Mr. Karl Brooks 

Page Two 

Department ofNatural Resources' Air Pollution Control Program, P.O. Box 176, Jefferson 

City, Missouri 65102, or by telephone at (573) 751-4817. 

Sincerely, 

AIR POL UTION CONTROL PROGRAM 

KLM:akc 

Enclosures: 

Copy of Missouri's Regional Haze 5-Year Progress Report with Appendices 

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 

c: 	 Missouri Air Conservation Commission 

Proj ect #1999-RH -7 

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


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

State of Missouri Regional Haze Plan 

5-Year Progress Report 

 

A Missouri State Implementation Plan Revision 

Prepared for the 

Missouri Air Conservation Commission

Adopted: 

August 28, 2014 

Division of Environmental Quality 

Air Pollution Control Program 

P.O. Box 176 

1659 East Elm Street 

Jefferson City, Missouri 65101 

Telephone (573) 751-4817 

Project # 1999-RH-7 Progress Report 

 
 
i 

Table of Contents

EXECUTIVE SUMMARY ...................................................................................................................... 1

I. REGIONAL HAZE FIVE-YEAR PROGRESS REPORT REVIEW REQUIREMENTS ........... 3

A. INTRODUCTION .................................................................................................................................. 3

B. BACKGROUND SUMMARY .................................................................................................................. 3

C. PURPOSE ............................................................................................................................................ 4

II. PROGRESS REPORT ELEMENTS ................................................................................................. 6

A. STATUS OF CONTROL STRATEGIES IN THE REGIONAL HAZE SIP .................................................... 6

A.1. Control Measures included in the 2009 RH plan .................................................................... 6

A.1.1. Clean Air Interstate Rule (CAIR) ...................................................................................... 6

A.1.2. Best Available Retrofit Technology (BART) ..................................................................... 7

A.1.3. Tier 2 ..................................................................................................................................... 7

A.1.4. Tier 4 ..................................................................................................................................... 8

A.1.5. NOX SIP Call ........................................................................................................................ 8

A.2. Additional Measures not included in the 2009 RH plan ....................................................... 10

A.2.1. 2010 SO2 NAAQS Attainment Demonstrations .............................................................. 10

A.2.2. Illinois Multi-Pollutant Regulation................................................................................... 10

A.2.3. Tier 3 ................................................................................................................................... 10

A.2.4. 2007 Heavy-Duty Highway Rule (40 CFR Part 86, Subpart P) ..................................... 11

A.3. Facilities with Expected Emission Changes to Occur between 2012-2017 .......................... 11

B. EMISSIONS REDUCTIONS FROM REGIONAL HAZE SIP STRATEGIES .............................................. 14

C. VISIBILITY PROGRESS ...................................................................................................................... 16

C.1. Area Specific Information and Analysis ................................................................................ 17

C.1.1 Mingo National Wildlife Refuge ........................................................................................ 17

C.1.2. Hercules Glades National Wilderness Area ..................................................................... 25

C.1.3. El Dorado Springs Protocol Site ....................................................................................... 33

C.2. Visibility Trends in Nearby Out-of-State Class I Areas ....................................................... 36

C.2.1. Upper Buffalo Wilderness Area – Arkansas ................................................................... 36

C.2.2. Caney Creek Wilderness Area – Arkansas...................................................................... 37

D. EMISSIONS PROGRESS ...................................................................................................................... 38

E. ASSESSMENT OF CHANGES IMPEDING VISIBILITY PROGRESS ........................................................ 44

F. ASSESSMENT OF CURRENT STRATEGY ............................................................................................ 44

H. DETERMINATION OF ADEQUACY ..................................................................................................... 46

III. GENERAL PLANNING PROVISIONS ........................................................................................ 47

A. EPA ADMINISTRATIVE PROCESS REQUIREMENTS ......................................................................... 47

B. REPORT SUBMISSION ....................................................................................................................... 47

C. PUBLIC PARTICIPATION ................................................................................................................... 47

D. CONSULTATION AND COMMITMENT TO REVISE PLAN .................................................................. 48
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iii 

LIST OF APPENDICES 

Appendix A: Underlying Data Tables 

Appendix B: Online Public Notice Screenshot with Date Stamp 

Appendix C: Written Comments and Responses and Consultation Correspondence 

Appendix D: MACC Adoption Signature Page 

LIST OF TABLES 

Table 1. Tier 4 emission limits with corresponding implementation years 

Table 2. Facilities with Expected Emission Changes to Occur between 2012-2017 

Table 3. Missouri’s EGU Trends for 2007-2012. As depicted graphically in Figure 2. From 

http://ampd.epa.gov/ampd/ 

Table 4. Established Visibility Conditions for Missouri Class I Areas 

Table 5. Mingo Visibility Conditions Reasonable Progress Summary Table – Worst 20% Days 

Table 6. Mingo Visibility Conditions Reasonable Progress Summary Table – Best 20% Days 

Table 7. Hercules Glades Visibility Conditions Reasonable Progress Summary Table-Worst 20% Days 

Table 8. Hercules Glades Visibility Conditions Reasonable Progress Summary Table-Best 20% Days 

Table 9. Arkansas – Upper Buffalo Visibility Conditions Reasonable Progress Summary Table 

Table 10. Arkansas – Caney Creek Visibility Conditions Reasonable Progress Summary Table 

Table 11. 2011 Missouri Emission Inventory as reported to the NEI 

Table 12. 2008 Missouri Emission Inventory as reported to the NEI 

Table 13. 2005 Missouri Emission Inventory as reported to the NEI 

LIST OF FIGURES 

Figure 1. Map of Missouri’s Class I Federal areas 

Figure 2. Missouri’s EGU Trends for 2007-2012, from EPA’s Clean Air Markets Division (CAMD) 

online database. http://ampd.epa.gov/ampd/

Figure 3. Mingo’s Reasonable Progress Summary Chart –Worst 20% Days 

Figure 4. Mingo’s Reasonable Progress Summary: Deciviews - 5-Year Averages-Worst 20% Days 

Figure 5. Mingo’s Reasonable Progress Summary: Total Light Extinction – 5-Year Averages-Worst 

20% Days 
iv 

Figure 6. Mingo’s Reasonable Progress Summary Chart –Best 20% Days 

Figure 7. Mingo’s Reasonable Progress Summary: Deciviews – 5-Year Averages-Best 20% Days 

Figure 8. Mingo’s Reasonable Progress Summary: Total Light Extinction – 5-Year Averages-Best 20% 

Days 

Figure 9. Mingo’s Annual Monitored Visibility Data with Glidepath to 2018 RPGs 

Figure 10. Mingo – Light Extinction Monitoring Data for Worst 20% Days 

Figure 11. Mingo – Light Extinction Monitoring Data for Best 20% Days 

Figure 12. Mingo – Mass Concentrations Monitoring Data for Worst 20% Days 

Figure 13. Mingo – Mass Concentrations Monitoring Data for Best 20% Days 

Figure 14. Hercules Glades’ Reasonable Progress Summary Chart for Worst 20% Days 

Figure 15. Hercules Glades’ Reasonable Progress Summary: Deciviews 5-Year Averages-Worst 20% 

Days 

Figure 16. Hercules Glades’ Reasonable Progress Summary: Total Light Extinction – 5-Year AveragesWorst 20% Days 

Figure 17. Hercules Glades’ Reasonable Progress Summary Chart for Best 20% Days 

Figure 18. Hercules Glades’ Reasonable Progress Summary: Deciviews 5-Year Averages-Best 20% 

Days 

Figure 19. Hercules Glades’ Reasonable Progress Summary: Total Light Extinction – 5-Year AveragesBest 20% Days 

Figure 20. Hercules Glades’ Annual Monitored Visibility Data with Glidepath to 2018 RPGs 

Figure 21. Hercules Glades – Light Extinction Monitoring Data for Worst 20% Days 

Figure 22. Hercules Glades – Light Extinction Monitoring Data for Best 20% Days 

Figure 23. Hercules Glades – Mass Concentrations Monitoring Data for Worst 20% Days 

Figure 24. Hercules Glades – Mass Concentrations Monitoring Data for Best 20% Days 

Figure 25. El Dorado Springs’ Annual Monitored Visibility Data with Glidepath to 2018 RPGs 

Figure 26. El Dorado Springs – Light Extinction Monitoring Data for Worst 20% Days 

Figure 27. El Dorado Springs – Light Extinction Monitoring Data for Best 20% Days 

Figure 28. El Dorado Springs – Mass Concentrations Monitoring Data for Worst 20% Days 

Figure 29. El Dorado Springs – Mass Concentrations Monitoring Data for Best 20% Days 

Figure 30. Missouri’s Point Source Total Emission Trends for Top Visibility Impairing Pollutants: 

2005, 2008, 2011
1 

EXECUTIVE SUMMARY 

The purpose of this SIP revision is to provide a 5-year report on the progress toward reasonable progress 

goals (RPGs) as required by the federal Regional Haze Rule (RHR) [64 FR 35714, July 1, 1999]. The plan 

addresses the requirements for a 5-year progress report as specified in 40 CFR 51.308(g) and (h). The plan 

includes a review of current regional haze strategies, an emissions reductions summary from those 

strategies, and an assessment of visibility progress. 

The Clean Air Act (CAA) establishes requirements for the protection of visibility in the 156 mandatory 

Federal Class I areas, consisting of national parks and wilderness areas. In 1999, the U.S. 

Environmental Protection Agency (EPA) issued the RHR which addressed regional haze impairment 

from manmade air pollution and established a comprehensive visibility protection program for Class I 

areas. States are required to submit State Implementation Plans (SIPs) to the EPA that demonstrate 

reasonable progress toward meeting the national goal of a return to natural visibility conditions by 2064. 

The rule directs states to graphically show what would be a “uniform rate of progress,” also known as 

the “glide path,” toward natural conditions for each Class I area within the State. The two Federal Class 

I areas within Missouri are Mingo and Hercules Glades. 

On August 5, 2009, the Air Program submitted the initial RH plan to EPA, hereafter referenced as the 

2009 RH plan. The 2009 RH plan included a long-term strategy and examined the possible application 

of Best Available Retrofit Technology (BART) among other reduction measures in order to establish 

RPGs for Mingo and Hercules Glades. The Air Program also submitted a technical supplement to the 

2009 RH plan to EPA on January 30, 2012. On June 26, 2012, EPA finalized limited approval of the 

2009 RH plan [77 FR 38007]. The BART for Electric Generating Units (EGUs) portion of the 2009 RH 

plan based on the Clean Air Interstate Rule (CAIR) and its successor Cross State Air Pollution Rule 

(CSAPR) was addressed in federal rulemaking finalized on June 7, 2012. Together these two EPA 

actions constitute full approval of Missouri’s 2009 RH plan. 

Strategies in the 2009 RH plan focus on the reduction of sulfur dioxide (SO2) emissions and oxides of 

nitrogen (NOX) emissions, which are the largest contributors to visibility impairment at both Hercules 

Glades and Mingo. Major sources of these emissions are EGUs and large industrial boilers. A majority 

of these sources have installed controls because of a number of requirements, including CAIR, CSAPR, 

state programs, and state and federal consent agreements. These mechanisms and additional recent 

regulations imposed on this source sector have reduced SO2 and NOX emissions during the 5-year period 

evaluated for this report. 

The technical analyses contained in this plan demonstrate that both of the Class I areas in Missouri will 

achieve their 2018 RPGs. In the 2009 RH plan, the model-projected visibility conditions at Mingo and 

Hercules Glades were 23.71 dv and 23.06 dv, respectively, for 2018. These conditions were adopted as 

each area’s RPG. Since then, Missouri sources have realized and planned reductions. As a result both 

Class I areas’ visibility conditions are improving. This downward trend in visibility impairment at 

Missouri’s Class I areas can most likely be attributed to the realized and planned reductions in SO2 and 

NOX emissions at EGUs, boilers, and other sources. Consequently, the Air Program has determined that 

current strategies in the 2009 RH plan are sufficient to achieve RPGs for visibility improvement and 

emissions reductions. The Air Program submits to EPA a negative declaration that further revision of 

the 2009 RH plan is not needed at this time. 
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3 

I. Regional Haze Five-Year Progress Report Review Requirements 

A. Introduction 

The Clean Air Act (CAA) establishes requirements for the protection of visibility, especially in Federal 

Class I areas. In 1999, the US Environmental Protection Agency (EPA) finalized the Regional Haze 

Rule (RHR) [64 FR 35714, July 1, 1999]. The rule addressed regional haze impairment from manmade 

air pollution and established a comprehensive visibility protection program for the 156 mandatory Class 

I Federal Areas, consisting of national parks and wilderness areas. Class I areas as defined by the Clean 

Air Act include national parks greater than 6,000 acres, wilderness areas and national memorial parks 

greater than 5,000 acres, and international parks, that existed as of August 1977. 

States are required to develop state implementation plans (SIPs) to submit to the EPA in order to reduce 

the pollution that causes visibility impairment. These plans establish goals and emission reduction 

strategies based on trends from various sources including area source emissions, mobile source 

emissions (both on-road and non-road emissions), biogenic emissions, and wildfire and agriculture 

emissions. These plans were developed with the express intent that by 2064, the visibility in the Class I 

areas will be returned to natural conditions. Five multi-state regional planning organizations (RPOs) 

worked together to develop the technical basis for these SIPs. States used the products of the RPOs to 

establish monitoring strategies for evaluating visibility conditions, baselines and trends, and to develop 

long-term (10 to 15 years) strategies for making “reasonable progress” toward eliminating all manmade 

visibility impairment in mandatory Class I areas. 

B. Background Summary 

On August 5, 2009, the Air Program submitted the initial regional haze plan to EPA, hereafter 

referenced as the 2009 RH plan1. With the help of the Central Regional Air Planning Association 

(CENRAP) RPO, Missouri developed the 2009 RH plan to address visibility impairment in the state’s 

two Class I Federal Areas: Hercules Glades Wilderness Area located in southwest Missouri and Mingo 

National Wildlife Refuge located in southeast Missouri, as shown in Figure 1. The United States 

Department of Agriculture (USDA) Forest Service manages the Hercules Glades Wilderness Area 

(Hercules Glades), as part of the Mark Twain National Forest. The area includes 12,413 acres located in 

the rugged hills of the Missouri Ozarks. The US Fish and Wildlife Service (FWS) manages the Mingo 

National Wildlife Refuge (Mingo), which is situated along the Mississippi Flyway. Only a portion of 

the refuge is a Class I area (7,730 acres out of a total 21,592 acres). In order to measure visibility 

impairment and pollutant concentrations in these protected areas, the IMPROVE (Interagency 

Monitoring of Protected Visual Environments) program was created and implemented an extensive 

long-term monitoring program. An IMPROVE monitor is located in each of Missouri’s Class I areas. A 

third monitor, El Dorado Springs, located in Southwest Missouri, is a Protocol monitoring site that is 

maintained by the department to also measure visibility impairment in Missouri, but it is not located in a 

federal Class I area. It was established to aid in determining impacts to portions of the country where no 

Class I areas exist. This site provides trends and regional information while still following the same 

                                                            

1

 State of Missouri Regional Haze Plan Revision, August 5, 2009 (Available at: 

http://dnr.mo.gov/env/apcp/sips.htm#regionalhaze) 
4 

protocol as IMPROVE sites that are located in Class I areas. All three sites were included in this 

report’s technical analysis to better characterize visibility and concentration trends across the entire 

state. 

Between 2000 and 2007, Missouri participated in the CENRAP workgroup process to develop technical 

analyses and control strategies for the 2009 RH plan. Missouri determined baseline visibility conditions 

for each Class I area using monitoring data collected from 2000 through 2004 and compared them to 

established natural background conditions. The technical analyses showed that both of the Class I areas 

in Missouri will meet their 2018 Reasonable Progress Goals (RPG). The analyses in the 2009 RH plan 

demonstrate that the 2018 visibility goals for Mingo and Hercules Glades will be largely achieved from 

Electric Generating Unit (EGU) emission reductions resulting from the federal Clean Air Interstate Rule 

(CAIR) program. Missouri’s long-term strategy also consists of other air pollution programs including 

the Missouri Oxides of Nitrogen (NOX) State Implementation Plan (SIP) call, Tier 2 vehicle emission 

standards, other states’ SIP controls, Missouri’s and other states’ Best Available Retrofit Technology 

(BART) controls, as well as other programs. 

C. Purpose 

In its final RHR, published as final July 1, 1999, (64 FR 35714), the EPA included two main 

requirements for comprehensive periodic plan revisions (section 51.308(f)) and progress reviews 

(section 51.308(g)). Section 51.308(f) requires the states to submit a comprehensive SIP revision in 

2018 and every 10 years thereafter. Section 51.308(g) requires progress reports for each Class I area in 

the state in the form of SIP revisions every 5 years. 

This plan addresses the requirements of 40 CFR 51.308(g) requiring periodic reports evaluating progress 

towards the RPGs established for each mandatory Class I area. In accordance with the requirements 

listed in Section 51.308(g) of the RHR, Missouri, in the 2009 RH plan, committed to submitting a report 

on reasonable progress to EPA every five years following the initial submittal of the plan. This 

document fulfills this requirement and is in the form of a SIP revision. This progress report evaluates 

the progress made towards the RPGs for Missouri’s federal Class I areas: Mingo and Hercules Glades.

This plan follows the guidelines outlined in EPA’s document entitled, “General Principles for the 5-Year 

Regional Haze Progress Reports for the Initial Regional Haze State Implementation Plans2,” released in 

April 2013. 

                                                            

2

 EPA’s General Principles Document for 5-Year Regional Haze Progress Reports, April 10, 2013. Available at: 

http://www.4cleanair.org/Documents/haze_5year_4-10-13.pdf
5 

Figure 1. Map of Missouri’s Class I Federal areas. 
6 

II. Progress Report Elements 

A. Status of Control Strategies in the Regional Haze SIP 

40 CFR 51.308(g)(1), requires “A description of the status of implementation of all measures included 

in the implementation plan for achieving reasonable progress goals for Class I areas both within and 

outside the State.” 

This summary provides a status of the emission reduction measures that were included in the 2009 RH 

plan and the associated modeling efforts. This summary includes discussions of benefits associated with 

each measure. Such benefits are quantified wherever possible. In instances where implementation of a 

measure did not occur in a timely manner, information is provided on the source category and its relative 

impact on the overall future year emissions inventories. 

The paragraphs below also contain information on emissions strategies that were not included in the 

2009 RH SIP submittal. At that time, these measures had not yet been published in final form or were 

not fully documented, and therefore the benefits of these measures were not included in future year 

inventories. Emission reductions from these measures are expected to help ensure that each Class I area 

meets or exceeds the visibility progress goal set in the 2009 RH plan. 

Missouri used “on the books” control programs, found in A.1.1 – A.1.5, in the 2009 RH plan’s modeling 

demonstration to meet the RPG requirements. Measures that were not included in the 2009 RH plan’s 

modeling efforts but have since been or are currently being implemented and that could aid in improving 

visibility conditions are included in this summary and can be found in A.2.1 – A.2.5. 

A.1. Control Measures included in the 2009 RH plan 

A.1.1. Clean Air Interstate Rule (CAIR) 

On March 10, 2005, EPA signed the Clean Air Interstate Rule (CAIR), following a three-year modeling 

study and cost analysis on SO2 and NOX controls (equivalent to a four-factor analysis). 

As required by CAIR, Missouri promulgated state rules to implement CAIR. The rules were presented 

for public hearing at the December 7, 2006, Missouri Air Conservation Commission (MACC) Meeting 

and they were adopted at the February 1, 2007, MACC Meeting. The rules established a cap and trade 

system for NOX and SO2 emissions, and Missouri sources are included in the national program. The 

state rules are 10 CSR 10-6.362 Clean Air Interstate Rule Annual NOX Trading Program and 10 CSR 

10-6.366 Clean Air Interstate Rule SOX Trading Program. State rule 10 CSR 10-6.362 includes 

schedules for compliance and unit-level emission allocations for years 2009-2014 and 2015 and beyond. 

State rule 10 CSR 10-6.366 incorporates by reference the following federal rules: 

 40 CFR 96.206 

 40 CFR 96.207 

 40 CFR 96.208 

 40 CFR 96, subparts BBB promulgated as of April 28, 2006 

 40 CFR 96, subparts CCC promulgated as of April 28, 2006 

 40 CFR 96, subparts DDD promulgated as of April 28, 2006 
7 

 40 CFR 96, subparts FFF promulgated as of April 28, 2006 

 40 CFR 96, subparts GGG promulgated as of April 28, 2006 

 40 CFR 96, subparts III promulgated as of April 28, 2006 

The controls in the state rules and the federal rules incorporated by reference have been in effect since 

their promulgation and will remain in effect, pending the outcome of litigation on EPA’s Cross-State Air 

Pollution Rule (CSAPR). 

A table summarizing all SO2, NOX, and PM controls installed prior to emission year 2013 on Missouri 

EGU’s that are subject to CAIR is included in Appendix A. It was not included here due to its length. 

The table was generated from a query of the EPA’s Clean Air Markets Division (CAMD) database. 

A.1.2. Best Available Retrofit Technology (BART) 

In developing the 2009 RH plan (submitted to EPA on August 5, 20093), Missouri prepared a long-term 

strategy and examined the possible application of BART along with other programs in order to establish 

reasonable progress goals (RPGs) for Mingo and Hercules Glades. A BART analysis was performed to 

assure that the 2009 RH plan met the federal RHR requirements. This analysis included BART source 

development, screen-modeling analyses, and refined modeling. Twenty-six potential BART sources 

were identified, and twenty-five were eliminated through either screening or refined analyses. As a 

result, Missouri identified one source that is subject to BART. 

