t 

STATE OF MISSOURI Jeremiah W Uay) Nlxon, Governor . Sara Parker Pau.ley, Direcror 

DEPARTNfENT OF NATURAL RESOURCES 

/ www.dnr.mo .gov 

APR - 3 2014 

Mr. Karl Brooks 

Regional Administrator 

U.S. EPA, Region VII 

11201 Renner Boulevard 

Lenexa, KS 66219 

Dear Mr. Brooks: 

The Missouri Department ofNatural Resources' Air Pollution Control Program (Air 

Program) hereby submits the following Missouri State Implementation Plan (SIP) revision 

for your approval: 

Proposed Revision to the Limited Maintenance Plan for the St. Louis Nonclassifiable 

Maintenance Areafor the 8-Hour Carbon Monoxide National Ambient Air Quality Standard 

Through this SIP submittal, the Air Program is requesting that EPA approve the maintenance 

plan as meeting the requirements ofthe Clean Air Act, section 175A. 

The Missouri Air Conservation Commission adopted this plan at the March 27,2014 

commission meeting. A public hearing for the proposed plan was held on January 30,2014 

and comments were accepted from December 30,2013 through February 6,2014. During 

the public comment period for the proposed plan, no comments were received. 

In order to comply with Attachment A ofthe "Regional Consistency for the Administrative 

Requirements of State Implementation Plan Submittals and the Use of'Letter Notices'" 

memo dated April 6, 2011, a searchable pdf version of this document will be emailed to the 

EPA Regional Office and will be posted on our website at 

http://dnr.mo.gov/env/apcp/stateplans.htm. 

Also, due to their size, paper copies ofthe 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. Ifyou have any questions regarding this 

submittal, please contact Ms. Wendy Vit with the Missouri Department ofNatural 

o RU.\llljl 1"1111 r 
Mr. Karl Brooks 

Page Two 

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 

~e 

// ;z:'-/ ~ Director 


KLM:ewc 


Enclosures: 


Copy ofplan (paper copies ofthe appendices are not included) 


Copy of commission signature page certifying Missouri Air Conservation Commission 


adoption 

Copy ofpublic hearing notices 

Copy of public hearing transcript introductory statement 

Copy of recommendation for adoption 

CD with electronic copy of the plan with appendices 

c: Missouri Air Conservation Commission 

File# 1971-CO-5 STL 2nd Maintenance 

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


To learn more about the Missouri Department ofNatural Resources visit dnr.mo.gov. 

Proposed Revision to the Limited Maintenance Plan 

for the St. Louis Nonclassifiable Maintenance Area for 

the 8-Hour Carbon Monoxide National Ambient Air 

Quality Standard 

Prepared for the 

Missouri Air Conservation Commission 

Adoption 

March 27, 2014 

Division of Environmental Quality 

Air Pollution Control Program 

P.O. Box 176 

1659 East Elm Street 

Jefferson City, Missouri 65102-0176 

Telephone (573) 751-4817

Project Number: 1971-CO-5 

TABLE OF CONTENTS 

TABLE OF CONTENTS .............................................................................................................. i

List of Tables ................................................................................................................................. ii

List of Figures ................................................................................................................................ ii

List of Appendices ......................................................................................................................... ii

Executive Summary ...................................................................................................................... 1

1. Introduction ........................................................................................................................... 2

1.1 National Ambient Air Quality Standard for CO ........................................................... 2

1.2 Description of the St. Louis Nonclassifiable CO Nonattainment Area ........................ 3

1.3 Limited CO Maintenance Plan Option ......................................................................... 3

1.4 St. Louis CO Monitoring Network ............................................................................... 4

1.5 Quality Assurance Program .......................................................................................... 4

1.6 Continued Monitoring Commitment............................................................................. 5

2. Maintenance Demonstration ................................................................................................ 7

2.1 Continued Enforceable Control Measures .................................................................... 7

2.1.1 Permanent and Enforceable Controls ...................................................................... 8 

2.1.2 Provisions for Permitting New or Modified Emissions Sources ............................ 8 

3. 2008 Base Year Emission Inventory .................................................................................... 8

4. Contingency Measures........................................................................................................ 10

5. Transportation and General Conformity ......................................................................... 12

6. Public Participation ............................................................................................................ 13

7. Conclusion ........................................................................................................................... 13
LIST OF TABLES 

Table 1 2006-2012 2nd Highest 8-Hour Average CO Monitored Values (ppm)* ................... 7

Table 2 2008 CO Emissions for St. Louis County and City (tons/average winter day) ............ 9

Table 3 Contingency Plan for the St. Louis Nonclassifiable CO Maintenance Area .............. 11 

Table 4 Potential Contingency Measures for the St. Louis Nonclassifiable 

CO Maintenance Area ................................................................................................. 12 

LIST OF FIGURES 

Figure 1 St. Louis Nonclassifiable CO Maintenance Area ......................................................... 3 

Figure 2 St. Louis CO Monitoring Network ............................................................................... 6 

LIST OF APPENDICES 

Appendix A 2008 Base Year Annual Carbon Monoxide Emissions Inventory Summary 

for St. Louis County and St. Louis City 

 Appendix A-1 List of St. Louis City and County Point Source Emissions by 

Facility 

 Appendix A-2 List of On Road Emissions by SCC for St. Louis County and 

 St. Louis City 

 Appendix A-3 Nonroad Inventory Documentation 

 Appendix A-4 Nonroad Emissions by SCC 

 Appendix A-5 Nonpoint ICI Combustion Methodology 

 Appendix A-6 Inspection/Maintenance Input Table Development Protocol for 

MOVES for Counties in the St. Louis Ozone Nonattainment Area 

Appendix B 2008 Base Year Average Winter Day Carbon Monoxide Emissions 

Inventory for St. Louis County and St. Louis City 

 Appendix B-1 2008 Point Source Average Winter Day Emissions 

 Appendix B-2 2008 Area Source Average Winter Day Emissions 

 Appendix B-3 2008 On-Road Source Mobile Average Winter Day Emissions 

 Appendix B-4 2008 Off-Road Mobile Source Average Winter Day Emissions 

 Appendix B-5 Temporal Allocation Methodology Applied to Residential Fuel 

Combustion Area Source Categories 

 Appendix B-6 EPA NONROAD Modeling Protocol for 2008 and 2022 Off-Road 

Mobile Source Emissions in the St. Louis Nonattainment Area 

Appendix A 2008 Base Year Average Winter Day Carbon Monoxide Emissions 

Inventory 
Appendix A-1 Point Source Emissions 

Appendix A-2 Area Source Emissions 

Appendix A-3 On-Road Mobile Source Emissions 

Appendix A-4 Off-Road Mobile Source Emissions 

1 

EXECUTIVE SUMMARY 

This document outlines the Missouri Department of Natural Resources’ Air Pollution Control 

Program’s (hereafter referred to as the ‘Air Program’) Limited Maintenance Plan (hereafter 

referred to as the ‘plan’) for the St. Louis nonclassifiable Carbon Monoxide (CO) maintenance 

area (hereafter referred to as the ‘St. Louis area’). This is the second of two required ten-year 

maintenance plans developed for the St. Louis area. 

