattainment area:

 St. Louis County, MO

 St. Louis City, MO

 St Charles, MO

 Jefferson County, MO

 Franklin County, MO

 Madison County, IL

 St. Clair County, IL

 Monroe County, IL

 Jersey County, IL

Under the final implementation requirements, the St. Louis area was to de monstrate attainment of the 1997 8-hour ozone standard by June 15, 2010. On April 30, 2012, EPA published a final action that the St. Louis area attained the standa rd by this deadline date [77 FR 25363].7 Figure 1-1 1997 8-Hour Ozone Nonattain ment Area for St. Louis (MO-IL) Region8 

### 1.3 St. Louis Ozone History

1.3.1 One Hour Ozone Standard The Clean Air Act Amendments of 1990 (CAA) requi red states with nonattainment areas like St. Louis to develop revisions to the SIP to bri ng those areas into compliance. St. Louis was classified as a moderate ozone nonattainment ar ea for the 1-hour standard. The CAA included very specific requirements for areas under each classification. The most important requirement for moderate areas was that attainment was to be achieved by 1996. Under the Amendments, failure to attain by the assigne d date would result in reclassi fication to the more demanding classification of “serious.” Serious areas were subject to an additional set of requirements.

St. Louis was required to achieve a minimum of 15 percent reduction in emissions of VOCs, and submit this Rate of Progress (ROP) plan for achieving that reduction. On November 15, 1993 the Air Program submitted an initial ROP plan. Subsequent amendments to the ROP plan were made in 1994, 1995, and 1996. These amendments were the result of refinements to inventory calculations and improvements in the documents.

Although the ROP requirement was one of the key obligations of the CAA, the primary obligation was to develop a plan to achieve the national ozone standard in St. Louis. This plan is referred to as an attainment demonstration. An attainment demonstration was prepared and submitted to the EPA on October 25, 1995, which s howed that the area w ould attain the air quality standard by 1996. The St. Louis area, howeve r, failed to attain the 1-Hour ozone standard by 1996. The States of Missouri and Illinois proceed ed with a request to extend the attainment deadline.

To qualify for an attainment deadline extension, Missouri and Illinois had to demonstrate three requirements: that the area was significantly aff ected by ozone or ozone precursors transported from upwind sources; that all nece ssary local control measures have been implemented; and that the states had made the necessary administrative submittals. As part of this attainment date extension, additional photochemical grid modeling was conducted. This modeling included a number of regional control measures, in addi tion to the 15 percent ROP controls such as Reformulated Gasoline (RFG) and the enhan ced Vehicle Inspection/Maintenance (I/M) programs. The attainment demonstration submit ted as part of the 1-hour extension request focused on the evaluation of emission reductions th at were expected from electric generating utilities resulting from EPA’s regional NOx SIP call. This SIP call resulted from EPA’s determination that ozone transport from one region to another interfered with some states’ ability to attain their ozone air quality goals. The NOx SIP call applied to twenty-two states in the eastern United States, and included emission reduc tions from sources loca ted in the eastern onethird of Missouri. The study showed that both regional NOx controls and local VOC controls were necessary for attainment of the 1-hour st andard, and that St. Louis was significantly affected by ozone transport and emissions from other states, and theref ore, qualified for the attainment date extension. St. L ouis was granted the extension, a nd subsequently attained the 1- hour ozone standard.9 1.3.2 1997 8-Hour Ozone Standard 

### 1.3.2.1 1997 8-Hour Ozone Boundary Designations EPA promulgated the 8-hour ozone standard in June 1997. The new standard was set 0.08 parts per million (ppm) averaged over 8 hours and replaced the 1-hour ozone standard. An exceedance of the 8-hour ozone standard o ccurs when a monitor measures ozone above 0.084 ppm (per the rounding convention). A violation of the standard occurs when the average of the annual fourth highest daily maximum 8-hour ozone values over three consecutive y ears is greater than or equal to 0.085 ppm. This three-year average is called th e design value for the m onitor. The three-year period from 1997-1999 were used for the purposes of designation. The design value for the St. Louis Area was based on the monitor in the region with the highest design value. This monitor is located in West Alton, MO a nd had a three year design value of 0.95 ppm. Areas such as St. Louis which had design values th at ranged from 0.92 to 0.107 ppm we re classified as moderate ozone nonattainment areas.

Boundary designation recommendations under the 1997 standard were developed using guidance published by EPA on March 28, 2000 and titled “ Boundary Guidance on Air Quality Designations for the 8-Hour Ozone National Ambient Air Quality Standards .” The boundary recommendation for the 8-hour standard was iden tical to the old 1-hour boundary. It included the City of St. Louis and the c ounties of St. Louis, Franklin, Jefferson, and St. Charles. This recommendation was based on an in-depth techni cal evaluation based on EPA guidance. The Air Program sought stakeholder i nput. During the workgroup proce ss, many complex issues were raised and discussed.

In July 2000, on behalf of the Governor, the Air Program sent the original recommendation regarding the classification of counties under the revise d ozone standard. These recommendations were based on EPA guidan ce released on June 25, 1999 and March 28, 2000. Based on 1997-1999 air quality data, the Air Prog ram recommended the same boundary for the 8-hour ozone nonattainment area as was used fo r the previous one-hour ozone nonattainment area. Based on the litigation surrounding the 1997 NAAQS (discussed in section 1.1) no formal action was taken on the initial boundary designat ion submittal. EPA requested updated, revised, or new designation recommendations and documen tation from each state governor be submitted to the Regional Administrator by July 15, 2003. These recommendations were to be based on 2000-2002 quality assured air qua lity monitoring data.

Based on the input from stakeholders and the technical review, the Air Program presented a proposed boundary recommendation to the Miss ouri Air Conservation Commission (MACC) on June 26, 2003, and it was adopted on July 24, 2003. The nonattainment area boundary recommended remained unchanged from th e 2000 recommendation and the 1-hour ozone designations. The Department submitted the recommendation to EPA on August 2, 2003.

In letters received December 4 and 12, 2003, the EPA stated that they intend to modify the boundary recommendations for eight-hour ozone nona ttainment areas. The EPA intended to modify the recommendation to include St. Ge nevieve County. In response to this EPA comment, the Department offered an alternat ive, involving addressi ng upwind NOX emissions rather than including all of Ste. Genevi eve County. On March 25, 2004, the MACC signed a resolution committing the Department to promulga te a rule controlling emissions from large10 NOx sources upwind and outside of the St. L ouis nonattainment area. This rule, 10 CSR 10- 6.345 Control of NOx Emissions From Upwind Sources, was subsequently promulgated and became effective on December 30, 2006.

On April 30, 2004, EPA classified the St. Louis ar ea as a moderate nonattainment area for the new eight-hour ozone standard [69 FR 23858]. Th e area’s boundaries were designated as recommended and excluded Ste. Genevieve Count y. The state then had three years to develop the St. Louis nonattainment area 8-Hour Ozone SIP Revision.



### 1.3.2.2. 1997 8-Hour Ozone Implementation Plan The EPA’s 8-hour ozone implementation rule requi red a number of elements for an approvable SIP revision. These elements included: an em issions inventory; attainment demonstration; Reasonably Available Control Technology (RACT) requirements; a ROP demonstration; a demonstration that New Source Review (NSR) permitting met all EPA requirements; motor vehicle emissions budgets to meet both the rate of progress and attainment; a discussion of specific individual area controls; a nd identification of contingency m easures in case the area was not able to meet its at tainment deadline.

Extensive work, effort and resources were required to develop all elements of the implementation plan within the time frame established by EPA. The final result of the evaluations and the modeling of available data showed that the St. L ouis Nonattainment Area would attain the 1997 standa rd by the 2010 deadline.

Per the implementation rule, the RACT demonstr ation was required to be completed prior to other elements of the SIP revision. It was s ubmitted to EPA following adoption by the MACC on December 6, 2006. All other required elements of the revision were submitted as part of, or concurrent with, the 2007 revision to the SIP. The I/M portion of the SIP was resubmitted as a separate revision at a later date due to subsequent cha nges that were made in the program as the result of new state laws.

A public hearing of the 8-Hour ozone nonattain ment plan SIP revision was held on April 26, 2007, before the MACC. Comments were receiv ed from the EPA and the East-West Gateway Council of Governments. A number of docum ent edits were made in response to these comments, but no substantive change s to control strategies were needed. These revisions were presented on May 31, 2007, and adopted by the Commission.

The eight-hour ozone plan was submitted to the EPA on June 13, 2007, meeting the June 15, 2007 federal deadline. The plan showed that th e St. Louis non-attainment area will attain the 1997 NAAQS for ozone by the 2010 deadline.

Attainment of the 1997 NAAQS 8-Hour Ozone Standard was achieved following the 2009 ozone season, allowing for the development of a reque st for redesignation and maintenance plan.11 1.3.3 New NAAQS Revision: 2008 8-Hour Ozone Standard On March 27, 2008, the U.S. Environmental Protect ion Agency (EPA) released a revised 8-hour ozone standard [73 FR 16436]. This revision lowers the ozone standard to 0.075 ppm (or 75 ppb).

With a revised NAAQS, the CAA requires states to review air quality monitoring data and submit ozone boundary designation recommendati ons. In March 2009, Missouri submitted its original boundary recommendati on for the 2008 ozone NAAQS to EPA, based on the ozone air quality monitoring data for the three y ears of 2005–2007. Then in December 2011, Missouri updated the boundary recommendations based on ai r quality data for the three years of 2008– 2010. More information on Missouri’s boundary de signation recommendations may be found at: http://dnr.mo.gov/env/apcp/naaqsboundarydesignations.htm

. On May 21, 2012, EPA finalized the area designa tions. The St. Louis area was designated nonattainment area and classified as marginal for the 2008 ozone standard [77 FR 30088]. The boundaries of the Missouri portion of the nonattainment area remained the same as for the 1997 ozone standard but its classifica tion changed from moderate. Marg inal nonattainment areas have until December 31, 2015 to attain the 2008 Ozone NAAQS [40 CFR 51.1103].

Since the St. Louis Ozone Area is a bi-state non attainment area, Illinoi s went through a similar designation process for its portion – the Metro-East side of the St. Louis area. For the Illinois portion under the 2008 ozone NAAQS, Jersey Count y is no longer designat ed as nonattainment as it was for the 1997 ozone standard. For more information on EPA’s final state designations,

see - http://www.epa.gov/glo/designa tions/2008standards/state.htm.

Lastly, because, air quality st andards are periodically revisite d pursuant to the CAA, another revision to the Ozone NAAQ S is anticipated for 2015.


### 1.4 Current Status / Background Summary: 1997 Ozone NAAQS On June 9, 2011, EPA published a final clean data determination in the Fe deral Register stating that the St. Louis ozone nonattain ment area covering both Missouri and Illinois had attained the 1997 8-hour ozone standard based on three cons ecutive ozone seasons (2008-2010) of qualityassured ambient air monitoring data [76 FR 33647, June 9, 2011]. On December 16, 2013, the Air Program submitted a letter to EPA certifying that the most recent three years (2011-2013) of quality-assured ambient air quality data is in compliance with the 1997 ozone NAAQS. Information regarding the air m onitoring network and air quality monitoring data are included in chapter 3 of this document.

CAA Section 107 establishes specific requirements to be met in order for a nonattainment area to be considered for redesignation. Clean air quality data is one of those requirements. The state must demonstrate that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementa tion of the SIP and other federal requirements. The development of a maintenance plan is anot her. This document addresses the maintenance plan requirements, and includes additional information on the permanent and enforceable12 measures used to demonstrate attainment a nd continued compliance with the 1997 8-hour ozone NAAQS.

In 2011, the Air Program submitted the first versi on of this redesignation/maintenance plan but the plan was not approved at that time due to litigation surrounding the federal interstate air pollution transport rules: CAIR& its successor, CSAPR.

The District of Columbia Circuit Court ruled to vacate CSAPR and directed EPA to continue implementing CAIR while awaiting an acceptable replacement rule. Since CAIR remains in effect until the Supreme Court makes a decision or a satisfactory replacement rule is enacted, the emission reductions from CAIR are permanent and enforceable.

As a result, in 2013, the Air Program decided to proceed once again with the redesignation request. This document serves that purpose as an updated revision to th e original 2011 plan. More information on this may be found in the Foreword at the beginning of this document and elsewhere in this plan.

Despite a newer more protective standard, the rede signation to attainment for the St. Louis area under the 1997 0zone standard, is important to —

 Demonstrate that St. Louis metro ozone air quality concentrations are improving and are on a continued downward trend;

 Show that air quality goals ar e being met in the St. Louis area as a result of permanent and enforceable emission reductions;

 Establish a contingency plan that will act as a safeguard and backstop against potential future elevated ozone concentrations in the St. Louis area; and

 Terminate uncertainty about future pla nning obligations under the 1997 Ozone NAAQS prior to it being revoked so that resources can be focused on the new more protective standard(s).13 

## 2. Redesignation and Main tenance Plan Requirements

An area designated as nonattainment for a pollutant can be redesignated to attainment if specific conditions are met. Missouri has followed the EPA published Memorandum entitled, “Procedures for Requests to Redesignate Areas to Attainment”, from John Calcagni, Director, Air Quality Management Divisi on, dated September 4, 1992, in preparing the redesignation demonstration and the maintenance plan. Th e memorandum provides guidance regarding the processing of requests for redesignation of nonatt ainment areas to attainment for ozone, carbon monoxide, particulate matter, sulfur dioxide, nitrogen dioxide, and lead.

Furthermore, the CAA, lists five (5) oblig ations that the EPA must meet during the redesignation process. S ection 107(d)(3)(E) states:

The Administrator may not promulgate a redesignation of a nonattainment area (or portion thereof) to attainment unless –

(i) the Administrator determines that the area has attained the national ambient air quality standard; (ii) the Administrator has fully approved the applicable implementation plan for the area under section 110(k); (iii) the Administrator determines that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the applicable implementation plan and applicable Federal air pollutant control regulations and other permanent and enforceable reductions; (iv) the Administrator has fully approved a maintenance plan for the area as meet ing the requirements of section 175A; and (v) the State containing such area has met all requiremen ts applicable to the area under section 110 and part D.
These five (5) obligations must be met before EPA can redesignate an area to attainment; however, a state may submit both the redesignation request and the maintenance plan at the same time so that rulemaking on both may proceed on a parallel track. This document outlines Missouri’s redesignation request and demonstrat es how the state supports EPA’s promulgation obligations towards the redesignation of the St. Louis nonattainment area to attainment under the 1997 ozone NAAQS.


### 2.1 Attainment of the Standard CAA Section 107(d)(3)(E)(i) states that EPA must determine that the area is attaining the applicable NAAQS. For the 1997 NAAQS, this de termination must be demonstrated using the design value based on the average of the last three (3) years’ 4 th highest maximum daily 8-hour average concentrations. This design value must be lower than the level of the NAAQS, 0.08 ppm. The state submitted a Clean Data Request to the EPA on December 4, 2009. On June 9, 2011, EPA published a final clean data determinati on that the St. Louis ozone nonattainment area has attained the 1997 ozone sta ndard [76 FR 33647] . Subs equently, on April 30, 2012, EPA stated that the St. Louis area had attained this standard by the three- years allowed after the moderate nonattainment classi fication pursuant to CAA Secti on 182(b) [77 FR 25363]. More information may be found in chapter 3 of this document which demonstrates how the St. Louis area has satisfied the redesignation requirement of CAA Section 107(d)(3)(E)(i) for NAAQS attainment.14 

### 2.2 Implementation Plan Approval The CAA requirement in Section 107(d)(3)(E)(ii ) for redesignation states that the EPA administrator must have fully approved the ap plicable implementation plan for the area under Section 110(k). The 2007 Revision of the State Implemen tation Plan for the St. Louis 8-Hour Ozone Nonattainment Area was proposed for public hearing on April 26, 2007; was adopted by the MACC on May 31, 2007 and was submitted to the EPA on June 13, 2007. This ozone SIP was deemed to be complete on December 21, 2007.

As stated earlier, EPA has published a final rule in the Federal Register st ating that the St. Louis ozone nonattainment area covering both Missouri and Illinois has attained the 1997 8-hour ozone standard based on three years of quality assured ambient air quali ty data [76 FR 33647, June 9, 2011]. Once an area attains the standard for a criteria pollutant , certain SIP element requirements that are developed to demonstrat e and achieve attainment become unnecessary because the area has already atta ined the standard. These SIP elements that are tied to demonstration of attainment become suspended as long as the Clean Data Determination has not been rescinded. These particular SIP elements would never be required if the area is redesignated to a maintenance area for that pollu tant. Guidance on this subject is found on page 6 of the EPA’s Memorandum, Procedures for Requests to Redesignate Areas to Attainment , from John Calcagni, Director, Air Quality Management Division , dated September 4, 1992 which states “requirements for reasonable further progress ... will not apply for redesignations because they only have meaning for areas not attaining the standard.”

This guidance is reaffirmed in EPA’s Apr il 6, 2011 Memorandum from Janet McCabe, Deputy Assistant Administrator, Office of Air Quality Planning and Standards, titled Reasonable Consistency for the Administra tive Requirements of State Im plementation Plan Submittals and the Use of “Letter Notices”. Attachment C of the 2011 McCabe memo details that suspensions are only valid while the area is in complian ce with the standard and how the suspended requirements are relieved:

Upon EPA’s promulgation of a final Clean Data Determination for a nonattainment area, the obligation for the State to s ubmit for such an area the attainment demonstration, associated reasonably avail able control measures, reasonable further progress plan, contingency measures, and other attainment-related planning requirements is suspended until such time as the area is redesignated to attainment, at which time the requirements no longer apply; or until EPA determines that the area has violated the NAAQS, at which tim e the obligations would again apply.