The remaining one source, Holcim – Clarksville, entered into a consent agreement with the Missouri 

Department of Natural Resources, which requires them to limit emissions of SO2 and NOX to: 

 SO2—58,787 lb/day using a 30-day rolling average 

 NOX—42,287 lb/day using a 30-day rolling average 

The emission limits are to be met as expeditiously as practicable, but no later than four years after 

approval of Missouri’s regional haze plan. The U.S. Environmental Protection Agency granted limited 

approval of Missouri’s regional haze plan on June 26, 2012 (77 FR 38007), including the consent 

agreement with Holcim – Clarksville. Therefore, Holcim – Clarksville has until June 26, 2016 to 

comply with the emission limits. 

Since the consent agreement included in the 2009 plan, Holcim - Clarksville has discontinued Portland 

cement manufacturing and hazardous waste fuel burning operations. Remaining operations at the 

facility include receiving, storing, and shipping. The facility’s operating permit (OP2004-002) was 

reclassified from a Part 70 to a Basic operating permit in 2010. The facility’s new SO2 and NOX

potential emissions are both zero tons per year. 

No other sources were found to be subject to BART and, therefore, implementation of an emission 

trading program, other emission controls or other alternative measure in place of BART are not 

necessary. 

A.1.3. Tier 2 

                                                            

3

 State of Missouri Regional Haze Plan Revision, August 5, 2009 (Available at: 

http://dnr.mo.gov/env/apcp/sips.htm#regionalhaze) 
8 

Tier 2 standards are federal emission standards for passenger cars, light trucks, and larger passenger 

vehicles. The program is designed to focus on reducing the emissions most responsible for the ozone 

and PM impact from these vehicles – NOX and non-methane organic gases, consisting primarily of 

hydrocarbons and contributing VOCs. The Tier 2 standards reduce new vehicle NOX levels to an 

average of 0.07 grams per mile. For new passenger cars and light duty trucks, these standards were 

phased in starting in 2004, and the standards were fully phased in by 2007. For heavy trucks and similar 

vehicles, the Tier 2 standards were phased in beginning in 2008, with full compliance in 2009.

During the phase-in period from 2004-2007, all passenger cars and light trucks not certified to the 

primary Tier 2 standards had to meet an interim average standard of 0.30 g/mi NOX. During the period 

2004-2008, heavy trucks and similar vehicles not certified to the final Tier 2 standards phased in to an 

interim program with an average standard of 0.20 g/mi NOX. Those not covered by the phase-in must 

meet a per-vehicle standard (i.e., an emissions “cap”) of 0.60 g/mi NOX for trucks and 0.09 g/mi for 

similar vehicles. 

A.1.4. Tier 4 

EPA's Clean Air Nonroad Diesel Rule (Tier 4) requires stringent pollution controls on diesel engines 

used in industries such as construction, agriculture, and mining, and it will slash sulfur content of diesel 

fuel. This rule is the latest in a series of actions that are designed to reduce emissions from nearly every 

type of diesel vehicle and equipment. This nonroad diesel program combines cleaner engine 

technologies with cleaner fuel – similar to the on-highway diesel program. The standards cut emissions 

from nonroad diesel engines by over 90 percent. Nonroad diesel equipment, as described in this rule, 

accounts for 47 percent of diesel PM and 25 percent of NOX from mobile sources nationwide.

Sulfur levels were reduced in nonroad diesel fuel by 99 percent from past levels (from approximately 

3,000 parts per million (ppm) to 15 ppm in 2010). The lower sulfur fuel also reduces PM from engines 

in existing nonroad equipment. It makes it possible for engine manufacturers to use advanced clean 

technologies, similar to catalytic technologies used in passenger cars. 

The Tier 4 emission limits are based on engine horsepower and were implemented in the stages depicted 

in Table 1. 

Table 1. Tier 4 emission limits with corresponding implementation years. 

Power Category Model Year 

Kw < 19 2008 

19 < Kw < 56 2008 

56 < Kw < 130 2012 

130 < Kw < 560 2011 

Kw > 560 2011 

A.1.5. NOX SIP Call 

The NOX SIP call was promulgated to assist downwind ozone areas in attaining the one-hour and 8-hour 

ozone NAAQS by providing upwind NOX emission control. This rulemaking was developed through 
9 

the EPA’s interpretation of the Ozone Transport Assessment Group (OTAG) recommendations and 

subsequent modeling and cost analysis of NOX controls to reduce ozone transport. The final NOX SIP 

call was published in the Federal Register on October 27, 1998. 

Missouri’s initial rule in response to the NOX SIP Call, 10 CSR 10-6.350 Emission Limitations and 

Emissions Trading of Oxides of Nitrogen, was adopted by the MACC on April 24, 2003. The rule 

established an emission limitation of 0.25 lbs NOX /MMBtu heat input for electric generating units in 

the eastern one-third of the state and a lower limit of 0.18 lbs NOX /MMBtu heat input for Labadie, Rush 

Island, and Meramec power plants. EGUs in the western two-thirds of the state were limited to an 

emission rate of 0.35 lbs NOX /MMBtu of heat input. Cyclone boilers (Sibley and Asbury power plants) 

that burn tire-derived fuels are allowed to meet 0.68 lbs NOX /MMBtu heat input. Implementation of the 

NOX SIP Call began on May 1, 2004.

On April 21, 2004, the EPA finalized the second phase of NOX SIP call. Phase II of the SIP call 

excluded the portion known as the “coarse grid” (the western 2/3 of Missouri) from the NOX SIP Call, 

defined the area of the eastern 1/3 of Missouri to include the same counties as established in 10 CSR 10-

6.350, with the one exception of not including Phelps County, and revised the cap for NOX emissions 

from the previous statewide budget of 114,532 tons of NOX per ozone season to a partial state budget of 

61,406 tons of NOX per ozone season in the eastern 1/3 of Missouri. The budget assumed control levels 

of 0.15 lbs/MMBtu for electric generating units, 82 percent emissions reductions for large natural gasfired stationary internal combustion engines, 90 percent emissions reductions for diesel and dual fuel 

stationary internal combustion engines, 60 percent emissions reductions for non-utility boilers and 

turbines, and 30 percent emissions reductions for cement manufacturing plants. Small cogeneration 

units were excluded from the NOX SIP Call. Small cogeneration units are units that supply one-third or 

less of their potential electrical output capacity, or 25 megawatts or less, to any utility power distribution 

system for sale. 

The department’s Air Pollution Control Program developed 10 CSR 10-6.360 Control of NOX Emissions 

from Electric Generating Units and Non-Electric Generating Boilers, 10 CSR 10-6.380 Control of NOX

Emissions from Portland Cement Kilns, and 10 CSR 10-6.390 Control of NOX Emission from Large 

Stationary Internal Combustion Engines. This set of three rules constitutes Missouri’s response to 

EPA’s NOX SIP Call. These rules were presented at public hearing on April 28, 2005 and were adopted 

at the May 26, 2005 MACC meeting. The state rules include schedules for compliance, sources affected 

by the rule and emissions limitations. 

State rules 10 CSR 10-6.350 Emission Limitations and Emissions Trading of Oxides of Nitrogen and 10 

CSR 10-6.360 Control of NOX Emissions from Electric Generating Units and Non-Electric Generating 

Boilers will be superseded by CAIR and eventually CSAPR, when the legal proceedings against CSAPR 

have been adjudicated. 

CAIR and CSAPR do not, however, regulate portland cement kilns or large stationary internal 

combustion engines, therefore state rules 10 CSR 10-6.380 Control of NOX Emissions from Portland 

Cement Kilns and 10 CSR 10-6.390 Control of NOX Emission from Large Stationary Internal 

Combustion Engines are not superseded by CAIR or CSAPR. 
10 

Ongoing air pollution control programs, as described above, are sufficient to meet the 2018 Regional 

Progress Goals for the Mingo and Hercules Glades Class I areas. These ongoing programs such as 

CAIR, CSAPR, or BART have been demonstrated to be very cost-effective in reducing the visibility 

impairment in Missouri’s Class I areas. 

A.2. Additional Measures not included in the 2009 RH plan 

Additional measures not explicitly included in the modeling demonstration in the 2009 RH plan but that 

could aid in reducing visibility impairment and in achieving the RPGs in Missouri’s Class I areas are 

described below. These additional control measures include the 2010 SO2 NAAQS Attainment 

Demonstrations, Illinois Multi-Pollutant Regulation, Federal Tier 3 vehicle emission and fuel standards, 

and the 2007 Federal Heavy-Duty Highway Rule. 

A.2.1. 2010 SO2 NAAQS Attainment Demonstrations 

Missouri is in the process of preparing implementation plans or attainment demonstrations to bring the 

portions of Jackson and Jefferson counties designated as nonattainment under the 2010 SO2 NAAQS 

into attainment. As part of the attainment demonstration, extensive dispersion modeling must be 

performed to evaluate nearby SO2 emitting sources, their potential impacts on the nonattainment area 

must be identified, and any necessary control measures must be determined in order to demonstrate 

compliance. In doing so, it is expected that significant reductions in SO2 emissions will be achieved 

prior to the attainment date for this standard, October 4, 2018. Any reductions in SO2 emissions will 

greatly benefit visibility conditions throughout Missouri and nearby areas; as mentioned previously, SO2

is a large contributor to visibility impairment. 

A.2.2. Illinois Multi-Pollutant Regulation 

In 2006, the Illinois Pollution Control Board and the Joint Committee on Administrative Rules approved 

a multi-pollutant standard (MPS) rule. This multi-pollutant rule resulted in measurable reductions in 

mercury, SO2, and NOX emissions. The rule targeted the three largest coal-fired power plant companies 

in Illinois: Midwest Generation, Ameren, and Dynegy. These three companies represent 88 percent of 

Illinois’ 17,007 Megawatts of electric generating capacity from coal-fired plants. By implementation of 

this rule, the Illinois Environmental Protection Agency estimated the total emissions reduction from all 

three power companies is 233,600 tons per year of SO2 and 61,434 tons per year of NOX. These 

significant emission reductions in Illinois can be expected to improve visibility in Missouri as well. 

A.2.3. Tier 3 

On April 28, 2014, EPA finalized Tier 3 motor vehicle emission and fuel standards (79 FR 23414). The 

Tier 3 vehicle standards reduce both tailpipe and evaporative emissions from passenger cars, light-duty 

trucks, medium-duty passenger vehicles, and some heavy-duty vehicles. The gasoline sulfur standard 

will make emission control systems more effective for both existing and new vehicles, and will enable 

more stringent vehicle emissions standards. The Tier 3 standards are scheduled to start in 2017. 

Compared to current standards, the non-methane organic gases (NMOG) and NOX, presented as 

NMOG+NOX, tailpipe standards for light-duty vehicles represent approximately an 80% reduction from 
11 

today’s fleet average and a 70% reduction in per-vehicle particulate matter (PM) standards. Heavy-duty 

tailpipe standards represent about a 60% reduction in fleet average NMOG+NOX and per-vehicle PM 

standards. 

The evaporative emissions program represents a 50 percent reduction from current standards and applies 

to all light-duty and onroad gasoline powered heavy-duty vehicles. 

The gasoline sulfur standards limit federal gasoline to no more than 10 parts per million (ppm) sulfur on 

an annual average basis. 

A.2.4. 2007 Heavy-Duty Highway Rule (40 CFR Part 86, Subpart P) 

In this regulation, EPA set a PM emissions standard for new heavy-duty engines of 0.01 grams per brake 

horsepower-hour (g/bhp-hr), which took full effect for diesel engines in the 2007 model year. This rule 

also included standards for NOX and non-methane hydrocarbons (NMHC) of 0.20 g/bhp-hr and 0.14 

g/bhp-hr, respectively. These diesel engine NOX and NMHC standards were successfully phased in 

together between 2007 and 2010. The rule also required that sulfur in diesel fuel be reduced to facilitate 

the use of modern pollution-control technology on these trucks and buses. The EPA required a 97 

percent reduction in the sulfur content of highway diesel fuel -- from levels of 500 ppm (low sulfur 

diesel) to 15 ppm (ultra-low sulfur diesel). These requirements were successfully implemented on the 

timeline in the regulation. 

A.3. Facilities with Expected Emission Changes to Occur between 2012-2017 

The Air Program’s Air Quality Analysis Section gathered this information to assist EPA in their 

development of the 2011 base year Modeling Platform, which will be used to forecast emissions for 

several EPA projects (see http://www.epa.gov/ttnchie1/emch/). Facilities with significant expected 

changes listed are based on information from the Air Program’s permit, planning, and enforcement staff, 

and Energy Information Administration (EIA) reports submitted by electric generation facilities. These 

expected changes are detailed in Table 2. The changes listed herein may not be final action and 

therefore subject to change. These changes were not included in the 2009 RH plan’s modeling 

demonstration, as they are not yet permanent and enforceable. These changes are included for 

informational purposes only. Total emission changes are approximated for each facility, and the total 

change in emissions from 2012 to 2017 is estimated to be 36,000 tons of emissions reduced. 
12 

Table 2. Facilities with Expected Emission Changes to Occur between 2012-2017. 

FIPS Facility Permit # Project # Notes Expected Emission Change

175-

0001 Thomas Hill

042013-

002 

Specifies the use of refined coal for 

Unit 3 starting in 2014. A specific 

reduction is not listed other than 

possible reduction in mercury and 

PM

Estimated PM/HAP emission 

reductions ~ 10 tons.

175-

0002 Thomas Hill

2012-05-

075

Specified the use of powdered 

activated carbon for units 1 and 2 

starting in 2014 was submitted by 

the facility to control mercury, but 

the project did not require a permit.

Estimated PM/HAP emission 

reductions ~ 10 tons.

201-

0017

Sikeston 

Power Station

2013-01-

013

The wet scrubber on unit 1 was 

shutdown in 1998 when the 

company switched to low sulfur 

coal. The wet scrubber will start 

up again in 2015. This is according 

to an application, that did not 

require a permit. 

Reported emissions in 2012 

were 5,200 tons of SO2, after 

the change there is a reduction 

estimate of ~3,000 tons in 

2015

097-

0001

Empire 

District 

Electric Co. - 

Asbury Plant

022012-

010

The addition of a dry scrubber and 

powdered activated carbon based 

to EU # 7 (Boiler) starting in 2014, 

the permit also notes the baghouse 

at the facility will continue to 

operate

Last reported emissions were 

6,200 tons of SO2 in 2012, 

with an SO2 reduction 

estimate of ~4,000 tons in 

2014 after the change

151-

0002

Central 

Electric 

Power 

Cooperative, 

Chamois

Facility shut down in September 

2013.

Reported emissions in 2011 

were 5,500 tons total 

chargeable, which dropped by 

almost half in 2012 to 2,500 

tons chargeable. Total 

reduction estimate for all 

pollutants is to 1,000 tons in 

2013 and zero tons in 2014

083-

0001

Kansas City 

Power and 

Light Co, 

Montrose 

Generating 

Station

P06 - Boiler Unit 1 will be retired in 

2016 per the EIA

In 2012, the facility reported 

2,400 tons of SO2, 1,100 tons 

of NOx, and 50 tons of PM10. 

The expected reduction 

estimate is 3,500 tons in 2016

095-

0031

Kansas City 

Power and 

Light Co, 

Sibley 

Generating 

Station

EU# 5A - Boiler 1 and EU# 5B - 

Boiler 2 will be retired in 2017 per 

the EIA

In 2012, the facility reported 

(from boilers 1 & 2) 700 tons 

of SO2 and 300 tons of NOx. 

The expected reduction 

estimate is 1,000 tons in 2017

Expected Facility Changes - EGU's 
13 

FIPS Facility Permit # Project # Notes Expected Emission Change

031-

0053

Procter & 

Gamble

092012-

006

Facility will be adding 3 natural gas 

boilers in 2014 

Estimate around 100 tons per 

year increase in emissions (the 

majority being NOx)

127-

0001 BASF

2013-04-

015

Facility will shut down its coal 

boilers and install natural gas 

boilers. This project has not been 

permitted yet; the application for 

this project was received in April of 

2013 

The facility reported 1,300 

tons of SO2 and 400 tons of 

NOx in 2012. The expected 

reduction estimate is 1,700 

tons by 2015

095-

0017 Folgers

The Kansas City plant is shutdown 

as of March 2012

The facility reported 600 tons 

of total chargeable emissions 

in 2010. This dropped down 

to 14 tons in 2012 for a partial 

year of operation then reduces 

to zero in 2013.

099-

0003

Doe Run 

Herculaneum

The smelter shutdown Dec. 31, 

2013.

The facility reported 18,000 

tons of SO2 emissions in 

2012. The expected reduction 

estimate is then approximately 

18,000 tons (remaining 

sources ~50 tons).

093-

0009

Doe Run 

Buick

The facility will be adding a wet 

scrubber to EP-08 starting in 2014. 

The facility reported 2,800 

tons of SO2 emissions in 

2012. The expected reduction 

estimate is 2,000 tons.

023-

0062

Nordyne - 

Poplar Bluff

053-

0021

Nordyne -

Boonville

Expected Facility Changes - Non-EGU's 

Nordyne will be closing their Poplar 

Bluff and Boonville facilities by the 

end of 2015, according to their 

website. 

http://www.nordyneinfo.com/

The sites reported 60 tons of 

VOC emissions combined for 

2012, which results in an 

expected reduction estimate of 

60 tons in 2016.

Total Estimated Emissions Reduction for all changes listed in Table (from the 2012 level until the last change takes 

effect in emission year 2017) : 36,000 tons of emissions reduced
14 

B. Emissions Reductions from Regional Haze SIP Strategies 

Section 51.308(g)(2) 

A summary of the emissions reductions achieved throughout the State through implementation of the 

measures described in paragraph (g)(1) of this section.

As in the 2009 RH plan submittal, this periodic update is focused on one of the largest contributors to 

visibility impairment, sulfates. Overall SO2 emissions have decreased in Missouri. The main source 

category related to SO2 emissions is electric generating units (EGUs). The information presented here 

only captures available data for EGUs (units with output greater than 25 Megawatts) that are required to 

operate Continuous Emission Monitoring Systems (CEMS) and to report emissions to EPA’s Clean Air 

Markets Division (CAMD); therefore, this analysis does not capture reductions in emissions from units 

not required to operate CEMS. 

The reductions in SO2 emissions from EGUs during this period resulted from many factors, including 

installation of controls, units switching to cleaner fuels, load shifting from dirtier units to cleaner units, 

and an overall decrease in demand for generation. EPA’s CAMD data for Acid Rain Program units 

from 2007 through 2012 indicate that reductions in SO2 emissions appear to be maintained, and further 

reductions achieved, even though heat input to these units increased between 2009 and 2011. 

Figure 2. Missouri’s EGU Trends for 2007-2012, from EPA’s Clean Air Markets Division (CAMD) 

online database. http://ampd.epa.gov/ampd/ 

Figure 2 depicts the trends for Missouri’s Acid Rain Program units that report annual emissions to 

CAMD. Between 2007 and 2011, heat input to these units actually increased from approximately 

0.000

0.100

0.200

0.300

0.400

0.500

0.600

0.700

0.800

0

100000

200000

300000

400000

500000

600000

700000

800000

900000

2006 2007 2008 2009 2010 2011 2012 2013

lbs/MMBtu

tons/year and 1000 MMBtu Heat Input

Year

Missouri EGU Emission and Heat Input Trends

2007‐2012, Acid Rain Units Reporting to CAMD

SO2 (tons/year) NOx (tons/year) Heat Input (1000 MMBtu/yr)

NOx Rate (lbs/MMBtu) SO2 Rate (lbs/MMBtu)
15 

800,610,888 MMBtu to 838,655,089 MMBtu. However, actual SO2 emissions from these units 

decreased from 255,201 tons annually in 2007 to 138,805.42 tons annually in 2012, a decrease of 45.6 

percent. Furthermore, the average SO2 emission rate from these units decreased from 0.637 lbs SO2/ 

MMBtu in 2007 to 0.361 lbs SO2/ MMBtu in 2012, a decrease of 43.4 percent. The reductions in 

emissions demonstrate that even with an increase in demand for power, as evidenced by the increased 

heat input to these units, a significant reduction to overall SO2 emissions occurred due to the installation 

of controls and the use of cleaner burning fuels. 

During the period of 2009-2011, SO2 emissions fell from 240,201.92 tons to 196,255.62 tons, 

respectively. For this same time period, heat input data for Missouri went up slightly, from 761,579,014 

MMBtu to 838,655,089 MMBtu, indicating SO2 emission reductions and power demand were not 

influenced by changing economic conditions during this period.

As indicated in Table 3, NOx emissions decreased from 105,921 tons in 2007 to 69,562 tons in 2012. 

NOx emission rates also depict a decrease from 2007 to 2012, from 0.265 lbs NOx/MMBtu to 0.181 lbs 

NOx/MMBtu, respectively. 

As additional controls are installed to meet the stringent requirements of the Cross State Air Pollution 

Rule (CSAPR), the Industrial Boiler Maximum Achievable Control Technology (MACT) regulation, 

and the Mercury and Air Toxics Standard (MATS), emission rates may decrease even further. Since 

sulfates have been shown to be the predominant species of concern to visibility impairment at both 

Hercules Glades and Mingo during the first round of regional haze planning, visibility improvements 

from reduced sulfate contribution should continue into the future even though demand for power and 

heat input to these units may increase. Table 3 summarizes these trends for Missouri. 