The St. Louis area includes the City of St. Louis and the portion of St. Louis County 

encompassed by Interstate 270 and the Mississippi River. The area was originally designated 

nonattainment for the 8-hour CO National Ambient Air Quality Standard (NAAQS) in 1978, 

with a design value of 14.0 ppm at the Shreve and Interstate 70 site in St. Louis City. Following 

the Clean Air Act (CAA) Amendments of 1990, the St. Louis area was not classified and prior 

designation was retained by operation of law in 1991 but without a measured violation based on 

1988-89 or 1999-2000 data. The area is referenced as a nonclassifiable CO nonattainment area. 

Carbon monoxide air quality dramatically improved in the St. Louis region as a result of the 

implementation of state and federal control measures since the designation of the St. Louis area 

as nonattainment in 1978. The last exceedance occurred in 1994, and previous to that, the last 

exceedance occurred in 1987. Subsequently, in 1997, the Air Program submitted a request to 

redesignate the area to attainment and prepared a plan to maintain the standard through 2008. 

The plan was approved by the U.S. Environmental Protection Agency (EPA) on January 26, 

1999. (See 64 FR 3855). 

On October 6, 1995, Joseph W. Paisie sent EPA Regional Air Branch Chiefs a memorandum 

detailing a Limited Maintenance Plan Option for nonclassifiable CO areas. This memorandum 

describes a set of minimal maintenance plan requirements for CO nonattainment areas whose 

design values are less than or equal to 85 percent of the exceedance level of the CO NAAQS, or 

7.65 parts per million (ppm). The EPA does not believe that the full maintenance plan 

requirements need be applied to these areas because they have achieved air quality levels well 

below the standard without the application of control measures required by the CAA 

Amendments of 1990 for classified CO nonattainment areas. Also, these areas do not have either 

a recent history of monitored violations of the CO NAAQS or a long prior history of monitored 

CO air quality problems. The St. Louis area met the requirement for the Limited Maintenance 

Plan option in the original redesignation and maintenance plan approved in 1999. The design 

value at that time (1994-95) was 5.7 ppm. The St. Louis area continues to qualify for the 

Limited Maintenance Plan option because its most recent design value (2011-2012) is 1.8 ppm. 

This second maintenance plan provides for continued attainment of the 8-hour CO NAAQS for 

the St. Louis area through 2018. The plan also provides assurances that, in the event of a 

subsequent violation of the CO NAAQS, additional control 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 seven years and an updated 

emission inventory for average winter day CO emissions in the St. Louis area. 
2 

1. INTRODUCTION 

1.1 NATIONAL AMBIENT AIR QUALITY STANDARD FOR CO 

The CAA requires that the EPA carry out a periodic review of NAAQS for pollutants considered 

harmful to public health and the environment. These pollutants are carbon monoxide, lead, total 

suspended particles, sulfur dioxide, nitrogen oxide, and ozone. These pollutants are referred to 

as “criteria” pollutants. There are two categories of NAAQS set by the EPA: primary and 

secondary. The primary standards are health-based and are designed to establish limits to protect 

public health. The secondary standards are commonly referred to as “welfare-based” and are 

established to protect public welfare and are intended to protect against decreased visibility, and 

damage to crops, animals, and buildings. 

The EPA establishes a standard for each criteria pollutant. If an area is found to exceed this 

value, it is classified as a nonattainment area for that specific pollutant. The States and/or tribes 

responsible for the affected area must then develop and carry out strategies and measures to 

attain the NAAQS. The goal is for any areas designated as “nonattainment” to be reclassified by 

the EPA to attainment for the pollutant. When that goal is achieved, the reclassified area enters 

the first of two ten-year maintenance periods. The St. Louis area is in the second maintenance 

period. 

The CO NAAQS was initially set in April 1971 and has been reviewed three times: 1985, 1994, 

and 2011. In the 1985 review, the secondary CO NAAQS was revoked due to a lack of evidence 

of adverse effects on public welfare at or near ambient concentrations and has not been restored 

since. The EPA reviewed the CO NAAQS in 2011 (76 FR 50294) and determined that the 

current primary standard for CO was adequate to protect public health and the environment. In 

each review, the primary standards were retained without revision. However, the 2011 review 

included new provisions for States to develop near roadway monitoring networks (see section 

1.4). 

The CO NAAQS includes a 1-hour standard and an 8- hour standard; this plan addresses the 8-

hour standard. The 8-hour standard is computed by first finding the maximum and second 

maximum (non-overlapping) eight-hour average values at each monitoring site each year for two 

years and using the higher second maximum value from the two years as the design value for 

that monitoring site. For a metropolitan area, such as St. Louis, that has more than one 

monitoring site, the design value for each site is determined and the highest of these values 

serves as the design value for the entire area. The St. Louis area’s design value for the most 

recent two years of data (2011 – 2012) is 1.8 ppm. 

If the design value exceeds the level of the standard, 9 ppm for CO, that area is in violation of the 

NAAQS. An exceedance of the standard is different than a violation. An exceedance occurs when 

any 8-hour average reading exceeds the standard. A second exceedance in one year results in a 

violation.
3 

1.2 DESCRIPTION OF THE ST. LOUIS NONCLASSIFIABLE CO 

NONATTAINMENT AREA 

The St. Louis area includes the City of St. Louis and the portion of St. Louis County 

encompassed by Interstate 270 and the Mississippi River as shown in Figure 1 below. 

