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STATE Of' MISSOURI Jeremiah \'II Oay) Nixon, Governor. Sara Parker Pauley, Director 

QEPARTMENT OF NATURAL RESOURCES 


vlww.d nr.mo .gov 

DEC - 8 2011 

Mr. Karl Brooks 

Regional Administrator 

U.S. EPA, Region VII 

901 North Fifth Street 

Kansas City, KS 66101 

Dear Mr. Brooks: 

Enclosed please find the state of Missouri's revised boundary recommendations for the 2008 

Ozone National Ambient Air Quality Standard. This submittal is in response to the 

U.S. Environmental Protection Agency (EPA) memo dated September 22, 2011, from 

Gina McCarthy, Assistant Administrator regarding the ability for states to revise previously 

submitted boundary recommendations in light of more recent quality-assured monitoring 

data from 2008-2010. 

In light of the most recent quality- assured monitoring data from 2008-2010, the state of 

Missouri is recommending the following boundary designations: 

• 	 Nonattainment - St. Louis City and St. Charles, St. Louis, Franklin and Jefferson 

counties; 

• 	 Attainment - Lincoln, Ste. Genevieve, Perry, Greene, Cass, Clay and Clinton 


counties; and 


• 	 Attainmentlunclassifiable - all other counties in the state of Missouri. 

This revised area boundary recommendation replaces the previous recommendation 

submitted on March 11 , 2009. For convenience, we are also enclosing an electronic copy of 

the technical support documentation that was submitted along with our original 

recommendation. Aside from the monitoring data and the county-by-county map of our 

recommendation which we are now updating, the technical analysis is still valid and 

supportive of our current recommendation. 

Enclosed with this letter is a table listing all 114 counties in Missouri and the City of 

St. Louis along with their conesponding recommended designations. The Missouri Air 

Conservation Commission adopted this revised recommendation at the December 8, 2011 , 

commission meeting after considering the comments received during the public hearing and 

comment process. 

o Rt:('yd l-dPapl'r 
Mr. Karl Brooks 

Page Two 

Thank you for the opportunity to revisit these recommendations due to the length of time that 

has elapsed since their initial submittal. If you have any questions, please contact 

Kyra Moore at (573) 751-7840. 