Table 3. Missouri’s EGU Trends for 2007-2012. As depicted graphically in Figure 2. From 

http://ampd.epa.gov/ampd/

As evidenced by the trend graph, emission rates for SO2 and NOX have declined over the past 5 years 

and are expected to continue declining as more federal regulations are implemented in the future. This 

reinforces the determination that Missouri’s Class I areas will meet the established RPGs in the required 

timeframe. 

Year SO2 (tons) NOx (tons)

Heat Input

(MMBtu)

SO2 Rate

(lbs/MMBtu)

NOx Rate

(lbs/MMBtu)

2007 255,202 105,921 800,610,888 0.638 0.265

2008 258,269 88,600 770,260,872 0.671 0.230

2009 240,202 53,475 761,579,014 0.631 0.140

2010 236,217 58,364 808,226,597 0.585 0.144

2011 196,256 63,278 838,655,089 0.468 0.151

2012 138,805 69,562 769,110,993 0.361 0.181

Missouri Emission Trends from CAMD
16 

C. Visibility Progress 

 

Section 51.308(g)(3) 

For each mandatory Class I Federal area within the State, the State must assess the following visibility 

conditions and changes, with values for most impaired and least impaired days expressed in terms of 5-

year averages of these annual values. 

 (i) The current visibility conditions for the most impaired and least impaired days; 

(ii) The difference between current visibility conditions for the most impaired and least impaired days 

and baseline visibility conditions; 

(iii) The change in visibility impairment for the most impaired and least impaired days over the past 5 

years. 

The goal of the Regional Haze Rule is to restore natural visibility conditions to the 156 Class I areas 

identified in the 1977 CAA Amendments. For each Class I area, there are three metrics of visibility that 

are part of the determination of reasonable progress: 

 Baseline Conditions

 Natural Conditions

 Current Conditions

The RHR at 40 CFR Section 51.308(d)(1) requires states to establish RPGs (in deciviews) for each Class 

I area within the state that provide for reasonable progress towards achieving natural visibility. In 

developing the 2009 RH plan (submitted to EPA on August 5, 2009,4

), Missouri prepared a long-term 

strategy and examined the possible application of BART along with other programs in order to establish 

RPGs for Mingo and Hercules Glades. 

IMPROVE monitoring sites were required to have three valid years of data, during the five-year (2000-

2004) baseline period, from which the baseline conditions were constructed. As provided in the 2009 

RH plan, Missouri established baseline visibility conditions for each area. Missouri elected to perform 

all visibility projections using the revised IMPROVE algorithm. The natural conditions (for 2064) were 

estimated using the EPA’s document entitled, “Guidance for Tracking Progress under the Regional Haze 

Rule,” as released September 2003.5

 The natural visibility conditions for both Class I areas for the 

twenty percent worst visibility days were set, using EPA default conditions, at 11.3 dv. Also established 

in the 2009 RH plan is a uniform rate of progress glidepath, which is a linear visibility glidepath in 

deciviews from the observed 2000-2004 baseline for the worst 20 percent days to the set 2064 Natural 

Conditions. It is with these calculations and the model predictions that Missouri developed RPGs for 

each Class I area, as described in the 2009 RH plan. 

                                                            

4

 State of Missouri Regional Haze Plan Revision, August 5, 2009 (Available at: 

http://dnr.mo.gov/env/apcp/sips.htm#regionalhaze) 

5

 EPA’s “Guidance for Tracking Progress under the Regional Haze Rule,” September 2003 (Available at: 

http://www.epa.gov/ttn/oarpg/t1/memoranda/rh_tpurhr_gd.pdf)
17 

Baseline conditions, natural conditions, and the established 2018 RPGs, are detailed in Table 4. Sitespecific data analysis was performed to evaluate reasonable progress and to predict whether RPGs for 

2018 will likely be met. These data and trend analyses are detailed in the following paragraphs. All 

data utilized in the following analyses are publicly available through the Western Regional Air 

Partnership’s (WRAP) Technical Support System (TSS) website, 

http://vista.cira.colostate.edu/tss/Results/HazePlanning.aspx. Tables of the underlying data for the 

following charts are also included in Appendix A. Underlying Data Tables, for ease of reference. 

Visibility conditions are typically measured using the unit of deciview. A deciview is a measurement of 

haze that gauges the impact air pollutants have on visibility. A reading of zero deciviews indicates clear 

conditions with no visibility impairment. The more deciviews measured, the more visibility impairment, 

which limits the distance one can see. Another method of measuring visibility conditions is light 

extinction. The extinction coefficient is a measure of the ability of particles or gases to absorb and 

scatter photons from a beam of light. It is a number that is proportional to the number of photons 

removed from the sight path per unit length, the unit for this is an inverse Megameter (Mm-1). A higher 

measured extinction coefficient means a higher level of visibility impairment. 

The technical analyses contained in this plan only cover Missouri’s Class I areas (and the protocol site); 

however, the emission reductions and visibility improvements that have already been achieved and 

future emission reductions expected to occur in Missouri will also benefit visibility conditions at nearby 

areas in other states. The logic applied in this regard concludes that if current and expected emission 

reductions from Missouri sources are great enough for Missouri’s Class I areas to achieve their 

reasonable progress goals in 2018, then Missouri’s impact would be even less in other states’ Class I 

areas and therefore would not hinder the attainment of their RPGs. 

Table 4. Established 20% Worst Days Visibility Conditions for Missouri Class I Areas. 

Federal Class I 

Area 

Established Baseline 

Conditions (dv) 

(2000-2004) 

Established 2064 

Natural 

Conditions (dv) 

Established 2018 

RPGs (Modeled 

Predictions) (dv) 

Expected to 

Meet 2018 

RPGs? 

Mingo 28.02 11.3 23.71 Yes 

Hercules Glades 26.75 11.3 23.06 Yes 

C.1. Area Specific Information and Analysis 

C.1.1 Mingo National Wildlife Refuge 

In order to determine reasonable progress for an area, a baseline condition must be established as a 

starting point. The IMPROVE monitor located in Mingo National Wildlife Refuge began sampling all 

pollutants that affect visibility on May 24, 2000. Sampling data taken from Mingo is quality assured by 

staff at Colorado State University (CSU) on behalf of the Air Program. Staff at CSU noticed a decrease 

in trends of the Organic Carbon (OC) and Elemental Carbon (EC) concentrations, (both are categories of 

species measured as fine particulate matter, PM2.5) at Mingo that was not noticed at any neighboring 
18 

sampling sites. It was later discovered that there was a monitor inlet clogging problem associated with a 

particular inlet design that was difficult to clean. Because of the clogged Module C Inlet, carbon data 

was not available from June 2000 to January 2002. The resolution was a substitution protocol 

developed by Warren White using organic mass hydrogen (OMH) to develop a surrogate for organic 

mass carbon (OMC). Data filling was used to obtain sufficient data so that three years of valid data 

were available from which baseline conditions could be calculated. Mingo monitoring data for 2005 and 

2012 are currently unavailable on the technical support site, due to completeness and quality assurance 

issues; therefore, they could not be included in this analysis. 

The baseline condition for visibility for the twenty percent worst sampling days was estimated at 28.02 

dv. The established baseline condition for the twenty percent best days is 13.76 dv. The natural 

condition for the worst days is set at 11.3 dv using EPA default conditions. As detailed in the 2009 RH 

plan, the modeled prediction for 2018 was adopted as the RPG for Mingo at 23.71 dv for the worst 

sampling days. Monitored data available through the WRAP TSS, as both annual and five-year 

averages depict a downward trend toward the RPG. The goal for the twenty percent best sampling days 

is to show no degradation in visibility conditions from the baseline, and the available monitored data for 

this first planning period show no degradation, and in fact show improvement. 

The following figures depict trends for the Mingo Class I area for visibility on the best and worst 20% 

sampling days. Trends for all speciated pollutants are analyzed by mass concentration and light 

extinction, for the 20% best and worst days, in order to properly characterize the conditions at Mingo. 

 

The following table is a summary of visibility conditions including five-year averages for this first 

planning period, which breaks out the individual species as well as total light extinction, and deciviews. 

As shown in the table, there is a noticeable downward trend in sulfate measurements as well as in total 

light extinction and deciviews. This table is available on the WRAP TSS. These trends are also 

depicted graphically in the figures following the corresponding tables. 

Table 5. Mingo Visibility Conditions Reasonable Progress Summary Table – Worst 20% Days 

Class I Area Visibility Summary: Mingo NWRW, MO Class I area 

Visibility Conditions: Worst 20% Days 

Reasonable Progress Summary

2000-04 

Baseline 

Conditions 

(Mm-1) 

2005-09 

Progress 

Period 

(Mm-1) 

2006-10 

Progress 

Period 

(Mm-1) 

2007-11 

Progress 

Period 

(Mm-1) 

2008-12 

Progress 

Period 

(Mm-1) 

Sulfate 104.6 93.7 84.6 75.0 63.5 

Nitrate 27.2 12.5 15.9 19.9 22.2 

Organic 

Carbon 20.5 22.6 23.9 24.3 22.2 

Elemental 

Carbon 5.5 6.4 6.3 6.1 5.6 
19 

Fine Soil 1.4 2.0 2.0 1.7 1.6 

Coarse 

Material 6.5 7.4 7.3 6.6 6.1 

Sea Salt 0.2 0.3 0.3 0.3 0.3 

Total Light 

Extinction 177.9 156.8 152.5 145.9 133.6 

Deciview 28.02 27.1 26.8 26.4 25.7 

Figure 3. Mingo’s Reasonable Progress Summary Chart –Worst 20% Days 

0

20

40

60

80

100

120

140

160

180

2000‐04

Baseline

Conditions

2005‐09

Progress

Period

2006‐10

Progress

Period

2007‐11

Progress

Period

2008‐12

Progress

Period

Light Extinction, Bext (Mm‐1)

Successive 5‐Year Averages

Mingo ‐ Reasonable Progress Summary Chart

20% Worst Days Sea Salt

Coarse Material

Fine Soil

Elemental

Carbon

Organic Carbon

Nitrate

Sulfate
20 

Figure 4. Mingo’s Reasonable Progress Summary: Deciviews - 5-Year Averages-Worst 20% Days 

Figure 5. Mingo’s Reasonable Progress Summary: Total Light Extinction – 5-Year Averages-Worst 

20% Days 

28.02

27.1

26.8

26.4

25.7

24.5

25

25.5

26

26.5

27

27.5

28

28.5

2000‐04 Baseline

Conditions

2005‐09 Progress

Period

2006‐10 Progress

Period

2007‐11 Progress

Period

2008‐12 Progress

Period

Deciviews

Mingo: Reasonable Progress Summary: Deciviews

5‐Year Averages ‐ Worst 20% Days

177.9

156.8

152.5

145.9 133.6

0

20

40

60

80

100

120

140

160

180

200

2000‐04 Baseline

Conditions

2005‐09 Progress

Period

2006‐10 Progress

Period

2007‐11 Progress

Period

2008‐12 Progress

Period

Light Extinction, Bext (Mm‐1)

Mingo: Reasonable Progress Summary

Total Light Extinction ‐ 5‐Year Averages ‐ Worst 20% Days
21 

Table 6. Mingo Visibility Conditions Reasonable Progress Summary Table – Best 20% Days 

Class I Area Visibility Summary: Mingo NWRW, MO Class I area

Visibility Conditions: Best 20% Days

Reasonable Progress Summary 

 

2000-04 

Baseline 

Conditions 

2005-09 

Progress 

Period 

2006-10 

Progress 

Period 

2007-11 

Progress 

Period 

2008-12 

Progress 

Period 

Sulfate 13.8 13.6 13.7 12.7 12.2 

Nitrate 4.4 4.2 3.9 3.7 3.1 

Organic 

Carbon 6.3 5 5 5 4.8 

Elemental 

Carbon 2.3 2.1 2 1.9 1.8 

Fine Soil 0.4 0.5 0.5 0.5 0.5 

Coarse 

Material 3.2 3.2 3.1 3.3 3 

Sea Salt 0.1 0.2 0.2 0.2 0.2 

Total Light 

Extinction 42.5 41 40.6 39.3 37.6 

Deciview 14.3 13.9 13.8 13.5 13.1 

Figure 6. Mingo’s Reasonable Progress Summary Chart –Best 20% Days 

0

5

10

15

20

25

30

35

2000‐04

Baseline

Conditions

2005‐09

Progress Period

2006‐10

Progress Period

2007‐11

Progress Period

2008‐12

Progress Period

Light Extinction, Bext (Mm‐1)

Mingo ‐ Reasonable Progress Summary Chart

Best 20% Days

Sea Salt

Coarse Material

Fine Soil

Elemental Carbon

Organic Carbon

Nitrate

Sulfate
22 

Figure 7. Mingo’s Reasonable Progress Summary: Deciviews – 5-Year Averages-Best 20% Days 

Figure 8. Mingo’s Reasonable Progress Summary: Total Light Extinction – 5-Year Averages-Best 20% 

Days 

14.3 13.9

13.8

13.5

13.1

12.4

12.6

12.8

13

13.2

13.4

13.6

13.8

14

14.2

14.4

2000‐04 Baseline

Conditions

2005‐09 Progress

Period

2006‐10 Progress

Period

2007‐11 Progress

Period

2008‐12 Progress

Period

Deciviews

Mingo‐ Reasonable Progress Summary:

Deciviews 5‐Year Averages ‐ Best 20% Days

42.5 41

40.6

39.3

37.6

35

36

37

38

39

40

41

42

43

2000‐04 Baseline

Conditions

2005‐09 Progress

Period

2006‐10 Progress

Period

2007‐11 Progress

Period

2008‐12 Progress

Period

Light Extinction, Bext (Mm‐1)

Mingo‐ Reasonable Progress Summary: Total Light

Extinction 5‐Year Averages ‐ Best 20% Days
23 

Figure 9. Mingo’s Annual Monitored Visibility Data with Glidepath to 2018 RPGs

Figure 10. Mingo – Light Extinction Monitoring Data for Worst 20% Days. 

0

5

10

15

20

25

30

35

1999 2004 2009 2014 2019

Deciviews

Mingo ‐ Annual Monitored Visibility Data for Best and

Worst 20% Days

Worst 20% Days

2018 RPG

Best 20% Days

Baseline Conditions

Glidepath

Linear (Best 20%

Days)

0

20

40

60

80

100

120

140

160

180

200

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Light Extinction, Bext (Mm‐1)

Mingo ‐ Light Extinction Monitoring Data for Worst

20% Days

Sea Salt

Coarse Mass

Soil

Elemental Carbon

Organic Mass

Carbon

Nitrate

Sulfate

23.7 dv
24 

Figure 11. Mingo – Light Extinction Monitoring Data for Best 20% Days. 

Figure 12. Mingo – Mass Concentrations Monitoring Data for Worst 20% Days. 

0

5

10

15

20

25

30

35

40

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Light Extinction, Bext (Mm‐1)

Mingo ‐ Light Extinction Monitoring Data for Best

20% Days

Sea Salt

Coarse Mass

Soil

Elemental Carbon

Organic Mass Carbon

Nitrate

Sulfate

0

5

10

15

20

25

30

35

40

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Mass Concentrations (ug/m3)

Mingo ‐ Mass Concentrations for 20% Worst

Days

Sea Salt

Coarse Mass

Soil

Elemental Carbon

Organic Mass

Carbon

Amm Nitrate

Amm Sulfate
25 

Figure 13. Mingo – Mass Concentrations Monitoring Data for Best 20% Days.

C.1.2. Hercules Glades National Wilderness Area 

In order to determine reasonable progress for an area, a baseline condition must be established. The 

IMPROVE monitor located in the Hercules Glades National Wilderness Area began monitoring and 

reporting data on March 2, 2001. The baseline condition for the twenty percent worst days at Hercules 

Glades, using sampling data from the period 2001 through 2004, is estimated at 26.75 deciviews (dv). 

The established baseline condition for the twenty percent best days is 12.84 dv. The natural conditions 

at Hercules Glades for the worst days were set at 11.3 dv using EPA default conditions. As detailed in 

the 2009 RH plan, the modeled prediction for 2018 was adopted as the RPG for Hercules Glades at 

23.06 dv for the worst sampling days. Monitored data available through the WRAP TSS, as both annual 

and five-year averages depict a downward trend toward the RPG. The goal for the twenty percent best 

sampling days is to show no degradation in visibility conditions from the baseline, and the available 

monitored data for this first planning period show no degradation, and in fact show improvement. 

The following figures depict trends for the Hercules Glades Class I area for visibility on the best and 

worst 20% sampling days. Trends for all speciated pollutants are analyzed by mass concentration and 

light extinction, for the 20% best and worst days, in order to properly characterize the conditions at 

Hercules Glades. 

 

The following table is a summary of visibility conditions including five-year averages for this first 

planning period, which breaks out the individual species as well as total light extinction, and deciviews. 

This table depicts the downward trends in sulfate measurements as well as in total light extinction and 

0

2

4

6

8

10

12

14

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Mass Concentrations (ug/m3)

Mingo ‐ Mass Concentrations for Best 20%

Days

Sea Salt

Coarse Mass

Soil

Elemental Carbon

Organic Mass

Carbon

Amm Nitrate

Amm Sulfate
26 

deciviews. This table is available using the WRAP TSS. These trends are also depicted graphically in 

the figures following the corresponding tables. 

Table 7. Hercules Glades Visibility Conditions Reasonable Progress Summary Table-Worst 20% Days 

Class I Area Visibility Summary: Hercules-Glades W, MO Class I area 

Visibility Conditions: Worst 20% Days 

Reasonable Progress Summary

2000-04 

Baseline 

Conditions 

(Mm-1) 

2005-09 

Progress 

Period 

(Mm-1) 

2006-10 

Progress 

Period 

(Mm-1) 

2007-11 

Progress 

Period 

(Mm-1) 

2008-12 

Progress 

Period 

(Mm-1) 

Sulfate 87.9 86.7 67.3 61.4 50.4 

Nitrate 17.9 17.4 19.8 21.8 22.2 

Organic 

Carbon 25.3 18.5 17.2 16.6 15.5 

Elemental 

Carbon 5.2 5.1 4.6 4.3 4.0 

Fine Soil 0.9 0.9 0.9 0.8 0.7 

Coarse 

Material 2.8 3.5 3.7 4.0 4.1 

Sea Salt 0.2 0.5 0.3 0.3 0.2 

Total Light 

Extinction 151.2 143.5 124.8 120.1 108.1 

Deciview 26.7 26.0 24.9 24.5 23.5 
27 

Figure 14. Hercules Glades’ Reasonable Progress Summary Chart for Worst 20% Days

Figure 15. Hercules Glades’ Reasonable Progress Summary: Deciviews 5-Year Averages-Worst 20% 

Days 

0

20

40

60

80

100

120

140

160

2000‐04

Baseline

Conditions

2005‐09

Progress Period

2006‐10

Progress Period

2007‐11

Progress Period

2008‐12

Progress Period

Light Extinction, Bext (Mm‐1)

Successive 5‐Year Averages

Hercules Glades ‐ Reasonable Progress Summary Chart

Worst 20% Days Sea Salt

Coarse

Material

Fine Soil

Elemental

Carbon

Organic

Carbon

Nitrate

Sulfate

26.7 26

24.9

24.5

23.5

21

22

23

24

25

26

27

2000‐04 Baseline

Conditions

2005‐09 Progress

Period

2006‐10 Progress

Period

2007‐11 Progress

Period

2008‐12 Progress

Period

Deciviews

Hercules Glades: Reasonable Progress Summary‐

Deciviews ‐ 5‐Year Averages ‐ Worst 20% Days
28 

Figure 16. Hercules Glades’ Reasonable Progress Summary: Total Light Extinction – 5-Year AveragesWorst 20% Days 

Table 8. Hercules Glades Visibility Conditions Reasonable Progress Summary Table-Best 20% Days 

Class I Area Visibility Summary: Hercules-Glades W, MO Class I area

Visibility Conditions: Best 20% Days

Reasonable Progress Summary 

 

2000-04 Baseline 

Conditions 

2005-09 

Progress 

Period 

2006-10 

Progress 

Period 

2007-11 

Progress 

Period 

2008-12 

Progress 

Period 

Sulfate 10.8 11.8 10.7 9.6 9.1 

Nitrate 4.9 3.9 3.6 3.5 2.8 

Organic 

Carbon 5.1 4.5 4.3 4.1 3.8 

Elemental 

Carbon 2 1.9 1.7 1.6 1.5 

Fine Soil 0.3 0.3 0.3 0.3 0.3 

Coarse 

Material 2.3 2.3 2.4 2.6 2.7 

Sea Salt 0.2 0.1 0.1 0.1 0.1 

Total Light 

Extinction 36.6 35.8 34.1 32.8 31.3 

Deciview 12.8 12.5 12.1 11.7 11.3 

151.2

143.5

124.8 120.1

108.1

80

90

100

110

120

130

140

150

160

2000‐04 Baseline

Conditions

2005‐09 Progress

Period

2006‐10 Progress

Period

2007‐11 Progress

Period

2008‐12 Progress

Period

Light Extinction, Bext (Mm‐1)

Hercules Glades: Reasonable Progress Summary

Total Light Extinction ‐ 5‐Year Averages ‐ Worst 20% Days
29 

Figure 17. Hercules Glades’ Reasonable Progress Summary Chart for Best 20% Days 

Figure 18. Hercules Glades’ Reasonable Progress Summary: Deciviews 5-Year Averages-Best 20% 

Days 

0

5

10

15

20

25

30

2000‐04

Baseline

Conditions

2005‐09

Progress Period

2006‐10

Progress Period

2007‐11

Progress Period

2008‐12

Progress Period

Light Extinction, Bext (Mm‐1)

Hercules Glades ‐ Reasonable Progress Summary Chart

Best 20% Days

Sea Salt

Coarse Material

Fine Soil

Elemental Carbon

Organic Carbon

Nitrate

Sulfate

12.8

12.5 12.1

11.7

11.3

10.5

11

11.5

12

12.5

13

2000‐04 Baseline

Conditions

2005‐09 Progress

Period

2006‐10 Progress

Period

2007‐11 Progress

Period

2008‐12 Progress

Period

Deciviews

Hercules Glades‐ Reasonable Progress Summary:

Deciviews 5‐Year Averages ‐ Best 20% Days
30 

Figure 19. Hercules Glades’ Reasonable Progress Summary: Total Light Extinction – 5-Year AveragesBest 20% Days 

Figure 20. Hercules Glades’ Annual Monitored Visibility Data with Glidepath to 2018 RPGs

36.6

35.8

34.1

32.8

31.3

28

29

30

31

32

33

34

35

36

37

2000‐04 Baseline

Conditions

2005‐09 Progress

Period

2006‐10 Progress

Period

2007‐11 Progress

Period

2008‐12 Progress

Period

Light Extinction, Bext (Mm‐1)

Hercules Glades‐ Reasonable Progress Summary: Total

Light Extinction 5‐Year Averages‐Best 20% Days

0

5

10

15

20

25

30

35

1999 2004 2009 2014 2019

Deciviews

Hercules Glades ‐ Annual Monitored Visibility

Data for Best and Worst 20% Days

Worst 20% Days

2018 RPG

Best 20% Days

Baseline Conditions

Glidepath

Linear (Best 20% Days)

23.1 dv
31 

Figure 21. Hercules Glades – Light Extinction Monitoring Data for Worst 20% Days. 