Figure 1 St. Louis Nonclassifiable CO Maintenance Area 

1.3 LIMITED CO MAINTENANCE PLAN OPTION 

The Air Program is using the Limited Maintenance Plan option in preparing this second ten-year 

revision to the SIP. The option is explained in EPA guidance of October 6, 1995, from Joseph 
4 

W. Paisie, Group Leader, Integrated Policy and Strategies Group, EPA. The guidance allows for 

a less rigorous approach than was previously required in developing attainment/maintenance 

plans for CO nonattainment areas that have design values at or below 7.65 ppm (85% of the CO 

NAAQS). The EPA believes the continued applicability of prevention of significant deterioration 

(PSD) requirements, any control measures already in the State Implementation Plan (SIP), and 

federal measures (such as the federal motor vehicle control program) should provide adequate 

assurance of maintenance for these areas. 

The limited maintenance plan approach has five required elements: a description of and 

commitment to a sustained monitoring network, a maintenance demonstration, an attainment 

emission inventory, a contingency plan in case of a violation, and a conformity determination. 

Monitoring Network and Continued Attainment of the CO NAAQS. 

This section presents monitoring information that demonstrates St. Louis has continued to 

maintain the 8-hour CO standard of 9 ppm, and that the design value in the area is lower than the 

7.65 ppm design value required for limited maintenance plans. The department maintains an 

EPA-approved network of ambient air quality monitors to verify attainment status of the St. 

Louis area. This demonstration is based on the past six years of quality assured air monitoring 

data monitored through the St. Louis CO monitoring network as specified in 40 CFR 58. The 

data was collected and quality assured in accordance with 40 CFR 58 and recorded in EPA’s Air 

Quality System (AQS) database. 

1.4 ST. LOUIS CO MONITORING NETWORK 

There is currently one site, Blair Street, that monitors CO in the St. Louis area. The Blair St. site 

is Missouri’s National Core (NCore) multipollutant monitoring site. Carbon monoxide 

monitoring is required at NCore sites. Prior to September of 2010, there were three sites that 

monitored ambient CO concentrations in the St. Louis area: Blair St., Sunset Hills and 

Margaretta. Due to reductions in measured CO concentrations and funding restrictions, the CO 

monitors at the Sunset Hills and Margaretta sites were discontinued. The justification for the 

permanent discontinuation of the Sunset Hills and Margaretta CO Monitors was addressed in the 

2011 Monitoring Network plan 

http://dnr.mo.gov/env/apcp/docs/2011monitoringnetwork.pdf (see pages 26 through 28) which 

was subsequently approved by the EPA Region VII administrator on December 12, 2011. EPA’s 

Monitoring Network Plan approval letter can be found at the Region VII air quality programs 

page: http://www.epa.gov/region07/air/quality/quality.htm#mo_air 

In addition to the continued CO monitoring at the Blair Street Site, a near roadway CO 

monitoring site began operation at the Forest Park Site in the St. Louis on January 1, 2013. The 

CO monitoring network for the St. Louis area is presented below in Figure 2. 

1.5 QUALITY ASSURANCE PROGRAM 

Ambient air monitoring data for CO is collected, verified, and validated in accordance with 40 

CFR 58 and a Quality Assurance Project Plan (QAPP). The QAPP outlines standard operating 

procedures for operating the network and validating the data. In addition, the network is 

reviewed annually through the Annual Monitoring Network Plan, which outlines the proposed 

changes to the network for implementation in the subsequent year. Review of the network takes 
5 

into consideration changes to the regulations, requested special projects, budget issues etc. A 

site can either be discontinued or relocated based on the annual review and with approval from 

the EPA. The network is further reviewed more comprehensively every five years through a 

Network Assessment, according to 40 CFR 58.10, for determining, at a minimum, if the network 

is meeting the monitoring objectives. The quality assured data collected at the site(s) is 

submitted to AQS and is available for public review as outlined in 40 CFR 58. 

1.6 CONTINUED MONITORING COMMITMENT 

The Department of Natural Resources, through the Air Program and the Environmental Services 

Program, is committed to continue operating an appropriate CO monitoring network in the St. 

Louis area in accordance with 40 CFR 58 and EPA-approved annual monitoring plans to verify 

the attainment status of the area. The department will continue to quality assure the ambient air 

monitoring data in accordance with 40 CFR 58 and submit the data to AQS in a timely fashion. 

The department is committed to continue working with the EPA to ensure that the CO 

monitoring network sufficiently meets the requirements of 40 CFR 58 and its monitoring 

objectives. 
6 

Figure 2 St. Louis CO Monitoring Network 
7 

2. MAINTENANCE DEMONSTRATION 

The maintenance demonstration is considered to be satisfied if the monitoring data show that the 

area is meeting the air quality criteria for limited maintenance areas – a concentration less than or 

equal to 7.65 ppm. 

Design values for CO are determined by using the second-highest non-overlapping 8-hour 

average value for each of two consecutive years. The higher of the 8-hour averages from the two 

years is the design value. Table 1 shows the second highest 8-hour average values at each CO 

monitoring site in the St. Louis area since 2006. As described in section 2.1, there were three 

CO monitoring sites in the St. Louis area until the Sunset Hills and Margaretta CO monitors 

were discontinued in 2010. 

The St. Louis area's design value for the first ten-year maintenance plan (1994 – 1995) was 5.7 

ppm. The St. Louis area's 2008 – 2009 design value using 2008 as the emission inventory base 

year is 2.8 ppm (approximately 30% of the CO NAAQS). The design value for the St. Louis 

area’s most recent 2-year period, 2011 – 2012, is 1.8 ppm (approximately 20% of the CO 

NAAQS). 

The second highest 8-hour average values recorded in St. Louis since 2006 have not been more 

than 35 percent of the 8-hour CO NAAQS. This monitoring data qualifies the St. Louis area for 

the Limited Maintenance Plan option and provides assurance that the St. Louis area continues to 

maintain compliance with the CO NAAQS. 