Sincerely, 

DEPARTMENT OF NATURAL RESOURCES 

c!'l~lJ~~ ~i2 Sara Parker Pauley 

Director 

SPP:wvd 

Enclosures 

Missouri Revised 2008 Ozone Area Designation Recommendation 

September 2011 

County Recommended 

Classification 

ADAIR Attainment/unclassifiable 

ANDREW Attainment/unclassifiable 

ATCHISON Attainment/unclassifiable 

AUDRAIN Attainment/unclassifiable 

BARRY Attainment/unclassifiable 

BARTON Attainment/unclassifiable 

BATES Attainment/unclassifiable 

BENTON Attainment/unclassifiable 

BOLLINGER Attainment/unclassifiable 

BOONE Attainment/unclassifiable 

BUCHANAN Attainment/unclassifiable 

BUTLER Attainment/unclassifiable 

CALDWELL Attainment/unclassifiable 

CALLAWAY Attainment/unclassifiable 

CAMDEN Attainment/unclassifiable 

CAPE GIRARDEAU Attainment/unclassifiable 

CARROLL Attainment/unclassifiable 

CARTER Attainment/unclassifiable 

CASS Attainment 

CEDAR Attainment 

CHARITON Attainment/unclassifiable 

CHRISTIAN Attainment/unclassifiable 

CLARK Attainment/unclassifiable 

CLAY Attainment 

CLINTON Attainment 

COLE Attainment/unclassifiable 

COOPER Attainment/unclassifiable 

CRAWFORD Attainment/unclassifiable 

DADE Attainment/unclassifiable 

DALLAS Attainment/unclassifiable 

DAVIESS Attainment/unclassifiable 

DeKALB Attainment/unclassifiable 

DENT Attainment/unclassifiable 

DOUGLAS Attainment/unclassifiable 

DUNKLIN Attainment/unclassifiable 

FRANKLIN Nonattainment 

GASCONADE Attainment/unclassifiable 

GENTRY Attainment/unclassifiable 

GREENE Attainment 
GRUNDY Attainment/unclassifiable 

HARRISON Attainment/unclassifiable 

HENRY Attainment/unclassifiable 

HICKORY Attainment/unclassifiable 

HOLT Attainment/unclassifiable 

HOWARD Attainment/unclassifiable 

HOWELL Attainment/unclassifiable 

IRON Attainment/unclassifiable 

JACKSON Attainment/unclassifiable 

JASPER Attainment/unclassifiable 

JEFFERSON Nonattainment 

JOHNSON Attainment/unclassifiable 

KNOX Attainment/unclassifiable 

LACLEDE Attainment/unclassifiable 

LAFAYETTE Attainment/unclassifiable 

LAWRENCE Attainment/unclassifiable 

LEWIS Attainment/unclassifiable 

LINCOLN Attainment 

LINN Attainment/unclassifiable 

LIVINGSTON Attainment/unclassifiable 

McDONALD Attainment/unclassifiable 

MACON Attainment/unclassifiable 

MADISON Attainment/unclassifiable 

MARIES Attainment/unclassifiable 

MARION Attainment/unclassifiable 

MERCER Attainment/unclassifiable 

MILLER Attainment/unclassifiable 

MISSISSIPPI Attainment/unclassifiable 

MONITEAU Attainment/unclassifiable 

MONROE Attainment 

MONTGOMERY Attainment/unclassifiable 

MORGAN Attainment/unclassifiable 

NEW MADRID Attainment/unclassifiable 

NEWTON Attainment/unclassifiable 

NODAWAY Attainment/unclassifiable 

OREGON Attainment/unclassifiable 

OSAGE Attainment/unclassifiable 

OZARK Attainment/unclassifiable 

PEMISCOT Attainment/unclassifiable 

PERRY Attainment 

PETTIS Attainment/unclassifiable 

PHELPS Attainment/unclassifiable 

PIKE Attainment/unclassifiable 

PLATTE Attainment 

POLK Attainment/unclassifiable 
PULASKI Attainment/unclassifiable 

PUTNAM Attainment/unclassifiable 

RALLS Attainment/unclassifiable 

RANDOLPH Attainment/unclassifiable 

RAY Attainment/unclassifiable 

REYNOLDS Attainment/unclassifiable 

RIPLEY Attainment/unclassifiable 

ST. CHARLES Nonattainment 

ST. CLAIR Attainment/unclassifiable 

ST. FRANCOIS Attainment/unclassifiable 

STE. GENEVIEVE Attainment 

ST. LOUIS Nonattainment 

SALINE Attainment/unclassifiable 

SCHUYLER Attainment/unclassifiable 

SCOTLAND Attainment/unclassifiable 

SCOTT Attainment/unclassifiable 

SHANNON Attainment/unclassifiable 

SHELBY Attainment/unclassifiable 

STODDARD Attainment/unclassifiable 

STONE Attainment/unclassifiable 

SULLIVAN Attainment/unclassifiable 

TANEY Attainment/unclassifiable 

TEXAS Attainment/unclassifiable 

VERNON Attainment/unclassifiable 

WARREN Attainment/unclassifiable 

WASHINGTON Attainment/unclassifiable 

WAYNE Attainment/unclassifiable 

WEBSTER Attainment/unclassifiable 

WORTH Attainment/unclassifiable 

WRIGHT Attainment/unclassifiable 

ST. LOUIS CITY Nonattainment 
 2008-2010 Statewide Validated Ozone Design Values 

Site County 

4th High 8-hr Average 

(ppb) Design Value 

St. Louis 2008 2009 2010 08-10 

Arnold West Jefferson 70 70 77 72 

Blair Street St. Louis City 73 65 71 69 

Maryland Heights St. Louis 69 70 76 71 

Orchard Farm St. Charles 72 73 77 74 

Pacific St. Louis 64 64 69 65 

West Alton St. Charles 76 71 84 77 

 