Figure 22. Hercules Glades – Light Extinction Monitoring Data for Best 20% Days. 

0

20

40

60

80

100

120

140

160

180

200

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Light Extinction, Bext (Mm‐1)

Hercules Glades ‐ Light Extinction Monitoring Data for

Worst 20% Days

Sea Salt

Coarse Mass

Soil

Elemental Carbon

Organic Mass Carbon

Nitrate

Sulfate

0

5

10

15

20

25

30

35

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Light Extinction, Bext (Mm‐1)

Hercules Glades‐ Light Extinction Monitoring Data for Best

20% Days

Sea Salt

Coarse Mass

Soil

Elemental Carbon

Organic Mass Carbon

Nitrate

Sulfate
32 

Figure 23. Hercules Glades – Mass Concentrations Monitoring Data for Worst 20% Days. 

Figure 24. Hercules Glades – Mass Concentrations Monitoring Data for Best 20% Days. 

0

5

10

15

20

25

30

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Mass Concentrations (μg/m3)

Hercules Glades ‐ Mass Concentrations for Worst 20%

Days

Sea Salt

Coarse Mass

Soil

Elemental Carbon

Organic Mass Carbon

Amm Nitrate

Amm Sulfate

0

1

2

3

4

5

6

7

8

9

10

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Mass Concentrations (μg/m3)

Hercules Glades ‐ Mass Concentrations for Best 20% Days

Sea Salt

Coarse Mass

Soil

Elemental Carbon

Organic Mass Carbon

Amm Nitrate

Amm Sulfate
33 

C.1.3. El Dorado Springs Protocol Site 

El Dorado Springs’ IMPROVE Protocol monitor began monitoring and reporting data on June 1st, 2002. 

In order to determine reasonable progress for an area, a baseline condition must be established. In the 

first few years of operation at El Dorado Springs there were some inconsistencies across sampling data 

for varying PM2.5 species, therefore a different time period was chosen to represent the baseline 

conditions for the worst sampling days. The chosen time period, 2005 through 2007, resulted in 

estimated baseline conditions for the worst 20% sampling days of 26.97 deciviews (dv). The natural 

conditions for the worst days are estimated at 11.3 dv. 

The following figures depict trends for the El Dorado Springs Protocol Site for visibility on the best and 

worst 20% sampling days. Trends for all speciated pollutants are analyzed by mass concentration and 

light extinction, for the best and worst days, in order to properly characterize the conditions at El Dorado 

Springs. Analysis and trends for El Dorado Springs were included to strengthen the argument that 

visibility conditions across the entire state, not just in the required Class I areas, are in fact improving at 

a reassuring rate, and are expected to achieve the established 2018 reasonable progress goals. 

Figure 25. El Dorado Springs’ Annual Monitored Visibility Data with Glidepath to 2018 RPGs

0

5

10

15

20

25

30

35

2000 2005 2010 2015 2020

Deciviews

El Dorado Springs ‐ Annual Monitored Visibility Data for

Best and Worst 20% Days

Worst 20% Days

2018 RPG

Best 20% Days

Baseline Conditions

Glidepath

Linear (Best 20%

Days )

23.3 dv
34 

Figure 26. El Dorado Springs – Light Extinction Monitoring Data for Worst 20% Days. 

Figure 27. El Dorado Springs – Light Extinction Monitoring Data for Best 20% Days.

0

20

40

60

80

100

120

140

160

180

200

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Light Extinction, Bext (Mm‐1)

El Dorado Springs ‐ Light Extinction Monitoring Data for

Worst 20% Days

Sea Salt

Coarse Mass

Soil

Elemental Carbon

Organic Mass Carbon

Nitrate

Sulfate

0

5

10

15

20

25

30

35

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Light Extinction, Bext (Mm‐1)

El Dorado Springs‐ Light Extinction Monitoring Data for

Best 20% Days

Sea Salt

Coarse Mass

Soil

Elemental Carbon

Organic Mass Carbon

Nitrate

Sulfate
35 

Figure 28. El Dorado Springs – Mass Concentrations Monitoring Data for Worst 20% Days. 

Figure 29. El Dorado Springs – Mass Concentrations Monitoring Data for Best 20% Days. 

0

5

10

15

20

25

30

35

40

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Mass Concentrations (μg/m3)

El Dorado Springs ‐ Mass Concentrations for Worst

20% Days

Sea Salt

Coarse Mass

Soil

Elemental Carbon

Organic Mass Carbon

Amm Nitrate

Amm Sulfate

0

2

4

6

8

10

12

14

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Mass Concentrations (μg/m3)

El Dorado Springs ‐ Mass Concentrations for Best 20%

Days

Sea Salt

Coarse Mass

Soil

Elemental Carbon

Organic Mass Carbon

Amm Nitrate

Amm Sulfate
36 

C.2. Visibility Trends in Nearby Out-of-State Class I Areas 

Two Class I areas are located within 250 km of the Missouri boundary, Upper Buffalo and Caney Creek 

which are in Arkansas. These areas were included in the 2009 RH plan analysis; therefore, a brief 

summary of their visibility trends is included here. The reasonable progress summary tables below 

depict a downward trend in visibility impairment in these areas, as was also shown for the areas within 

Missouri. This supports the claim that Missouri’s current strategy is still adequate and that reductions 

achieved in Missouri have benefited areas both in and outside the state. 

The following tables summarize visibility conditions, including five-year averages for this first planning 

period, for individual species as well as total light extinction, and deciviews, for the two nearby Class I 

areas located in Arkansas. Both tables depict downward trends in sulfate measurements as well as in 

total light extinction and deciviews. These are available on the WRAP TSS. 

C.2.1. Upper Buffalo Wilderness Area – Arkansas 

 

Table 9. Arkansas – Upper Buffalo Visibility Conditions Reasonable Progress Summary Table 

 

 

Class I Area Visibility Summary: Upper Buffalo W, AR Class I area 

Visibility Conditions: Worst 20% Days 

Reasonable Progress Summary

2000-04 Baseline 

Conditions

(Mm-1)

2005-09 Progress 

Period

(Mm-1)

2006-10 Progress 

Period

(Mm-1)

2007-11 Progress 

Period

(Mm-1)

2008-12 Progress 

Period

(Mm-1)

Sulfate 83.2 90.0 70.0 62.1 50.7

Nitrate 13.3 11.9 13.0 14.4 14.4

Organic 

Carbon 22.5 19.8 18.7 18.7 14.9

Elemental 

Carbon 4.7 4.7 4.2 4.1 3.7

Fine Soil 1.2 1.2 1.3 1.1 1.1

Coarse 

Material 6.8 4.9 5.5 5.1 5.4

Sea Salt 0.2 0.4 0.5 0.4 0.4
37 

Total Light 

Extinction 142.9 143.9 124.1 117.0 101.6

Deciview 26.3 25.9 24.7 24.1 22.9

C.2.2. Caney Creek Wilderness Area – Arkansas 

 Table 10. Arkansas – Caney Creek Visibility Conditions Reasonable Progress Summary Table. 

 

 

Class I Area Visibility Summary: Caney Creek W, AR Class I area 

Visibility Conditions: Worst 20% Days 

Reasonable Progress Summary

2000-04 Baseline 

Conditions

(Mm-1)

2005-09 Progress 

Period

(Mm-1)

2006-10 Progress 

Period

(Mm-1)

2007-11 Progress 

Period

(Mm-1)

2008-12 Progress 

Period

(Mm-1)

Sulfate 87.1 87.0 63.4 53.9 51.9

Nitrate 13.8 9.5 11.2 12.6 12.5

Organic 

Carbon 23.4 16.4 14.8 14.1 13.3

Elemental 

Carbon 4.8 4.2 3.5 3.3 3.3

Fine Soil 1.1 1.2 1.5 1.3 1.4

Coarse 

Material 3.7 4.0 4.3 4.3 4.2

Sea Salt 0.2 0.3 0.3 0.4 0.5

Total Light 

Extinction 145.1 133.6 110.1 100.9 97.9

Deciview 26.4 25.3 23.7 23.0 22.7
38 

D. Emissions Progress 

 

Section 51.308(g)(4) 

An analysis tracking the change over the past 5 years in emissions of pollutants contributing to visibility 

impairment from all sources and activities within the State. Emissions changes should be identified by 

type of source or activity. The analysis must be based on the most recent updated emissions inventory, 

with estimates projected forward as necessary and appropriate, to account for emissions changes during 

the applicable 5-year period.

According to the EPA’s recent guidance on 5-year progress reports, in order to track changes in 

emissions over the past 5 years: State-wide emissions from at least two separate points in time, at least 5 

years apart, with one being the most recent updated emission inventory year, must be compared. The 

Air Program selected to compare data from 2005, 2008, and 2011, which exceeds the aforementioned 

minimum requirements for this report element. The following three tables include emissions totals from 

different source categories as reported in the National Emission Inventory (NEI), in 2011, 2008, and 

2005, respectively. As mentioned before, the pollutants that affect visibility the most include: sulfur 

dioxide, nitrogen oxides, particulate matter, and in some cases Volatile Organic Compounds (VOCs). A 

graph including these pollutants that depicts the downward trend in point source emissions over the last 

three NEI years, is shown in Figure 30. Generally downward trends for these pollutants correlate 

strongly to a reduction in visibility impairment, as was shown for the areas of interest in previous 

sections. 

Emissions that contribute to visibility impairment can be from both manmade and natural sources, which 

can also be viewed as controllable and uncontrollable emissions. Controlling point sources provides a 

much higher level of reduction certainty than other source sectors; therefore, point source emissions 

trends are the most relevant to visibility improvement, as discussed in this report. Though the 

decreasing trend in point source emissions of SO2 and NOX are of the greatest significance to visibility 

improvement, other changes in emission levels also occurred between 2008 and 2011 that warrant 

clarification. Point source carbon monoxide (CO) levels increased by 23% or 21,033 tons from 2008 to 

2011. This increase in CO emissions is due to increased industrial activity and increased demand for 

power generation over this period. Point source PM2.5 emission levels increased by 6% or 567.53 tons 

between 2008 and 2011. Many point sources had significant changes in PM2.5 emissions. The increases 

in PM2.5 emissions are due to both updated stack test emission factors and increased activities at several 

sources. During this period, there were also decreases in emissions due to the shutdown of HolcimClarksville’s main operations and reduced activities at several other sources. The overall effect was a 

small increase in emissions. Despite these increases in emissions, the decrease in SO2 and NOX

emissions from point sources and the corresponding improvement in visibility conditions are most 

significant and therefore are the focus of this report. 

Nonpoint fire source emissions increased for all pollutants from 2008-2011. Per EPA’s Draft 

2011NEIv1 Technical Support Document from November 2013, 

(http://www.epa.gov/ttn/chief/net/2011nei/2011_neiv1_tsd_draft.pdf), page 209 describes the 2011 fire 

inventory and compares it to 2008. Their estimate of about 30% more acres burned in 2011 compared to 

2008 is reflected in the higher emissions in 2011. The events cited in the 2011 fire inventories include 

several forest fires of over 1,000 acres within the Mark Twain National Forest in Southern Missouri. A 

windstorm in 2009 knocked down much timber in the area providing ample fuel for the 2011 fires. 
39 

According to the USDA Forest Service Fiscal Year 2010 Monitoring and Evaluation Report for the 

Mark Twain National Forest, page 24, 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5401002.pdf, FY08 was an anomalously 

low year for wildland fires, with only 3,150 acres burned compared to the 5-year period with between 

5,000 and 7,500 acres burned. Page 28 also shows that prescribed fire burn acreage of 22,551 was lower 

than following years with 34,000 and 42,000 acres burned, on track to meet their goal of 45,000 acres 

burned annually to meet forest management goals. 

Biogenic emissions also changed between 2008 and 2011 with some pollutants increasing and some 

decreasing. EPA used their Biogenic Emissions Inventory System (BEIS) version 3.14 to create the 

2011 inventory with 2011 meteorology. EPA used BEIS 3.14 with 2007 meteorology to create the 2008 

inventory. The technical support documents for the 2008 and 2011 inventories do not explicitly describe 

the changes to the vegetation dataset or other factors between years; therefore, EPA would need to 

clarify the reason for the changes in biogenic emissions between 2008 and 2011. 

The theme of this section is that the paramount pollutants to visibility improvement, SO2 and NOX 

emissions, show a steady downward trend over the last 5 years that can be linked to steadily improving 

visibility conditions. Though other emissions varied slightly during this first planning period, the main 

visibility impacting pollutants have decreased and visibility has improved. 
40 

Table 11. 2011 Missouri Emission Inventory as reported to the NEI.

CO NH3 NOX PM10‐PRI PM25‐PRI SO2 

113,272.26 1,642.30 92,721.41 16,726.61 9,834.40 255,21

6,931.82 1,716.57 123.17 106.55 21

120,204.08 1,642.30 94,437.98 16,849.78 9,940.94 255,43

577,332.72 63,288.46

45,214.61 4,521.46

187,392.57 37,478.18

680,308.91 9,936.42 11,274.56 73,499.14 59,444.47 6,00

115,151.42 124,463.94 14,402.78 21,606.47 19,375.72 99

795,460.33 134,400.36 25,677.34 905,045.51 184,108.29 6,99

599,053.56 2,587.85 180,579.42 8,415.68 6,759.82 1,20316,737.16 50.76 41,970.54 4,133.56 3,952.02 10

5,331.30 16.57 36,093.55 1,194.79 1,104.83 37

322,068.46 67.33 78,064.09 5,328.35 5,056.85 47

138,953.65 28,310.97 

1,975,740.08 138,697.84 407,069.79 935,639.32 205,865.91 264,11

Area Source Total

2011 Missouri Emission Inventory ‐ Statewide Totals in tons per year

Permitted Facilities

Airports

Point Source Total

Paved and Unpaved Roads

Construction Dust

Agricultural Tilling

Fires (Agricultural, Prescribed, Wildland)

All other area sources

Biogenic Total

Statewide Totals

Onroad Mobile

Mobile Equipment from Nonroad Model

Commercial Marine, Locomotive

Offroad Mobile Total
41 

Table 12. 2008 Missouri Emission Inventory as reported to the NEI.

CO NH3 NOX PM10-PRI PM25-PRI SO2 

 1,655 92,239 129,953 18,318 9,267 367,

 

 - 5,215 1,714 118 45 

 

 1,655 97,454 131,667 18,436 9,312 367,

 

 59,357.59 545,853.93 4,284.01 42,840.09

 36,793.16 183,967.32

 4,786.40 317,134.78 5,355.11 33,515.30 28,964.19 2,411

 

 125,959.11 78,609.33 15,684.64 21,876.74 13,173.76 44,212

 

 130,745.51 395,744.12 21,039.75 828,053.39 142,572.70 46,623

 

978,206.68 6,919.69 117,463.88 3,516.20 2,289.89 1,21366,432.23 48.12 47,584.00 4,626.39 4,427.17 88

 17.19 5,654.53 38,156.92 1,269.45 1,175.73 533

 

372,086.76 65.32 85,740.93 5,895.84 5,602.90 1,42

 29,967.34 123,861.94 

 139,385.97 1,967,353.23 385,878.57 855,901.84 159,777.65 416,830

 

Area Source Total

2008 Missouri Emission Inventory ‐ Statewide Totals in tons per year

Permitted Facilities

Airports

Point Source Total

Paved and Unpaved Roads

Construction Dust

Agricultural Tilling

Fires (Agricultural, Prescribed, Wildland)

All other area sources

Biogenic Total

Statewide Totals

Onroad Mobile

Mobile Equipment from Nonroad Model

Commercial Marine, Locomotive

Offroad Mobile Total
42 

Table 13. 2005 Missouri Emission Inventory as reported to the NEI.

State Data Category CO NH3 NOx PM10‐PRI PM25‐PRI 

MO Event 5,848.25 97.76 171.01 676.40 573.22 

MO Nonpoint 309,960.74 115,064.35 108,752.50 968,551.08 134,742.75 MO Nonroad 3,223.15 17.44 63.50 43.82 

MO Onroad 1,249,014.53 7,061.16 159,980.03 4,487.03 3,163.71 

MO Point 85,276.36 1,005.39 163,012.19 22,200.27 13,058.87 

MO Biogenic (duplicate 2002) *** 134,123.40 22,518.60 

Statewide Total (tons) 1,787,446.43 123,228.65 454,451.78 995,978.28 151,582.36 

** Point source emissions in the NEI do not match emissions in Missouri's database.

*** EPA did not run the biogenic model in 2005 due to the reduced effort year, so 2002 emissions were copied forward (as was done for non

See http://www.epa.gov/ttn/chief/net/2005inventory.html for an explanation of the 2005 reduced effort inventory.

Due to differences in the point source totals in the NEI and MoEIS, below is a display of the first‐cut emissions from MoEIS for comparison a

State Data Category CO NH3 NOx PM10‐PRI PM25‐PRI 

MO Point 102,945.18 2,691.58 169,128.59 19,617.73 3,404.17 

2005 Missouri Emission Inventory ‐ Statewide Totals in tons per year
43 

Figure 30. Missouri’s Point Source Total Emission Trends for Top Visibility Impairing Pollutants; 2005, 2008, 201

y = ‐11429x + 2E+07

y = ‐16668x + 3E+07

0

50000

100000150000200000250000300000350000400000

2004 2005 2006 2007 2008 2009 2010 2011 201

Emissions in Tons Per Year

Year

Missouri's Point Source Total Emissions Trends for Top Visibility Impairing

Pollutants, From 2005, 2008, and 2011 NEI's
44 

E. Assessment of Changes Impeding Visibility Progress 

Section 51.308(g)(5) 

An assessment of any significant changes in anthropogenic emissions within or outside the State 

that have occurred over the past 5 years that have limited or impeded progress in reducing 

pollutant emissions and improving visibility.

The visibility and pollutant trends from the three monitoring sites indicate an overall decreasing 

trend in visibility impairment, as discussed in previous sections. However, one extraneous peak 

appears in the data for 2010, especially at the El Dorado protocol site. This can most likely be 

attributed to a fire event that occurred that year. Missouri State University (in Springfield, 

Missouri) monitored an exceedance of PM2.5 (35.7 μg/m3, 24-hour average) on March 6, 2010. 

There was a prescribed fire agricultural burning activity in the region prior to the exceedance. 

However, the PM2.5 concentrations during the remainder of 2010 and in the preceding and 

following years were measurably lower than the standard so the single exceedance was not 

enough to trigger a violation in any of the design values that include 2010. 

Missouri adopted its current Smoke Management Plan (SMP) in 2007. The purpose of the SMP 

is to identify the responsibilities of the department, FLMs and state land managers to coordinate 

procedures that mitigate the impacts of prescribed fire and wildland fire. The plan was designed 

to meet the policies of the EPA’s Interim Air Quality Policy on Wildland and Prescribed Fires 

(1998). This SMP establishes a basic framework of procedures and requirements for managing 

smoke from fires managed for resource benefits. The intent of a SMP is to mitigate the nuisance 

and public safety hazards posed by smoke intrusions into populated areas; to prevent 

deterioration of air quality and NAAQS violations; and to address visibility impacts in 

mandatory federal Class I areas. Class I areas are protected visual environments and are 

particularly sensitive receptors to smoke intrusion and subsequent visibility impairment. The 

purpose of the Missouri SMP is to provide additional protection to the federal Class I areas. 

If in the future there is a fire event that results in a NAAQS violation or other extreme case, the 

SMP may undergo an evaluation for possible revision, to prevent such a scenario from recurring. 

As mentioned in previous sections, there is an overall downward trend in visibility impairment 

that can be expected to continue in the coming years as more federal regulations are 

implemented and as federal health-based standards continue to be tightened. As depicted in 

Table 2, there are several facilities with large expected changes within the next few years. These 

changes will contribute to the downward trend as well. 