Table 1 2006-2012 2nd Highest 8-Hour Average CO Monitored Values (ppm)* 

Monitoring Site Name 2006 2007 2008 2009 2010 2011 2012 

Blair Street 1.9 1.4 2.6 1.3 1.7 1.4 1.8

Sunset Hills 1.2 1.0 0.8 0.7 ** 0.6 - -

Margaretta 2.5 2.7 2.8 1.7 ** 1.2 - -

* Concentrations as reported by AQS AMP 450 Report as of 08/27/13 

** Incomplete Data and Discontinued Monitor 

2.1 CONTINUED ENFORCEABLE CONTROL MEASURES 

The St. Louis area was designated as nonattainment of the 8-hour CO NAAQS in 1978. Since 

that time, the implementation of permanent and enforceable reductions of CO emissions has 

contributed to improvements in ambient CO concentrations and to the continued attainment of 

the 8-hour CO NAAQS. The primary control measures used to attain and maintain the 8-hour 

CO standard include: 

 New Source Performance Standards (NSPS) 

 PSD Permitting (10 CSR 10-6.060 Construction Permits Required) 

 National Emissions Standards for Hazardous Air Pollutants (NESHAPS)/Maximum 

Achievable Control Technology (MACT) Standards 

 Federal gasoline detergent additive rule 

 Heavy-Duty Diesel Engine Standards 

 Tier 2 Rule-Vehicle Standards 
8 

 Tier 4 Rule-Off Road Mobile Engine Standards 

 Reformulated Gasoline (RFG) 

 Gateway Vehicle Inspection Program 

 Open Burning Restrictions 

During the first 10 year maintenance period, federal control measures such as the Federal Motor 

Vehicle Emission Control Program and emission standards for non-road engines were noted as 

projected improvements to ambient air quality. The mobile source control measures have 

resulted in significant reductions in CO emissions. Federal regulations for the control of mobile 

sources are expected to continue to be tightened in the future. The tightening of federal motor 

vehicle standards and the phase out of older higher polluting vehicles will continue to contribute 

to the maintenance of the 8-hour CO NAAQS. 

2.1.1 Permanent and Enforceable Controls 

The Air Program provides assurance that all of the control measures adopted by state rules and 

listed in this document that have been used to attain and maintain the 8-hour CO standard are 

permanent and enforceable. Any revisions to the control measures included in this document 

will be submitted as a SIP revision to EPA for approval. 

2.1.2 Provisions for Permitting New or Modified Emissions Sources 

In accordance with the CAA, Missouri has a long-standing and fully implemented New Source 

Review (NSR) permitting program for new major sources and significant modifications of 

existing sources. This NSR program in any attainment area is referred to as a PSD permitting 

program. Missouri has adopted the PSD Program under State rule 10 CSR 10-6.060, 

Construction Permits Required. 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. 

3. 2008 BASE YEAR EMISSION INVENTORY 

In accordance with the Limited Maintenance Plan guidance, the Air Program must provide an 

emissions inventory that “should represent emissions during the time period associated with the 

monitoring data showing attainment. The inventory should be based on actual “typical winter 

day” emissions of CO.” 

In 1997, the Air Program submitted a request to redesignate the area to attainment and prepared a 

plan to maintain the standard through 2008. This plan establishes 2008 as the base year of the 

second ten-year maintenance period. A base year of 2008 is representative of the time period 

associated with the monitoring data summarized in Table 1 of the previous section. The 2008 

base year inventory includes a comprehensive average winter day CO emissions inventory for 

the City of St. Louis and St. Louis County from point, area, on-road mobile, and off-road mobile 

emissions (Table 2). Biogenic emissions are not included in these summaries. The 2008 base 

year inventory is based on actual activity levels in 2008 and includes all emissions in St. Louis 
9 

City and St. Louis County, even though the maintenance area only includes the City of St. Louis 

and the portion of St. Louis County encompassed by the I-270 loop. 

Annual point source emissions for CO were compiled from Missouri’s Air Emissions Database. 

Annual emissions inventories for point, area, on road mobile and off road mobile source 

categories are described in detail in Appendix A. The unit of measurement for this inventory is 

tons CO per average winter day. In order to calculate the emissions in tons CO per average 

winter day for St. Louis City and St. Louis County, the Air Program followed the methods listed 

in Appendix B of this document. For point sources, annual emissions were divided by 366 (2008 

was a leap year) to get average winter day emissions. 

Similarly, for area sources other than residential fuel combustion, annual emissions were divided 

by 366 to get average winter day emissions. Annual area source emissions were calculated using 

the most recently available methodologies and emissions factors from U.S. EPA along with 

activity data (typically population, employment, fuel use, etc.) specific to 2008. For residential 

fuel combustion source categories, temporal allocation methods were used to adjust the annual 

emissions to an average day in January. The two area source values were then summed to obtain 

a total area source tons CO/average winter day value. 

On-road mobile source emissions were calculated using EPA’s Motor Vehicle Emissions 

Simulator (MOVES) version 2010a for 2008 for the months of January, February, March, and 

December and then divided by 122, the number of days in those months, to get the average 

winter day emissions. For off-road mobile sources, emissions were developed using EPA’s 

NONROAD 2008a emissions model to calculate average winter day CO emissions. 

Table 2 2008 CO Emissions for St. Louis County and City (tons/average winter day) 

County Source Category CO Emissions 

(tons/average winter day)

St. Louis County Point Sources 13.65

St. Louis County Area Sources 52.33

St. Louis County On Road Mobile Sources 425.49

St. Louis County Off Road Mobile Sources 211.50

St. Louis County sub-total 702.97

St. Louis City Point Sources 3.61

St. Louis City Area Sources 17.93

St. Louis City On Road Mobile Sources 106.93

St. Louis City Off Road Mobile Sources 38.97

St. Louis City sub-total 167.44

Total (St. Louis City and County) Point Sources 17.26

Total (St. Louis City and County) Area Sources 70.26

Total (St. Louis City and County) On Road Mobile Sources 532.42

Total (St. Louis City and County) Off Road Mobile Sources 250.48

Total (St. Louis City and County) Total 870.42
10 

4. CONTINGENCY MEASURES 

Section 175(A) of the CAA specifies the requirements for maintenance plans. In addition to 

providing a plan for the maintenance of the NAAQS for an additional ten (10) years after 

expiration of the first maintenance period, this plan also includes a list of contingency measures 

to correct any violation of the 8-hour CO NAAQS that might occur in the future. 

Contingency measures are to be used to further reduce emissions in the event that future 

violations of the 8-hour CO NAAQS occur. While these measures do not need to be fully 

adopted by the Missouri Air Conservation Commission prior to the occurrence of a NAAQS 

violation, the contingency measures 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 plan for the St. Louis nonclassifiable CO 

maintenance area. The contingency plan, which details the Level I and Level II triggers and 

corresponding actions to be taken, is summarized in Table 3. The potential contingency 

measures, to be evaluated after a triggering event, are listed in Table 4. Consistent with this 

contingency plan, the Air Program agrees to adopt and implement the necessary corrective 

actions in the event that violations of the 8-hour CO NAAQS occur anywhere within the St. 