As such, on June 21, 2011, the state withdrew th e above mentioned 8-hour Ozone Attainment Demonstration and Reasonable Further Progress Demonstration, because the area has already attained the NAAQS. All emission reductions and control measures from the plan remain in place as permanent and enforceable because they are based on federal or SIP-approved state regulations or consent agreements. By withdr awing the attainment demonstration, the EPA administrator was no longer required to approve or disapprove this plan. The attainment demonstration is no longer applicable because th e area has attained the standard. Missouri has submitted to EPA all applicable SIP provisions to ensure the protection of the standard. See section 2.5 of this document for a discussion rega rding the applicable SI P elements required15 under Section 110 and Part D of the CAA for the Mi ssouri portion of the St . Louis nonattainment area for the for the 1997 8-ozone NAAQS, and see chapter 4 of this document for a discussion regarding the control measures in Missouri’s SIP that were used to attain the 1997 ozone NAAQS.


### 2.3 Permanent and Enforceable Improvement Redesignation requirement (iii) of CAA Section 107(d)(3)(E) states that EPA must determine that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the applicable plan, applicable federa l air pollutant control regulations and other permanent and enforceable re ductions. Therefore, EP A must show that the improvement in air quality between the year that violations occurred, and the attainment year, is attributed to permanent and enforceable emi ssion reductions. Chapter 4 of this document presents the emission reductions that were achie ved from federal and state measures in the St. Louis area. The emission reducti ons are not based on temporary shutdowns or adverse economic conditions, but due to permanent and enforceable control measures. This plan includes a state commitment to continue to enforce all applicable requirements of past re visions to the SIP after the St. Louis ozone nonattainment area is rede signated to attainment thus satisfying CAA 107(d)(3)(E)(iii).


### 2.4 Maintenance Plan Requirements The CAA redesignation requirement of Section 1 07(d)(3)(E)(iv) states that EPA must have a fully-approved maintenance plan for the area as meeting the requirements of CAA Section 175A. Under Section 175A, this 8-Hour Ozone Maintenan ce Plan is the State’s SIP revision to provide for continued attainment of the 1997 8-hour oz one NAAQS for the St. Louis nonattainment area for a period of at least ten year s after EPA has formally redesignated the area to attainment. This maintenance plan and redesignation request has been prepared in accordance with the requirements specified in EPA’ s guidance documents and in coordination with EPA Region 7 staff. Section 2.4 addresses how the following required maintenance plan elements of CAA Section 175A have been met in the subsequent correspondingly-numbered paragraphs:

1. A public hearing on the maintenance plan prior to adoption;

2. A comprehensive emissions inventory of the precursors of ozone completed for the “attainment year”;

3. A projection of the emissions inventory forw ard to a year at least ten years after redesignation and a demons tration that the projected level of emissions is sufficient to maintain attainment of the ozone NAAQS;

4. A commitment that, once redesignated, th e state will continue to operate an appropriate monitoring network to verify maintenance of the attainment status;

5. A demonstration of legal authority to implement and enforce all control measures contained in the SIP;

6. Provisions for future updates of the inve ntory to enable tracking of emissions16 levels, including an annual emissions statement from major sources;

7. Motor vehicle emissions budgets (MVEBs) for transportation conformity for the ten-year maintenance period;

8. A commitment to submit a revised ma intenance plan eight years after redesignation;

9. A list of potential contingency measur es and a commitment to enact and implement these measures expeditiously in the event that future violations of the NAAQS occur.

2.4.1 Public Participation In accordance with Section 110(a)(2) of the CAA, the State of Missouri held a public hearing prior to adoption of this maintenance plan and the subsequent submittal to the EPA. The Air Program notified the public and other interested parties of an upcoming public hearing and comment period thirty (30) days prior to holdi ng such hearing for this maintenance plan as follows:

 Notice of availability of the redesignation request and maintenance plan was posted on the Department of Natural Resources’ Air Pollution Control Program website on February 24, 2014: http://www.dnr.mo.gov/env/ap cp/stateplanrevisions.htm

 A public hearing date to receive comments on the redesignation re quest and maintenance plan was held on March 27, 2014 beginning at 9:00 am at the Lamplighter Inn, Missouri Two Meeting Room, 2820 N Glenstone Avenue, Springfield, MO 65803.

 A public comment period was opened after the redesignation request and maintenance plan was posted on the Department of Natu ral Resources’ Air Pollution Control Program website on February 27, 2014 and closed on Apr il 3, 2014, seven (7) days after the public hearing.

Comprehensive “Attainment Year” Emissi ons Inventory of Ozone Precursors The state has developed a comprehensive em ission inventory for the St. Louis ozone nonattainment area which includes the emissions from the following four source categories: point sources, area sources, on-road mobile sources and off-road mobile sources. The attainment year emission inventory, as required in the main tenance plan, is detailed in chapter 5 of this document.

Projected Emission Inventory for 2025 The state has compiled a list of growth and control factors and de veloped a county-level emission inventory for the future year of 2025 for the Missouri portion of the St. Louis nonattainment area. These projected emissions show substantial decreases between 2008 and 2025 in cumulative emissions that contribute to ground-level ozone concentrations in the ambient air. This future year emission inventory is detailed in chapter 5 of this document and the17 state asserts that these projected future emission levels are sufficient to maintain attainment of the 1997 8-hour ozone NAAQS.

2.4.4 Continued Monitoring Commitment
The State of Missouri is committed to con tinue monitoring ambient ground-level ozone concentrations in the St. Louis area and througho ut the state in accordance with 40 CFR Part 58 and EPA approved Annual Monitoring Plans. Miss ouri will continue to quality assure the ambient air monitoring data in accordance with 40 CFR 58 and submit the data into the AQS in a timely fashion. Detailed information about the ground-level ozone monitoring network in the St. Louis nonattainment area, along with further disc ussion about the state’s continued monitoring commitment, can be found in chapter 3 of this document.

2.4.5 Legal Authority to Implement and Enforce
The Missouri Air Conservation Commission has the legal authority to develop, implement, and enforce regulations regarding air pollution includi ng the requirements of this SIP submittal under Section 643.050 of the Revised Statues of Mi ssouri, also known as the Missouri Air Conservation Law.

2.4.6 Provisions for Future Updates to the Emission Inventory The State of Missouri is committed to provide fu ture inventory updates to enable tracking of emissions levels during the 10-year maintenance period. State Regulation 10 CSR 10-6.110, Reporting Emissions Data, Emission Fees, and Process Information , requires that all installations located in the state that are requir ed to obtain air quality construction or operating permits must report their annual emissions to th e Air Program. The methods for calculating and reporting their emissions are detailed in each instal lation’s applicable permit. The data collected on emissions inventory questionnaires from permitte d sources form the basis of the point source emissions inventory that is compiled on an annua l basis. In addition, in compliance with the Federal Air Emission Reporting Rule [73 FR 76539] , the Air program develops a comprehensive emissions inventory of point, area, a nd mobile sources every three years.

2.4.7 Motor Vehicle Emission Budgets
The establishment of motor vehicle emissi on budgets (MVEBs) for the 1997 ozone NAAQS is no longer necessary with th e revocation of the 1997 ozone NAAQS for Transportation Conformity purposes [77 FR 30160].

However, the State of Missouri has develope d MVEBs for the (newer) 2008 ozone NAAQS in its Early Progress Plan [ http://www.dnr.mo.gov/env/apcp/docs/complete-epp-submittal-8-16- 13.pdf ]. EPA has deemed these budgets to be adequate in a letter dated November 28, 2013. East-West Gateway Council of Governments, th e metropolitan planning organization for the greater St. Louis area, has already started using these MVEBs for the revised ozone standard in their most recent Transportation Conformity dete rmination cycle. It should be noted that the 2008 ozone NAAQS is exactly the same form, but more stringent in concentration, than the 1997 ozone NAAQS. More information on Transportati on Conformity may be found in chapter 6 of this document.18 2.4.8 Commitment to Revise Plan Under CAA Section 175A, an area designated as maintenance for a NAAQS is required to submit a second maintenance plan eight (8) years af ter redesignation of any area as an attainment area under Section 107(d). This second maintenance plan is intended to maintain the NAAQS for ten (10) years after the expi ration of the initial ten year pe riod. The Air Program recognizes the importance of an up-to-date, current main tenance plan, and commits to updating it as
necessary.

2.4.9 Contingency Measures
The State of Missouri is committed to mainta ining compliance with the 1997 8-hour ozone standard. If future violations of the standa rd take place, the state will enact contingency measures as expeditiously as possible, that wi ll allow for the area to come back in compliance with the standard as quickly as feasible. Fu rther information about this commitment to enact contingency measures, and a potentia l list of contingency measures that would be evaluated if the area falls out of compliance with this standard in the future are located in chapter 7 of this document.


### 2.5 Section 110 and Part D Requirements The CAA requirement in Section 107(d)(3)(E)(v) for redesignation states that, all the requirements of Section 110 Implementation Plans and Part D of the CAA that were applicable prior to submittal of a complete redesignation request must be met.

2.5.1 Section 110 Requirements On May 8, 2007, EPA approved the Missouri SIP to address the requirements of Section 110(a)(2)(D)(i) of the CAA for the 1997 8-hour oz one NAAQS [72 FR 25975]. In addition EPA approved Missouri’s SIP submissi on addressing the remaining ozone NAAQS infrastructure SIP elements of CAA 110(a)(2) for the entire state on July 11, 2011 [76 FR 40619]. All other CAA Section 110 provisions are administ rative, procedural or options that do not require a submission on behalf of the State.

2.5.2 Part D Requirements Certain requirements under Part D of the Clean Air Act (Nonattainment Plan Provisions) are suspended when a nonattainment area achieve s the NAAQS because these requirements are related to the attainment of the air quality goal as discusse d above in sec tion 2.2 of this document. Thus the intention of these requirements has been fulfilled with attainment of the NAAQS without the necessity of further s ubmittals as long as the area’s Clean Data Determination has not been rescinded.

Other requirements under Part D of the Clean Air Act remain applicable despite the clean data determination because they are no t directly related to attainme nt of the NAAQS. The Part D elements that are relevant and applicable to th is redesignation process ar e found in CAA Sections 172(c) and 182(b). Section 172(c) pertains to nonattainment plan prov isions for all NAAQS, while 182(b) elements are specific to moderate ozone nonattainment areas such as the St. Louis area under the 1997 NAAQS. The list below outlines the pertinent elements of these two CAA sections that remain applicable to the St. Louis moderate ozone nonattainment area under the19 1997 NAAQS despite the Clean Data Determination along with a statement of how each element is addressed:

 Section 172(c)(3) Emissions Inventory ( & Section 182(a)(1) Inventory ): The 2002 Base Year Inventory for the Missour i Portion of the St. Louis Ozone Nonattainment area was approved on May 31, 2007 [72 FR 30272]. See section 4.1.

 Section 172(c)(5) Permitting Requirements (& Section 182(a)(2)(C) Permitting Programs) : Missouri has a long-standing and fully-implemented New Source Review (NSR) permitting program for new major s ources and significant modifications of existing sources under St ate rule 10 CSR 10-6.060, Construction Permits Required . See section 5.4.

 Section 182(b)(2) Reasonably Availabl e Control Technology : The St. Louis ozone moderate nonattainment area has an approved VOC RACT De monstration [79 FR 580] and a NO x RACT waiver [76 FR 43598] for the 1997 ozone NAAQS. See section 4.3.

 Section 182(b)(3) Gasoline Vapor Recovery : The St. Louis moderate ozone nonattainment area has a refueling vapor r ecovery program implemented through State rule 10 CSR 10-5.220 Control of Petroleum Liquid Storage, Loading and Transfer. The Air Program is currently deve loping a revision to this rule to account for the federal declaration of widespread use of onboard refueling vapor recovery (ORVR) technology and Stage II waiver [77 FR 28772, May 16, 2012]. See paragraph 5.1.2.

 Section 182(b)(4) Motor Vehicle Inspection and Maintenance: The Inspection/Maintenance (I/M) program for the St. Louis moderate ozone nonattainment area, known as the Gateway Vehicle Inspecti on Program (GVIP), is established by State rule 10 CSR 10-5.381 On-board Diagnostics Motor Vehi cle Emissions Inspection.

 Section 182(a)(3)(B) Emissions Statements: The State complies with this requirement that stationary sources report th eir actual annual emissions of NO x and VOCs through State rule 10 CSR 10-6.110 Reporting Emission Data, emission Fees, and Process Information. This obligation was deemed satisfied and approved into the SIP along with the 2002 Emissions Inventory menti oned above on May 31, 2007 [72 FR 30274].20 

## 3. Ozone Monitoring

Note: This chapter refers to ozone air quality monitoring data specifically for the years 2008- 2010 as this is the three-consecutive year pe riod upon which the original 2011 maintenance plan and redesignation request was based and the Clean Data Determ ination was made. An update for the most recent three-year period is found in section 3.7 of this document and a summary of recent years’ ozone data may be found at http://dnr.mo.gov/env/apcp/docs/ozonemonitordata.pdf

. This chapter presents monitoring information th at demonstrates St. L ouis has attained the 1997 8-hour ozone standard of 0.08 ppm. As mentioned in chapter 2 of this document, attaining the NAAQS is one of the requirements for an area to be redesignated to a ttainment [CAA Section 107(d)(3)(E)(i)]. This demonstrat ion is based on three consecu tive ozone seasons of quality assured data monitored at the St. Louis ozone monitoring network as specified in 40 CFR 58. The ambient air quality monitoring data demonstrat es that the area has attained the applicable NAAQS consistent with methods ci ted in the EPA guidance document: “ Procedures for Processing Request to Redesignate Areas to Attainment ”. The following are requirements for the use of ambient air monitoring data in demonstrat ing that the area is at taining the applicable NAAQS:

 Monitoring data must show that the non- attainment area is attaining the NAAQS.

 The data should be collected and quality assured in accordance with 40 CFR 58 and recorded in the U.S. EPA Air Quality Syst em (AQS) database in order for it to be available to the public for review.


### 3.1 St. Louis Ozone Monitoring Network In 2010, there were 15 sites that monitored ozone in the St. Louis Region. 11 of these sites are located within the St. Louis nonattainment area; 6 in Missouri and 5 in Illinois. In addition, Missouri and Illinois operate at least a monitor upwind and downwi nd of the nonattainment area. The upwind monitors are located in Bonne Te rre, Ste. Genevieve County, Missouri and in Hickory, Randolph County, Illinois. Downwind monitors outside of the nonattainment area are located in Foley, Lincoln County, Missouri and Nilwood, Macoupin County, Illinois. Figure 3-1 shows all monitors in the St. Louis Ozone Monitoring Network.21 Figure 3-1 St. Louis Ozone Monitoring Network



### 3.2 Ambient Air Monitoring Data As previously mentioned, exceedances of the standard are determined on a per monitor basis. An exceedance of the standard occurs any time th at an 8-hour average value is greater than 0.084 ppm. A monitor can exceed the 8-hour standard a nd not violate the standard. A violation of the standard at a specific monitor is determined by taking the fourth-highe st, eight-hour average reading at a monitor for each of three consecutive years and averaging them together. The eighthour ozone standard is 0.08 ppm and, due to r ounding, a monitor must have a fourth highest eight-hour, three-year average reading of 0.085 ppm (85 parts per billion, or ppb) or higher for it to be considered a violat ion of the standard.

Design values are calculated by averaging the annual fourth-highest daily maximum 8-hour ozone concentrations over the thre e consecutive years (40 CFR Part 50). The standard at a site is met when the site’s design value is less than or equal to 0.084 ppm (84 ppb). Design values are used as indicators of a region’s air quality. Th e higher a design value for a monitor, the poorer the air quality is in that area. Along the same lines, if an area shows an increasing design value over a number of years, monitoring data is indi cating that the air qual ity is worsening.22 Figures 3-2 and 3-3 show the design value trends for the monitors in the Missouri portion of the St. Louis nonattainment area and the Illinois portion of the St. Louis nonattainment area, respectively. As indicated by the tr ends in the figures, ozone concen trations have decreased at all monitors, indicating improved air quality throughout the St. Louis region. Within the Missouri portion of the St. Louis nonattainment area, there were a total of 11 sites that violated the 1997 standard according to 2001-2003 air monitoring data (Figure 3-2). During the same time period of 2001-2003, two sites in the Illinois portion of th e St. Louis nonattainment area also violated the 1997 standard (Figure 3-3). As of the thre e-consecutive year period ending in 2010, all sites in the area, , were in compliance of the standard , as shown by the design value data in Figures 3- 2 and 3-3, as well as the comparison maps in Figur e 3-4. Sites that have been discontinued or relocated show design values below the standard at the time of discontinuance or relocation (Figures 3-2 and 3-3).23 Figure 3-2 2001-2010 8-hour Ozone Design Value Trends - MO St. Louis Nonattainment Area, MO (1997 NAAQS = 84 ppb)24 Figure 3-3 2001-2010 8-hour Ozone Design Value Trends - IL St. Louis Nonattainment Area, IL (1997 NAAQS = 84 ppb)25 Figure 3-4 2001-2003 & 2008-2010 Design Values Comparison St. Louis Nonattainment Area 8-hour Ozone Design Values (1997 NAAQS = 84 ppb)

2001-2003 Design Values

2008-2010 Design Values26 

### 3.3 St. Louis Ozone Monitoring Data Analysis The St. Louis area’s complianc e with the 1997 ozone NAAQS is determined by comparing the area’s calculated design values to the ozone standard. As describe d previously, design values are calculated at each monitor by averaging the annual fourth-highest daily maximum 8-hour ozone concentrations over the three cons ecutive years (40 CFR Part 50). The standard at a site is met when the site’s design value is less than or equal to 84 ppb.