 

F. Assessment of Current Strategy 

Section 51.308(g)(6) 

An assessment of whether the current implementation plan elements and strategies are sufficient 

to enable the State, or other States with mandatory Federal Class I areas affected by emissions 

from the State, to meet all established reasonable progress goals. 
45 

The realized and planned controls and reductions discussed in Section A detail the current 

strategy as relied upon in the 2009 RH plan as well as additional measures that were not relied 

upon but will aid visibility improvement. The realized reductions and improvements are 

evidenced in the emissions trends and extensive visibility analyses contained in Sections B and 

C, respectively. Section D also details realized emission reductions that have occurred in the 

first planning period. 

Based on the trends and data analyses contained in the preceding sections, the current relied upon 

strategy as established in the 2009 RH plan continues to be sufficient in achieving the reasonable 

progress goals for 2018. Table 4 summarizes Missouri’s Class I Areas’ visibility conditions 

including the baseline conditions compared to current trends for each area, based on available 

monitoring data. The glidepath from baseline conditions to the 2018 RPGs is compared to the 

trend of monitored data for each area, and the monitored trends are currently below this 

glidepath. This reinforces the assessment that the current strategy is still adequate. In addition, 

the current strategy continues to be sufficient in not impeding visibility progress in nearby Class 

I areas, i.e. Upper Buffalo and Caney Creek in Arkansas, as evidenced by the downward trends 

in visibility impairment seen in both areas, depicted in Tables 9 and 10, respectively. The 

downward trends in nearby out-of-state Class I areas further reinforces that Missouri’s current 

strategy continues to be sufficient in reducing visibility impairment in Class I areas. 

G. Review of Visibility Monitoring Strategy 

Section 51.308(g)(7) 

A review of the State's visibility monitoring strategy and any modifications to the strategy as 

necessary. 

The Missouri Regional Haze monitoring strategy will continue to rely on the IMPROVE 

Monitoring Network in the Hercules Glades Wilderness and Mingo Wildlife Refuge Class I 

areas of the state. 

The 2009 RH plan indicated that when CENRAP was created the organization identified large 

visibility data voids in southern Arkansas, Iowa, Kansas, Southern Minnesota, Nebraska, and 

Oklahoma. Only five IMPROVE sites were located in the CENRAP region at that time. 

Because of this evaluation, states added other sites to fill some spatial gaps in the IMPROVE 

monitoring network. Between 2000 and 2003, five more IMPROVE sites and 15 IMPROVE 

protocol sites were installed in the CENRAP Region. Missouri installed an IMPROVE protocol 

sampler located at the El Dorado Springs ambient air monitoring site in Cedar County, Missouri. 

Missouri will continue IMPROVE monitoring at Hercules Glades Wilderness and Mingo 

Wildlife refuge Class I areas consistent with the requirements of 40 CFR 51.308(d)(4)(iv). 

IMPROVE Protocol monitoring will continue at El Dorado Springs since this data can 

supplement potential data analysis projects which may be needed to address issues regarding 

regional transport of PM2.5 air pollution regulated under the recently revised Annual PM2.5 

NAAQS. El Dorado Springs is classified as a regional transport site for PM2.5 consistent with the 

network design requirements of 40 CFR 58 Appendix D, Section 4.7.3. 
46 

The three IMPROVE monitoring sites provide spatial coverage for the Regional Haze program. 

There are no weaknesses in the network or any plans to change the monitoring network. 

However, recent reductions in both state and federal funding in recent years have put core 

monitoring programs under considerable strain. Federal funding for the Regional Haze program 

is critical for continued operation of Class I area IMPROVE monitoring. Federal funding 

supports all of the analytical analysis for the Missouri IMPROVE monitoring sites. If federal 

funding were reduced such that the State of Missouri would be required to fund some or all of 

the sample analysis, serious consideration would be given to whether or not the El Dorado 

Springs protocol site would be continued. 

H. Determination of Adequacy 

 

Section 51.308(h) 

(h) Determination of the adequacy of existing implementation plan. At the same time the State is 

required to submit any 5-year progress report to the EPA in accordance with paragraph (g) of 

this section, the State must also take one of the following actions based upon the information 

presented in the progress report: 

(1) If the State determines that the existing implementation plan requires no further substantive 

revision at this time in order to achieve established goals for visibility improvement and 

emissions reductions, the State must provide to the Administrator a negative declaration that 

further revision of the existing implementation plan is not needed at this time. 

(2) If the State determines that the implementation plan is or may be inadequate to ensure 

reasonable progress due to emissions from sources in another State(s) which participated in a 

regional planning process, the State must provide notification to the Administrator and to the 

other State(s) which participated in the regional planning process with the States. The State 

must also collaborate with the other State(s) through the regional planning process for the 

purpose of developing additional strategies to address the plan's deficiencies. 

(3) Where the State determines that the implementation plan is or may be inadequate to ensure 

reasonable progress due to emissions from sources in another country, the State shall provide 

notification, along with available information, to the Administrator. 

(4) Where the State determines that the implementation plan is or may be inadequate to ensure 

reasonable progress due to emissions from sources within the State, the State shall revise its 

implementation plan to address the plan's deficiencies within one year. 

Based on the analysis and trends discussed in preceding sections, Missouri has determined that 

the current strategy as established in the 2009 RH plan, continues to be adequate and sufficient in 

achieving the goals laid out by the Federal Regional Haze Rule. Based on the options given and 

the evidence presented in this report, Missouri submits a negative declaration specifying that no 

additional controls or further revision of the 2009 RH plan is necessary during this, the first 5-

year progress report. 
47 

III. General Planning Provisions 

A. EPA Administrative Process Requirements 

The Air Program has been working with EPA Region 7 to simplify general procedural 

requirements. The following two memoranda were the result of nationwide EPA and State 

cooperation and were taken into consideration when developing this report and throughout the 

corresponding consultation and public participation process. 

 (1) Memorandum from Janet McCabe to the EPA Regional Administrators: Regional 

Consistency for the Administrative Requirements of State Implementation Plan Submittals and 

the Use of “Letter Notices.” April 11, 2011. 

http://www.epa.gov/airquality/urbanair/sipstatus/docs/mccabeLltrRAs.pdf

(2) Memorandum from Janet McCabe to the EPA Regional Administrators: Guidance for 

Preparing Letters Submitting State Implementation Plans (SIPs) to the EPA and for Preparing 

Public Notices for SIPs. November 22, 2011. 

http://www.epa.gov/airquality/urbanair/sipstatus/docs/FINALSIPGuidelinesSubLtrsPN.pdf 

B. Report Submission 

Pursuant to the requirements of 51.308(a) and (b), this Missouri Regional Haze 5-Year Progress 

Report is being submitted to the EPA for inclusion into the Missouri State Implementation Plan 

(SIP) as adopted to meet the requirements of EPA’s Regional Haze Rule that was implemented 

to comply with requirements set forth in the CAA. This report is being submitted as a SIP 

revision. Elements of this report address the core requirements pursuant to 40 CFR 51.308(d). 

In addition, this plan addresses regional planning; state/tribe and FLM coordination; and contains 

a commitment to provide plan revisions and adequacy determinations. Missouri will have 

adopted this plan submittal in accordance with state laws and rules. This report is due within 5 

years of the initial Missouri Regional Haze plan submittal date to EPA. The original plan was 

submitted on August 5, 2009, so this 5-year progress report is due to EPA no later than August 5, 

2014. 

C. Public Participation 

In accordance with the federal Regional Haze Rule, the Air Program is required to hold a public 

hearing prior to adoption of this progress report 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 30 days prior to holding such hearing for this state plan as follows: 

 Federal Land Managers (FLMs) were provided the opportunity for review of this report 

beginning on February 14, 2014, which is at least 60 days prior to the scheduled public 

hearing for this report. 

 Notice of availability of the Regional Haze 5-Year Progress Report was posted on the 

Department of Natural Resources’ Air Pollution Control Program website on April 28, 2014, 

at: http://dnr.mo.gov/env/apcp/public-notices.htm 
48 

 The public comment period for this Missouri Regional Haze 5-Year Progress Report opened 

when it was posted on the Department of Natural Resources’ Air Pollution Control Program 

website on Monday, April 28, 2014, and closed on Thursday, June 5, 2014, seven days after 

the public hearing. 

 The public hearing on the Regional Haze 5-Year Progress Report was scheduled for 9:00 

a.m., Thursday, May 29, 2014. The public hearing was held at the St. Louis Regional Office, 

7545 S. Lindbergh, Suite 220, DESE Conference Room, in St. Louis, Missouri. 

A printout of the online public notice with date stamp is included in Appendix B. 

A copy of the MACC adoption signature page is included in Appendix D. 

D. Consultation and Commitment to Revise Plan 

In keeping with the EPA’s recommendations related to consultation, the Air Program enlisted the 

support of appropriate state and local air pollution control agencies as well as EPA Region 7 and 

the Federal Land Management Agencies (FLMs) to formulate this report. As part of this 

commitment, the Air Program made an advanced, draft copy of this report available to the 

aforementioned agencies and sought their input. Comments received as part of this consultation 

are included in Appendix C. Relevant comments were taken into account in the development of 

this progress report. 

Consultation between the states and the FLMs will continue as the federal regional haze program 

progresses. Missouri will continue to coordinate with other states, FLMs, EPA, CenSARA, 

CENRAP, and other RPOs to maintain/improve the visibility in Missouri’s Class I areas. This 

coordination will continue to include five-year progress reports and any necessary SIP revisions. 

If deemed necessary, there will be face-to-face consultation meetings. It will also provide for 

consideration of any other programs that are implemented and have the potential to aid in 

reducing the impairment of visibility in Class I areas. 
LIST OF APPENDICES 

Appendix A: Underlying Data Tables 

Appendix B: Online Public Notice Screenshot with Date Stamp 

Appendix C: Written Comments and Responses and Consultation Correspondence 

Appendix D: MACC Adoption Signature Page 
Appendix A: Underlying Data Tables 

Missouri’s CAMD Acid Rain Program Unit Data: 

State Year SO2 (tons) NOx (tons) Heat Input (MMBtu) MO 2007 255201.637 105921.124 800610887.9MO 2008 258268.854 88599.982 770260872.5MO 2009 240201.919 53474.868 761579014MO 2010 236216.924 58364.015 808226596.8MO 2011 196255.617 63277.666 838655088.9MO 2012 138805.424 69561.901 769110993.1

Visibility Data from the WRAP TSS for Mingo, Hercules Glades, and El Dorado Springs: Note: Underlying Data for Figures included in the Visibility Progress Section are also publicly available online t

TSS website, http://vista.cira.colostate.edu/tss/Results/HazePlanning.aspx. 

Extinction (Mm-1) and Deciviews for Worst 20% Days:Site Method Year N Deciview Total Extinction SO4 Extinction NO3 Extinction OMC Extinction ECExtinction Soil Extinction MING1 NIA 2001 23 29.5 200.25 91.58 39.27 38.47 8.95 1.55 MING1 NIA 2002 13 141.31 18.35 1.73 MING1 NIA 2003 19 113.31 29.7 1.1 MING1 NIA 2004 21 72.09 21.54 1.2 MING1 NIA 2005MING1 NIA 2006 23 27.3 158.68 101.77 9.43 17.05 6.19 2.71 
MING1 NIA 2007 23 29.1 195.08 120.95 10.75 32.32 8.09 2.12 

MING1 NIA 2008 22 26.8 147.21 87.92 14.4 20.13 5.56 1.67 MING1 NIA 2009 20 25.1 126.28 64.02 15.35 20.73 5.8 1.44 MING1 NIA 2010 21 25.7 135.02 48.48 29.56 29.33 6.07 2.2 MING1 NIA 2011 20 25.2 125.99 53.56 29.62 18.75 5.06 1.1 HEGL1 NIA 2002 25 27.2 156.8 104.15 14.6 18.16 4.96 1.04 HEGL1 NIA 2003 24 26.6 149.33 87.02 14.99 27.36 5.59 0.82 HEGL1 NIA 2004 25 26.5 147.58 72.64 24.15 30.28 5.12 0.89 HEGL1 NIA 2005 24 29.5 200.64 139.16 15.27 22.82 6.71 0.69 HEGL1 NIA 2006 24 25.9 138.54 76.78 20.29 19.51 5.62 1.5 HEGL1 NIA 2007 25 26.2 146.19 92.61 10 21.87 5.59 0.84 HEGL1 NIA 2008 22 25 125.01 73.04 19.41 13.84 3.57 0.77 HEGL1 NIA 2009 25 23.6 107.26 51.87 21.97 14.29 3.96 0.72 HEGL1 NIA 2010 24 23.6 107.09 42.24 27.31 16.48 4.33 0.91 HEGL1 NIA 2011 23 24.1 115.12 47.09 30.35 16.69 3.9 0.59 HEGL1 NIA 2012 25 21.2 86.08 37.65 11.9 16.25 4.15 0.63 ELDO1 NIA 2003 24 27.9 168.43 75.41 39.94 26.14 6.41 1.27 ELDO1 NIA 2004 23 26.6 149.22 58.82 37.27 30.32 4.8 1.05 ELDO1 NIA 2005 23 28.6 185.3 109.67 30.53 16.24 5.68 1.71 ELDO1 NIA 2006 20 26.1 138.25 66.63 30.74 14.06 5.02 1.63 ELDO1 NIA 2007 21 26.1 140.62 69.47 30.73 15.49 5.1 1.56 ELDO1 NIA 2008 25 24.5 117.74 55.36 23.79 15.54 4.3 0.96 ELDO1 NIA 2009 23 24.1 114.86 46.19 33.27 12.56 4.45 0.93 ELDO1 NIA 2010 23 24.7 121.79 37.77 50.74 13.19 3.99 0.69 ELDO1 NIA 2011 21 25.2 127.41 42.85 44.49 16.66 4.3 0.79 ELDO1 NIA 2012 24 23.4 106.08 38.74 25.47 11.2 3.87 2.75 
Mass Concentrations (μg/m3) for Worst 20% Days: 

Site Method Year N ammSO4 ammNO3 OMC EC Soil CM MING1 NIA 2001 23 8.78 3.85 8.39 0.9 1.55 14 MING1 NIA 2002 13 12.42 1.76 1.73 8.57 MING1 NIA 2003 19 10.89 3.15 1.1 7.44 MING1 NIA 2004 21 7.36 2.23 1.2 13.05 MING1 NIA 2006 23 9.68 1.09 4.63 0.62 2.71 15.27 MING1 NIA 2007 23 11.15 1.26 7.44 0.81 2.12 14.08 MING1 NIA 2008 22 8.69 1.51 5.11 0.56 1.67 8.72 MING1 NIA 2009 20 6.58 1.59 5.31 0.58 1.44 11.09 MING1 NIA 2010 21 5.26 2.97 6.76 0.61 2.2 11.93 MING1 NIA 2011 20 5.88 3.05 4.98 0.51 1.1 9.13 HEGL1 NIA 2002 25 9.93 1.45 4.89 0.5 1.04 4.8 HEGL1 NIA 2003 24 8.71 1.65 6.4 0.56 0.82 4.24 HEGL1 NIA 2004 25 7.42 2.51 6.87 0.51 0.89 4.87 HEGL1 NIA 2005 24 12.56 1.47 5.71 0.67 0.69 6.91 HEGL1 NIA 2006 24 7.83 2.21 4.96 0.56 1.5 5.48 HEGL1 NIA 2007 25 9.07 1.13 5.63 0.56 0.84 6.47 HEGL1 NIA 2008 22 7.57 1.89 3.9 0.36 0.77 5.25 HEGL1 NIA 2009 25 5.59 2.29 3.86 0.4 0.72 5.32 HEGL1 NIA 2010 24 4.8 2.83 4.32 0.43 0.91 7.93 HEGL1 NIA 2011 23 5.26 2.98 4.55 0.39 0.59 8.56 HEGL1 NIA 2012 25 4.33 1.29 4.05 0.41 0.63 7.01 ELDO1 NIA 2003 24 7.79 3.97 6.18 0.64 1.27 13.76 ELDO1 NIA 2004 23 6.25 3.72 6.68 0.48 1.05 8.89 ELDO1 NIA 2005 23 10.4 3.12 4.36 0.57 1.71 17.01 ELDO1 NIA 2006 20 7.09 3.28 3.84 0.5 1.63 14.56 ELDO1 NIA 2007 21 7.26 3.22 4.26 0.51 1.56 11.38 
ELDO1 NIA 2008 25 6 2.52 4.12 0.43 0.96 10.82 

ELDO1 NIA 2009 23 5.11 3.31 3.58 0.45 0.93 10.3 ELDO1 NIA 2010 23 4.36 5.13 3.54 0.4 0.69 6.93 ELDO1 NIA 2011 21 4.95 4.4 4.52 0.43 0.79 11.19 ELDO1 NIA 2012 24 4.46 2.59 3.28 0.39 2.75 21.03 

Extinction (Mm-1) and Deciviews for Best 20% Days: 

Site Method Year N Deciview Total Extinction SO4 Extinction NO3 Extinction OMC Extinction ECExtinction Soil Extinction MING1 NIA 2001 22 13.7 39.81 13.16 5.08 4.99 2.1 0.37 MING1 NIA 2002 12 15.81 4.29 0.56 MING1 NIA 2003 18 13.98 4.05 0.46 MING1 NIA 2004 20 12.45 4.36 0.28 MING1 NIA 2006 23 14.2 42.1 14.15 4.06 5.01 2.42 0.61 MING1 NIA 2007 22 15.1 46.08 14.5 6.11 5.79 2.58 0.72 MING1 NIA 2008 22 13.9 41.02 14 4.51 5.09 1.82 0.47 MING1 NIA 2009 19 12.3 34.62 11.79 2.12 4.24 1.62 0.29 MING1 NIA 2010 21 13.5 39.04 14.07 2.88 4.86 1.78 0.64 MING1 NIA 2011 19 12.5 35.73 9.05 2.74 4.95 1.91 0.52 HEGL1 NIA 2002 24 13.6 39.28 11.69 6.09 5.47 2.37 0.3 HEGL1 NIA 2003 24 12.2 34.44 9.25 4.32 5.26 1.83 0.34 HEGL1 NIA 2004 24 12.7 36.02 11.6 4.27 4.6 1.83 0.32 HEGL1 NIA 2005 23 13.6 40.28 14.83 4.16 4.79 2.19 0.39 HEGL1 NIA 2006 23 13.3 38.3 13.72 3.91 4.89 2.51 0.3 HEGL1 NIA 2007 24 13 37.3 10.21 5.99 5.1 1.92 0.32 HEGL1 NIA 2008 21 11.7 32.74 10.48 2.85 4.13 1.41 0.33 HEGL1 NIA 2009 24 11 30.4 9.52 2.36 3.65 1.41 0.26 
HEGL1 NIA 2010 23 11.5 31.87 9.35 3.1 3.49 1.41 0.43 

HEGL1 NIA 2011 22 11.4 31.49 8.67 3 3.9 1.63 0.28 HEGL1 NIA 2012 24 10.9 30.18 7.28 2.7 3.62 1.78 0.39 ELDO1 NIA 2003 24 13.4 38.84 9.5 5.66 5.9 2.37 0.4 ELDO1 NIA 2004 22 12.7 36.49 9.78 4.09 5.4 2.04 0.55 ELDO1 NIA 2005 22 13.8 40.53 12.32 6.11 4.52 2.23 0.53 ELDO1 NIA 2006 19 14.2 41.81 13.41 5.75 4.73 2.47 0.44 ELDO1 NIA 2007 21 13.7 40.03 11.68 5.4 4.5 1.87 0.67 ELDO1 NIA 2008 24 11.8 32.92 10 3.49 3.75 1.48 0.35 ELDO1 NIA 2009 23 11.9 33.15 9.73 4.78 3.63 1.48 0.29 ELDO1 NIA 2010 23 11.8 33.04 9.04 3.63 3.8 1.58 0.49 ELDO1 NIA 2011 20 12.7 36.18 9.54 4.29 4.28 1.6 0.47 ELDO1 NIA 2012 23 11.5 31.9 7.11 3.71 3.72 1.48 0.59 

Mass Concentrations (μg/m3) for Best 20% Days: 

Site Method Year N ammSO4 ammNO3 OMC EC Soil CM SeaSaltMING1 NIA 2001 22 1.68 0.61 1.61 0.21 0.37 3.5 0MING1 NIA 2002 12 1.89 0.48 0.56 5.38 0MING1 NIA 2003 18 1.74 0.48 0.46 5.34 0MING1 NIA 2004 20 1.54 0.5 0.28 6.81 0.04MING1 NIA 2006 23 1.72 0.47 1.6 0.24 0.61 5.81 0.06MING1 NIA 2007 22 1.8 0.71 1.84 0.26 0.72 6.76 0.05MING1 NIA 2008 22 1.74 0.53 1.63 0.18 0.47 4.96 0.02MING1 NIA 2009 19 1.5 0.26 1.39 0.16 0.29 4.02 0.02MING1 NIA 2010 21 1.77 0.34 1.57 0.18 0.64 4.58 0.01MING1 NIA 2011 19 1.16 0.33 1.58 0.19 0.52 6.77 0.08
HEGL1 NIA 2002 24 1.5 0.72 1.75 0.24 0.3 3.94