Louis nonclassifiable maintenance area during the maintenance period covered by this plan. The 

implementation of contingency measures will take place as expeditiously as practicable, but in 

no event later than twenty-four (24) months after the Air Program makes a determination that a 

violation of the appropriate trigger has occurred, based on quality-assured ambient air quality 

data that has been uploaded into EPA’s Air Quality System (AQS). 

The contingency plan provides for different levels of corrective responses should the ambient 8-

hour CO levels exceed the NAAQS in any year. A Level I response would occur in the event 

that an 8-hour CO concentration at any monitoring site in the St. Louis nonclassifiable 

maintenance area exceeds 9 ppm at any point. 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. If controls are required, the potential contingency measures 

listed in Table 4 will be evaluated in addition to other measures that may be identified through 

the evaluation or that become available through future advances in control technology and 

methods. It is noted that the EPA does not require a state to implement contingency measures 

when occasional exceedances are recorded. The Air Program’s voluntary commitment to initiate 

a Level I response is intended to prevent future violations of the NAAQS from ever occurring. 

A Level II trigger occurs when a violation of the 8-hour CO NAAQS at any monitoring station in 

the St. Louis nonclassifiable CO maintenance area is recorded during the maintenance period 

after this plan has been adopted by EPA. 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 4 or from any other measured identified and deemed 

appropriate and effective at the time the selection is made. Level II triggers are more serious 
11 

than Level I triggers and cost effectiveness thresholds could be increased when determinations 

for additional controls are made. 

The contingency measures listed in Table 4 are expected 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 takes place. These 

additional federal actions, while not actual contingency measures, 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 control measures are necessary. The future 

federal measures that may be evaluated in the event of a future trigger include future federal onroad vehicle standards, future federal nonroad engine standards, future federal MACT 

requirements, and future federal NSPS and NESHAP requirements. Furthermore, the Air 

Program remains committed to addressing future CO NAAQS revisions through state 

implementation plans. These plans could include other control techniques not included in 

Table 4. These and any other newly identified potential control measures may also be 

considered in the analysis following a future Level I or II triggering event. 

The Air Program commits to compiling annual CO emissions inventories for the St. Louis 

nonclassifiable CO maintenance area every three years for the duration of this limited 

maintenance plan to facilitate the emissions trends analysis included in the contingency plan 

under Levels I and II. 

Adoption of additional control measures is subject 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. 

Table 3 Contingency Plan for the St. Louis Nonclassifiable CO Maintenance Area 

Contingency Measure 

Trigger Action to be Taken 

Level I Trigger 

A single exceedance of the 

8-hour CO NAAQS at any 

monitor located in the St. 

Louis nonclassifiable CO 

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 necessary, control measures shall be 

adopted and implemented as expeditiously as practicable, taking into 

consideration the ease of implementation and the technical and 

economic feasibility of the selected measures. This action will be 

taken no later than 24 months after the Air Program has determined 

that a Level I trigger has occurred through quality assured 

monitoring data that has been uploaded into EPA’s Air Quality 

System (AQS). 
12 

Level II Trigger 

A monitored violation of 

the NAAQS at any CO 

monitoring station in the 

St. Louis nonclassifiable 

CO 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 months of a Level II trigger as identified 

through quality assured monitoring data that has been uploaded into 

EPA’s Air Quality System (AQS). Once the analysis is complete, 

the selected measures shall be implemented as expeditiously as 

practicable, taking into consideration the ease of implementation and 

the technical and economic feasibility of the selected measures. The 

completion of the analysis and the implementation of the selected 

measures will occur no later than 24 months after the date of the 

Level II trigger. 

Table 4 Potential Contingency Measures for the St. Louis Nonclassifiable CO Maintenance Area 

Contingency Measure 

Method List of Potential Contingency Measures to be Considered 

Implement controls for 

local individual sources 

with significant effects on 

the monitored violation 

 Identify local sources with significant CO emissions and develop 

controls through consent agreements or rules 

Revise rules that control 

CO emissions 

 Lower the applicability thresholds in existing rules that control CO 

emissions 

 Lower the CO limits in existing rules 

 Broaden the geographical area of existing rules that limit CO 

emissions 

 Include new source categories under the applicability of existing 

rules that limit CO emissions 

 Implement New Source Review Permitting Conditions for new 

and modified major sources of CO 

New rules that control CO 

emissions 

 Enhanced Heavy-Duty Diesel Anti-Idling Program (i.e. mandated 

rest periods and locomotives) 

 Implement mandatory wood-burning restrictions 

5. TRANSPORTATION AND GENERAL CONFORMITY 

As required by Section 176 of the CAA, the Air Program has developed transportation/air quality 

conformity procedures (10 CSR 10-5.480) and general conformity procedures (10 CSR 10-

6.300) that are consistent with federal conformity regulations. Under these rules, one means of 

demonstrating conformity of federal actions is to indicate that expected emissions from planned 

actions are consistent with the emissions budget for the area. 
13 

Under the Limited Maintenance Plan approach, emissions budgets may be treated as essentially 

not constraining for the length of the maintenance period because it is “unreasonable to expect 

that such an area will experience so much growth in that period that a violation of the CO 

NAAQS would result” (see Limited Maintenance Plan guidance section 3.e). In other words, 

EPA would be concluding that emissions need not be capped for the maintenance period. 

Therefore, in areas with approved limited maintenance plans, federal actions requiring 

conformity determinations under both the transportation conformity rule and the general 

conformity rule are considered to satisfy the "budget test". 

According to the EPA's Limited Maintenance Plan guidance, and SIP and conformity 

requirements, a regional emissions analysis will not need to be performed for conformity 

determinations for the respective long range transportation plan or transportation improvement 

program. While the St. Louis area is not subject to the budget test, the area remains subject to 

other transportation and general conformity requirements. 

6. PUBLIC PARTICIPATION 

In accordance with Section 110(a)(2) of the CAA, the Air program is required to hold a public 

hearing prior to adoption of this maintenance plan and the subsequent submittal to the EPA. The 

Air Program will notify the public and other interested parties of an upcoming public hearing and 

comment period 30 days prior to holding such hearing for this plan as follows: 

 Notice of availability of the plan was posted on the Department of Natural Resources’ Air 

Pollution Control Program website on December 30, 2013: 

http://www.dnr.mo.gov/env/apcp/stateplanrevisions.htm 

 A public comment period opened when the plan was posted on Department of Natural 

Resources’ Air Pollution Control Program’s website on December 30, 2013, and closed 

on February 6, 2014, seven days after the public hearing. 