The design value for the entire St. Louis nonattai nment area is determined by comparing all of the design values for the monitors in the nona ttainment area. The area’s design value is determined by the single highest individual mon itor’s design value for each three consecutive ozone season averaging period. Th e area’s status of attainment or nonattainment is determined by this design value. For the eight-hour ozone standard, the design value at all monitors for the three-year time periods from 2008 through 2010 did not exceed 0.084 ppm, and thus achieved attainment for the St. Louis nonattainment area. The calculated 2008-20 10 8-hour design values for sites in the St. Louis nonattainment area are pr esented in Table 3-1. As shown in the table, all sites three-year design values are less than th e 1997 standard, demonstrating that the St. Louis area has attained the 8-hour ai r quality standard. The St. Louis nonattainment area’s design value monitor would be the West Alton monitor, due to its design value being the highest. The West Alton monitor is bold in Table 3-1.

Table 3-1 2008-2010 St. Louis 8-Hour Design Values (1997 NAAQS = 84 ppb)

County Monitoring Sites 2008 4 th High 2009 4 th High 2010 4 th High 2008-2010 Design Value
Missouri St. Charles Orchard Farm 72 73 77 74 St. Charles West Alton 76 71 84 77 St. Louis City Blair Street 73 65 71 69 St. Louis Maryland Heights 69 70 76 71 St. Louis Pacific 64 64 69 65 Jefferson Arnold West 70 70 77 72


### 3.4 Missing Data Under the 1997 8-Hour Ozone Standard Eight-hour ozone attainment is determined by a th ree-year average of the annual fourth highest daily maximum. Missing days are of importanc e only in determining whether sufficient data was sampled to determine compliance. A m onitoring day must include 18 valid eight-hour averages for a daily maximum to be determined. To calculate a design value, an average of 90% of the possible daily maximums over a three year period must be complete, with no single year having less than 75% completeness. The final resu lt is that no more than 53 missed days in one year, or 64 missed days total for the three-year pe riod are allowed. If these criteria are not met, then compliance with the 8-hour ozone standard cannot be established. To date, acceptable monitoring has been maintained and exceeded in the Missouri portion of the St. Louis nonattainment area for the 8-hour ozone standard.27 

### 3.5 Quality Assurance Program Ambient air monitoring data from the Missouri oz one network is quality assured in accordance with 40 CRF Part 58 and the Missouri Quality Assurance Project Pl an (QAPP). The QAPP outlines standard operating procedures for operating the network and validating the data. In addition the network is reviewed annually thr ough the Annual Monitoring Plans, according to 40 CFR Part 58.10. A site can either be discontinued or relocated based on the annual review and with an approval from the EPA. The quality assure d data collected at the sites is submitted in the Air Quality System (AQS) and is available for public review as outlined in 40 CFR Part 58. Illinois EPA follows a similar quality assurance system.


### 3.6 Continued Monitoring Commitment The Air Program is committed to continue operating the appropriate ozone network in the St. Louis area, in accordance with 40 CFR 58 and a pproved Annual Monitoring Plans, to verify the attainment status of the area. Missouri will cont inue to quality assure the ambient air monitoring data in accordance with 40 CFR 58 and submit the data to AQS in timely fashion. The St. Louis Metropolitan Statistical Ar ea (MSA) satisfies and exceeds the minimum monitoring requirement for ozone [40 CFR 58 Appe ndix D, Table 2], revisions to the Ambient Air Monitoring Regulations [71 Federal Re gister 61240, October 17, 2006] note that –

While the final rule of re gulations requires fewer mon itors than are now operating for ozone and PM 2.5 , as did the pre-existing monitoring rule, EPA does not intend to encourage net reductions in the number of ozone and PM 2.5 monitoring sites in the U.S. as a whole. The surplus in the existing netw orks relative to minimum requirements gives States more flexibility to choose where to apply monitoring resources for ozone and PM 2.5
. The Air Program is committed to continue monito ring ozone ambient air concentrations in the St. Louis area and throughout the state in accordance with 40 CFR Part 58 and EPA-approved Annual Monitoring Network Plans. Missouri will continue to quality a ssure the ambient air monitoring data in accordance with 40 CFR 58 an d submit the data into the AQS in a timely fashion. Missouri’s most recent proposed air qu ality monitoring network plan is available at: http://dnr.mo.gov/env/apcp/monitoring/monitoringnetworkplan.pdf . Also, visit EPA Region 7’s Air Quality Monitoring Network plan site for more information or to review Missouri’s previous approved network plans: http://www.epa.gov/region07/ai r/quality/quality.htm#mo_air

.


### 3.7 Clean Data Determination On June 9, 2011, EPA published a final clean data determination in the Fe deral Register stating that the St. Louis ozone nonattain ment area covering both Missouri and Illinois has attained the 1997 ozone standard based on three years of quality assured ambient air m onitoring data [76 FR 33647]. Subsequently, EPA also determined that th e St. Louis area had attained this standard by the regulatory deadline of June 15, 2010 [ 77 FR 25363, April 30, 2012]. On December 16, 2013, the Air Program submitted a letter to EPA certifyi ng that the most recent three years (2011-2013) of quality-assured ambient air quality data is in compliance with the 1997 ozone standard.28 

## 4. Redesignation Request: Emissi on Inventory and Controls from 2002 - 2008 A redesignation request must c ontain a demonstration that the improvement in air quality, between the year that violations occurred and the year that atta inment was achieved, is based on permanent and enforceable emissions reductions. As described previously in chapter 3, threeconsecutive ozone season monitoring periods are used to evaluate whether actual air quality attainment has been achieved. In this chapter, the “attainment year” refers to the first year (2008) of the three-year period (2008-2010) used to demonstrate attainment, and the base year refers to the mid-point year (2002) of the thre e-year period used to determine the nonattainment designation. The inventories de tailed in this chapter for 2002 and 2008 include data categories for point, area, on-road mobile , and non-road emissions for NO x and VOC. Additional details for the base and attainment year inventorie s for 2002 and 2008 are found in Appendices A and B, respectively.



### 4.1 Base Year and Attainment Year Inventories Table 4.1 is a comprehensive emissions invent ory for the Missouri side of the St. Louis nonattainment area, including point, area, on-road m obile, and non-road sources for precursors of ground-level ozone (NO x and VOC) for the base year, 2002. Table 4.2 summarizes the emissions inventory for the Missouri side of the St. Louis nonattainment area for NO x , and VOC for the attainment year, 2008. Both the 2002 a nd 2008 inventories are based on actual activity levels. Illinois has an approved maintenance plan for their portion of the nonattainment area under the 1997 ozone NAAQS, which was approved by EPA on June 12, 2012 [77 FR 34819]. Therefore, this section only includes emissions inventorie s for the Missouri portion of the nonattainment area. The emissions invent ories for the years 2002 and 2008 for the Illinois portion of the nonattainment area, which were included in Illinois’ maintenance plan, are provided for reference in Appendix H.

The 2002 base year inventory includes emissions from point, area, on-road mobile and non-road emissions. Table 4.1 states the 2002 emissions in tons/ozone season day, and summarizes the emissions by major source category and by pollutant for the St. Louis nona ttainment area. On May 31, 2007, EPA approved Missouri’s 2002 Base Year Inventory for the Missouri Portion of the St. Louis Ozone Nonattainment area [ 72 FR 30272]. Summary tables of the 2002 anthropogenic emissions inventory for the St. Lo uis ozone nonattainment area may be found in Appendix A.

The 2008 emissions inventory listed in this chapter is listed in tons /ozone season day. In order to calculate the emissions in tons/ozone seas on day for the Missouri portion of the ozone nonattainment area, the Air Program followed the methods listed in Appendix B of this document. Briefly, for point sources, ozone season day emissions are calculated on the EIQ form 2.0Z, Ozone Season Information. The facil ity-reported maximum daily throughput during the ozone season is multiplied by the pollutant em ission factor and reduced by control device to reach the ozone season daily emissions. For area sources, ozone season day emissions were calculated from Emissions Modeling Clearinghouse (EMCH) temporal allocation profiles that are Standard Classification Codes (SCC)-specific. Ozone season day emissions are typical of a Tuesday in July. See Appendix B-7 for the tempor al allocation method tables. Appendix B-729 outlines this procedure for area sources, and gi ves an example. Non-road ozone season day emissions may be found in Appendix B-6.

Finally, for on-road mobile sources, emissions were created using Mobile6.2 via the National Mobile Inventory Model (NMIM) with 2008 vehicl e miles traveled (VMT) data provided by the East West Gateway Council of Governments in coordination with the In teragency Council of Governments. The 2008 VMT data was generated from East-West Gateway's Traffic Demand Model and then compared to Highway Performa nce Monitoring System (HPMS) data. Through this comparison, calibration factor s were developed and then app lied to the VMT data from the Traffic Demand Model in order to estimate the actual 2008 VMT for the St. Louis nonattainment area. The NMIM National County Database (NCD) was updated with Missouri specific data. Please see Appendix B-4 for additional details regarding the 2008 on-road mobile emissions calculated using Mobile 6.2 via NMIM.

The EPA’s Mobile6.2 emissions model was used to generate the mobile source emissions in this chapter in order to allow for a useful comparison between 2002 and 2008 mobile emissions. The mobile emissions generated for the 2002 em issions inventory used Mobile6.2, and it was necessary to use the same mobile emission mode l to compare the base and attainment year mobile source emissions. However, in chapte r 5 of this document, the 2008 and 2025 mobile source emissions were generated using EPA’s Motor Vehicle Emissions Simulator (MOVES). More information about the use of these two different emission models can be found in chapter 5 and Appendix B-5 of this document.

Tables 4-1 and 4-2 summarize the 2 002 and 2008 average daily ozone season NO x and VOC emissions from the Missouri side of the St. L ouis ozone nonattainment ar ea, respectively. Table 4.3 shows the differences in inventories between these two years for each source category and pollutant of concern. As seen in Table 4-3, NO x emissions decreased by 121 tons per ozone season day, which is a reduction by nearly 1/3 (33%) from the 2002 levels. Meanwhile, total VOC emissions remained relatively stable, incr easing by only 1.4 tons/day, which is less than 1%. As can be seen, VOC emi ssions decreased for every categor y except for area sources. The area source VOC increase is due to a change in the reporting of small, non-Title-V-permitted sources from the point category in 2002 to the nonpoint category in 2008, as well as numerous changes in the area source esti mation methodologies and emission factors. The substantial reduction in NO x emissions between 2002 and 2008, along wi th other regional controls have resulted in the improved monitored ground-leve l ozone concentrations in the St. Louis nonattainment area attributable to the 1997 ozone NAAQS compliance.

Table 4-1. 2002 VOC and NOx Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattainment Area (tons per ozone season day)

Source Category NO x VOC Point Sources 127.2 32.7 Area Sources 19.4 71.3 On-Road Mobile Sources 159.0 68.1 Non-Road Sources 60.7 47.0 Total 366.3 219.130 Table 4-2. 2008 VOC and NO x Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattainment Area (tons per ozone season day)

Source Category NO x VOC Point Sources 88.8 18.0 Area Sources 6.5 99.5 On-Road Mobile Sources 96.2 57.9 Non-Road Sources 53.6 45.2 Total* 245.2 220.5 *Note: Values may not total exactly due to rounding.

Table 4-3. Comparing 2002 and 2008 VOC and NO x Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattain ment Area (tons per ozone season day)

Source Category NO x VOC Point Sources* -38.4 -14.7 Area Sources* -12.9 +28.2 On-Road Mobile Sources* -62.8 -10.2 Off-Road Mobile Sources* -7.1 -1.8 Total** -121.1 +1.4 *Note: A negative value indicates a d ecrease in emissions from 2002 to 2008. A positive value indicates an increase in emissions from 2002 to 2008. **Note: Values may not total exactly due to rounding. 

### 4.2 Permanent and Enforceable Contro ls Used to Attain the Standard The St. Louis area was designated as nonattain ment of the 1997 8-hour ozone NAAQS in 2004. Since that time, the implementation of pe rmanent and enforceable reductions of NO x and VOC emissions have contributed to improvements in ground level ozone concentrations and to the attainment of the 1997 8-hour ozone NAAQS. The pr imary control measures used to attain the 1997 8-hour ozone standard include:

 New Source Performance Standards (NSPS)

 National Emissions Standards for Hazardous Air Pollutants (NESHAPS)/Maximum Achievable Control Tec hnology (MACT) Standards

 Federal gasoline detergent additive rule

 NO x SIP Call

 Clean Air Interstate Rule (CAIR)

 Heavy-Duty Diesel Engine Standards

 Tier 2 Rule-Vehicle Standards

 Tier 4 Rule-Off Road Mobile Engine Standards

 Reformulated Gasoline (RFG)

 Gateway Vehicle Inspection Program31  National VOC Emission Standards for Consumer and Commercial Products (Part 59)

o Automobile Refinishing Rule

o Architectural and Industrial maintenance coating rule

o Consumer Products so lvent control rule

 Missouri State Rules

4.2.1 Federal Emission Trading Programs and the NO x SIP Call

The NO x SIP Call and CAIR required states to re duce emissions that are prohibited by the interstate transport provisions of the Clean Air Act Section 110( a)(2)(D)(i)(I). Both rules also established emission trading program s that states could use to re duce the transport of emissions that have significant impacts on downwi nd nonattainment and maintenance areas.

One outcome of the NOx SIP Call was the establ ishment of the NOx Budget Trading Program (NBP). The first year in which covered sources were required to comply with the NBP was 2003. Missouri complied with the requirements of the NBP through state rule 10 CSR 10-6.360 Controlling NO x Emissions From Electric Generating Units and Non-Electric Generating Boilers , which required applicable sources in the easte rn third of the state to participate in the NBP. Implementation of the NBP greatly reduced ozone season NO x emissions from large sources such as electric genera ting units (EGUs). According to data from CAMD’s Website, the total ozone season NO x emissions from EGUs located in th e St. Louis nonattainment area have been reduced by 4,942 tons (approx. 32.3 tons/oz one season day) from 2002 to 2008. These reductions are almost exclusively attributed to implementation of the NBP. In Missouri, three non-EGU boilers also participated in the NBP, specifically Trigen Units 5 and 6 and Anheuser Busch Unit 6.

Also in response to the NO x SIP Call, three other State rules were developed to control ozone season NO x emissions from covered sources in the eastern third of the state. The rules written to comply with the NO x SIP Call requirements include the statewide NO x rule 10 CSR 10-6.350 Emissions limitations and Emissions Trading of Oxides of Nitrogen , which established a statewide NO x trading program for EGUs, 10 CSR 10-6.380 Control of NO x Emissions From Portland Cement Kilns , which controls ozone season NO x emissions from cement kilns, and 10 CSR 10-6.390 Control of NO x Emissions From Large Stationa ry Internal Combustion Engines

. From 2002 to 2008, the NO x emission reductions from all poi nt sources in the nonattainment area totaled 38.4 tons /ozone season day. Th is accounts for a more than 30% reduction.

CAIR, which was promulgated several years after the NO x SIP Call, established three emission trading programs that states could use to address transported emissions – the CAIR NO x ozone season trading program, the CAIR annual NO x trading program and the CAIR SO 2 trading program. The CAIR ozone-season NO x trading program replaced the NBP and the statewide NO x rule (10 CSR 10-6.350). In the St. Louis area, the CAIR ozone season NO x trading program required the same EGUs and the same three non-E GU boilers mentioned above to participate as were required under the NBP. However these th ree units have all been retired and received retired unit exemptions that pr ohibit these units from operating. The signed EPA retired unit exemption forms for these three units are in cluded in this document as Appendix F.32 The CAIR ozone-season NO x trading program, along with the CAIR annual NO x trading program began in 2009. In regards to the EGUs lo cated in the St. Louis nonattainment area, the ozone season NO x requirements in CAIR were comparab le to the requirements under the NO x SIP Call. However, CAIR had a significant impact on the EGUs located in the western twothirds of the state, and these sources significantly re duced their ozone season NO x emissions. Some of the facilities in the west ern two-thirds of the state instal led controls earlier than 2009 in anticipation of CAIR. While the NO x controls added in the western two-thirds of the state do not affect the NO x emissions inventory for the St. Louis nona ttainment area, they did have a positive impact in reducing the transporte d or regional contribution of NO x emissions to the ozone monitors located in the nonattainment area.

It was anticipated that EPA’s Cross-State Air Pollution Rule (CSAPR) would replace the CAIR trading programs beginning January 1, 2012. EPA promulgated CAIR on May 12, 2005 and the CAIR federal implementation plans on April 26, 2006. In 2008, the US Court of Appeals for the DC Circuit remanded CAIR to the agency, and EPA finalized CSAPR to replace CAIR on July 6, 2011. However, prior to CSAPR implementation, the District of Columb ia Circuit Court of Appeals stayed the implementation of CSAPR in December 2011. The court directed EPA to continue implementing CAIR until the legal decision regarding CSAPR is resolved. In August 2012, the U.S. District of Columbia Circuit Cour t of Appeals issued a decision vacating CSAPR and directed EPA to continue to implement CA IR until they can implement a replacement rule that addresses the Court’s concerns.