0

HEGL1 NIA 2003 24 1.17 0.5 1.69 0.18 0.34 3.79 0.03HEGL1 NIA 2004 24 1.46 0.49 1.49 0.18 0.32 3.53 0.05HEGL1 NIA 2005 23 1.87 0.51 1.54 0.22 0.39 4.7 0.02HEGL1 NIA 2006 23 1.67 0.44 1.59 0.25 0.3 2.94 0.03HEGL1 NIA 2007 24 1.27 0.69 1.64 0.19 0.32 4.24 0.03HEGL1 NIA 2008 21 1.34 0.33 1.33 0.14 0.33 4.15 0.01HEGL1 NIA 2009 24 1.23 0.29 1.2 0.14 0.26 3.39 0.03HEGL1 NIA 2010 23 1.18 0.37 1.15 0.14 0.43 5.05 0.01HEGL1 NIA 2011 22 1.09 0.35 1.28 0.16 0.28 4.58 0.04HEGL1 NIA 2012 24 0.94 0.32 1.19 0.18 0.39 5.37 0.03ELDO1 NIA 2003 24 1.2 0.66 1.87 0.24 0.4 6.6 0.01ELDO1 NIA 2004 22 1.28 0.5 1.71 0.2 0.55 5.62 0.05ELDO1 NIA 2005 22 1.59 0.74 1.46 0.22 0.53 6.18 0.02ELDO1 NIA 2006 19 1.67 0.67 1.53 0.25 0.44 6.51 0.02ELDO1 NIA 2007 21 1.48 0.63 1.46 0.19 0.67 7.85 0.03ELDO1 NIA 2008 24 1.28 0.43 1.23 0.15 0.35 4.55 0.02ELDO1 NIA 2009 23 1.27 0.58 1.2 0.15 0.29 3.35 0.04ELDO1 NIA 2010 23 1.18 0.45 1.24 0.16 0.49 5.78 0.01ELDO1 NIA 2011 20 1.23 0.51 1.4 0.16 0.47 7.9 0.04ELDO1 NIA 2012 23 0.94 0.45 1.23 0.15 0.59 6.74 0.04
Mingo’s Reasonable Progress Chart of 5-Year Averages for Worst and Best 20% Days – from T

Class I Area Visibility Summary: Mingo NWRW, MO Class I area 

Visibility Conditions: Worst 20% Days 

Reasonable Progress Summary

2000-04 

Baseline 

Conditions 

(Mm-1) 

2005-09 

Progress 

Period 

(Mm-1) 

2006-10 

Progress 

Period 

(Mm-1) 

2007-11 

Progress 

Period 

(Mm-1) 

2008-12 

Progress 

Period 

(Mm-1) 

Sulfate 104.6 93.7 84.6 75.0 63.5 

Nitrate 27.2 12.5 15.9 19.9 22.2 

Organic 

Carbon 20.5 22.6 23.9 24.3 22.2 

Elemental 

Carbon 5.5 6.4 6.3 6.1 5.6 

Fine Soil 1.4 2.0 2.0 1.7 1.6 

Coarse 

Material 6.5 7.4 7.3 6.6 6.1 

Sea Salt 0.2 0.3 0.3 0.3 0.3 

Total Light 

Extinction 177.9 156.8 152.5 145.9 133.6 

Deciview 28.02 27.1 26.8 26.4 25.7 
Class I Area Visibility Summary: Mingo NWRW, MO Class I area

Visibility Conditions: Best 20% Days

Reasonable Progress Summary 

2000-04 

Baseline 

Conditions 

2005-09 

Progress 

Period 

2006-10 

Progress 

Period 

2007-11 

Progress 

Period 

2008-12 

Progress 

Period 

Sulfate 13.8 13.6 13.7 12.7 12.2 

Nitrate 4.4 4.2 3.9 3.7 3.1 

Organic 

Carbon 6.3 5 5 5 4.8 

Elemental 

Carbon 2.3 2.1 2 1.9 1.8 

Fine Soil 0.4 0.5 0.5 0.5 0.5 

Coarse 

Material 3.2 3.2 3.1 3.3 3 

Sea Salt 0.1 0.2 0.2 0.2 0.2 

Total Light 

Extinction 42.5 41 40.6 39.3 37.6 

Deciview 14.3 13.9 13.8 13.5 13.1 
Hercules Glades’ Reasonable Progress Chart of 5-Year Averages for Worst and Best 20% Days – 

Class I Area Visibility Summary: Hercules-Glades W, MO Class I area 

Visibility Conditions: Worst 20% Days 

Reasonable Progress Summary

2000-04 Baseline 

Conditions 

(Mm-1) 

2005-09 Progress 

Period 

(Mm-1) 

2006-10 Progress 

Period 

(Mm-1) 

2007-11 Progress 

Period 

(Mm-1) 

2008-12 Pr

Period 

(Mm-1

Sulfate 87.9 86.7 67.3 61.4 50.4 

Nitrate 17.9 17.4 19.8 21.8 22.2 

Organic 

Carbon 25.3 18.5 17.2 16.6 15.5 

Elemental 

Carbon 5.2 5.1 4.6 4.3 4.0 

Fine Soil 0.9 0.9 0.9 0.8 0.7 

Coarse 

Material 2.8 3.5 3.7 4.0 4.1 

Sea Salt 0.2 0.5 0.3 0.3 0.2 

Total Light 

Extinction 151.2 143.5 124.8 120.1 108.1 

Deciview 26.7 26.0 24.9 24.5 23.5 
Class I Area Visibility Summary: Hercules-Glade W, MO Class I area

Visibility Conditions: Best 20% Days

Reasonable Progress Summary 

2000-04 

Baseline 

Conditions 

2005-09 

Progress 

Period 

2006-10 

Progress 

Period 

2007-11 

Progress 

Period 

2008-12 

Progress 

Period 

Sulfate 10.8 11.8 10.7 9.6 9.1 

Nitrate 4.9 3.9 3.6 3.5 2.8 

Organic 

Carbon 5.1 4.5 4.3 4.1 3.8 

Elemental 

Carbon 2 1.9 1.7 1.6 1.5 

Fine Soil 0.3 0.3 0.3 0.3 0.3 

Coarse 

Material 2.3 2.3 2.4 2.6 2.7 

Sea Salt 0.2 0.1 0.1 0.1 0.1 

Total Light 

Extinction 36.6 35.8 34.1 32.8 31.3 

Deciview 12.8 12.5 12.1 11.7 11.3 
Arkansas – Upper Buffalo 

Class I Area Visibility Summary: Upper Buffalo W, AR Class I area 

Visibility Conditions: Worst 20% Days 

Reasonable Progress Summary

2000-04 Baseline 

Conditions

(Mm-1)

2005-09 Progress 

Period

(Mm-1)

2006-10 Progress 

Period

(Mm-1)

2007-11 Progress 

Period

(Mm-1)

2008-12 Progress 

Period

(Mm-1)

Sulfate 83.2 90.0 70.0 62.1 50.7

Nitrate 13.3 11.9 13.0 14.4 14.4

Organic 

Carbon 22.5 19.8 18.7 18.7 14.9

Elemental 

Carbon 4.7 4.7 4.2 4.1 3.7

Fine Soil 1.2 1.2 1.3 1.1 1.1

Coarse 

Material 6.8 4.9 5.5 5.1 5.4

Sea Salt 0.2 0.4 0.5 0.4 0.4
Total Light 

Extinction 142.9 143.9 124.1 117.0 101.6

Deciview 26.3 25.9 24.7 24.1 22.9

Arkansas – Caney Creek 

Class I Area Visibility Summary: Caney Creek W, AR Class I area 

Visibility Conditions: Worst 20% Days 

Reasonable Progress Summary

2000-04 Baseline 

Conditions

(Mm-1)

2005-09 Progress 

Period

(Mm-1)

2006-10 Progress 

Period

(Mm-1)

2007-11 Progress 

Period

(Mm-1)

2008-12 Progress 

Period

(Mm-1)

Sulfate 87.1 87.0 63.4 53.9 51.9

Nitrate 13.8 9.5 11.2 12.6 12.5

Organic 

Carbon 23.4 16.4 14.8 14.1 13.3

Elemental 

Carbon 4.8 4.2 3.5 3.3 3.3

Fine Soil 1.1 1.2 1.5 1.3 1.4
Coarse 

Material 3.7 4.0 4.3 4.3 4.2

Sea Salt 0.2 0.3 0.3 0.4 0.5

Total Light 

Extinction 145.1 133.6 110.1 100.9 97.9

Deciview 26.4 25.3 23.7 23.0 22.7

2013 EGU Control Summary for Units Subject to CAIR (queried from CAMD): 

FacilityName

Facility

ID(ORISPL)

Unit

ID Year Unit Type

Fuel Type

(Primary)

Fuel Type

(Secondary)

SO2

Control(s) NOx Control(s)

Asbury 2076 1 2013

Cycloneboiler Coal

OverfireAir<br>SelectiveCatalyticReduction

AudrainPower Plant 55234 CT1 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

AudrainPower Plant 55234 CT2 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners
Audrain

Power Plant 55234 CT3 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

AudrainPower Plant 55234 CT4 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

AudrainPower Plant 55234 CT5 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

AudrainPower Plant 55234 CT6 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

AudrainPower Plant 55234 CT7 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

AudrainPower Plant 55234 CT8 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

Blue Valley 2132 3 2013

Tangentially‐fired Coal

Pipeline

Natural Gas

Low NOx Burner

Technology w/

Closed‐coupledOFA

ChamoisPower Plant 2169 2 2013

Cycloneboiler Coal Diesel Oil

Chillicothe 2122 GT1A 2013

Combustionturbine

PipelineNaturalGas Diesel Oil

Chillicothe 2122 GT1B 2013

Combustionturbine

PipelineNaturalGas Diesel Oil

Chillicothe 2122 GT2A 2013

Combustionturbine

PipelineNaturalGas Diesel Oil
Chillicothe 2122 GT2B 2013

Combustionturbine

PipelineNaturalGas Diesel Oil

Columbia 2123

6 2013 Stoker Coal 

Columbia 2123

7 2013 Stoker Coal 

Columbia 2123

8 2013

Dry bottom

wall‐fired

boiler

PipelineNaturalGas

ColumbiaEnergyCenter (MO) 55447 CT01 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

ColumbiaEnergyCenter (MO) 55447 CT02 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

ColumbiaEnergyCenter (MO) 55447 CT03 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

ColumbiaEnergyCenter (MO) 55447 CT04 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

DogwoodEnergyFacility 55178 CT‐1 2013

Combinedcycle

PipelineNaturalGas

SelectiveCatalyticReduction

DogwoodEnergyFacility 55178 CT‐2 2013

Combinedcycle

PipelineNaturalGas

SelectiveCatalyticReduction

EmpireDistrict Elec

Co Energy

Ctr 6223 1 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection
Empire

District Elec

Co Energy

Ctr 6223 2 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

EmpireDistrict Elec

Co Energy

Ctr 6223 3A 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

EmpireDistrict Elec

Co Energy

Ctr 6223 3B 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

EmpireDistrict Elec

Co Energy

Ctr 6223 4A 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

EmpireDistrict Elec

Co Energy

Ctr 6223 4B 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

Essex Power

Plant 7749 1 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

Fairgrounds 2082 CT01 2013

Combustionturbine Diesel Oil

GreenwoodEnergyCenter 6074 1 2013

Combustionturbine

PipelineNaturalGas Diesel Oil

GreenwoodEnergyCenter 6074 2 2013

Combustionturbine

PipelineNaturalGas Diesel Oil

GreenwoodEnergyCenter 6074 3 2013

Combustionturbine

PipelineNaturalGas Diesel Oil
Greenwood

EnergyCenter 6074 4 2013

Combustionturbine

PipelineNaturalGas Diesel Oil

Hawthorn 2079 5A 2013

Dry bottom

wall‐fired

boiler Coal

Dry LimeFGD

Low NOx Burner

Technology w/

OverfireAir<br>SelectiveCatalyticReduction 

Hawthorn 2079 6 2013

Combustionturbine

PipelineNaturalGas Other

Hawthorn 2079 7 2013

Combustionturbine

PipelineNaturalGas Other

Hawthorn 2079 8 2013

Combustionturbine

PipelineNaturalGas Other

Hawthorn 2079 9 2013

Combinedcycle

PipelineNaturalGas

SelectiveCatalyticReduction

HigginsvilleMunicipalPower Plant 2131 4A 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

HigginsvilleMunicipalPower Plant 2131 4B 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

HoldenPower Plant 7848 1 2013

Combustionturbine

PipelineNaturalGas Diesel Oil

Dry Low NOx

Burners<br>Water Injection
Holden

Power Plant 7848 2 2013

Combustionturbine

PipelineNaturalGas Diesel Oil

Dry Low NOx

Burners<br>Water Injection

HoldenPower Plant 7848 3 2013

Combustionturbine

PipelineNaturalGas Diesel Oil

Dry Low NOx

Burners<br>Water Injection

HowardBend 2102 CT1A 2013

Combustionturbine Diesel Oil

HowardBend 2102 CT1B 2013

Combustionturbine Diesel Oil

Iatan 6065 1 2013

Dry bottom

wall‐fired

boiler Coal

Wet Lime

FGD

Low NOx Burner

Technology w/

OverfireAir<br>OverfireAir<br>SelectiveCatalyticReduction 

Iatan 6065 2 2013

Dry bottom

wall‐fired

boiler Coal

Wet Lime

FGD

Low NOx Burner

Technology w/

OverfireAir<br>OverfireAir<br>SelectiveCatalyticReduction 

James River 2161 **GT1 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

James River 2161 **GT2 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection
James River 2161 3 2013

Dry bottom

wall‐fired

boiler Coal

Pipeline

Natural Gas

Low NOx Burner

Technology w/

Overfire Air

James River 2161 4 2013

Dry bottom

wall‐fired

boiler Coal

Pipeline

Natural Gas

Low NOx Burner

Technology w/

Overfire Air

James River 2161 5 2013

Dry bottom

wall‐fired

boiler Coal

Pipeline

Natural Gas

Low NOx Burner

Technology w/

Overfire Air

John TwittyEnergyCenter 6195 1 2013

Dry bottom

wall‐fired

boiler Coal

Diesel Oil,

PipelineNatural Gas

Other<br>Selective Catalytic

Reduction

John TwittyEnergyCenter 6195 2 2013

Dry bottom

wall‐fired

boiler Coal

Pipeline

Natural Gas

FluidizedBedLimestoneInjection

SelectiveCatalyticReduction 

John TwittyEnergyCenter 6195 CT1A 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

John TwittyEnergyCenter 6195 CT1B 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

John TwittyEnergyCenter 6195 CT2A 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

John TwittyEnergyCenter 6195 CT2B 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection
Labadie 2103 1 2013

Tangentially‐fired Coal

Low NOx Burner

Technology w/

Closed‐coupled/Separated OFA

Labadie 2103 2 2013

Tangentially‐fired Coal

Low NOx Burner

Technology w/

Closed‐coupled/Separated OFA

Labadie 2103 3 2013

Tangentially‐fired Coal

Low NOx Burner

Technology w/

Closed‐coupled/Separated OFA

Labadie 2103 4 2013

Tangentially‐fired Coal

Low NOx Burner

Technology w/

Closed‐coupled/Separated OFA

Lake Road 2098 6 2013

Cycloneboiler Coal

PipelineNatural Gas Overfire Air

Lake Road 2098 GT5 2013

Combustionturbine

PipelineNaturalGas Diesel Oil

McCartneyGeneratingStation 7903 MGS1A 2013

Combustionturbine

PipelineNaturalGas Water Injection

McCartneyGeneratingStation 7903 MGS1B 2013

Combustionturbine

PipelineNaturalGas Water Injection
McCartney

GeneratingStation 7903 MGS2A 2013

Combustionturbine

PipelineNaturalGas Water Injection

McCartneyGeneratingStation 7903 MGS2B 2013

Combustionturbine

PipelineNaturalGas Water Injection

Meramec 2104 1 2013

Tangentially‐fired Coal

Low NOx Burner

Technology w/

Separated OFA

Meramec 2104 2 2013

Tangentially‐fired Coal

Low NOx Burner

Technology w/

Separated OFA

Meramec 2104 3 2013

Dry bottom

wall‐fired

boiler Coal

Low NOx Burner

Technology w/

Overfire Air

Meramec 2104 4 2013

Dry bottom

wall‐fired

boiler Coal

Low NOx Burner

Technology w/

Overfire Air

Meramec 2104 CT01 2013

Combustionturbine Diesel Oil

Meramec 2104 CT2A 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

Meramec 2104 CT2B 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

Mexico 6650 CT01 2013

Combustionturbine Diesel Oil

Moberly 6651 CT01 2013

Combustionturbine Diesel Oil
Montrose 2080 1 2013

Tangentially‐fired Coal

Montrose 2080 2 2013

Tangentially‐fired Coal Overfire Air

Montrose 2080 3 2013

Tangentially‐fired Coal Overfire Air

Moreau 6652 CT01 2013

Combustionturbine Diesel Oil

New Madrid

Power Plant 2167 1 2013

Cycloneboiler Coal Diesel Oil

SelectiveCatalyticReduction<br>Overfire Air

New Madrid

Power Plant 2167 2 2013

Cycloneboiler Coal Diesel Oil

SelectiveCatalyticReduction<br>Overfire Air

NodawayPower Plant 7754 1 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

NodawayPower Plant 7754 2 2013

Combustionturbine

PipelineNaturalGas

Dry Low NOxBurners

NortheastGeneratingStation 2081 11 2013

Combustionturbine Diesel Oil

NortheastGeneratingStation 2081 12 2013

Combustionturbine Diesel Oil

NortheastGeneratingStation 2081 13 2013

Combustionturbine Diesel Oil
Northeast

GeneratingStation 2081 14 2013

Combustionturbine Diesel Oil

NortheastGeneratingStation 2081 15 2013

Combustionturbine Diesel Oil

NortheastGeneratingStation 2081 16 2013

Combustionturbine Diesel Oil

NortheastGeneratingStation 2081 17 2013

Combustionturbine Diesel Oil

NortheastGeneratingStation 2081 18 2013

Combustionturbine Diesel Oil

Peno Creek

EnergyCenter 7964 CT1A 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

Peno Creek

EnergyCenter 7964 CT1B 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

Peno Creek

EnergyCenter 7964 CT2A 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

Peno Creek

EnergyCenter 7964 CT2B 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

Peno Creek

EnergyCenter 7964 CT3A 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection
Peno Creek

EnergyCenter 7964 CT3B 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

Peno Creek

EnergyCenter 7964 CT4A 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

Peno Creek

EnergyCenter 7964 CT4B 2013

Combustionturbine

PipelineNaturalGas Diesel Oil Water Injection

Ralph Green

Station 2092 3 2013

Combustionturbine

PipelineNaturalGas Water Injection

Rush Island 6155 1 2013

Tangentially‐fired Coal

Low NOx BurnerTechnology w/

Closed‐coupled/Separated OFA

Rush Island 6155 2 2013

Tangentially‐fired Coal

Low NOx BurnerTechnology w/

Closed‐coupled/Separated OFA

Sibley 2094 1 2013

Cycloneboiler Coal

OverfireAir<br>SelectiveNon‐catalyticReduction

Sibley 2094 2 2013

Cycloneboiler Coal

OverfireAir<br>SelectiveNon‐catalyticReduction
Sibley 2094 3 2013

Cycloneboiler Coal

OverfireAir<br>SelectiveCatalyticReduction

Sikeston 6768 1 2013

Dry bottom

wall‐fired

boiler Coal Other Oil

Selective Non‐catalyticReduction<br>Low NOx Burner

Technology (Dry

Bottom only)

Sioux 2107 1 2013

Cycloneboiler Coal

Wet

Limestone

OverfireAir<br>Other

Sioux 2107 2 2013

Cycloneboiler Coal

Wet

Limestone

OverfireAir<br>Other

SouthHarperPeakingFacility 56151 1 2013

Combustionturbine

PipelineNaturalGas

SouthHarperPeakingFacility 56151 2 2013

Combustionturbine

PipelineNaturalGas

SouthHarperPeakingFacility 56151 3 2013

Combustionturbine

PipelineNaturalGas

St. Francis

Power Plant 7604 1 2013

Combinedcycle

PipelineNaturalGas

Dry Low NOxBurners<br>Selective Catalytic

Reduction
St. Francis

Power Plant 7604 2 2013

Combinedcycle

PipelineNaturalGas

Dry Low NOxBurners<br>Selective Catalytic

Reduction

State Line(MO) 7296 1 2013

Combustionturbine

PipelineNaturalGas Diesel Oil

Dry Low NOx

Burners<br>Water Injection

State Line(MO) 7296 41671 2013

Combinedcycle

PipelineNaturalGas

SelectiveCatalyticReduction

State Line(MO) 7296 41672 2013

Combinedcycle

PipelineNaturalGas

SelectiveCatalyticReduction

Thomas Hill

EnergyCenter 2168 MB1 2013

Cycloneboiler Coal Diesel Oil

OverfireAir<br>SelectiveCatalyticReduction

Thomas Hill

EnergyCenter 2168 MB2 2013

Cycloneboiler Coal Diesel Oil

OverfireAir<br>SelectiveCatalyticReduction

Thomas Hill

EnergyCenter 2168 MB3 2013

Dry bottom

wall‐fired

boiler Coal Diesel Oil

OverfireAir<br>Low NOxBurnerTechnology (Dry

Bottomonly)<br>Selective Catalytic

Reduction
Appendix B: Online Public Notice Screenshot with Date Stamp 

 
 
Appendix C: Written Comments and Responses and Consultation Correspondence 

In order to fulfill the 60-day required consultation with the Federal Land Management agencies 

(FLMs) the Air Program submitted an official letter and draft copy of the report with each of the 

three FLMs: Forest Service, Fish & Wildlife Service, and National Park Service, on February 14, 

2014. 