 The public hearing date on this plan is to be held on January 30, 2014, beginning at 9:00 

a.m. at the Bennett Springs Conference Room, 1730 E. Elm St., Jefferson City, MO 

65101. 

7. CONCLUSION 

The Missouri Department of Natural Resources’ Air Pollution Control Program has prepared this 

plan to meet the requirements of Section 175A of the CAA. This plan provides for the continued 

attainment of the 8-hour CO NAAQS for a period of ten years after expiration of the previous 

ten-year period. All controls in this plan will remain in place after the end of this second ten-year 

period. Any further changes will be addressed through the requirements of Section 110(l) of the 

CAA. 
14 

This plan contains all the required elements for the Limited Maintenance Plan option for CO: a 

description of and commitment to a sustained monitoring network, a maintenance demonstration, 

an attainment emission inventory, a contingency plan in case of a violation, and a conformity 

determination. 

The department is committed to operating a network of air quality monitors sufficient to verify 

that the CO NAAQS will be maintained throughout the second ten-year maintenance period, in 

accordance with all EPA monitoring requirements. This plan includes a demonstration that the 

St. Louis area is currently maintaining the CO NAAQS. The design value for the most recent 

two-year period, 2011-2012, is 1.8 ppm. The Air Program has prepared a comprehensive CO 

emissions inventory, in tons CO per average winter day, for the emission base year 2008. This 

plan includes contingency measures in the event a future violation occurs. In accordance with 

the Limited Maintenance Plan guidance, this plan considers federal actions are not constraining 

and satisfy both the transportation and general conformity budget tests. 

This limited maintenance plan has been prepared in accordance with the requirements of the 

CAA and in conjunction with the guidance provided by EPA documents and staff. 
The Missouri Air Conservation Commission ADOPTS the following action 

on this 27th day ofMarch, 2014: 

Missouri State Implementation Plan Revision - Limited Maintenance Plan 

for the St. Louis Nonclassifiable Maintenance Area for the 8-hour Carbon 

Monoxide National Ambient Air Quality Standard 

L e -- -,Chairman 

V 

________________, Vice Chairman 

cW~----",,--- " ___ I;jJj~'JjI1/li_, Member 

, Member 


__________________,Member 

__________________,Member 

__________________,Member 
1

Bechtel, Cheri

From: Missouri DNR <MODNR@public.govdelivery.com>

Sent: Tuesday, December 24, 2013 8:33 AM

To: Bungart, Renee; Archer, Larry; Beydler, Van; Lovejoy, Victoria; Moore, Kyra; Vit, Wendy; 

Bechtel, Cheri; Crawford, Betsy

Subject: Courtesy Copy: Missouri DNR Air Public Notices Update - Missouri Air Conservation 

Commission Public Hearing, Jan. 30, 2014

This is a courtesy copy of an email bulletin sent by Cheri Bechtel.

This bulletin was sent to the following groups of people:

Subscribers of Air Public Notices (535 recipients) 

Having trouble viewing this email? View it as a Web page.

MISSOURI AIR CONSERVATION COMMISSION 

WILL HOLD PUBLIC HEARING 

JEFFERSON CITY, MO -- The Missouri Air Conservation Commission will hold a public hearing on 

Thursday, January 30, 2014 beginning at 9 a.m. at the Elm Street Conference Center, 1730 East Elm Street, 

Lower Level, Bennett Springs Conference Room, Jefferson City, Missouri. The commission will hear 

testimony related to the following proposed action(s): 

* 10 CSR 10-6.200 (amendment) Hospital, Medical, Infectious Waste Incinerators 

 

This proposed amendment will remove language from the compliance and performance testing 

provisions that provide an exemption to the emission limits for hospital, medical, and infectious waste 

incinerators (HMIWI) during start-up, shutdown, or malfunction conditions. In addition, the hierarchy 

of definitions will clearly state that the applicable definitions in the Code of Federal Regulations take 

precedence over those in 10 CSR 10-6.020 Definitions and Common Reference Tables. At the same 

time, EPA test method references in the state rule will be revised to match how these methods are 

referred to in the federal HMIWI regulations. 

 

The above rule action will not be submitted for inclusion in the Missouri State Implementation Plan 

but will be submitted for inclusion in the plan established under Clean Air Act Section 111(d) 

covering existing sources of noncriteria pollutants. 

 

* 10 CSR 10-5.240 (rescission) Additional Air Quality Control Measures May be Required When 

Sources Are Clustered in a Small Land Area 

 
2

This proposed rescission will remove an outdated rule originally written in 1967, prior to the federal 

Clean Air Act. This rule was intended to provide the Missouri Air Conservation Commission 

authority to regulate particulate matter and sulfur dioxide emissions from concentrated sources in the 

St. Louis area. Given that section 643.050, RSMo provides the commission authority to promulgate 

regulations necessary to enforce the provisions of the Clean Air Act, this rule is no longer necessary. 

 

The above rule action will be submitted to the U.S. Environmental Protection Agency for removal 

from the Missouri State Implementation Plan. 

 

* 10 CSR 10-6.010 (amendment) Ambient Air Quality Standards 

 

This proposed amendment will update the standards for ambient air quality throughout Missouri in 

order to reflect recent changes in the National Ambient Air Quality Standards (NAAQS) for fine 

particulate matter (PM2.5), nitrogen dioxide (NO2), and sulfur dioxide (SO2); reorganize the standards 

table for clarity; and update the rule purpose statement to more accurately reflect the rule. The Clean 

Air Act requires periodic reviews of the air quality criteria, the science upon which the standards are 

based, and the NAAQS themselves. As a result of federal review, the U.S. Environmental Protection 

Agency has recently updated the PM2.5, NO2, and SO2 NAAQS, and this rulemaking would revise 

these values in the state rule for consistency. 