Furthermore, on November 19, 2012, EPA’s Assist ant Administrator Gina McCarthy issued a memorandum regarding Next Steps for Pending Rede signation Requests and State Implementation Plan Actions Affected by the Recent Court Decision Vacating the 2011 CrossState Air Pollution Rule : http://www.epa.gov/airquality/trans port/pdfs/CSAPR_Memo_to_Regions.pdf . In this memo, EPA referred to a number of various pending rede signation requests, maintenance plans, and SIP submittals from states and noted that because the court directed EPA to continue administering CAIR pending the promulgation of a valid replacement: ...we believe that it will be appropriate to rely on CAIR emission reductions as permanent and enforceable for cer tain actions in certain circ umstances. Specifically, we believe it will be appropriate to rely on thos e reductions until the petition and any further proceedings in the CSAPR case are resolved or, if the decision vacating CSAPR is not changed, until a valid replacement rule is developed and implementation plans complying with any new rule are submitted by the states and acted upon by the EPA. Thus, action on the pending requests and SIPs may go forward.

It is noted, that EPA has app ealed the DC Circuit Court’s de cision to vacate CSAPR to the Supreme Court, and the Supreme Cour t has agreed to hear the case. As a result of this continued litigation, there is still un certainty regarding CSAPR.

However, the CAIR requirements for ozone season NO x emission reductions remain in effect and this CAIR emission trading program is operating. Moreover, the D.C. Circuit has ordered EPA to continue implementing CAIR pending developm ent of a replacement rule. Therefore, CAIR may be relied upon as the permanent and enforcea ble control measures to control ozone season33 NO x emissions from EGUs that are included in this program until an equivalent or better rule / program is in place.

4.2.2 Federal Mobile Source Emission Controls Federal and state regulations for mobile sources that have been phased in since 2002 have had a positive impact on the emissions inventory for both NO x and VOC emissions from on-road and non-road mobile sources. Mobile source regul ations including Heavy-Duty Diesel Engine Standards and Low-Sulfur Diesel, Tier 2 Rule-Veh icle Standards, Tier 4 Rule-Off Road Mobile Engine Standards, Reformulated Gasoline (RFG ), and the Gateway Vehicle Inspection Program (10 CSR 10-5.381 On-Board Diagnostics Motor Vehicle Emissions Inspection .) have reduced the NO x and VOC emissions from the mobile sect or in the St. Louis nonattainment area.

Overall, the retirement of olde r higher polluting vehicles and th e phasing in of federal on-road mobile source standards from 2002 to 2008 have contributed to a decrease of 62.8 tons/ozone season day of direct NO x emissions (about 40% reduction), a nd 10.2 tons/ozone season day of VOC emissions (about 15% reduction). These on-ro ad mobile source emission reductions have significantly contributed to atta inment of the 1997 8-hour ozone NAAQS in the St. Louis area.

Federal regulations for the contro l of mobile sources are perman ent and enforceable, and it is likely that standards will become increasingly more stringent for the mobile source sector. The mobile source control measures have result ed in the significant reductions in both NO x and VOC emissions. The continued tightening of federal mobile source standards and phase out of older higher-polluting vehicles will continue to contribute to maintenance of the 1997 8-hour ozone NAAQS.

4.2.3 State Regulations In addition to the Gateway Vehicle Inspection Pr ogram, federal mobile source standards, and the state regulations written to control ozone season NO x emissions in response to the NO x SIP Call, there are numerous state regula tions that provide permanent a nd enforceable controls for NO x and VOC emissions in the St. Louis nonattainment area. The rules in Title 10 Division 10 Chapters 5 and 6 of the Missouri Code of Stat e Regulations include permanent and enforceable control measures for ozone precursor emissions in the St. Louis nonattainment area. These controls include control tec hnique guidelines for numer ous VOC sources, open burning restrictions, and emission standards for incine rators. For additiona l information on state regulations to control VOC emissions in the St. Louis area, see the 2011 Reasonably Available Control Technology Demonstration Update for the 1997 8-Hour Ozone Standard in the St. Louis Area discussed in section 4.3 below.

Furthermore, many regulations designed for one pollutant control program have a benefit in another. For example, the rules which implemen t the Air Toxics or Hazardous Air Pollutants (HAPs) program pursuant to CAA Section 112 also in many cases control VOCs. In Missouri, this program is implemented th rough State rules, 10 CSR 10-6.070 New Source Performance Regulations , 10 CSR 10-6.075 Maximum Achievable Control Technology Regulations & 10 CSR 10-6.080 Emission Standards for Hazardous Air Pollutants. Although these rules are ostensibly for the control of HAPs, they benefit ozone contro l (and as such are listed in section 4.2) because many HAPs are also VOCs.34 

### 4.3 Reasonably Available Cont rol Technology (RACT) Pursuant to Sections 172, 182(b) and (f) of the CAA, RACT is required for a ll existing major sources of the applicable criteria pollutant and its precursors located in nonattainment areas. The EPA defines RACT as the lowest emissions limita tion that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological feasibility and economic reasona bleness [70 FR 71612; November 29, 2005]. The major source threshold for moderate nonattainment ar eas is defined as 100 tons per year (tpy) of NO x or VOCs. A source generally consists of se veral units that emit pollutants. The sum of emissions from all units at the source determines if a unit is major and thus subject to RACT requirements.

On April 20, 2011, the Air Program requested an ex emption for sources of nitrogen oxides (NO x ) in the Missouri portion of the St. Louis metropo litan 8-hour ozone nonattainment area from the NO x RACT obligations pursuant to CAA Secti on 182(f). The waiver demonstrates that additional reductions of NO x emissions in the area would not contribute to attainment of the 1997 ozone NAAQS. EPA published this exempti on as a direct final rule and received no comments on this rule [76 FR 43598]. The rule became effective September 19, 2011. This NO x waiver alleviates the requirements for a demonstration that NO x RACT obligations have been met. Therefore, only VOC RACT demonstration requirements are necessary for redesignation.

Sections 172, 182(b)(2), and 182(f) of the C AA also require implem entation of RACT for sources that are subject to Control Techni ques Guidelines (CTGs) documents that are promulgated by the EPA. The EPA has issued CTGs defining presumptive RACT for those categories of sources that emit the greatest amounts of VOC emissions. In 2006-2008, the EPA issued 12 new CTG’s in three groups. The 2006 CTG’s addressed industrial cleaning solvents, offset lithographic printing and letterpress prin ting, flexible package printing and flat wood paneling coatings. The 2007 CTG’s address pape r, film, and foil coatings, large appliance coatings, and metal furniture coatings. The 2008 CTG’s address miscellaneous metal and plastic parts coatings, fiberglass boat manufacturing mate rials, miscellaneous industrial adhesives, and automobile and light-duty truck assembly coatings. Per the CAA, CTG’s establish presumptive RACT for the VOC sources they cover. CTG RACT can apply to sources at a level much lower than the 100 tpy threshold employed for other RACT sources in moderate ozone nonattainment areas. In fact, some of these newly-issued CTGs apply to sources with emissions as low as 2.5 tpy. Any state with moderate ozone nonattainment areas must implement equivalent RACT for all promulgated CTGs prior to redesignation of those areas. The Air Program developed amendments to four VOC rules to address th ese new CTGs for which there are existing applicable sources in the St . Louis nonattainment area.

The (4) four rules that have been ame nded to account for these new CTGs are —

 10 CSR 10-5.330 Control of Emissions From Indus trial Surface Coating Operations

 10 CSR 10-5.340 Control of Emissions From Ro togravure and Flexographic Printing

 10 CSR 10-5.442 Control of Emissions from Lithographic Printing Operations

 10 CSR 10-5.455 Control of Emissions from Solvent Cleanup Operations35 These new rulemakings were proposed for public hearing March 31, 2011, and were adopted by the MACC on April 28, 2011. The first three ru les listed above were approved by EPA on January 23, 2012 [77 FR 3146] for inclusion into the SIP. The fourth rule, 10 CSR 10-5.455, underwent another minor revision in 2012 and al so became SIP-approved by EPA on January 6, 2014 [79 FR 580]. The approval of these CTG rule s was a necessary element to allow the St. Louis area to be redesignated to at tainment for the 1997 ozone standard.

RACT is not a new requirement for the 1997 8- hour ozone NAAQS. Missouri has previously addressed RACT requirements in the St. Louis nonattainment area in developing attainment plans for the 1-hour ozone standard. For the 1997 8-hour standard, the Air Program developed a RACT demonstration as an element to the ozon e SIP revision. Per the federal implementation rule for the 1997 ozone standard, the RACT dem onstration was to be submitted as a separate element prior to the submittal of the attainment demo and other elements of the SIP revision. RACT plan was adopted on December 7, 2006 and submitted to the EPA on January 5, 2007.

Since these new CTGs were not co nsidered in the 2006 RACT demonstration, and in an effort to ensure that RACT determinations for th e St. Louis nonattainment area are ongoing and continuous, the Air Program developed an update to the 2006 RACT dem onstration to support this redesignation request. Because of the NOx RACT waiver, this updated RACT demonstration showed how VOC RACT has been upgraded as appropriate since the last RACT submittal. This updated VOC RACT docum ent was adopted by the MACC on April 28, 2011 and submitted to EPA on May 25, 2011. The doc ument was conditionally approved by EPA on January 23, 2012 and finally approved into the SIP on January 6, 2014 [79 FR 580].

For a more detailed discussion of RACT issues , please refer to the updated RACT demonstration adopted April 28, 2011, which can be found at http://dnr.mo.gov/env/apcp/sips.htm#ozone36 

## 5. Maintenance Plan Demonstr ation: Emission Inventory and Controls from 2008 - 2025

The purpose of this chapter is to address the fi rst two elements required for a maintenance plan as listed in subsection 2. 4 of this document, which include providing a comprehensive attainment year emissions inventory and a pr ojected emissions inventory at least ten years into the future after the SIP is approved. This sec tion demonstrates that emissions of NO x and VOC in the Missouri portion of the St. L ouis nonattainment area will remain below the levels of the attainment year emissions inventory, based on permanent and enforceable emission control requirements, for a period of ten years after EP A approves this maintenance plan. This section also includes an emissions inventory for an inter im year to demonstrate th at emissions in the St. Louis area will remain below the attainment y ear emissions inventory throughout the ten-year maintenance period.

The future year of 2025 was used in this maintena nce plan because the future year included in a maintenance plan must be at least 10 years into the future after EPA approves the plan. By selecting 2025 for the future year EPA will have more than a year to approve this plan and redesignate the area to attainment.

This chapter also includes a discussion of regul ations that have become effective since 2008, and a list of expected future regulations that will help to continue to control NO x and VOC emissions in the St. Louis area. The Air Program commits to keeping all previously adopted control measures that are included in Missouri’s appr oved SIP in place after redesignation unless the SIP is revised and approved by EPA to remove such requirements. If the removal of such requirements would potentially alleviate control re quirements for emission sources in Missouri, then the SIP revision shall require an “anti-back sliding” demonstration under Section 110(l) of the Clean Air Act. In addition, nonattainment new source review (NSR) permitting requirements will continue to apply to construction of new major sources and to significant modifications of existing sources due to the area’s designa tion as nonattainment under the more recently promulgated 2008 ozone NAAQS. These existing and future control measures identified in the maintenance plan are relied upon to maintain the 1997 8-hour ozone NAAQS.


### 5.1 Base/Attainment Year Inventory an d Future Year Emission Projections A maintenance plan must contain a demonstration that the levels of emissions projected for the ten-year period following redesign ation are sufficient to maintain the NAAQS. Accordingly, the Air Program has projected NO x and VOC emissions for the St. Louis nonattainment area for 2025. Emissions for this projection year are comp ared to emissions levels in 2008 to determine if emissions levels are sufficient to maintain the NAAQS during this period. Illinois has an approved maintenance plan for their portion of the nonattainment area under the 1997 ozone NAAQS, which was approved by EPA on June 12, 2012 [77 FR 34819]. Therefore, this section only includes emissions inventories and projectio ns for the Missouri portion of the nonattainment area. The emissions inventories for the years 2008, 2015, 2020, and 2025 for the Illinois portion of the nonattainment area, which were included in Illinois’ approved maintenance plan, are provided for reference in Appendix H.37 For the purposes of this section, a modified 2008 emission inventory was developed. The 2008 inventory in this secti on will act as the base year compared to the 2025 inventory detailed in this section. The base year 2008 inve ntory includes point, area, on-road mobile, and non-road source categories. The emissions from point, area, a nd non-road source categorie s are identical to the 2008 attainment year inventory lis ted in the previous chapter. However, the on-road mobile source inventory is different. This is due to the fact that a di fferent mobile emission model was used to develop the inventory in this section of the document, whic h is explained in further detail below in paragraph 5.1.1. The 2008 base year an nual emissions inventory for the Missouri side of the nonattainment area is include d in this plan as Appendix B.

5.1.1 On-Road Mobile Source Emissions Inventory Development For this section of the document, on-road motor vehicle emissions for the Missouri side of the nonattainment area were developed using U.S. EPA’s MOVES motor vehicle emissions model and VMT data from East-West Gateway Council of Government in coordination with the St. Louis Transportation Conformity Interagency Consultation Group.

The method for mobile emissions modeling was ch anged when EPA’s previous on-road mobile model (Mobile 6) was replaced with a completely redesigned model (MOVES). The MOVES model was redesigned to reflect EPA’s curren t understanding of the emissions produced by vehicles and the various factors that affect these emissions.

As a result of these changes to the model, MOVES produced higher emissions estimates for both 2008 and 2025 than were originally created with Mobile 6.2 via NM IM (refer to section 4.1). NO x emissions increased for the extended idli ng of heavy duty vehicles. VOC emissions calculated with MOVES are comparable to VOC em issions calculated with Mobile 6.2, however they are slightly higher. Ther efore, in addition to running a projected emissions budget for 2025 for on-road emissions, 2008 base year emissions were also run using MOVES for the Missouri portion of the nonattainment area. This allows for a meaningful comparison in emissions from 2008 to 2025. By using MOVES to calculate th e 2008 and 2025 mobile emission inventories, a smooth transition will occur for any new mobile m odeling that will be needed in future SIPrevisions. Additional details about the development of the MOVES-based 2008 and 2025 onroad mobile emissions inventories for the Missour i side of the nonattainment area are located in Appendix B for 2008 and Appendix D for 2025.

5.1.2 Point, Area, and Off-Road Mobile So urce Emissions Inventory Development for the Missouri Side of the Nonattainment Area The projected point and area source emissions in the Missouri portion of the St. Louis nonattainment area for 2025 were estimated usi ng the 2008 base year inventory and growth factors appropriate for each source category. Gr owth factors were created from the EGAS model ( http://www.epa.gov/ttnecas1/egas5.htm ) using economic growth projections from the Policy Insight® Model for Regional Economic Model, In c (REMI). Area source stage II refueling emissions for 2025 were calculated with MOVES and assumed that Stage II vehicle refueling vapor recovery controls would no longer be re quired in the St. Louis area by 2025. The Air Program is currently developing a SIP revision to remove Stage II requirements as a result of the widespread use of on-board vapor recovery systems, and it is exp ected that Stage II controls on38 refueling stations in the Missour i portion of the St. Louis nonatta inment area will be completely removed by December 31, 2015.

An adjustment was made to account for the retire ment of two units located at MEMC Electronic Materials, Inc. that were subj ect to a 2009 Consent Agreement. These two emission units will no longer be permitted to operate unless a new constr uction permit is granted, therefore, the consent agreement was terminated in 2013. A copy of the 2009 consent agreement and the letter from the Air Program terminating the agreement is included in this document as Appendix G.

Finally, ozone season NO x emissions from EGUs in the futu re year were projected based on permanent and enforceable controls in plac e for these sources. The ozone season NO x emissions from the following four EGU facilities: Ameren ’s Labadie, Meramec, Rush Island, and Sioux were grown as follows: the actual regu latory ozone season (May–September) NO x emissions from these Ameren units from 2008-2011 were obtained from the Clean Air Market Division database and averaged to obtain a year ly regulatory ozone season average of NO x emissions over these four years. This yearly regulatory ozone season average of NO x emissions over these four years were then divided by 153 (the number of days in the regul atory ozone season to obtain the projected average ozone season day emissions in 2025 for these four facilities. This four year average of regulatory ozone season NO x emissions was determined to be representative of the projected NO x emissions from these facilities in 2025 because of CAIR. In 2015, their allowances from CAIR drop significantly, but th ey will likely have some banked allowances allowing them to hold their ozone season NO x emissions steady for the first several years after the 2015 CAIR allocations take effect.

NO x and VOC emissions from non-road sources for 2008 and 2025 for the Missouri side of the nonattainment area were developed using the U.S. EPA’s NONROAD model. The non-road source emissions inventory also includes emissi ons from aircraft takeoffs and landings, commercial marine vessels, and locomotives. Th e emissions from these three categories were grown from 2008 levels to the future year usi ng EGAS growth factors. Additional details regarding the development of the 2008 and 2025 non-road source emissions inventory for the Missouri side of the nonattainment can be f ound in Appendix B for 2008 and in Appendix D for 2025.

5.1.3 2008 and 2025 Emissions Inventory Summary for the Missouri Side of the Nonattainment Area Table 5-1 displays the 2008 ozone season day emissions inventory summary for the Missouri portion of the nonattainment area for point, ar ea, on-road mobile, and non-road source categories. Table 5-2 displays the projected emi ssions inventory summary for the future year in this plan (2025) for the Missouri portion of the nonattainment area.