The same email from the Air Program Director with attached official letter and draft report was 

sent to all three agencies, as well as forwarded on to EPA Region 7 Staff. All emails/letters are 

included below for documentation purposes. Comments were requested back by April 18, 2014, 

in order to be incorporated before posting the report online for public notice. A conference call 

was held on March 17, 2014, with the Air Program and all three FLMs to discuss their comments 

and suggestions. Comments from the FLM agencies were shared with the Air Program via email 

and comment letters. These are included in this appendix as well. 

The draft report was shared with the following FLM agency contacts, the same contacts all 

participated in the aforementioned conference call as well. 

Fish & Wildlife Service: Tim Allen 

Forest Service: Claire O’Dea and Bret Anderson (the report was forwarded to Bret after it was 

sent officially to Claire) 

National Park Service: Patricia Brewer 

Emails from Air Program Director to FLM agency contacts: 

From: Moore, Kyra 

Sent: Friday, February 14, 2014 4:18 PM 

To: tim_allen@fws.gov 

Cc: Vit, Wendy; Wilbur, Emily; Jurgensmeyer, Ashley 

Subject: Missouri Regional Haze Periodic Update 

Mr. Allen, 

Please find attached a cover letter and a draft report regarding the Missouri Department of Natural 

Resources Regional Haze Report. 

If you have any questions, please let us know. 

Thank you! 

Kyra L. Moore, Director 

MDNR Air Pollution Control Program 

1659 E. Elm Street 

Jefferson City, MO 65102 

(573) 751-7840 

(573) 751-0303 direct line 

 
From: Moore, Kyra 

Sent: Friday, February 14, 2014 4:38 PM 

To: cbodea@fs.fed.us 

Cc: Vit, Wendy; Wilbur, Emily; Jurgensmeyer, Ashley 

Subject: Missouri Regional Haze Periodic Update 

Ms. Odea, 

Please find attached a cover letter and a draft report regarding the Missouri Department of Natural 

Resources Regional Haze Report. 

If you have any questions, please let us know. 

Thank you! 

Kyra L. Moore, Director 

MDNR Air Pollution Control Program 

1659 E. Elm Street 

Jefferson City, MO 65102 

(573) 751-7840 

(573) 751-0303 direct line 

From: Moore, Kyra 

Sent: Friday, February 14, 2014 4:40 PM 

To: Patricia_F_Brewer@nps.gov 

Cc: Vit, Wendy; Wilbur, Emily; Jurgensmeyer, Ashley 

Subject: Missouri Regional Haze Periodic Update 

Ms. Brewer, 

Please find attached a cover letter and a draft report regarding the Missouri Department of Natural 

Resources Regional Haze Report. 

If you have any questions, please let us know. 

Thank you! 

Kyra L. Moore, Director 

MDNR Air Pollution Control Program 

1659 E. Elm Street 

Jefferson City, MO 65102 

(573) 751-7840 

(573) 751-0303 direct line 

 
Official letter to FLMs (attached to the above emails): 

Mr. Tim Allen 

U.S. Fish & Wildlife Service 

7333 West Jefferson, Suite 375 

Lakewood, CO 80235 

RE: Regional Haze Rule Periodic Update Consultation with Federal Land Management 

Agencies 

Dear Mr. Allen: 

The purpose of this correspondence is to begin consultation with the Federal Land 

Management (FLM) agencies on the 1999 Regional Haze Rule (RHR) requirement for periodic 

reports. Enclosed with this letter is Missouri’s draft Regional Haze 5-Year Progress Report for 

the two federal Class I Areas: Hercules Glades National Wilderness Area and Mingo National 

Wildlife Refuge. 

The Missouri Department of Natural Resources (department) has prepared the enclosed report 

to meet the requirements at 40 CFR 51.308(g), which address the need for periodic reports that 

evaluate progress towards the reasonable progress goals established in the State 

Implementation Plan (SIP). The RHR also requires states to consult with the FLM agencies at 

least 60 days prior to holding any public hearing on a RHR SIP or SIP revision (40 CFR 

51.308(i)). 

State periodic reports for this first implementation period are due to the U.S. Environmental 

Protection Agency (EPA) no later than five years after the state’s initial SIP submittal to EPA. 

The department submitted its initial Regional Haze SIP to the EPA on August 5, 2009. 

Therefore, Missouri’s completed progress report is due to EPA no later than August 2014. In 

order to facilitate this process and to continue our collective efforts to develop a complete SIP 

package for submittal in August of this year, the department has tentatively scheduled a public 

hearing for this report on May 29, 2014 and the subsequent adoption hearing for July 30, 2014. 

The department requests that the FLM acknowledge the date of this submission as the formal 

commencement of the required 60-day consultation period. We would appreciate your 

comments on or before April 18, 2014. Should you have any further questions concerning 

Missouri’s 5-Year Progress Report, please do not hesitate to contact Ashley Jurgensmeyer at 

the Missouri Department of Natural Resources’ Air Pollution Control Program, 

P.O. Box 176, Jefferson City, Missouri 65102, or by telephone at (573) 751-4817. 

Sincerely, 

AIR POLLUTION CONTROL PROGRAM 
Kyra L. Moore 

Director 

KLM:ajc 

Enclosures: Copy of Missouri’s Draft Regional Haze 5-Year Progress Report 

c: Project #1999-RH-7 

Ms. Claire O’Dea, Ph.D. 

Air Quality Specialist 

USDA Forest Service Eastern Region 

Rosslyn Plaza C 

1601 North Kent Street, Suite 400 

Arlington, VA 22209 

RE: Regional Haze Rule Periodic Update Consultation with Federal Land Management 

Agencies 

Dear Ms. O’Dea: 

The purpose of this correspondence is to begin consultation with the Federal Land Management 

(FLM) agencies on the 1999 Regional Haze Rule (RHR) requirement for periodic reports. 

Enclosed with this letter is Missouri’s draft Regional Haze 5-Year Progress Report for the two 

federal Class I Areas: Hercules Glades National Wilderness Area and Mingo National Wildlife 

Refuge. 

The Missouri Department of Natural Resources (department) has prepared the enclosed report to 

meet the requirements at 40 CFR 51.308(g), which address the need for periodic reports that 

evaluate progress towards the reasonable progress goals established in the State Implementation 

Plan (SIP). The RHR also requires States to consult with the FLM agencies at least 60 days prior 

to holding any public hearing on a RHR SIP or SIP revision (40 CFR 51.308(i)). 

State periodic reports for this first implementation period are due to the U.S. Environmental 

Protection Agency (EPA) no later than five years after the state’s initial SIP submittal to EPA. The 

department submitted its initial Regional Haze SIP to the EPA on August 5, 2009. Therefore, 

Missouri’s completed progress report is due to EPA no later than August 2014. In order to 

facilitate this process and to continue our collective efforts to develop a complete SIP package for 

submittal in August of this year, the department has tentatively scheduled a public hearing for this 

report on May 29, 2014 and the subsequent adoption hearing for July 30, 2014. 

The department requests that the FLM acknowledge the date of this submission as the formal 

commencement of the required 60-day consultation period. We would appreciate your 

comments on or before April 18, 2014. Should you have any further questions concerning 

Missouri’s 5-Year Progress Report, please do not hesitate to contact Ashley Jurgensmeyer at the 
Missouri Department of Natural Resources’ Air Pollution Control Program, P.O. Box 176, 

Jefferson City, Missouri 65102, or by telephone at (573) 751-4817. 

Sincerely, 

AIR POLLUTION CONTROL PROGRAM 

Kyra L. Moore 

Director 

KLM:ajc 

Enclosures: Copy of Missouri’s Draft Regional Haze 5-Year Progress Report 

c: Project #1999-RH-7 

Ms. Patricia Brewer 

Environmental Protection Specialist 

Air Resource Division 

National Park Service 

Post Office Box 25287 

Denver, CO 80225 

RE: Regional Haze Rule Periodic Update Consultation with Federal Land Management 

Agencies 

Dear Ms. Brewer: 

The purpose of this correspondence is to begin consultation with the Federal Land Management 

(FLM) agencies on the 1999 Regional Haze Rule (RHR) requirement for periodic reports. 

Enclosed with this letter is Missouri’s draft Regional Haze 5-Year Progress Report for the two 

federal Class I Areas: Hercules Glades National Wilderness Area and Mingo National Wildlife 

Refuge. 

The Missouri Department of Natural Resources (department) has prepared the enclosed report to 

meet the requirements at 40 CFR 51.308(g), which address the need for periodic reports that 

evaluate progress towards the reasonable progress goals established in the State Implementation 

Plan (SIP). The RHR also requires states to consult with the FLM agencies at least 60 days prior 

to holding any public hearing on a RHR SIP or SIP revision (40 CFR 51.308(i)). 

State periodic reports for this first implementation period are due to the U.S. Environmental 

Protection Agency (EPA) no later than five years after the state’s initial SIP submittal to EPA. The 

department submitted its initial Regional Haze SIP to the EPA on August 5, 2009. Therefore, 

Missouri’s completed progress report is due to EPA no later than August 2014. In order to 

facilitate this process and to continue our collective efforts to develop a complete SIP package for 
submittal in August of this year, the department has tentatively scheduled a public hearing for this 

report on May 29, 2014 and the subsequent adoption hearing for July 30, 2014. 

The department requests that the FLM acknowledge the date of this submission as the formal 

commencement of the required 60-day consultation period. We would appreciate your 

comments on or before April 18, 2014. Should you have any further questions concerning 

Missouri’s 5-Year Progress Report, please do not hesitate to contact Ashley Jurgensmeyer at the 

Missouri Department of Natural Resources’ Air Pollution Control Program, P.O. Box 176, 

Jefferson City, Missouri 65102, or by telephone at (573) 751-4817. 

Sincerely, 

AIR POLLUTION CONTROL PROGRAM 

Kyra L. Moore 

Director 

KLM:ajc 

Enclosures: Copy of Missouri’s Draft Regional Haze 5-Year Progress Report 

c: Project #1999-RH-7 

Email from Air Program to EPA Region 7 informally sharing draft report: 

From: Vit, Wendy 

Sent: Tuesday, February 18, 2014 8:37 AM 

To: Amy Bhesania 

Cc: Wilbur, Emily; Jurgensmeyer, Ashley 

Subject: FW: Missouri Regional Haze Periodic Update 

Hi Amy. I’m forwarding the regional haze 5-year progress report. Please share with others as 

appropriate. (This email happens to be the one we sent to the National Park Service. We also sent 

copies to the Forest Service and Fish & Wildlife; let me know if you want me to forward those 

emails to you for your records.) We’re asking for comments from the FLMs by April 18, 2014, 

and we’d appreciate any feedback from you by then as well. Please let us know if you have 

questions or if you’d like to discuss this draft. Thanks. 

Wendy Vit 

Air Quality Planning Section Chief 

Air Pollution Control Program 

Missouri Department of Natural Resources 

(573) 526-3167 

wendy.vit@dnr.mo.gov

Comment Letter Received from the Forest Service on March 21, 2014: 
File Code: 2580 

Date: March 21, 2014 

 

Ms. Kyra L. Moore 

Director 

MDNR Air Pollution Control Program 

1659 E. Elm Street 

Jefferson City, MO 65102 

Dear Ms. Moore: 

The USDA Forest Service has completed our review of the document entitled “State of Missouri 

Regional Haze Plan 5-Year Progress Report: A Missouri State Implementation Plan Revision.” 

We appreciated the opportunity to review the document and the chance to once again work 

cooperatively with your staff. 

We concur with your findings that the Missouri Air Pollution Control Program is on track to 

meet the reasonable progress goal for the Hercules Glades Wilderness, a Federally mandated 

Class I area. The current projections of sulfur dioxide emissions from the electric generating 

units in Missouri are significantly lower than were originally projected for 2018 in the Regional 

Haze State Implementation Plan. Therefore, we agree with your conclusion that no additional 

controls are necessary for the first planning period for emission sources in Missouri in order to 

achieve reasonable progress in visibility for the Hercules Glades Wilderness. 

We do, however, have a few recommendations to enhance the clarity of the 5-Year Progress 

Report: 

1. The EPA document General Principles for the 5-Year Regional Haze Progress 

Reports for the Initial Regional Haze State Implementation Plans (2013), Section C. 

Visibility Progress, states that, “For each mandatory Class I Federal area within the 

State, the State must assess the following visibility conditions and changes, with 

values for most impaired and least impaired days expressed in terms of 5-year 

averages of these annual values.” In the 5-Year Progress Report, Missouri assesses 

visibility conditions and changes by calculating a rate of improvement comparing 

baseline with current conditions. We, therefore, recommend recalculating visibility 

improvements by expressing visibility conditions and changes in terms of 5-year 

averages. 

2. The Glide Path Projected 2018 Conditions value listed for Hercules-Glades Class I 

Area in Table 4, also referred to later in the document as the established 2018 

Reasonable Progress Goal (RPG), is listed at 22.63 deciviews. This value does not 

match the 2009 SIP 2018 RPG value of 23.06 deciviews (taken from Table 10.1, 

2018 Modeled Predictions where Missouri stated, “Missouri has determined that the 

modeled rate of visibility improvement by 2018 shown in Table 10.1 is reasonable 

and hereby adopts it as the RPG for the listed Class I areas”). We recommend 

clarifying why the 2018 RPG listed in the MO 5-Year Progress Report differs from 

the 2018 RPG selected in the 2009 SIP. 
3. As stated above, Missouri assesses visibility conditions and changes by calculating a 

rate of improvement comparing baseline with current conditions in the 5-Year 

Progress Report. In Table 4 of the 5-Year Progress Report, Missouri lists a projected 

rate of progress for Hercules-Glades Wilderness (from 2001 to June 2012, based on 

monitored values) of 0.494 deciviews/year. Trying to recreate these calculations, we 

calculate a rate of 0.4625 dv/yr, resulting in an expected 2018 visibility of 18.26 dv 

(instead of 18.84 dv). We ask for clarification of these calculations, including 

specifying values used for current visibility for 20% haziest and clearest days, so that 

these calculations can be replicated. 

4. The 5-Year Progress Report, Section A.2.1., discusses SO2 and NOx RACT in St. 

Louis. From our understanding, St. Louis has not officially been designated by EPA 

as nonattainment of the new PM2.5 12 μg National Ambient Air Quality Standard 

(NAAQS) standard, and further has petitioned EPA to not be included in the 

nonattainment area due to the fact that violations have occurred only on the Illinois 

side of St. Louis. We, therefore, recommend that this section reflect the uncertainty 

in RACT/RACM implementation based on the fact that St. Louis is not currently 

designated as nonattainment of the new PM2.5 NAAQS. 

5. The 5-Year Progress Report, Section C, identifies trends for visibility on the best and 

worst 20% sampling days for the three locations with IMPROVE monitors. This 

trends analysis focuses on sulfate and nitrate concentrations. Visibility impairment in 

the form of light extinction also occurs due to organic matter and elemental carbon. 

In fact, for the 2012 average of the worst 20% days, organic matter contributes more 

to light extinction than ammonium nitrate. We, therefore, recommend that trends in 

organic carbon matter and elemental carbon be included in the analysis. 

6. The 5-Year Progress Report, Section C, calculates rate of improvement from baseline 

to present and states that natural conditions will be achieved between 2025-2035 for 

all of the IMPROVE locations if this rate of improvement remains constant. Analysis 

of future on-the-books/on-the-way controls does not support a continued rate of 

improvement. We recommend providing justification for this assertion, or removing 

it from the analysis. 

We look forward to our continued close cooperation toward the national goal of no “man-made” 

visibility impairment to the Class I areas in our region by 2064. If you have questions, please 

contact Claire O’Dea at (202) 205-1686. 

Sincerely, 

/s/ William B. Nightingale 

WILLIAM B. NIGHTINGALE 

Forest Supervisor 

cc: 

Claire O’Dea 

 
Emailed comments from the Fish & Wildlife Service, received March 17, 2014: 

From: Allen, Tim [mailto:tim_allen@fws.gov] 

Sent: Monday, March 17, 2014 1:43 PM 

To: Jurgensmeyer, Ashley 

Cc: Wilbur, Emily; Patricia Brewer; Anderson, Bret A -FS; O'Dea, Claire B -FS 

Subject: Re: Missouri's Draft Regional Haze 5-Year Report Consultation 

Hi, 

Thank you for inviting me to discuss your Regional Haze 5yr review. I do appreciate the work 

you've put into this document and offer the following comments for consideration. 

1. In section E., visibility impacts from agricultural burning activity is attributed to impeding 

visibility progress. No discussion is provided on current or future potential changes to smoke 

management procedures that might resolve this concern. Agricultural burning is a source 

category that should be addressed by a certified smoke management plan, which includes use of 

best management practices, day-to-day burn calls, long term tracking of emissions, and a 

declaration that Class I areas are sensitive receptors. 

2. In section C.1.1 and associated Figures, data begins with 2006. Although monitoring data 

prior to 2006 had substitution requirements due to missing data, it was none-the-less used as part 

of establishing the visibility baseline for MINGO NWR in your Regional Haze SIP. Since this 5 

year review addresses progress from your prior SIP, it is important to continue to report those 

monitoring years. Please include data from 2002 on as with the other Class I area reported. 

3. In section C.1.1 narrative, a projection that natural conditions will be met by 2025 is included 

in the draft. Although we appreciate you optimism, it is unlikely that future emission reductions 

will continue at previous rates. 

The mid-term review does not require sufficient modeling analysis or refinements to emission 

inventories in a way to appropriately revise Class I reasonable progress goals (RPG). Please 

consider waiting to revise Mingo's RPG until the next major RH SIP revision. 

Thank you, 

Tim 

Emailed Comments from National Park Service, received March 17, 2014: 

From: Brewer, Patricia [mailto:patricia_f_brewer@nps.gov] 

Sent: Monday, March 17, 2014 6:34 PM 

To: Jurgensmeyer, Ashley 

Cc: O'Dea, Claire B -FS; Wilbur, Emily; Anderson, Bret A -FS; Tim_Allen@fws.gov 

Subject: Re: Missouri's Draft Regional Haze 5-Year Report Consultation 

Ashley and Emily, 
Attached are tables and charts for Hercules Glade and Mingo that are copied from the WRAP's 

Technical Support System. http://vista.cira.colostate.edu/tss/Results/HazePlanning.aspx

The tables of 5-year averages show the contributions of different pollutant species to light 

extinction and help to understand the dv trends. 

The charts show the relative contributions of the pollutants and show the annual variability that 

is missing in the tables of 5-year averages. 

Section C 1.1.1 indicates that the Mingo OC and EC data were invalidated for 2002-2205. But 

data substitution was done using approved methods (Hercules Glade as the donor site?) and EPA 

approved the 2000-2004 baseline in your Regional Haze SIP. Also, your progress report is 

focusing on SO4 and NO3 trends, still valid in the 2000-2004 period (and used for Hercules 

Glade). So you probably could use the 2000-2004 baseline to keep the longer period of record. 

I will provide written comments on other points next week. 

thanks, Pat Brewer 

Letter from National Park Service, received April 17, 2014: 

TRANSMITTED VIA ELECTRONIC MAIL - NO HARDCOPY TO FOLLOW 

N3615 (2350) 

April 17, 2014 

Kyra L. Moore, 

Director, Air Pollution Control Program 

Missouri Department of Natural Resources 

1659 E. Elm Street 

Jefferson City, MO 65102 

Dear Ms. Moore: 

Thank you for the opportunity to review and comment on Missouri’s Regional Haze Plan 5-Year 

Progress Report. We agree with Missouri Air Pollution Control Program, consistent with the 

periodic reporting requirements of 40 CFR 51.308(g) and (h), that the emissions reductions 

under Missouri’s Regional Haze Plan are sufficient for Missouri to meet the 2018 Reasonable 

Progress Goals set in the State’s Regional Haze plan. We also agree that no further revision of 

the Regional Haze Plan is needed at this time to meet the 2018 goals. However, we did not see 

discussion of Missouri’s contributions to haze in Class I areas in neighboring states, as required 

under 51.308(g)(6). 

We have several suggestions to better support Missouri’s demonstration: 

Executive Summary: 

In response to comments on Section C, please revise the discussion of expected visibility 

improvements by 2018. 
Section A: Status of Emissions Control Strategies: 

For Electric Generating Units (EGU) that installed controls under the Clean Air Interstate Rule 

(CAIR), please provide summary of specific facilities, controls, and year that controls began 

operation. 

Section A3: Please clarify if any of the emission reductions expected between 2012 and 2017 

(Table 2) were included in the 2018 projection inventory and modeling that was used to set 2018 

reasonable progress goals. 

Section B: Emissions Reductions: 

Please add brief summary of nitrogen oxide emission trends for electric generating units (EGU) 

in Figure 2 and Table 3. 

Section C: Visibility Trends 

We recommend using the same baseline data and natural condition assumptions for Mingo in the 

progress report as were used in the Missouri Regional Haze Plan. 

Substituted data were developed for Mingo for the baseline period. 

We do not recommend using a partial year of data for 2012. The 2012 IMPROVE data are 

currently not publicly available, so we recommend that Missouri use IMPROVE data through 

2011. 