 

* Missouri State Implementation Plan Revision – Supplement/Revision to the Redesignation 

Demonstration 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 

 

In August 2011, the Missouri Air Conservation Commission adopted the Redesignation 

Demonstration 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. This plan was 

then submitted to the U.S. Environmental Protection Agency on August 26, 2011 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 corrections to the emissions inventories included in the plan, 

includes emissions inventories and a discussion on controls for the Illinois portion of the 

nonattainment area, and changes the future year of the plan from 2022 to 2025. This technical 

supplement also establishes motor vehicle emissions budgets to be used in regional transportation 

conformity determinations for the base year (2008) and the future year (2025) of the plan. 

 

* Missouri State Implementation Plan Revision – Americold Logistics, LLC 24-Hour Particulate Matter 

(PM10) National Ambient Air Quality Standard (NAAQS) Consent Judgment 

 

As required by Section 110(a) of the Clean Air Act, Missouri’s State Implementation Plan (SIP) must 

ensure attainment and maintenance of all National Ambient Air Quality Standards (NAAQS). The 

Missouri Department of Natural Resources’ Air Pollution Control Program is proposing to amend and 

strengthen the 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 are scheduled for installation 

and operation by March 31, 2014. 

 

* Missouri State Implementation Plan Revision – Limited Maintenance Plan For The St. Louis 

Nonclassifiable Maintenance Area For The 8-Hour Carbon Monoxide National Ambient Air Quality 

Standard (NAAQS) 
3

 

The initial maintenance plan for the St. Louis 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 after 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 subsequent violation of the CO NAAQS, additional control 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 seven years and an updated emission inventory 

for average winter day CO emissions in the St. Louis area. 

 

If the Commission adopts these action(s), it will be the Department’s intention to submit the action(s) to the 

U.S. Environmental Protection Agency to be included in Missouri’s State Implementation Plan unless 

otherwise noted above. 

 

Documents for the above item(s) will be available for review at the Missouri Department of Natural 

Resources, Air Pollution Control Program, 1659 Elm Street, Jefferson City, 

(573) 751-4817 and in the Public Notices section of the program web site http://dnr.mo.gov/env/apcp/publicnotices.htm. This information will be available at least 30 days prior to the public hearing date. 

The Department will accept written or email comments for the record until 5 p.m. on February 6, 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 hearing testimony will be equally considered. 

 

Citizens wishing to speak at the public hearing should notify the secretary to the Missouri Air Conservation 

Commission, Missouri Department of Natural Resources, 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 presentations also provide a written 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 directly at (573) 751-4817, the Division 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 Commission Secretary, P.O. Box 176, Jefferson City, MO 65102. 

Hearing impaired persons may contact the program through Relay Missouri, (800) 735-2966. 

You are subscribed to the Air Public Notices topic for Missouri DNR. This information has recently been 

updated, and is now available at the link below. Thank you for your interest in the Air Public Notices. 

http://dnr.mo.gov/env/apcp/stateplanrevisions.htm

 

Update your subscriptions, modify your password or email address, or stop subscriptions at any time on your 

Subscriber Preferences Page. You will need to use your email address to log in. If you have questions or 

problems with the subscription service, please contact subscriberhelp.govdelivery.com. 
4

This service is provided to you at no charge by Missouri DNR. 
Jay Nixon, Governor 

Sara Parker Pauley, Director

Air Pollution Control Program

State Plan Actions                                                                    

On Public Notice | Proposed for Adoption

On Public Notice 

Supplement/Revision to the Redesignation Demonstration 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

Based on monitoring data from 2007-2009, the 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 Conservation 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 corrections to the emissions inventories included in 

the plan, includes emissions inventories and a discussion on controls for the Illinois portion 

of the nonattainment area, and changes the future year of the plan from 2022 to 2025.

This technical supplement also establishes motor vehicle emissions budgets to be used in 

regional transportation conformity determinations 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 provisions of the Clean Air Act, section 107;

•

Concurrently, EPA approve the associated maintenance plan as a revision to the State 

Implementation Plan (SIP) meeting the requirements of the Clean Air Act, section 

175A;

•

That EPA approve the 2008 base year inventory as meeting the requirements under 

Clean Air Action section 172(c)(3); and

•

Approve the Motor Vehicle Emissions Budgets (MVEBs) for the years 2008 and 2025 

pursuant to Clean Air Act Section 176(c).

•

State Plan Actions on Public Notice - DNR Page 1 of 3

http://www.dnr.mo.gov/env/apcp/stateplanrevisions.htm 12/24/2013
Proposed Supplement/Revision to the Redesignation Demonstration 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

Submit Comments

A public hearing is scheduled for this plan action on January 30, 2014. Comments about 

this plan action will be accepted through the close of business on February 6, 2014.

Missouri State Implementation Plan Revision - Limited Maintenance 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. Louis 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 after 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 subsequent violation of 

the CO NAAQS, additional control 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 seven years and an updated emission inventory for 

average winter day CO emissions in the St. Louis area.   

Proposed Revision to Limited Maintenance Plan for the St. Louis Nonclassifiable 

Maintenance Area for the 8-Hour Carbon Monoxide National Ambient Air Quality Standard

Appendices A and B

Submit Comments

A public hearing for this plan action will be held on Jan. 30, 2014. Comments about this 

plan action will be accepted through the close of business on Feb. 6, 2014. 

Missouri State Implementation Plan Revision - Americold Logistics, LLC 24-Hour Particulate Matter (PM10) 

National Ambient Air Quality Standard (NAAQS) Consent Judgment

As required by Section 110(a) of the Clean Air Act, Missouri’s State Implementation Plan 

(SIP) must ensure attainment and maintenance of all National Ambient Air Quality 

Standards (NAAQS).   The Missouri Department of Natural Resources’ Air Pollution Control 

Program is proposing to amend and strengthen the 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 are scheduled for installation and operation by 

March 31, 2014. 

State Plan Actions on Public Notice - DNR Page 2 of 3

http://www.dnr.mo.gov/env/apcp/stateplanrevisions.htm 12/24/2013
Proposed CCL PM10 SIP Revision 

Attachment 2 – Proposed CCL Consent Judgment 

Exempt Equipment List

Submit Comments

A public hearing for this plan action will be held on Jan. 30, 2014. Comments about this 

plan action will be accepted through the close of business on Feb. 6, 2014. 

Proposed for Adoption

None at this time. 