Table 5-3 provides a comparison of emissions for the years 2008 and 2025, using the 2008 onroad mobile source emissions listed in Table 5- 1 to reflect the MOVES values for consistent comparison purposes. Table 5-3 shows the diffe rences by source category along with the total changes in emissions for each pollutant listed. As shown in the table, both NO x and VOC emissions within the nonattainment area are expe cted to decrease sign ificantly between 2008 and 2025. NO x emissions are expected to drop nearly 47%, while VOC reductions are about 6.5%39 over the projected period. Based on these emissions trends for NO x and VOC it is expected that air quality will continue to meet the 1997 8-hour ozone NAAQS throughout the maintenance period.

Table 5-1. 2008 VOC and NO x Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattainment Area (tons per ozone season day) Source Category NO x VOC Point Sources 88.84 18.0 Area Sources 6.52 98.74 On-Road Mobile Sources 160.38 58.53 Off-Road Mobile Sources 60.85 46.44 Total 316.59 221.71

Table 5-2. 2025 VOC and NO x Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattainment Area (tons per ozone season day) Source Category NO x VOC Point Sources 89.81 28.01 Area Sources 6.85 130.91 On-Road Mobile Sources 41.66 20.15 Off-Road Mobile Sources 29.44 28.17 Total 167.76 207.24

Table 5-3. Comparison of 2008 and 2025 VO C and NOx Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone No nattainment Area (tons per ozone season day) Source Category NO x VOC Point Sources* +0.97 +10.01 Area Sources* +0.33 +31.44 On-Road Mobile Sources* -119.59 -40.71 Off-Road Mobile Sources* -24.17 -16.99 Total* -148.83 -14.47 *Note: A negative value indicates a projected decrease in emissions from 2008 to 2025. A positive value indicates a projected increase in emissions from 2008 to 2025.

It should be noted that the proj ected increase in VOC emissions for point and area sources are based on (EGAS) growth factors. Due to the us e of these growth factors, emissions of VOC from point and area sources are projected to increase by 2025. However, these projected increases are likely overstated and actual po int and area source emissions of VOC are not expected to increase as much as the growth f actors suggest. EPA’s Regul atory Impact Analysis (RIA) for the 2006 PM NAAQS rule, Appendix D ( http://www.epa.gov/ttn/ecas/regdata /RIAs/Appendix%20D--Inventory.pdf), notes on pages D29 to D-36, that though REMI data was used in their emission forecasting method, the40 oversimplification of emissions growth based on economic factors likely overestimates projected emissions. EPA’s recognition of the downward trend in emissions during times of economic growth supports the conclusion th at the VOC increases for area s ources are likely an artifact of the growth methodology. From page D-36 —

While it is not clear that all of the factors that have served to produce this historical decline will continue to operate in the futu re, it appears unreasonable to assume that we currently have arrived at an ‘inflection point’ past which the trend will stop or reverse itself. Indeed, because the available data s how that a number of large sources in the sectors of interest have no or limited pollution controls, it is reasonable to expect emissions rates will be steady or decline. C ontinuing to ignore this factor in future-year emission projections may incr easingly skew the predicte d emissions increase, and the farther into the future the forecast the more dramatic the impact. The preceding and other explanations suggested that we need to reevaluate our emission forecasting approaches for stationary non-EGU sources to incorporate fact ors not adequately considered in past methodologies.

Despite these conservative projectio ns from EGAS growth factors, NO x and VOC emissions are still projected to decrease on the Missouri side of the nonattainment area from 2008 – 2025, when looking at all source categories combined. The projected decrease from each pollutant on the Missouri side of the nonattainment area from 2008 to 2025 is due to permanent and enforceable control requirements.

The projected decreases in NO x and VOC emissions from 2008 to 2025 are primarily due to decreases in the on-road mobile and non-road source categories. Average ozone season daily NO x and VOC emissions in the St. Louis area from these two categories are projected to decrease by approximately 144 tons/day and 58 t ons/day, respectively. That amounts to an over 40% reduction of total NO x emissions in the area and an over 25% reduction of total VOC emissions in the area compared to emissions le vels in 2008 from on-road mobile and non-road

sources.

The maintenance demonstration is based on the comparison of the actual emission levels in 2008 and the projection of emissions in the future year of the plan. Because the area attained the standard in 2008, this is expected to be a level of emissions suitabl e to maintain the level of the standard. Because aggregate emissions in both po llutant categories in 2025 are expected to be less than 2008 actual leve ls, this satisfies the maintenan ce demonstration under the 1997 ozone NAAQS for the Missouri portion of the nonattainment area.

As mentioned above, additional details about the 2008 and 2025 emission inventories can be found in Appendices B and D, respectively. It should also be noted that the emissions projections included here do not re flect the reductions expected fr om a range of measures being implemented to reduce diesel emissions in the St. Louis nonattainment area. These measures include —

 U.S. EPA’s Midwest Clean Diesel Initiative

 Congestion Mitigation and Air Qualit y Improvement (CMAQ) Program41  Diesel Emissions Reduction Ac t (DERA) grant projects

 American Recovery and Reinvestment Act of 2009 (ARRA) grant projects

 Heavy Duty Diesel Idling Rule, 10 CSR 10-5.385

 Various supplemental environmental projects.
These projects include the instal lation of particulate filters, di esel oxidation catalysts, closedcrankcase ventilation systems, and direct-f ired heaters on school and transit buses, and municipally-owned utility vehicl es, upgrading diesel constructi on engines with engines meeting more stringent emissions standard s, and installing auxiliary powe r units on over-the-road trucks to reduce idling. It is anticipated that DE RA and CMAQ funding will continue to support additional diesel emissions reduction projects in the near future.


### 5.2 Interim Year Emission Inventory: 2017 The Air Program has developed an Interim Emissi on inventory for the Missouri portion of the St. Louis nonattainment area. Interim year 2017 is th e midway point between 2008, the base year of the maintenance plan, and 2025, the last year in the ten year maintenance plan period. An analysis of an interim year emissions inventory is necessary to demonstrate that future emission levels will remain below the attainment year emission levels throughout the entire 10-year maintenance period. This provides assurance that air quality in the St. Louis area will continue to comply with 1997 ozone NAAQS for the duration of the maintenance period addressed in this plan.

All assumptions and controls used in deve loping the projected 2025 emission inventory in section 5.1 of this document were also used to project the 2017 inventor y. Table 5.4 summarizes the emissions for point, area, on-road mobile, and non-road sources that are projected for 2017 for the Missouri portion of the St. Loui s nonattainment area. From 2008 to 2017, NO x emissions drop by 125.1 tons/day, a reduction of about 40% , while VOC emissions drop by 26.65 tons/day or about 12%. As seen in Table 5-4, the inte rim year emissions levels in the area will remain below the 2008 base year for both pollutant cate gories, thus demonstrat ing that the area will continue to maintain the standard throughout th e 10-year maintenance period. The Air Program commits to analyzing actual 2017 emissions for th e Missouri side of the St. Louis nonattainment area and comparing the actual 2017 emissions to the projected 2017 emissions listed in Table 5.4 to ensure the area keeps pace w ith the reductions expected th roughout the maintenance period. Additional details about the development of th e 2017 interim year emission inventory for the Missouri side of the nonattainment area can be found in Appendix C of this document.

Table 5-4. 2017 VOC and NO x Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattainment Area (tons per ozone season day) Source Category NO X VOC Point Sources 87.01 22.82 Area Sources 6.68 115.85 On-Road Mobile Sources 62.32 27.51 Off-Road Mobile Sources 35.53 28.88 Total 191.54 195.0642 

### 5.3 Future Federal Control Measures There are currently several federal control m easures that have recently been proposed or promulgated that are expected to greatly reduce the amount of NO x and VOC emissions in the St. Louis area. The control measures exp ected to have the greatest effect on NO x and VOC emissions in the St. Louis area include the federa l CAIR phase II and/or its future replacement, the Mercury and Air Toxics Standards for Fossi l-Fuel Fired Electric Ut ility Steam Generating Units (MATS), National Emission Standards fo r Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Inst itutional Boilers and Process H eaters (Boiler MACT), improved motor vehicle fuel efficiency standards, the pha se in of tier 4 emission standards for non-road engines

CAIR phase II and the improved federal mobile source regulations were both considered when developing the future emissions inventory in order to demonstrate continued maintenance with the 1997 8-hour ozone standard, which s hows that projected future year NO x and VOC emissions in the St. Louis area will remain below the levels experienced during the at tainment year. Under CAIR phase II, which begins in 2015, ozone season NO x emissions budgets for EGUs decrease by 17% for covered sources in the Missouri portion of the nonattainment area. As stated earlier, federal motor vehicle and non-road engine standard s are only expected to be tightened in the future, which will also contribute to NO x and VOC emission reductions. These recent and anticipated future federal control measures are expected to result in continued decreases in NO x and VOC emissions both nationwide and in the St . Louis area. These measures will greatly assist current and ongoing efforts in the St. L ouis area to maintain co mpliance with the 1997 8- hour ozone NAAQS.

The MATS and the Boiler MACT were both written to address h azardous air pollutants, and will therefore have the greatest reduc tions in pollutants such as PM 2.5 and SO 2 . However, if owners of boilers and EGUs subject to these new rules de cide to improve plant ef ficiency or switch to cleaner fuels for compliance strategies, then there is expected to be co-benefits for NO x and VOC emissions from these sources. The Air program did not rely on the Utility MACT or the Boiler MACT when developing the future year emission s inventory or to determine that the St. Louis area would remain in attainment of the 1997 8-h our ozone NAAQS. However, the anticipated reductions from these new rules may also contribute to the future attainment of the 1997 8-hour ozone NAAQS in the St. Louis area.


### 5.4 New Source Review: Permitting Ne w or Modified Emissions Sources In accordance with the Clean Air Act, Missouri has a long-standing and fully implemented New Source Review (NSR) permitting program for new major sources and significant modifications of existing sources enabled by State rule 10 CSR 10-6.060 Construction Permits Required. This NSR program in any attainment area is referred to as a Prevention of Significant Deterioration (PSD) permitting program. One of the major components of the PSD program is the implementation of Best Available Control Technology (BACT) on new major sources or significant modification of existing major sources. Missouri has been delegated full authority to implement the PSD program by the EPA.

In this document, the Air Program is request ing redesignation to attainment under the 1997 8- hour ozone standard. However, the St. Louis non attainment area has already been designated as43 nonattainment under the 2008 ozone NAAQS. Ther efore, the State of Missouri is fully committed to continuing its NSR permitting program for nonattainment areas which makes new major sources and significant modifications of ex isting sources subject to the Lowest Achievable Emission Rate (LAER) as well as offsets and an alternate site analysis pursuant to the CAA.

State rule 10 CSR 10-6.410 Emissions Banking and Trading , allows the banking and trading of emission reduction credits to be used for pe rmitting purposes. These emission reduction credits are reduced by 25 percent at the time they are banked and they are further reduced by 3 percent every year they remain banked. These credits are intended to be used for NSR offset purposes in nonattainment areas and for PSD increment purposes in areas designated attainment. However, these credits are only one aspect of obtaini ng a permit under Missouri’s EPA approved Title V permitting program, and do not alleviate any source from undergoing a NAAQS impact analysis in any area. Nor do these cred its alleviate any source from im plementing BACT requirements for PSD permits in attainment areas or LAER/a lternative site analysis requirements in nonattainment areas. Therefor e, the emission reduction cred its that have been banked by Missouri sources are not anticipated to have any impact on Missour i’s demonstration that the St. Louis area will continue to maintain the 1997 ozone NAAQS in the St. Louis area.

Therefore, Missouri has satisf ied the requirements of both CAA Sections 110(a)(2)(C) & 172(c)(5) (which in turn satisfi es a redesignation element of Section 107(d)(3)(E)(v)) for the 1997 ozone NAAQS through its approved NSR program.



### 5.5 Update: Recent Emission Reductions 2012 - Monitored ozone air quality concentrations in the St. Louis area for the most recent three-year period of 2011-2013 complied with the 1997 NAAQ S despite 2012 being among the hottest, most ozone-conducive years on record. This mainte nance plan demonstrates that the downward trend in ozone concentrations is due to perman ent and enforceable emission controls. This section addresses additional emi ssion reductions of ozone precur sors that have occurred since 2012 to support this downward trend.

5.5.1 Stationary Source Ozone Season NO x Emission Reductions from EGUs
Based on a review of continuous emissions mon itoring systems (CEMS) data reported to the EPA’s Clean Air Market Division, the four Am eren EGU facilities have reduced regulatory ozone season (May–September) NO x emissions by 248 tons between 2012 and 2013. These emission reductions are despite the fact th at these units produced an additional 283,000 Megawatt-hours of electricity in 2013 compared to 2012, meaning th at these reductions were not due to a reduction in electric ity production or demand but rather an improvement in average emission rates that have resulted from the con tinued optimization of the emission controls at these facilities.

Looking at the full eastern third of the state, whic h contributes to ozone concentrations in the St. Louis nonattainment area, regulatory ozone season NO x emissions from EGUs decreased by a total of 2,226 tons between 2012 and 2013. In 2013, electricity production from the EGUs located in the eastern third of the state was down 2% compared to 2012; however, the ozone season NO x emissions reductions achieved by thes e EGUs between 2012 and 2013 account for44 an 11% reduction, meaning that emission rates ha ve improved at these f acilities between these two years.

In 2015, CAIR phase II will begin, which will reduce NO x allowances by 17% for EGUs in Missouri. This is only expected to result in continued ozone season NO x emission reductions from EGUs in the states subject CAIR including the EGUs located in and in close proximity to the nonattainment area. These allo wance reductions also act as a margin of safety since the projected emission inventories for 2017 and 2025 used in this plan to demonstrate maintenance of the 1997 standard did not account for this re duction but rather assu med a steady level of emissions from these sources.

5.5.2 On-Road Mobile Source Emission Reductions
Due to federal motor vehicle standards and the retirement/replacement of older higher polluting engines, on-road mobile source emissions of NO x and VOC continue to decline each year in and around the St. Louis nonattainment area. EPA’ s MOVES model was used to calculate the onroad mobile source NO x and VOC emissions in the last two years. Between 2012 and 2013, onroad mobile source NO x and VOC emissions inside the Mi ssouri portion of the nonattainment declined by approximately 265 tons/ozone season and 407 tons/ozone season (April – October), respectively. On-road mobile source emission re ductions are expected to continue in the nonattainment area as additional older vehicles ar e retired and replaced by new vehicles meeting the latest federal motor vehicle standards.

On March 3, 2014 the EPA administrator signed the final rule for Tier I II motor vehicle engine standards, which will begin in 2017. EPA states in the final ruleFor many pollutants, the immediate reduc tions in 2018 are significant; for example, combined NO X and VOC emissions will be reduced by over 300,000 tons. By 2030, combined NO X and VOC emissions will be reduced by r oughly 500,000 tons, one quarter of the onroad inventory.

The Tier III standards were not relied upon in the maintenance dem onstration included with this plan, but the new standards will provide additi onal assurance that ozone precursor emissions continue to decline in the MO-S t. Louis nonattainment area and th roughout the entire country as a result of permanent and enforceable on -road mobile source control measures.

5.5.3 Diesel Emissions Reduction Act Projects The Missouri Department of Natural Resources has implemented numerous grant projects under the Diesel Emissions Reduction Act (DERA) sin ce 2008. These projects have resulted in the reduction of NO X , PM, VOC, CO, and CO 2 emissions from diesel engines that operate in Missouri. Many of the projects have targeted diesel fleets th at operate in and around the St. Louis nonattainment area including school buses, c onstruction equipment, refuse haulers, street sweepers, long-haul trucks, locomotives, and tugboats.

Below is a list of DERA projec ts that have been implemented by the Air Program in the St. Louis area since 2012:45 1. Massman Construction: Engine repowers for two 230 horsepower propulsion engines on a tugboat operating almost exclusively insi de the nonattainment area. The repower project replaced unregulated tier 0 engi nes with engines mee ting tier 2 emission standards. The tier 0 engines were disabl ed ensuring the permanence of the emissions reductions.

2. Pullen Enterprise: Early replacement for a long- haul class 8 truck th at operates almost exclusively in Missouri w ith approximately 50% of its operations inside the nonattainment area. The project replaced a 2000 model year truck with a 2013 model year truck that is certified at approximately 90% lower NO X and PM emissions standards that the truck that was replaced. The old truck’s engine and ch assis were disabled ensuring the permanence of the emissions reductions.

3. DeSoto School District: Idle reduction and ta ilpipe emission control retrofits for 23 buses operated by the school district. All of these buses operate al most exclusively inside the nonattainment area.

4. ADM Grain: Engine repower for a 1200 hor sepower engine for a switch locomotive stationed in the City of St. Louis that operates almost exclusively inside the nonattainment area. The repower project repl aced an unregulated tier 0 engine with a new engine meeting tier 3 emission standards. The old engine was disabled ensuring the permanence of the emissions reductions.

5. JB Marine: Engine repowers for four propulsion engines on tw o different tugboats operating almost exclusively inside the nonattainment area. Two engines were 285 horsepower and the other two were 300 horsepower. All four engines that were replaced were unregulated tier 0 engines, and each was replaced by new engines meeting tier 2 emissions standards. All four of the tie r 0 engines were disabled ensuring the permanence of the emissions reductions.