Missouri should not extrapolate from the rate of visibility improvement for 2006-2012 to 2018 or 

beyond (Figures 3, 11, 19.) Regional EGU controls between 2006 and 2012 significantly reduced 

sulfur dioxide emissions and sulfate concentrations in the Class I areas, but Missouri has not 

demonstrated that emissions reductions of that magnitude will continue in the future. We 

recommend that Missouri focus in Table 4 on visibility (measured in deciviews) for the 20% 

worst ad 20% best visibility days for the 2000-2004 

Baseline, Natural Conditions, 2018 Reasonable Progress Goals (from the Regional Haze Plan), 

and 2007-2011 5-year averages. Including pollutant contributions to light extinction would 

further identify the bases for the observed trends. These latter data are 

available on the WRAP Technical Support System website 

(http://vista.cira.colostate.edu/tss/Results/HazePlanning.aspx.) With the evidence available, 

Missouri can demonstrate that the state is on track to meet the 2018 reasonable progress goals. 

Redefining the 2018 goals would require regional emissions projections and regional air quality 

modeling that are beyond the expectations for the five year progress reports. 

Section E. Changes Impeding Visibility Progress 

Missouri did not include IMPROVE data to support the discussion of the contribution of 

prescribed fire in 2010 to visibility trends. You may want to add discussion of the role of 

agricultural burning compared to prescribed fire for forest management. Does Missouri 

have a smoke management plan? 

Section F. Assessment of Current Strategy 

Please add discussion of the contribution of Missouri emissions to haze in Class I areas in 

neighboring states. Source apportionment results from the Regional Haze Plan would support 

Missouri’s conclusion that it expects to meet the 2018 emission projections that 

were used to set reasonable progress goals for Class I areas in neighboring states and therefore is 

not impeding neighboring states from meeting their goals. 
Comment Letter from EPA Region 7 (Received June 2, 2014): 

Response to Received Comments: 

Response to Comments from Fish& Wildlife Service: (Emailed Comments 

received March 17, 2014) 

1. In response to comment 1., additional language was added to Section E. of the report. 

Specifically discussion was added to clarify the impact fire events could have on visibility 

conditions in sensitive Class I areas. In addition, Missouri’s current Smoke Management plan 

(SMP) should aid in protecting these visual environments and in the event of a violation or other 

extreme case the SMP may be evaluated and revised in order to properly protect these 

environments. 
2. All available visibility data was added to Section C. of the report in response to this comment 

and comments from other FLMs. 

3. Projections to 2018 and beyond were removed from the report in response to this comment 

and other FLM comments. 

Response to Comments from National Park Service: (Emailed Comments received 

March 17, 2014) 

1. The data used in the visibility analysis of this report in Section C., were updated using the 

Western Regional Air Partnership (WRAP) Technical Support System (TSS) data set as 

recommended by FLM comments and as referenced in the EPA’s Guiding Principles on 5-Year 

Reports document. 

2. The available 5-Year Average Summary tables and corresponding graphs were added to the 

visibility analysis section of the report. 

3. As mentioned in previous response to comments, all available data was added to the 

tables/graphs included in the visibility analysis section. 

Response to Comments from National Park Service: (Letter received April 17, 

2014)

1. The executive summary has been updated in response to this comment. 

2. In response to this comment, a table summarizing all SO2, NOX, and PM controls installed 

prior to emission year 2013 on Missouri EGU’s that are subject to CAIR was added to Appendix 

A. It was not included in the plan text due to its length. The table was generated by running a 

query of the EPA’s Clean Air Markets Division (CAMD) database. 

The expected facility changes included in Table 2 are new developments and are not yet 

permanent and enforceable; therefore, these changes were not included in the 2009 RH plan’s 

modeling efforts and language has been added to clarify this in the report in response to this 

comment. 

3. Brief language discussing the downward trend in NOx emissions and rates has been added to 

Section B in response to this comment. 

4. The baseline/natural conditions were changed to match 2009 RH plan estimations, this change 

is also discussed in the other comment responses as well. The partial year of data was removed 

from the analysis in response to this comment. The extrapolation to 2018 was removed from the 

report and a glidepath between the baseline and RPGs was added to show the trend of monitored 

data is below the glidepath and on track to achieve the RPGs. 

The available five-year average tables for all Class I areas for all speciated pollutant light 

extinctions and deciviews were added (from the TSS) to support the visibility analysis section in 

response to this and other comments received. 
5. Missouri currently has an adopted Smoke Management plan and additional clarifying 

language was added to Section E in response to this and other comments received. 

6. In response to this comment, monitoring trend data for the two nearby Class I areas in 

Arkansas were added to the visibility progress section of the report to reinforce the claim that 

Missouri will not prevent nearby areas from achieving their RPGs in 2018. Additional clarifying 

language was also added to Section F to fully address this comment. 

Response to Comments from Forest Service (Letter received March 21, 2014): 

1. All available 5-Year Average summary tables and graphs were added to the visibility analysis 

section of the report. The ‘reasonable progress’ tables were available using the WRAP TSS site, 

and include speciated pollutants, total light extinction and deciview trends to aid in 

characterizing visibility progress. 

2. and 3. In the first draft report, raw data was manipulated by the Air Program and due to slight 

differences, the RPGs were mischaracterized as different from the initial RH SIP. Therefore, the 

RPGs are indeed the same as adopted in the initial RH SIP and the data used for comparison and 

analysis was accessed (via the TSS) in final best/worst percent format to avoid any slight 

assumption differences due to external manipulation. The differences in data manipulation and 

assumptions as well as data availability at time of calculation can be accounted for the slight 

differences in values as discussed in Comment 3. Both comments are addressed by the 

replacement of data as described above. 

4. The reference to SO2 & NOx RACT in St. Louis was removed as it is no longer a control 

strategy, this was a remnant of the original SIP’s assumptions. The SO2 attainment 

demonstrations for Jackson and Jefferson Counties were added as a future control measure that 

will result in additional SO2 emission reductions not included in the initial RH SIP’s modeling 

efforts. 

5. Trends for all speciated pollutants were added to the analysis in response to this and other 

comments of the like. 

6. As mentioned in previous response to comments, the future predicted rate of visibility 

improvement to 2018 and beyond has been removed from the report. 

Response to Comments from EPA Region 7 (Letter received June 2, 2014): 

1. In response to comment 1, additional language was added to A.1.2. of the report to detail 

progress made by Holcim-Clarksville since the consent agreement. 

2. In response to comment 2, various minor changes were made to the report to correct any 

errors of tense, grammar, or spelling. 
3. In response to comment 3, additional explanation was added to Section D of the report to 

clarify referenced emissions trends and their correlation to overall visibility improvement. 

 
The Missouri Air Conservation Commission ADOPTS the following action on this 

28th day of August, 2014: 

Missouri State Implementation Plan Revision - Regional Haze Plan 5-Year 

Progress Report 

~7~..;;,o,JJ--/ ~~. ===========----, Chairman

__~ __ ____J _____, Vice Chairman 

_________________________________,Member 

_________________________________,Member 

_________________________________,Member 
The Missouri Air Conservation Commission ADOPTS the following action on this 

28th day of August, 2014: 

Missouri State Implementation Plan Revision - Regional Haze Plan 5-Year 

Progress Report 

~7~..;;,o,JJ--/ ~~. ===========----, Chairman

__~ __ ____J _____, Vice Chairman 

_________________________________,Member 

_________________________________,Member 

_________________________________,Member 
Jay Nixon, Governor 

Sara Parker Pauley, Director

Air Pollution Control Program

State Plan Actions                                                                    

On Public Notice | Proposed for Adoption

On Public Notice 

Missouri State Implementation Plan Revision – Regional Haze Plan 5-Year Progress Report 

The federal Clean Air Act establishes requirements for the protection of visibility in Class I 

areas, consisting of national parks and wilderness areas. States are required to submit 

state implementation plans (SIPs) that demonstrate reasonable progress toward meeting 

the national goal of a return to natural visibility conditions in Class I areas by 2064. There 

are two Class I areas in Missouri: Hercules Glades Wilderness Area and Mingo National 

Wildlife Refuge. Missouri’s regional haze SIP, which was submitted to the U.S. 

Environmental Protection Agency in August 2009, established visibility goals for the year 

2018 for each of the state’s Class I areas in order to make reasonable progress toward the 

2064 goal. The purpose of this report is to assess progress made toward the 2018 visibility 

goals in Hercules Glades and Mingo in the five years since Missouri’s regional haze SIP was 

submitted to EPA. This 5-year progress report demonstrates that both of Missouri’s Class I 

areas are expected to meet their 2018 visibility goals based on control strategies currently 

in place, which largely consist of sulfur dioxide and nitrogen oxides emission reduction 

measures for utilities, industrial boilers, and other sources.

Regional Haze Plan 5-Year Progress Report 

Appendices 

Submit Comments Now

A public hearing is scheduled for this plan action on May 29, 2014. Comments about this 

plan action will be accepted through the close of business on June 5, 2014.

Missouri State Implementation Plan Revision – Marginal Area Plan for the Missouri Portion of the St. Louis 

Nonattainment Area for the 2008 8-Hour Ground Level Ozone National Ambient Air Quality Standard

The purpose of this State Implementation Plan (SIP) revision is to address the emissions 

inventory and other marginal ozone nonattainment area requirements pursuant to Clean Air 

Act Section 182(a) for the Missouri portion of the St. Louis nonattainment area under the 

2008 8-hour ozone national ambient air quality standard (NAAQS). The Missouri portion of 

State Plan Actions on Public Notice - DNR Page 1 of 2

http://www.dnr.mo.gov/env/apcp/stateplanrevisions.htm 4/28/2014
the St. Louis nonattainment area includes the City of St. Louis and the Counties of St. 

Louis, St. Charles, Franklin, and Jefferson, which were designated as a marginal 

nonattainment area under the 2008 8-hour ozone NAAQS on May 21, 2012.

Marginal Area Plan for the Missouri Portion of the St. Louis Nonattainment Area for the 2008 

8-Hour Ground Level Ozone National Ambient Air Quality Standard

Appendix A 

Appendix B

Appendix B-1

Appendix B-2

Appendix B-3

Appendix B-4

Appendix B-5

Appendix B-6

Appendix B-7

Submit Comments Now

A public hearing is scheduled for this plan action on May 29, 2014. Comments about this 

plan action will be accepted through the close of business on June 5, 2014.

Proposed for Adoption

None at this time.

Back to top

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

http://www.dnr.mo.gov/env/apcp/stateplanrevisions.htm 4/28/2014
1

Bechtel, Cheri

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

Sent: Friday, April 25, 2014 2:54 PM

To: Bungart, Renee; Archer, Larry; Lovejoy, Victoria; Moore, Kyra; Vit, Wendy; Bechtel, Cheri; 

Crawford, Betsy; Terlizzi, Gena

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

Commission Public Hearing, May 29, 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 (579 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, May 29, 2014 beginning at 9 a.m. at the St. Louis Regional Office, 7545 S. Lindbergh, Suite 220, 

DESE Conference Room, St. Louis, Missouri. The commission will hear testimony related to the following 

proposed action(s): 

* 10 CSR 10-5.220 (amendment) Control of Petroleum Liquid Storage, Loading and Transfer 

 

This proposed amendment will remove the requirements for Stage II vapor recovery controls at 

gasoline dispensing facilities (GDFs) in the St. Louis area. Stage II systems control emissions of 

volatile organic compounds during vehicle refueling and have been an ozone-reduction measure in the 

St. Louis area since the late 1980s. In May 2012, the U.S. Environmental Protection Agency (EPA) 

determined that Onboard Refueling Vapor Recovery (ORVR) technology is in widespread use 

throughout the motor vehicle fleet for purposes of controlling motor vehicle refueling emissions. 

ORVR is an improved method of controlling the vapor displaced during refueling that is built into 

newer motor vehicles. ORVR makes Stage II controls obsolete, and EPA’s widespread use 

determination allows the removal of Stage II controls if Clean Air Act anti-backsliding requirements 

are met to ensure air quality is not adversely impacted. EPA has already given verbal concurrence on 

our technical analysis showing removal of Stage II controls as proposed in this rulemaking will not 

adversely affect St. Louis air quality. The rulemaking will also address the following items: 

- Certification and testing procedures for the remaining Stage I systems will use the California 

Air Resources Board (CARB) vapor recovery program instead of the Missouri Performance 

and Test Procedures (MOPETP). Stage I systems capture displaced vapors when fuel storage 
2

tanks at GDFs are loaded from delivery vessels. 

- The prohibition of aboveground storage tanks (ASTs) at GDFs will be codified. The rule never 

allowed ASTs because MOPETP never certified ASTs. Elimination of MOPETP requires 

adding language to the rule to clarify that ASTs will continue to be prohibited. 

- Permitting provisions will be revised to address the decommissioning of Stage II systems and 

clarify the permitting requirements and fees for Stage I systems. The permitting fees will 

remain $100 per permit but the frequency with which permits are issued will change. 

 

* Missouri State Implementation Plan Revision – Regional Haze Plan 5-Year Progress Report 

 

The federal Clean Air Act establishes requirements for the protection of visibility in Class I areas, 

consisting of national parks and wilderness areas. States are required to submit state implementation 

plans (SIPs) that demonstrate reasonable progress toward meeting the national goal of a return to 

natural visibility conditions in Class I areas by 2064. There are two Class I areas in Missouri: Hercules 

Glades Wilderness Area and Mingo National Wildlife Refuge. Missouri’s regional haze SIP, which 

was submitted to the U.S. Environmental Protection Agency in August 2009, established visibility 

goals for the year 2018 for each of the state’s Class I areas in order to make reasonable progress 

toward the 2064 goal. The purpose of this report is to assess progress made toward the 2018 visibility 

goals in Hercules Glades and Mingo in the five years since Missouri’s regional haze SIP was 

submitted to EPA. This 5-year progress report demonstrates that both of Missouri’s Class I areas are 

expected to meet their 2018 visibility goals based on control strategies currently in place, which 

largely consist of sulfur dioxide and nitrogen oxides emission reduction measures for utilities, 

industrial boilers, and other sources. 

 

* Missouri State Implementation Plan Revision – Marginal Area Plan for the Missouri Portion of the St. 

Louis Nonattainment Area for the 2008 8-Hour Ground Level Ozone National Ambient Air Quality 

Standard 

 

The purpose of this State Implementation Plan (SIP) revision is to address the emissions inventory and 

other marginal ozone nonattainment area requirements pursuant to Clean Air Act Section 182(a) for 

the Missouri portion of the St. Louis nonattainment area under the 2008 8-hour ozone national 

ambient air quality standard (NAAQS). The Missouri portion of the St. Louis nonattainment area 

includes the City of St. Louis and the Counties of St. Louis, St. Charles, Franklin, and Jefferson, 

which were designated as a marginal nonattainment area under the 2008 8-hour ozone NAAQS on 

May 21, 2012. 

 

* 10 CSR 10-6.040 (amendment) Reference Methods 

 

This proposed amendment will update the incorporation by reference date to include the latest Federal 

Register notices for ambient air monitoring methods. Two of these notices promulgated existing 

methods as new equivalency methods for measuring lead, nitrogen dioxide, particulate matter less 

than 2.5 microns, particulate matter less than 10 microns, and particulate matter between 10 and 2.5 

microns in diameter. In addition, EPA finalized a new Federal Reference Method for measuring lead 

in total suspended particulate matter and, at the same time, designated it as a new Federal Equivalency 

Method. 

 

If the Commission adopts the 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 
3

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 June 5, 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. 

 

 

Celebrating 40 years of taking care of Missouri's natural resources. To learn more visit dnr.mo.gov.

http://dnr.mo.gov/env/apcp/rulemaking.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. 

This service is provided to you at no charge by Missouri DNR. 
 PUBLIC HEARING 5/29/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334

MIDWEST LITIGATION SERVICES

Page 1

1 MISSOURI AIR CONSERVATION COMMISSION MEETING

2 St. Louis Regional Office

3

4

5

6

7

8

9

10

11

12 PUBLIC HEARING

13 TAKEN ON BEHALF OF

14 THE MISSOURI DEPARTMENT OF NATURAL RESOURCES

15 MAY 29, 2014

16

17

18

19

20

21

22 (Starting time of the hearing: 9:01 a.m.)

23

24

25
 PUBLIC HEARING 5/29/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334

MIDWEST LITIGATION SERVICES

Page 5

1 IT IS HEREBY STIPULATED AND AGREED that

2 this hearing may be taken in shorthand by

3 Rebecca Brewer, RPR, CRR, CSR, Certified

4 Court Reporter, and Notary Public, and

5 afterwards transcribed into typewriting;

6 * * * * *

7 MR. PENDERGRASS: The hearing will come to

8 order. Let the record show the following

9 commissioners are present: Jack Baker, Mark

10 Garnett, Gary Pendergrass, and David Zimmermann.

11 The Air Conservation Commission of the State of

12 Missouri has called this public hearing pursuant to

13 Section 643.070, Revised Statutes of Missouri, EPA

14 Promulgated Rule 40 CFR 51.102 for the purpose of

15 hearing testimony related to: 10 CSR 10-5.220,

16 amendment, Control of Petroleum Liquid Storage,

17 Loading and Transfer; Missouri State Implementation

18 Plan Revision, Regional Haze Plan, 5-year Progress

19 Report; Missouri State Implementation Plan

20 Revision, Marginal Area Plan for the Missouri

21 Portion of the St. Louis Non-Attainment area for

22 the 2008 8-hour Ground Level Ozone National Ambient

23 Air Quality Standard; and 10 CSR 10-6.040,

24 amendment, Reference Methods.

25 The hearing record will close at 5
 PUBLIC HEARING 5/29/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334

MIDWEST LITIGATION SERVICES

Page 15

1 MR. PENDERGRASS: Thank you. Next we have

2 Missouri State Implementation Plan Revision,

3 Regional Haze Plan, 5-year Progress report. Emily

4 Wilbur?

5 * * * * *

6 EMILY WILBUR,

7 Of lawful age, produced and sworn, deposes

8 and says:

9 MS. WILBUR: Mr. Chairman, members of the

10 Commission, my name is Emily Wilbur. I'm employed

11 as the State Implement Plan, or SIP, Unit Chief

12 with the Missouri Department of Natural Resources

13 Air Pollution Control Program. I work at 1659 East

14 Elm Street, Jefferson City, Missouri. I am here

15 today to present testimony on the proposed Missouri

16 SIP revision entitled Missouri's Regional Haze

17 Plan, 5-year Progress Report.

18 The executive summary for the plan

19 starts on Page 97 of the briefing document. In this

20 testimony and presentation, I will cover an

21 introduction to regional haze, regulatory

22 background, Missouri regional haze plan, and this

23 5-year progress report.

24 Regional haze or visibility

25 impairment is caused by microscopic particles in the
RECOMMENDATION FOR ADOPTION 

PROPOSED REVISION TO 

MISSOURI STATE IMPLEMENTATION PLAN – 

State of Missouri Regional Haze Plan 5-Year Progress Report 

On May 29, 2014, the Missouri Air Conservation Commission held a public hearing concerning 

a revision to the Missouri State Implementation Plan (SIP) – Regional Haze Plan 5-Year 

Progress Report. 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 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 revised. If the commission 

adopts this plan, it will be the department’s intention to submit it 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 – 

State of Missouri Regional Haze Plan 5-Year Progress Report 

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

(SIP) for the Regional Haze Plan 5-Year Progress Report opened on April 28, 2014, and closed 

on June 5, 2014. 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. Any 

changes to the proposed plan are included in the response to comments. 

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

Air Program received three comments from EPA Region 7. 

COMMENT #1: Under Section A.1.2 of the report, EPA Region 7 commented that the Air 

Program should address whether progress has been made toward Holcim-Clarksville’s compliance 

with the emission limits imposed through a consent agreement to satisfy Best Available Retrofit 

Technology (BART) requirements. 

RESPONSE AND EXPLANATION OF CHANGE: The Air Program added the language below 

to Section A.1.2 explaining that Holcim-Clarksville has ceased all SO2 and NOX emitting 

operations since the consent agreement and are now in compliance with the consent agreement. 

 “Since the consent agreement included in the 2009 plan, Holcim (US) Inc., in Clarksville, 

Missouri, has discontinued Portland cement manufacturing and hazardous waste fuel burning 

operations. Remaining operations at the facility include receiving, storing, and shipping. The 

facility’s operating permit (OP2004-002) was reclassified from a Part 70 to a Basic operating 

permit in 2010. The facility’s new SO2 and NOX potential emissions are both zero tons per 

year.” 

COMMENT #2: EPA Region 7 commented that the Air Program should review the document and 

figures for consistent tense, timeframes, data values, and labels. 

RESPONSE AND EXPLANATION OF CHANGE: The Air Program reviewed the document 

and made minor revisions to ensure correct and consistent tense, timeframes, values, and labels. 

Specifically, revisions of a grammatical nature were made in Sections A, B, and C. 

COMMENT #3: EPA Region 7 commented that the Air Program should review and provide 

additional explanations for emission trend values in the tables in Section D. 

RESPONSE AND EXPLANATION OF CHANGE: The Air Program reviewed Section D and 

added a discussion explaining the emissions trends depicted in the tables. The decreasing trend 
in point source emissions of SO2 and NOX are of the greatest significance to visibility 

improvement, therefore, these trends are the focus of Section D. However, other pollutants and 

source sectors show varying trends that warranted additional clarification. These other trends 

include a slight increase in carbon monoxide (CO) emissions and fine particulate emissions, and 

a slight increase in fire and biogenic emissions. A majority of the changes are due to new 

calculation methods and emission factors being used to estimate emissions values. Despite these 

increases in emissions, the decrease in SO2 and NOX emissions from point sources and the 

corresponding improvement in visibility conditions are most significant and are the focus of the 

progress report.