Back to top

State Plan Actions on Public Notice - DNR Page 3 of 3

http://www.dnr.mo.gov/env/apcp/stateplanrevisions.htm 12/24/2013
 HEARING 1/30/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334

MIDWEST LITIGATION SERVICES

Page 1

1

MISSOURI DEPARTMENT OF NATURAL RESOURCES'

2 AIR CONSERVATION COMMISSION MEETING

3 PUBLIC HEARING

 THURSDAY, JANUARY 30, 2013

4

5

 REPORTED BY SUSAN M. FIALA

6 CERTIFIED COURT REPORTER

 REGISTERED PROFESSIONAL REPORTER

7

8

9

10

11

12

13

14

15

16

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18

19

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21

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25
 HEARING 1/30/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334

MIDWEST LITIGATION SERVICES

Page 3

1 PROCEEDINGS

2 CHAIRMAN PENDERGRASS: The hearing will

3 come to order. Let the record show the

4 following Commissioners are present: Jack

5 Baker, Mark Garnett, Gary Pendergrass, and David

6 Zimmerman.

7 The Air Conservation Commission of the

8 State Of Missouri has called this public hearing

9 pursuant to Section 643.070, Revised Statutes of

10 Missouri; EPA promulgated rule 40 CFR 51.102,

11 for the purpose of hearing testimony related to:

12 Missouri State Implementation Plan

13 Revision - Supplement/Revision to the

14 Redesignation Demonstration and Maintenance Plan

15 for the Missouri Portion of the St. Louis

16 Nonattainment Area for the 1997 Annual Fine

17 Particulate Matter National Ambient Air Quality

18 Standard.

19 Missouri State Implementation Plan

20 Revision - Americold Logistics, LLC Particulate

21 Matter (PM10) Consent Judgment.

22 Missouri State Implementation Plan

23 Revision - Limited Maintenance Plan for the St.

24 Louis Nonclassifiable Maintenance Area for the

25 8-hour Carbon Monoxide National Ambient Air
 HEARING 1/30/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334

MIDWEST LITIGATION SERVICES

Page 4

1 Quality Standard.

2 10 CSR 10-6.200 (amendment) Hospital,

3 Medical, Infectious Waste Incinerators.

4 10 CSR 10-5.240 (rescission) Additional

5 Air Quality Control Measures May be Required

6 When Sources are Clustered in a Small Land Area.

7 10 CSR 10-6.010 (amendment) Ambient Air

8 Quality Standards.

9 The hearing record will close at 5:00

10 p.m. on February 6, 2014.

11 Anyone who has not been scheduled to

12 appear, but who wishes to be heard, should

13 indicate that you wish to speak on the sign-in

14 sheets available at the door or by letting the

15 commission know by telephone after the public

16 hearing has been presented.

17 Section 643.100 of the Missouri

18 Statutes provides that all oral testimony be

19 given under oath. Accordingly, when you are

20 called to testify, please present yourself to

21 the court reporter first to be sworn in.

22 When you testify, please state your

23 name, business address and your occupation or

24 affiliation. If you have a prepared statement,

25 it will be helpful if you would provide a copy
 HEARING 1/30/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334

MIDWEST LITIGATION SERVICES

Page 16

1 MS. WILBUR: Good morning, Chairman,

2 members of the Commission. My name is Emily

3 Wilbur. I am employed with the Air Pollution

4 Control Program as the State Implementation Plan

5 (SIP) Unit Chief. I work at 1659 East Elm

6 Street, Jefferson City, Missouri. I am here

7 today to present testimony on a Limited

8 Maintenance Plan for the St. Louis

9 Nonclassifiable Maintenance Area for the 8-Hour

10 Carbon Monoxide National Ambient Air Quality

11 Standard, or NAAQS. An executive summary of the

12 plan can be found on Page 117 of your briefing

13 document.

14 This plan is the second of two ten-year

15 maintenance plans required by the federal Clean

16 Air Act. This plan demonstrates that the St.

17 Louis area has continued to maintain compliance

18 with the 8-hour CO NAAQS of 9 parts per million,

19 which was initially set in April 1971.

20 The St. Louis area, which includes the

21 City of St. Louis and the portion of St. Louis

22 County encompassed by Interstate 270 and the

23 Mississippi River, was originally designated

24 nonattainment in 1978, with a design value of 14

25 parts per million. Since then, carbon monoxide
RECOMMENDATION FOR ADOPTION 

PROPOSED REVISION TO 

MISSOURI STATE IMPLEMENTATION PLAN – 

Proposed Revision to the Limited Maintenance Plan for the St. Louis Nonclassifiable 

Maintenance Area for the 8-Hour Carbon Monoxide National Ambient Air Quality 

Standard 

On January 30, 2014, the Missouri Air Conservation Commission held a public hearing 

concerning a revision to the Missouri State Implementation Plan (SIP) for the Proposed Revision 

to the Limited Maintenance Plan for the St. Louis Nonclassifiable Maintenance Area for the 8-

Hour Carbon Monoxide National Ambient Air Quality Standard (CO NAAQS). This second 

maintenance plan provides for continued attainment of the 8-hour CO NAAQS for the St. Louis 

area from 2008 through 2018, pursuant to Section 175A(b) of the federal Clean Air Act. 

No comments were received during the public comment period. 

The proposed plan has not been reprinted in the briefing document due to its volume. The entire 

proposed plan is available for review at the Missouri Department of Natural Resources’ Air 

Pollution Control Program, 1659 East Elm Street, 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 proposed. If the commission 

adopts this plan, it will be the department’s intention to submit this plan to the U.S. 

Environmental Protection Agency for inclusion in the Missouri State Implementation Plan. 

 
COMMENTS AND RESPONSES ON 

PROPOSED REVISION TO 

MISSOURI STATE IMPLEMENTATION PLAN – 

Proposed Revision to the Limited Maintenance Plan for the St. Louis Nonclassifiable 

Maintenance Area for the 8-Hour Carbon Monoxide National Ambient Air Quality 

Standard 

The public comment period for the proposed revision to the Missouri State Implementation Plan 

(SIP) for the Limited Maintenance Plan for the St. Louis Nonclassifiable Maintenance Area for 

the 8-Hour Carbon Monoxide National Ambient Air Quality Standard opened on December 30, 

2013 and closed on February 6, 2014. No revisions to the proposed plan were made as a result 

of comments. 

The following is a summary of comments received and the Missouri Department of Natural 

Resources’ Air Pollution Control Program’s (Air Program’s) corresponding responses. 

SUMMARY OF COMMENTS: During the public comment period for the proposed plan, the 

Air Program received no comments.