These permanent voluntary emissions reductions, a lthough not relied upon in th is plan to attain the NAAQS or to demonstrate maintenance of the NAAQS, provide additional emissions reductions that have occurred in th e St. Louis area in the recent past, which have contributed to improved ozone concentrations in the area.46 

## 6. Transportation Conformity

Transportation conformity is required under CAA Section 176(c) (42 U.S.C. 7506(c)) to ensure that transportation plans, transportation impr ovement programs and federally supported highway transit project activities are consistent with (“co nform to”) the purpose of the SIP. Conform to the purpose of the SIP means that transporta tion activities will not cause new air quality violations, worsen existing violations, or delay timely attainment of the relevant NAAQS or any interim milestones. These requirements are found in CAA Section 176(c)(B)( i), (ii), and (iii):

That such activities will not cause or contribute to any ne w violation of any standard in any area; increase the frequency or severity of any existing violation of any standard in any area; or delay timely attainment of any standard or any required interim emissions reductions or other mi lestones in any area.

Transportation conformity applies only to thos e areas that are designa ted nonattainment, and those areas redesignated to atta inment after 1990 (“maintenance ar eas”) for transportation-related criteria pollutants: Carbon monoxide (CO), ozone, nitrogen dioxide (NO 2 ) and particulate matter (PM 2.5 and PM 10 ). The Transportation Conformity program for the St. Louis area is included in the SIP via State ru le 10 CSR 10-5.480 St. Louis Area Transportation Conformity Requirements.

The establishment of MVEBs for transportation c onformity purposes is one of the redesignation elements of CAA Section 175A as mentioned in s ection 2.4 of this document. EPA’s final rule for establishing ozone area classification th resholds under the 2008 ozone NAAQS revoked the 1997 ozone NAAQS for transportation conformity purposes [77 FR 30160]. This revocation is effective one year after the e ffective date of designations for the 2008 ozone NAAQS (July 20, 2013). Therefore, transp ortation conformity (and the corr esponding establishment of MEVBs) for the 1997 ozone NAAQS is no longer required. This revocation date al so corresponds with the end of the one-year conformity grace peri od for the 2008 ozone NAAQS. This action was taken by EPA to bring certainty to the transpor tation planning process in ozone nonattainment and maintenance areas. EPA stated that no b acksliding will result from the revocation for purposes of transportation conformity, and area s designated nonattainme nt for the 2008 ozone NAAQS will be required to use any existing adeq uate or approved SIP MVEBs for a prior ozone NAAQS when determining conformity for the 2008 ozone NAAQS until budgets for the 2008 ozone NAAQS are either found adequate or are approved. Therefore because of the revocation, this maintenance plan does not es tablish MVEBs for the 1997 ozone NAAQS.

As mentioned above, transporta tion conformity for the 2008 ozone NAAQS applies one year after the effective date of nonattainment designa tions for this NAAQS, i.e., July 20, 2013. As a result, on January 30, 2013, East-West Gateway Council of Governments, the designated Metropolitan Planning Organizatio n for the greater St. Louis area, approved a Transportation Conformity Determination addressing the 2008 NAAQS : http://www.ewgateway.org/pdffiles/libra ry/AQ/AQConformityDoc/AQConformityDocFY2013.pdf

. Although not a requirement for this redesignatio n under the 1997 standard, an Early Progress Plan establishing MVEBs for the 2008 standard has been separately developed by the Air47 Program prior to our marginal-classified area plan obligations for the St. Louis area under this newer standard. This Early Progress Plan was adopted by the Missouri Air Conservation Commission on March 28, 2013. The Air program submitted the plan to EPA on August 16, 2013 and EPA deemed the new budgets adequate in a letter dated October 28, 2013 just in time for the next conformity determination that bega n in the fall of 2013. More information on the MVEBs for the 2008 ozone NAAQS may be fo und in the Early Progress Plan at: http://www.dnr.mo.gov/env/apcp/docs/ complete-epp-submittal-8-16-13.pdf

.48 

## 7. Contingency Measures

CAA Section 175(A) specifies the requirements for maintenance plan s. In addition to providing a plan for the maintenance of the NAAQS for at l east ten (10) years afte r the redesignation, the plan shall also include a list of contingency measures to corr ect any violation of the fine particulate matter NAAQS after redesignation to attainment.

Contingency measures are to be used to furt her reduce emissions in the event that future violations of the 1997 8-hour ozone NAAQS occu r after redesignation to attainment. While these measures do not need to be fully adopt ed by the Missouri Air Conservation Commission prior to the occurrence of a NA AQS violation, the contingency m easures are expected to be implemented as expeditiously as possible once a triggering event occurs. The maintenance plan must identify the triggers that determine when contingency measures will be adopted, and the measures that the Air Program will consider.

The Air Program has developed a contingency pl an for the Missouri portion of the St. Louis ozone maintenance area. The contingency plan wh ich details the Level I and Level II triggers and corresponding actions to be taken is summar ized in Table 7-1. The potential contingency measures, to be evaluated after a triggering event, are listed in Ta ble 7-2. Consistent with this contingency plan, the Air Program agrees to ad opt and implement, as expeditiously as is practicable, the necessary corrective actions in th e event that violations of the 1997 8-hour ozone NAAQS occur anywhere within the St. Louis oz one maintenance area after redesignation to attainment. The implementation of contingency m easures under Level I or Level II triggers will take place as expeditiously as practicable, but in no event later than tw enty-four (24) months after the Air Program makes a determination that a trigger has occurred, based on quality-assured ambient data that has been entered into EPA’s Air Quality System database.

The contingency plan provides for different leve ls of corrective responses should the ambient 8- hour ozone levels exceed the NAAQS in any year. A Level I response would occur in the event that the fourth highest 8-hour ozone concentration at any mon itoring site in the St. Louis maintenance area (including sites in Missouri and Illinois) exceeds 84 ppb in any year. The Air Program will evaluate the air quality and determ ine if adverse emission trends are likely to continue. If so, the Air Program will determin e what and where controls may be required, as well as the level of emissions reductions needed to avoid a violation of the NAAQS. If controls are required, the potential continge ncy measures listed in Table 7- 2 will be evaluated in addition to other measures that may be identified through the ev aluation or that become available through future advances in control tec hnology and methods. It should be noted that the EPA does not require a state to implement contingency measur es when occasional exceedances are recorded. The Air Program’s voluntary commitment to initia te a Level I response is intended to prevent future violations of the NAA QS from ever occurring.

A Level II trigger occurs when a violation of the 1997 8-hour ozone NAAQS at any monitoring station in the St. Louis maintenan ce area is recorded after it has b een redesignated to attainment. The Air Program will conduct a thorough analysis to determine appropriate measures to address the cause of the violation. Contingency measures will be selected from those listed in Table 7.2 or from any other measured identified and deem ed appropriate and effective at the time the49 selection is made. Level II trigge rs are more serious than Level I triggers and cost effectiveness thresholds could be increased when determ inations for additional controls are made.

The contingency measures listed in Table 7.2 are exp ected to be evaluated in the event of a Level I or Level II trigger; however federal actions that require control measures may also be taken into account when the analysis to determine the cause of a future violation occurs. These additional federal actions, while not actual contingency measur es, may be evaluated in the event of a trigger to determine their effect on the levels of expected emissions from sources in the area in order to determine whether or not additional local contro l measures are necessary. The measures that may be evaluated in the event of a future trigger include future federal on-road vehicle standards, future federal non-road engine standards for mari ne and locomotive engines, any future federal emission trading programs designed to addres s future ozone NAAQS promulgations, the Commercial-Industrial-Institutional Boiler Max imum Achievable Control Technology (MACT) requirements, and the Utility MATS requirement s. Furthermore, the Air Program remains committed to addressing future ozone NAAQS re visions through state implementation plans. These plans could include other control techni ques not included in Table 7.2. These and any other newly identified potential control measur es may also be considered in the analysis following a future Level I or II triggering event.

The Air Program commits to compiling NO x and VOC emissions inventories for the St. Louis maintenance area every three years for the duration of the Maintenance Plan to facilitate the emissions trends analysis included in the contingency plan under Le vels I and II. Since St. Louis is a bi-state nonattainment area, the Air Program commits to work with Illinois EPA to evaluate emissions trends and the causes of Level I and Leve l II triggers to determine appropriate control measures needed to assure continued attainment of the 1997 8-hour ozone NAAQS.

Adoption of additional control measures is s ubject to necessary administrative and legal processes. The Air Program will solicit input from all interested and affected persons in the area prior to selecting appropriate control measures. No contingency measures will be implemented without providing the opportunity for full public participation. This process will include publication of notices, an opportunity for public hearing, and other measures required by Missouri law.50 Table 7-1. Contingency Plan for the Misso uri Portion of the 1997 St. Louis 8-Hour Ozone Maintenance Area Contingency Measure Trigger Action to be Taken Level I Trigger

Fourth highest monitored 8-hour average ozone concentration exceeding 84 ppb in any year at any monitoring station in the St. Louis, MO-IL maintenance area. The Air program will evaluate the air quality and determine if adverse emission trends are likely to continue. If so, the Air Program will determine what and where controls may be required, as well as the level of emissions reductions needed to avoid a violation of the NAAQS. The evaluation shall be completed as expeditiously as possible and, if n ecessary, control measures shall be adopted and implemented as expediti ously as practicable, taking into consideration the ease of implem entation and the technical and economic feasibility of the selected measures. This action will be taken no later than 24 months afte r the Air Program has determined that a Level I trigger has occurred. Level II Trigger

A monitored violation of the NAAQS at any monitoring station in the St. Louis, MO-IL maintenance area. The Air Program will conduct a thorough analysis to determine appropriate measures to address the cause of the violation. Analysis shall be completed within 6 mont hs after the tr igger occurs. Selected measures shall be im plemented as expeditiously as practicable, taking into considera tion the ease of implementation and the technical and economic feasibili ty of the selected measures. The appropriate contingency measures to address the violation shall be implemented as expeditiously as possible, but no later than 24 months after quality-assured ambient data that has been entered into EPA’s Air Quality System database indicating that this trigger has occurred.51 Table 7-2. Potential Contingency Measures for the Missouri Portion of the 1997 St. Louis 8-Hour Ozone Maintenance Area

List of Potential Contingency Measures to be Considered

 Identify local sources with significant NO x and/or VOC emissions and deve lop controls through rules, NSR/PSD permits or consent agreements (e.g. For major NO x sources — boilers, cement kilns & incinerators);

 Lower the applicability thresholds in existing rules that control NO x and VOC:

o Some recent CTG RACT rules have reduced threshold for subject sources from 100 tpy to as low as 2.5 tpy. See section 4.3.

o Examine other source categories for similar reductions and revise rules accordingly.

 Lower the emission limits in existing rules:

o Review current state of control technologies. Reference RACT/BACT/LAER Clearinghouse for new ideas.

o Revisit RACT determination and update RACT plan accordingly.

o Example: Lower the emissions from certain surface coating sources under 10 CSR 10-5.330 Control of Emissions From Industrial Surface Coating Operations as lower VOC content / control technology improves.

 New or strengthened Alternative Control Techniques (ACTs) for NO x sources & CTGs for VOC
sources;

 Develop rules to address contributing parts of Mi ssouri outside of St. Louis nonattainment area;

 Enhanced Heavy-Duty Diesel Anti-Idling Program (e.g. mandated rest periods and locomotives);

 Update 10 CSR 10-6.130 Controlling Emissions During Episodes of High Air Pollution Potential:

o Lower the alert / action trigger levels.

o Amend rule to require alert / action level abatement plans at more facilities.

o Require existing abatement plans be amended with more current emission reduction measures (e.g. telecommuting at major facility would lower vehicle CO, VOC, NOx emissions)

 Architectural/Industrial/M aintenance (AIM) Coatings similar to Ozone Transport Commission (OTC) model rule.52 

## 8. Conclusion

The St. Louis nonattainment area has atta ined the 1997 0.080 ppm 8-hour ozone NAAQS and has complied with the applicable provisions of the CAA required of moderate ozone nonattainment areas. Missouri has supported, with appropriate submittals, including this one, all of EPA’s redesignation obligati ons under CAA Section 107 and has addressed all the applicable maintenance plan requirements of CAA Section 175A. This plan submission serves as the official redesignation request for the Missouri po rtion of the St. Louis moderate nonattainment area under the 1997 ozone NAAQS to be consider ed for approval concurrently with the maintenance plan also contained herein.

The Missouri Department of Natural Resources’ Ai r Pollution Control Program has prepared this maintenance plan to provide for the continue d attainment of the 1997 8-hour ozone NAAQS for a period of ten years after U.S. EPA has formally redesignated the area to attainment and also supplies adequate contingency m easures for potential, additiona l emissions reductions in the event that future violations of the 1997 8- hour ozone NAAQS are observed in the area.

The Air Program has prepared a comprehensive em issions inventory of the precursors of ozone completed for the “attainment” year 2008, and has prepared projecti ons of the emissions inventory to 2025. These emissions projections indicate th at emissions levels in the St. Louis nonattainment area will continue to decrease from attainment year 2008 levels, thereby maintaining the ozone NAAQS in future years. The state commits to continue to operate an appropriate air quality monitoring network to verify the maintenance of the attainment status once the area has been redesignated and to pr epare a second maintenance plan 8 years after redesignation. The Air Program has the legal au thority to implement and enforce all control measures. This maintenance plan has been prep ared in accordance with the requirements of the CAA and in conjunction with EP A staff and guidance documents.

### The Missouri Air Conservation Commission ADOPTS 

### the following action

on this 24th day of April, 2014:

Missouri State Implementation Plan Revision

- SupplementlRevision to the Redesignation Demonstration and Maintenance Plan for the Missouri Portion of the St. Louis Nonattainment Area for the 1997 8-Hour Ground-Level Ozone National Ambient Air Quality Standard 

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_______________________ ,Member

____________________________ ,MemberJay Nixon, Governor Sara Parker Pauley, Director 

## Air Pollution Control Program

State Plan Actions

On Public Notice | Proposed fo r Adoption

On Public Notice

Missouri State Implementation Plan Revision - Supp lement/Revision to the Re designation Demonstration and Maintenance Plan for the Missou ri Portion of the St. Louis Nona ttainment Area for the 1997 8-Hour Ground Level Ozone National Ambient Air Quality Standard

The Missouri Department of Natural Resources’ Air Pollution Control Program (Air Program) is in the process of redesignating the St . Louis area to attainment for the 1997 ozone NAAQS. On Nov. 27, 2011, the Missouri Air Conservati on Commission adopted the Redesignation Demonstration and Maintenance Plan for the Missouri Portion of the St. Louis Nonattainment Area for the 1997 Ozone NAAQS. The plan was th en submitted to the U.S. Environmental Protection Agency (EPA) on Nov. 28, 2011 for in clusion in the Missouri State Implementation Plan. The plan was not acted upon at that time due to litigation surrounding the federal interstate air pollution transport rules. Th e Air Program is now proposing a technical supplement/revision to the 2011 plan. This revision will make corrections to the emissions inventories in the plan and update the future year projections of the plan from 2022 to 2025.
Proposed Supplement/Revision to the Redesignation Demonstr ation and Maintenance Plan for the Missouri Portion of the St. Louis No nattainment Area for the 1997 8-Hour Ground Level Ozone National Ambient Air Quality Standard
Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Appendix H

Submit Comments Now Pa g e 1 of 3 State Plan Actions on Public Notice - DN R

2/24/2014 htt p ://www.dnr.mo. g ov/env/a p c p /state p lanrevisions.htmA public hearing is scheduled for th is plan action on March 27, 2014. Comments about this plan action will be accept ed through the close of business on April 3, 2014.

Proposed for Adoption

Missouri State Implementation Plan Revision - Supp lement/Revision to the Re designation Demonstration and Maintenance Plan for the Missou ri Portion of the St. Louis Nona ttainment Area for the 1997 Annual Fine Particulate Matter National Ambient Air Quality Standard

Based on monitoring data from 2007-2009, th e St. Louis nonattainment area achieved attainment of the 1997 annual fine particulate matter (PM2.5) national ambient air quality standard (NAAQS). In August 2011, the Missouri Air Co nservation Commission adopted the Redesignation Demonstration and Maintenance Plan for the Missouri Portion of the St. Louis Nonattainment Area for the 1997 Annual PM2.5 NAAQS. This plan was then submitted to the U.S. Environmental Protection Agency for inclusion in the Missouri State Implementation Plan. The Missouri Department of Natural Resources Air Pollution Control Program has developed a technical supplement/revision to this plan. The technical supplement/revision to this plan makes correctio ns to the emissions in ventories included in the plan, includes emissions inve ntories and a discussion on cont rols for the Illinois portion of the nonattainment area, an d changes the future year of the plan from 2022 to 2025. This technical supplement also establishes mo tor vehicle emissions bu dgets to be used in regional transportation conformity determinat ions for the base year (2008) and the future year (2025) of the plan. Through this SIP submittal, the Missouri Department of Natural Resources Air Pollution Control Program is requesting that:
EPA redesignate the Missouri Portion of the St. Louis 1997 PM2.5 nonattainment area to attainment pursuant to the provis ions of the Clean Air Act, section 107; •

Concurrently, EPA approve the associated main tenance plan as a revision to the State Implementation Plan (SIP) meeting the requ irements of the Clean Air Act, section 175A; •

That EPA approve the 2008 base year inventory as meetin g the requirements under Clean Air Action section 172(c)(3); and •

Approve the Motor Vehicle Emissions Bu dgets (MVEBs) for th e years 2008 and 2025 pursuant to Clean Air Act Section 176(c). •

Proposed Supplement/Revision to the Redesignation Demonstr ation and Maintenance Plan for the Missouri Portion of the St. Louis Nonattainment Area for the 1997 Annual Fine Particulate Matter National Ambient Air Quality Standard Appendices A through L
A public hearing was held for this plan action on January 30, 2014. Comments about this plan action were accepted through the close of business on February 6, 2014. Pa g e 2 of 3 State Plan Actions on Public Notice - DN R

2/24/2014 htt p ://www.dnr.mo. g ov/env/a p c p /state p lanrevisions.htmMissouri State Implementation Plan Revision - Limited Main tenance Plan for the St. Louis Nonclassifiable Maintenance Area for the 8-Hour Carbon Monoxide National Ambient Air Quality Standard

The initial maintenance plan for the St. Lo uis nonclassifiable Carbon Monoxide (CO) maintenance area ensured attainment of the CO NAAQS through 2008. Pursuant to Section 175A(b) of the Clean Air Act, the State must submit a subsequent plan revision for maintaining the standard for an additional 10 year period afte r the expiration of the first maintenance period. The Air Program has developed a second maintenance plan that provides for continued attainment of the 8- hour CO NAAQS for the St. Louis area from 2008 through 2018. The plan provides assurances that, in the event of a subseq uent violation of the CO NAAQS, additional co ntrol options, called contingency measures, can quickly be implemented to prevent any future violations. In addition, this plan includes CO ambient air quality monitoring data from the last seve n years and an updated emission inventory for average winter day CO emissi ons in the St. Louis area.
Proposed Revision to Limited Maintenanc e Plan for the St. Louis Nonclassifiable Maintenance Area for the 8-Hour Carbon Mono xide National Ambient Air Quality Standard Appendices A and B
A public hearing was held for this plan action on January 30, 2014. Comments about this plan action were accepted through the close of business on February 6, 2014.