St. Genevieve 

Bonne Terre St. Genevieve 71 69 72 70 

 

South East 

Farrar Perry 70 71 77 72 

Kansas City 

Liberty Clay 70 72 70 70 

RG South Cass 66 64 67 65 

Rocky Creek Clay 69 72 76 72 

Trimble Clinton 70 75 76 73 

Watkins Mill Clay 69 74 73 72 

 

Springfield 

Fellows Lake Greene 69 66 69 68 

Hillcrest H.S. Greene 67 62 66 65 

 

Outstate 

El Dorado Springs Cedar 67 62 68 65 

Mark Twain Monroe 64 61 70 65 

Foley Lincoln 72 67 79 72 

Red = Violation of the 2008 NAAQS 
Pursuant to 643 .055 RSMo, the Missouri Air Conservation Commission has 

determined that this action is needed to have a U.S . Environmental Protection 

Agency approved State Implementation Plan. 

The Revised 2008 8-Hour Ozone Standard Boundary Recommendation is hereby 

adopted by the Missouri Air Conservation Commission this 8th day of December, 

2011 . 

~~~~~_'Chairman 

6}k&L~r~ , Vice Chairman 

-----,,.,-LJ __~---'--->\..._=+)-~-c;..-.-:: ------_-_-___, Member 

__________________________________,Member 

__________________________________,Member 
COMMENTS AND RESPONSES 

AND 

RECOMMENDATION FOR ADOPTION 

PROPOSED REVISION TO

THE 2008 8-HOUR OZONE NATIONAL AMBIENT AIR QUALITY STANDARD 

BOUNDARY DESIGNATION RECOMMENDATION 

On Sept. 22, 2011, the U.S. Environmental Protection Agency released a memorandum to clarify 

for states the status of the 2008 Ozone National Ambient Air Quality Standard. In this document, 

EPA explicitly stated that the current standard is 0.075 parts per million, or 75 parts per billion. 

EPA also announced their intentions to move forward with designations under the 2008 National 

Ambient Air Quality Standard, starting with the recommendations made by states in 2009, and 

then updating them with the most current, certified air quality data from the 2008 – 2010 

monitoring period. 

Based on the 2008-2010 monitoring period, Missouri is submitting a revised area boundary 

recommendation as an amendment to the original boundary recommendation and technical 

support document submitted to EPA in March 2009. This revision will recommend the 

following: 

 Nonattainment – St. Louis City and St. Charles, St. Louis, Franklin and Jefferson counties. 

 Attainment – Lincoln, Ste. Genevieve, Perry, Greene, Cass, Clay and Clinton counties. 

 Attainment/unclassifiable – all other counties in the state of Missouri. 

The following pages are included in the briefing document for reference: 

- Statewide county by county map of the revised boundary designation recommendation 

- County by county list of recommended area designation 

- 2008-2010 quality assured air quality monitoring data values 

The Missouri Department of Natural Resources’ Air Pollution Control Program recommends the 

commission adopt the boundary recommendation as proposed. If the commission adopts this 

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

Environmental Protection Agency. 

SUMMARY OF COMMENTS: The Missouri Department of Natural Resources received three 

(3) comments from three (3) different sources: The Empire District Electric Company (Empire 

District), the Environmental Task Force of Jasper and Newton Counties (Environmental Task 

Force) and the Southeast Missouri Regional Planning Commission Board of Directors (SEMO 

Board). 

COMMENT: Empire District, Environmental Task Force and the SEMO Board all expressed 

their support of the revised 2008 ozone boundaries as proposed. The SEMO Board formally 

adopted a Resolution of Support for the revised recommendations. Empire District and 

Environmental Task Force also commended MDNR for their support and encouragement of the 

development of clean air alliances across the state. 
RESPONSE: Support for the revised recommendations as well as the time and effort staff has 

invested in outreach to affected areas of the state are greatly appreciated. No changes were made 

to the recommendations as a result of these comments.