Missouri State Implementation Plan Revision - Ameri cold Logistics, LLC 24-Hour Particulate Matter (PM10) National Ambient Air Quality St andard (NAAQS) Consent Judgment

As required by Section 110(a) of the Clean Ai r Act, Missouri’s State Implementation Plan (SIP) must ensure attainment and maintena nce of all National Ambient Air Quality Standards (NAAQS). The Missouri Department of Natura l Resources’ Air Pollution Control Program is proposing to amend and strengthen th e Missouri SIP to address violations of the 24-hour coarse particulate matter (PM10) NAAQS of 150 micrograms per cubic meter (μg/m3) near the Americold Logistics, LLC’s Carthage Crushed Limestone (CCL) facility. The SIP revision consists of a consent judgment with CCL for measures intended to reduce PM10 emissions at the facility, all of which ar e scheduled for installa tion and operation by March 31, 2014.
Proposed CCL PM10 SIP Revision Attachment 2 – Proposed CCL Consent Judgment Exempt Equipment List
A public hearing was held for this plan action on January 30, 2014. Comments about this plan action were accepted through the close of business on February 6, 2014.
Back to top Pa g e 3 of 3 State Plan Actions on Public Notice - DN R

2/24/2014 htt p ://www.dnr.mo. g ov/env/a p c p /state p lanrevisions.htm1 Bechtel, Cheri

From: Missouri DNR <MODNR@public.govdelivery.com> Sent: Monday, February 24, 2014 9:04 AM To: Bungart, Renee; Archer, Larry; Beydler, Van; Lovejoy, Victoria; Moore, Kyra; Vit, Wendy; Bechtel, Cheri; Crawford, Betsy; Terlizzi, Gena Subject: Courtesy Copy: Missouri DNR Air Public No tices Update - Missouri Air Conservation Commission Public Hearing, March 27, 2014

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MISSOURI AIR CONSER VATION COMMISSION WILL HOLD PUBLIC HEARING
JEFFERSON CITY, MO -- The Missouri Air Conser vation Commission will hol d a public hearing on Thursday, March 27, 2014 beginning at 9 a.m. at the Lamplighter Inn, 2820 N Glenstone Ave, Missouri Two Meeting Room, Springfield, Missouri. The commission will hear testimony related to the following proposed action(s):
* Missouri State Implementation Plan Revision – Supplement/Revision to the Redesignation Demonstration and Maintenance Plan for the Missour i Portion of the St. L ouis Nonattainment Area for the 1997 8-Hour Ground-Level Ozone Na tional Ambient Air Quality Standard

The Missouri Department of Natural Resources’ Air Pollution Control Program (Air Program) is in the process of redesignating th e St. Louis area to attainment for the 1997 ozone NAAQS. On November 27, 2011, the Missouri Air Conservati on Commission adopted the Redesignation Demonstration and Maintenance Plan for the Missour i Portion of the St. L ouis Nonattainment Area for the 1997 Ozone NAAQS. The plan was then s ubmitted to the U.S. Environmental Protection Agency (EPA) on November 28, 2011 for inclusion in the Missouri State Implementation Plan. The plan was not acted upon at that time due to litigat ion surrounding the federal interstate air pollution transport rules. The Air Program is now proposin g a technical supplement/revision to the 2011 plan. This revision will make corrections to the emissions inventories in the plan and update the future year projections of the plan from 2022 to 2025.

If the Commission adopts the action(s), it will be the De partment’s intention to submit the action(s) to the U.S. Environmental Protection Agency to be in cluded in Missouri’s State Implementation Plan.2 Documents for the above item(s) will be available for review at the Missour i Department of Natural Resources, Air Pollution Control Pr ogram, 1659 Elm Street, Jefferson Cit y, (573) 751-4817 and in the Public N otices section of the program web site http://dnr.mo.gov/env/apcp/public- notices.htm. This information will be available at least 30 days pr ior to the public hearing date.
The Department will accept written or email comments for the record until 5 p.m. on April 3, 2014. Please send written comments to Chief, Air Quality Planning Section, Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102-0176. Email comments may be submitted via the program web site noted above. All written and email comments and public hear ing testimony will be equally considered.

Citizens wishing to speak at the public hearing should notify the secretary to th e Missouri Air Conservation Commission, Missouri Department of Natural Resour ces, Air Pollution Control Program, P.O. Box 176, Jefferson City, Missouri 65102-0176, or telephone ( 573) 526-3420. The Department requests persons intending to give verbal presenta tions also provide a wr itten copy of their testimony to the commission secretary at the time of the public hearing.

Persons with disabilities requiring special services or accommodations to attend the meeting can make arrangements by calling the Program di rectly at (573) 751-4817, the Divisi on of Environmental Quality's toll free number at (800) 361-4827, or by writing two weeks in advance of the meeting to: Missouri Department of Natural Resources, Air Conservation Commissi on Secretary, P.O. Box 176, Jefferson City, MO 65102. Hearing impaired persons may contact the program through Relay Missouri, (800) 735-2966.

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.PUBLIC HEARING 3/27/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334 MIDWEST LITIGATION SERVICES Page 1

1 BEFORE THE MISSOURI AIR CONSERVATION COMMISSION

ADMINISTRATIVE HEARING COMMISSION

2

3

4 IN THE MATTER OF: )

)
5 Missouri State )
Implementation Plan )

6 Revision - )
Supplement/Revision to )
7 the Redesignation )

Demonstration and )

8 Maintenance Plan for the)

Missouri Portion of the )

9 St. Louis Nonattainment )

Area for the 1997 8-Hour)

10 Ground-Level Ozone )

National Ambient Air )
11 Quality Standard. )

12

13

14 REPORTER'S TRANSCRIPT

15 OF

16 PUBLIC HEARING

17
18 Taken on Thursday, March 27, 2014
19 Commencing at 9:17 o'clock a.m.
20 At Lamplighter Inn, Missouri Two

21 2820 N. Glenstone Avenue
22 Springfield, Missouri

23

24
25 REPORTED BY: PAULA C. VOYLES, CCR, RPR, CRRPUBLIC HEARING 3/27/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334 MIDWEST LITIGATION SERVICES Page 4

1 P R O C E E D I N G S

2

3 CHAIRMAN PENDERGRASS: The hearing wil l

4 come to order. Let the record show that the

5 following commissioners are present: Jack Baker,

6 Mark Garnett, Gary Pendergrass, and David

7 Zimmermann.

8 The Air Conservation Commission of the

9 State of Missouri has called this public hearing

10 pursuant to Section 643.070, Revised Statutes of

11 Missouri; EPA promulgated rule 40 CFR 51.102, for

12 the purpose of hearing testimony related to:

13 Missouri State Implementation Plan

14 Revision, Supplement/Revision to the Redesignatio n

15 Demonstration and Maintenance Plan for the Missou ri

16 portion of the St. Louis Nonattainment Area for t he

17 1997 8-Hour Ground-Level Ozone National Ambient A ir

18 Quality Standard.

19 The hearing record will close at 5 p. m.

20 on April 3rd, 2014.

21 Anyone who has not been scheduled to

22 appear, but who wishes to be heard, should indica te

23 that you wish to speak on the sign-in sheets

24 available at the door or by letting the Commissio n

25 know by telephone after the public hearing has be enPUBLIC HEARING 3/27/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334 MIDWEST LITIGATION SERVICES Page 6
1 of Natural Resources' website at least 30 days pri or

2 to this public hearing.

3 In addition to making the proposed pla n

4 available for viewing and comment, the Air Polluti on

5 Control Program distributed the public hearing

6 notice to over 480 citizens, organizations,

7 corporations, associations, and elected officials.

8 Finally, we notified the Kansas City, St. Louis

9 County, and Springfield local air pollution contro l

10 agencies; Illinois, Kansas and other surrounding

11 states; and the U.S. Environmental Protection Age ncy

12 of this public hearing.

13 Chairman, this concludes my testimony

.
14 CHAIRMAN PENDERGRASS: Okay. I have

15 Andy Knott -- I'm sorry. Can we back up just a

16 minute. I apologize for that. Joe Winkelmann.

17 (Whereupon, Mr. Joe Winkelmann

18 was duly sworn by the court reporter.)

19 EXAMINATION

20 MR. WINKELMANN: Good morning, Chairm an,

21 members of the Commission: My name is Joe

22 Winkelmann. I'm employed as an environmental

23 engineer with the Missouri Department of Natural

24 Resources' Air Pollution Control Program, or Air

25 Program, at 1659 East Elm Street, Jefferson City,PUBLIC HEARING 3/27/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334 MIDWEST LITIGATION SERVICES Page 7

1 Missouri.

2 I am here today to present testimony o n

3 the proposed Missouri State Implementation Plan, o r

4 SIP, revision entitled Supplement to the

5 Redesignation Demonstration and Maintenance Plan f or

6 the Missouri Portion of the St. Louis Nonattainmen t

7 Area for the 1997 8-Hour Ground-Level Ozone Nation al

8 Ambient Air Quality Standard, or NAAQS. The

9 proposal for the plan can be found on page 81 of

10 your briefing document.

11 Ozone air quality has dramatically

12 improved in the St. Louis area as a result of

13 implementation of State and Federal control measu res

14 since the designation of the St. Louis area as

15 nonattainment in 2004. On June 9th, 2011, EPA

16 issued a "Clean Data Determination" that the enti re

17 St. Louis Nonattainment Area achieved at lease th ree

18 consecutive ozone seasons (2008-2010) of complete ,
19 quality assured ambient air quality monitoring da ta

20 demonstrating attainment with the 0.080 parts per

21 million, or ppm, 8-hour ozone NAAQS promulgated i n

22 1997. The air quality monitoring data for the mo st

23 recent years of 2011 to 2013 also shows complianc e

24 with the 1997 NAAQS. These air quality improveme nts

25 are due to permanent enforceable emission controlRECOMMENDATION FOR ADOPTION

PROPOSED REVISION TO

MISSOURI STATE IMPLEMENTATION PLAN – SUPPLEMENT/REVISION TO THE REDESIGNATION DEMONSTRATIO N AND MAINTENANCE PLAN FOR THE MISSOURI PORTION OF THE ST . LOUIS NONATTAINMENT AREA FOR THE 1997 8-HOUR GROUND-LEVEL OZONE NATIONAL AMBIENT AI R QUALITY STANDARD

On March 27, 2014, the Missouri Air Conserva tion Commission held a public hearing concerning a revision to the Missouri St ate Implementation Plan (SIP) for the Supplement/Revision to the Redesignation De monstration and Maintenance Plan for the Missouri Portion of the St. L ouis Nonattainment Area for the 1997 8-Hour Ground Level Ozone National Ambient Air Quality Standard . A summary of comments received, and the Air Program’s corresponding responses, is included on the following page. Revisions were made to the proposed plan as a result of comments received.

The revised plan has not been reprinted in the briefing document due to its volume. The entire revised plan is available for review at the Missouri Departme nt of Natural Resources’ Air Pollution Control Program, 1659 East Elm St reet, Jefferson City, Missouri, 65101, (573)751- 4817. It is also available online at http ://dnr.mo.gov/env/apcp/stateplanrevisions.htm.

The Air Program recommends the commission adopt the plan as revised. If the commission adopts this plan, it will be the department’s in tention to submit it to the U.S. Environmental Protection Agency for inclusion in th e Missouri State Implementation Plan.COMMENTS AND RESPONSES ON

PROPOSED REVISION TO

MISSOURI STATE IMPLEMENTATION PLAN – SUPPLEMENT/REVISION TO THE REDESIGNATION DEMONSTRATIO N AND MAINTENANCE PLAN FOR THE MISSOURI PORTION OF THE ST . LOUIS NONATTAINMENT AREA FOR THE 1997 8-HOUR GROUND-LEVEL OZONE NATIONAL AMBIENT AI R QUALITY STANDARD

The public comment period for the proposed revisi on to the Missouri State Implementation Plan (SIP) for the Supplement/Revision to the Redesignati on Demonstration and Maintenance Plan for the Missouri Portion of the St. Louis Nona ttainment Area for the 1997 8-Hour Ground Level Ozone National Ambient Air Quality Standard (NAAQS) opened on February 24, 2014 and closed on April 3, 2014. Revisions to the proposed plan were made as a result of comments.

The following is a summary of comments recei ved and the Missouri Department of Natural Resources’ Air Pollution Control Program’s (A ir Program’s) corresponding responses. Any changes to the proposed plan are incl uded in the response to comments.

SUMMARY OF COMMENTS: During the public comment period for the proposed plan, the Air Program received six (6) comments from the Sierra Club and two (2) comments from the U.S. Environmental Protection Agency (EPA).

COMMENT #1: Sierra Club commen ted on the health effects of hi gh ozone concentrations. They pointed out several facts regarding the amount of asthma cases in the St. Louis area and how these figures compare with the rest of the state and country.

RESPONSE AND EXPLANATION OF CHANGE: Th e Air Program acknowledges the effects of ozone on certain health and respiratory cond itions, and it is the Air Program’s mission to protect air quality in the state to ensure th e safety of public health. This redesignation demonstration and maintenance plan will add an ex tra layer of protection fo r public health in the St. Louis area against elevated ozone concentrat ions, if it is adopted by the commission. The maintenance plan establishes a contingency plan that commits the state to implement additional control measures designed to address high ozone concentrations and safeguard against potential future elevated ozone concentrations. Additi onally, this plan mainta ins control requirements currently in place in the St. Louis area.

As a result of this comment, additional languag e has been added to the executive summary and Chapter 1 (Introduction/Purpose) of the plan to more clearly explai n the extra layer of environmental and public health protection for the St. Louis area through the potential implementation of contingency measur es if triggered in the future.

COMMENT #2: Sierra Club commented that there are five separate criteria that must be met in order for a nonattainment area to be redesigna ted to attainment. They specified that theimprovement in air quality must be due to permanent and enforceable control measures and not the result of favorable meteorology or economic downturn.

RESPONSE: This plan addresses each of the fi ve criteria including th e requirement that the improvement in air quality results from perman ent and enforceable emission reductions. The redesignation demonstration porti on of the plan compares the le vel of oxides of nitrogen (NO x ) and volatile organic compounds ( VOC) emissions from 2002, when the area was in nonattainment, to emissions from the attainment year of 2008. This demonstration shows that total NO x emissions in the Missouri portion of the St. Louis (MO-St. L ouis) nonattainment area from all sources have decreased a substantial 33% between 2002 and 2008. This NO x emissions reduction occurs despite the fact that both electricity produ ction and vehicle miles travel in creased within the MO-St. Louis area during this same timeframe: Power demand from electric generating units (EGUs) in the area increased by approximately 12% while vehicle m iles traveled (VMT) increased by approximately 6%. During this period, NO x emissions from EGUs in the MO-St. Louis nonattainment area reduced by approximately 5,000 tons per ozone season (~33 tons/day), and NO x emissions from on-road mobile sources decreased by over 62 to ns/day. Since electricity production and VMT grew between these two years, the emission reductions cannot be attributed to economic factors such as a downturn, but rather are the result of the implementation of enforceable emission control measures that have substantially reduced the rate at which NO x emissions are emitted from both the stationary and mobile source categories.

The 33% reduction in total NO x emissions in the MO-St. Louis nonattainment area also supports the conclusion that improvement in air quality was not based on favorable meteorology, but rather emission reductions. Figure 1 below displays th e maximum 3-year design values for 8-hour ozone concentrations from 2000–2013 for all of the MO-S t. Louis nonattainment area ozone monitors (dashed line). Based on EPA’s Guideline on Ai r Quality Models found in 40 CFR 51 Appendix W, a stable distribution of mete orological conditions occurs over a period in excess of 10 years. With data spanning more than 10 years, the figur e does not skew the results towards favorable or unfavorable meteorological conditions. The horizontal line indicates the level of violation of the 1997 8-hour ozone standard. The bold represents the best-fit trend-line for the maximum design value concentrations of all operati ng monitors each year. The ch art shows spikes and valleys for each ozone monitor, which is most likely the result of varying (favor able and unfavorable) meteorology during these years, but the trend- line shows that maximum recorded ozone concentrations in the MO-St. Louis area have be en declining over the past 13 years despite the fluctuations in yearly meteorology. This de monstrates that favorab le meteorology is not responsible for the declining tre nd in ozone concentrati ons experienced in the St. Louis area over the last 13 years. The plan asserts that the decr ease in ozone concentratio ns is in fact due to permanent and enforceable emission reductions, both regional and local. No changes to the plan were made as a result of this comment.

### Figure 1: Evaluation of Maximum Ozone Design Values from 2001-2013

COMMENT #3: Sierra Club co mmented that emission reducti ons resulting from the NO x Budget Program and the Clean Air Interstate Rule (C AIR) cannot be relied upon as permanent and enforceable because they allow for the trading/ purchasing of emission credits across the entire eastern third of the country, and it is possible that the trading pr ogram could cease in the future.

RESPONSE: The Air Program considered the effects of federal trading programs on EGU emissions inside the nona ttainment area. The EGU emissions in the MO-St. Louis nonattainment area that are subject to CAIR were evaluated from 2009–2013. Since the CAIR NO x Ozone Season trading program began in 2009, the EGUs subject to CA IR inside the MO-St. Louis nonattainment area have not once exceeded their ozone season NO x CAIR allotments in aggregate during any control period from 2009–2013. All of th e EGUs subject to CAIR in the MO-St. Louis 60 65 70 75 80 85 90 95 100

01-03 02-04 03-05 04-06 05-07 06-08 07-09 08-10 09-11 10-12 11-13^Concentration (ppb)

Violation of the 1997 NAAQS
Max STL Design Value
Max Design Value Trendline ^Quality assured data through Dec 31st, 2013 Ozone Season: Apri l 1 to October 31nonattainment area are owned by Ameren. Ameren ha s participated in emi ssion credits trading in the past, as is allowed under CAIR. The unit level CAIR allotments are occasionally exceeded from year to year. However, since CAIR bega n, any MO-St. Louis area EGU units that have exceeded their CAIR allotments have been offset by other units within the nonattainment area that held emissions below their CAIR allotments. Therefore, since 2009, total ozone season NO x emissions from EGUs in the MO-St. Louis nonattain ment area have been below the level of their total CAIR allotments each year. Ameren has complied with the NOx Ozone Season CAIR Program without purchasing or trading allowances from outside the nonattainment area. Instead, Ameren has relied on integral low NO x burners and over-fir e air to control NO x emissions from these EGUs. Because these devices are built-in or inherent to th e combustion process and work by increasing combustion efficiency, Ameren is not expected to uni nstall this inherent control technology to purchase allowances. Additionally, if Ameren did elect to uninstall the current control technology on any of thes e units, and the change trigge red a major modification, then Ameren would be subject to New Source Review (NSR) permitting requirements. In a nonattainment area (based on a new standard) these provisions would require NAAQS impact modeling and implementation of control devices at the lowest achievable emission rates (LAER).

The maintenance demonstration in cluded with this proposed SIP re vision projects future EGU emissions in the MO-St. Louis nonattainment area . As mentioned in Chapter 5 of the plan, although NO x Ozone Season CAIR allotments decr ease 17% by 2015 when compared to allotments granted in 2009–2014, the Air Program did not project future year EGU emissions based on the 2015 allotments. Instead, the plan pr ojects EGU emissions in the area to remain constant from the average levels from 2008–2011. Th is a very conservative estimate, especially considering the fact that NO x ozone season emissions from EGUs in the MO-St. Louis nonattainment area have continued to decrease in the la st two years and have actually been below the 2015 allotments in aggregat e for the last two years.

In addition, EPA has maintained that emission reductions from trading programs are permanent and enforceable. EPA has noted this during seve ral recent SIP approvals, including the CincinnatiHamilton Fine Particulate Matter (PM 2.5 ) area redesignation:

Further, EPA disagrees with the Comment er’s conclusion that emission reductions associated with trading programs such as the NO X SIP Call, CAIR, and CSAPR are not permanent and enforceable simply becaus e the underlying program is an emissions trading program... EPA disagrees with the Commenter ’s conclusion that reductions from trading programs can’t be considered permanent and enforceable because these programs allow individual sources to choos e between purchasing emission credits and reducing emissions. [76 FR 80255]

The Air Program has addressed the commenter’s concern, about the possibi lity that the CAIR program will end, in Chapter 4 of the proposed pla n. To summarize, CAIR has been remanded to EPA by the courts, and in 2011, EPA promulgated a replacement rule known as the cross-state air pollution rule (CSAPR). However, the D. C. Circuit court vacated the CSAPR in December 2011 and explicitly directed EPA to continue implemen ting CAIR until an acceptable rule that addresses the court’s concerns is promulgated. Based on an ti-backsliding provisions contained in the Clean Air Act, any replacement rule for CAIR must be e quivalent or better. Because of this, CAIR isconsidered a permanent and enforceable federal c ontrol program that meet s the requirements of CAA Section 107(d)(3)(E)(iii) fo r redesignation purposes. EPA has weighed in similarly. During the redesignation of the Indianapolis PM 2.5 area, EPA states that CAIR reductions are permanent and enforceable even if the rule is due to be replaced:

However, EPA disagrees that the Court’s instru ction in those two cases forecloses the Agency and states from relying on CAIR for pur poses such as redesignating an area from nonattainment to attainment. Subsection (iii) of section 107(d)(3)(E) is a backwards looking requirement; it requires that the attainment air quality in the area is ‘‘due to’’ permanent and enforceable emis sions reductions. The purpose of this requirement is to ensure that in redesignating areas from nona ttainment to attainment, EPA does not rely on ephemeral, temporarily improved air quality that results from circumstances such as temporary shutdowns of plants or redu ced emission rates because of slowed production... The anticipation that CAIR may be replaced during the maintenance period by another rule requiring upwind sour ces to reduce emissions does not require EPA to disapprove the redesignation request for Indianapolis current ly before it. EPA’s longstanding interpretation of section 107(d)(3)(E) in the Calcagni Memorandum contemplates that some re ductions required by existing control measures may be replaced in the future by other measures

... Therefore, the commenter’s concern that a future replacement rule might not require th e same reductions as CAIR is not a bar to approving Indiana’s redesi gnation request today. [78 FR 41700-41701]

Lastly, states must be able to a ssume that regulations at the federal level are useable for credit in the SIP. EPA reiterates this in th e Indianapolis area redesignation:

The structure of section 107( d)(3)(E)(iii) indicates that the CAA generally considers reductions resulting from SIPs and Federal regu lations as permanent and enforceable. It references ‘‘other’’ reducti ons that are comparable to me asures adopted into SIPs or Federally adopted regulations and can th erefore also qualify as permanent and enforceable reductions, indicating that, in ge neral, SIP reductions and reductions from Federal regulations are the types of reductions that the CAA views in the first instance as having the requisite permanence and enfor ceability for purposes of redesignation. [78 FR 41701]

No changes were made to the plan as a result of this comment.

COMMENT #4: Sierra Club commen ted that NAAQS are not an air quality target to be hit one time. The Sierra Club points out that the ar ea violated the standard based on 2010–2012 air quality data, and asked what is to prevent the area from violating the NAAQS in the future. Sierra Club cites that the Illinois portion of the nonattainment area ha s already been redesignated to attainment and is also a party to the 2010-2012 ozone air quality violation.

RESPONSE AND EXPLANATION OF CHANGE: The SIP must provide for attainment and maintenance of the NAAQS at all times. Howeve r, SIPs cannot foresee every possible situation and provide a guarantee that air quality will never ex ceed or violate a specific standard, especially for a pollutant such as ozone, where meteorology play s such a significant role in its photochemicalformation. For this reason, the Air Program em phasizes the importance of establishing the contingency measures contained in this maintenan ce plan, which would be implemented if future violations of the 1997 ozone NAAQS occur due to these unforeseen occurrences.

The summer of 2012 was among the hottest summers on record for the Midw est United States, and devastating droughts limited precipi tation across the region to well-be low-average levels. Despite this record-setting summer, only one monitor out of twelve operati onal monitors in the St. Louis area recorded a violation of the 1997 ozone NAAQS with a design value of 86 ppb from 2010– 2012 (due to regulatory rounding co nventions 85 ppb is considered a violation of the 1997 ozone NAAQS). In other words, violations of the 1997 ozone NAAQS concentra tions across the entire St. Louis area as a region are not occurring and ha ve not occurred since the area originally attained back in 2009.

As the country recovers from the recession a nd VMT, population, and electricity demand grow, emissions levels from the largest source categories continue to decline, an d ozone concentrations are trending downwards. All monitors in the 1997 St. Louis ozone nonattainment area are in compliance with the 1997 ozone NAAQS based on 2011 – 2013 air quality data. It is important to note, that the area is attaini ng even though the unusually high 2012 ozone season is still included in the 2011-2013 design value for the area.

Furthermore, ozone precursor emissions decrea sed from 2012 to 2013. Regulatory ozone season NO x emissions from EGUs within the MO-St. L ouis nonattainment area dec lined by 248 tons from 2012 to 2013. In addition, ozone season NOx and VOC emissions from on-road sources in the MO-St. Louis nonattainment area declined by ap proximately 265 tons and 407 tons, respectively, as a result of federal motor vehicle emission st andards and fleet turnove r. Moreover, motor vehicle emission standards are expected to continue to drop as a result of the recently promulgated federal Tier 3 standards to be implem ented starting in the 2017 model year.

Since the summer of 2012, the Air program has im plemented grant projects through the Diesel Emissions Reduction Act for engine repowers on three (3) tugboats operating exclusively inside the nonattainment area, an engine repower fo r one (1) switch locomotive operating in the nonattainment area, an early replacement for a l ong-haul tractor trailer operating inside the nonattainment area, and tailpipe/id le reduction retrofits for 23 sc hool buses operating in Jefferson County. These projects have further reduced NO x and VOC emissions in the nonattainment area since 2012 and are contributing to the continued declining trend in ozone concentrations.

In regard to the Illinois portion of the nonattainment area, the plan mentions that the four Illinois counties on the Metro-east side of the area have been redesignated to attainment. For the violation of the 1997 ozone NAAQS based on 2010–2012 air quality data, only one out of twelve air quality monitors in the area was out of compliance, and the location of that m onitor was on the Missouri side of the nonattainment area. In response, Illinois implemented a cont ingency measure pursuant to their approved maintenance plan. The Air Program again notes the importance of the contingency plan associated with Missouri’s re designation request and maintenance plan for the area. If another triggering event and/or violati on of the NAAQS occurs in the region, the Illinois EPA and the Air Program would wo rk together to determine the cause and implement contingency measures to further limit and re duce emissions in the area.As a result of this comment, additional language has been added to the plan to provide a discussion of the emissions reductions achieved in the MO-S t. Louis area since the summer of 2012 in an effort to demonstrate that emi ssions of ozone precursors within the nonattainment area continue to decline as a result of both permanent voluntary projects and permanent and enforceable control

measures.

COMMENT #5: Sierra Club commented that a newer, more protective 2008 ozone NAAQS has been promulgated and that an even more stringent ozone standard is expected to be proposed by EPA in the near future. They noted that the St. Louis area is currently designated as a marginal nonattainment area for the 2008 ozone NAAQS, and that the area will be reclassified from marginal to moderate classifica tion under the 2008 ozone NAAQS if th e area fails to attain by the attainment deadline for marginal areas. The Sierra Club suggests a more proactive approach, stating that the Air Program should use its mini mal resources to addres s these newer, more protective NAAQS, as opposed to addr essing the older 1997 ozone standard.

RESPONSE AND EXPLANATION OF CHANGE: The Air Program is currently developing a marginal area SIP submission to address the ar ea’s marginal nonattainme nt designation under the 2008 ozone NAAQS. If the downward trend of ozone precursor emissions described in the plan, and elsewhere here, is not enough to comply with the 2008 ozone NAAQS by the attainment date of December 31, 2015 and the area is reclassified to moderate, the State’s obligations become more stringent and the Air Program will be required to address them at that time. This redesignation of the MO-St. Loui s area to attainment for the 1997 ozone standard has no effect on the attainment or implementation of the 2008 NAAQS. By redesignating the MO-St. Louis area to attainment under the 1997 standard, the Air Program is putting contingency measures in place and concluding our planning oblig ations under the 1997 NAAQS.

The Air Program is taking a proactive approach through this redesignatio n request by reducing uncertainty regarding the State’s planning obligations for the old standard. This allows the Air Program to focus its limited resources on the curre nt, more protective 2008 ozone standard, as well as a more stringent ozone standard anticipat ed in late 2015. The Air Program has already developed an Early Progress Plan for the St. Loui s marginal ozone nonattainment area in order to establish motor vehicle emission budgets for th e area under the 2008 NAAQS. The Air Program is also nearing completion of a SIP revision under S ection 182(a) of the Clea n Air Act in order to address the state’s planning obliga tions for the marginal ozone nonattainment area. Furthermore, because of the possibility that St. Louis could be reclassified from marginal to moderate under the 2008 standard and classified moderate or higher under the revised ozone NAAQS expected in late 2015, the Air Program is currently reviewing 2018 emissions inve ntory projections and modeling input files in an early effort to develop a modeling construct to support any additional planning requirements in the event these scenarios occur. Both of these situations would require the Air Program to develop an attainment demonstrati on and a reasonable further progress plan under Section 182(b) of the Clean Air Act.

As a result of this comment, additional languag e has been added to the Executive Summary and Chapter 1 (Introduction/Purpose) of the plan to explain that a newer, more protective ozone NAAQS is in place and that an ev en more stringent ozone NAAQS is expected to be established inthe near future. The approval of this plan will conclude any obligations under the 1997 standard prior to its revocation, allowing the Air Program to focus its resources on addressing these newer, more protective ozone NAAQS.

COMMENT #6: Sierra Club commen ted that the Air Program shoul d get out ahead of the issue and require controls on large stati onary sources. They state that controlling stationary sources provides a much higher level of emission reducti on certainty than relying on motor vehicle fleet
turnover.

RESPONSE: Based on the Air Program’s 2008 comp rehensive baseline emissions inventory for the MO-St. Louis nonattainment area included w ith this plan, on-road motor vehicle emissions comprise over 50% and 25% of total NO x and VOC emissions, respectively. Whereas, point sources (i.e., large statio nary sources) only comprise 28% and 8% of total NO x and VOC emissions, respectively. Since on-road motor vehicl es contribute such a la rge percentage to the overall emissions inventory thes e emissions should be addres sed in order to reduce ozone concentrations effectively. Fede ral motor vehicle engine standards are permanent and enforced by requiring emission reductions at the engine/vehicle manufacturer level. Because of the continued tightening of federal motor vehicl e emission standards, each time an older car is retired and replaced by a newer car (referred to as ‘fle et turnover’), permanent emission reductions are achieved.

The Air Program develops comprehensive emissions inventories every three years as required by EPA’s Air Emissions Reporting Rule. In order to develop on-road motor vehicle emissions, the Air Program queries Missouri Depart ment of Revenue data for every registered vehicle in the state to determine the age distribution of the vehicle fleet in Missouri. Each year this query is performed, there is always a substantial number of the later model year vehicles, meaning that the latest model year cars continue to be purchased both in St. Louis and throughout the state on a regular basis. As demonstrated in the respons e to comment #2, emission reductions have outpaced VMT growth which can be attributed to regular motor vehicle fleet turnover.

Moreover, these motor vehicle emission reductions are based on conservative assumptions. The maintenance demonstration within this plan employs a 1.5% annual VMT and vehicle source population growth rate for motor vehicles in the MO-St. Louis nonattainment area, even though the East-West Gateway Council of Governments, the region’s transportation planning agency, currently estimates that the MO-St. Louis area VMT is only expected to grow at an annual rate of approximately 1% . Additionally, it is noted that the Air Program took no credit in the plan for the Federal Tier III motor vehicle engine standards th at EPA recently promulgated. These standards are expected to significantly reduce NO x and VOC emissions from the mobile source sector and provide additional assurance that ozone precursor em issions will continue to decline in the MO-St. Louis nonattainment area through permanent and en forceable control measures. Even with the conservative assumptions used in the plan, the stat e still demonstrates that the area will maintain the 1997 ozone NAAQS. No changes to the proposed pl an were made as a result of this comment.

COMMENT #7: EPA commented that Missouri s hould provide additional information to more accurately reflect that recent improvements to ai r quality are due to permanent and enforceable emission reductions.RESPONSE AND EXPLANATION OF CHANGE: As th is comment reflects some of the same issues addressed by the Sierra Club in their co mments, we defer to the responses to those comments in addressing this one as well. Please see the respons es to comment #2 and comment #4 above in regard to recent permanent and enforceable emissions reductions. As a result of this comment, additional language has been added to the plan to describe the recent emissions reductions since the summer of 2012 that have been achieved in the St. Louis area as a result of permanent and enforceable controls.

COMMENT #8: EPA commented that the Air Program should remove language in Chapter 7 of the plan in relation to submitting a second 10-year maintenance plan for the 1997 ozone NAAQS. The commitment to submit a second 10-year plan is not necessary for approving this current maintenance plan. In the event that a se cond 10-year maintenance plan is required, EPA’s future rulemakings will specifica lly clarify those requirements.

RESPONSE AND EXPLANATION OF CHANGE: As a result of this comment, the Air Program removed the commitment to develop the sec ond 10-year maintenance plan for the 1997 ozone NAAQS from Chapter 7 of the plan. If EPA promul gates a future rule requi ring the St. Louis area to develop a second 10-year maintenance plan for the 1997 ozone NAAQS, the Air Program would address the obligation at that time.