# Mr. Karl Brooks

Page Two

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 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 of Natural 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 PROGRE SS REPORT REVIEW REQUIREMENTS ........... 3

A. I NTRODUCTION



# .............................................................................................................................. .... 3

B. B ACKGROUND 

# S UMMARY 

# .................................................................................................................. 3

C. P URPOSE



# .............................................................................................................................. .............. 4

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

A. S TATUS OF 

# C ONTROL 

# S TRATEGIES IN THE 

# R EGIONAL 

# H AZE 

# 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. NO X 

# SIP Call ........................................................................................................................ 8

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

A.2.1. 2010 SO 2 

# 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 Emissi on Changes to Occur between 2012-2017 .......................... 11

B. E MISSIONS 

# R EDUCTIONS FROM 

# R EGIONAL 

# H AZE 

# SIP S TRATEGIES 

# .............................................. 14

C. V ISIBILITY 

# P ROGRESS 

# ...................................................................................................................... 16

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

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

C.1.2. Hercules Glades Na tional 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. E MISSIONS 

# P ROGRESS 

# ...................................................................................................................... 38

E. A SSESSMENT OF 

# C HANGES 

# I MPEDING 

# V ISIBILITY 

# P ROGRESS 

# ........................................................ 44

F. A SSESSMENT OF 

# C URRENT 

# S TRATEGY 

# ............................................................................................ 44

H. D ETERMINATION OF 

# A DEQUACY 

# ..................................................................................................... 46

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

A. EPA A DMINISTRATIVE 

# P ROCESS 

# R EQUIREMENTS 

# ......................................................................... 47

B. R EPORT 

# S UBMISSION 

# ....................................................................................................................... 47

C. P UBLIC 

# P ARTICIPATION 

# ................................................................................................................... 47

D. C ONSULTATION AND 

# C OMMITMENT TO 

# R EVISE 

# P LAN 

# .................................................................. 48

# ii 

# This page intentionally left blank.

# iii 

# LIST OF APPENDICES

Appendix A: Underlying Data Tables

Appendix B: Online Public Noti ce Screenshot with Date Stamp

Appendix C: Written Comments and Re sponses 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 C onditions for Missouri Class I Areas

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

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

Table 7. Hercules Glades Visibi lity Conditions Reasonable Progre ss Summary Table-Worst 20% Days

Table 8. Hercules Glades Visibi lity Conditions Reasonable Progre ss 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 I nventory as reported to the NEI

Table 12. 2008 Missouri Emission I nventory as reported to the NEI

Table 13. 2005 Missouri Emission I nventory 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, fr om EPA’s Clean Air Ma rkets 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: D eciviews - 5-Year Aver ages-Worst 20% Days

Figure 5. Mingo’s Reasonable Progress Summary: To tal 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: Tota l Light Extinction – 5-Year Averages-Best 20%

Days

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

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

Figure 11. Mingo – Light Extinction Mon itoring 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 Pr ogress 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 Su mmary: Total Light Extinction – 5-Year AveragesWorst 20% Days

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

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

Days

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

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

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

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

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

Figure 24. Hercules Glades – Mass Concentr ations 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 Extinc tion Monitoring Data for Worst 20% Days

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

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

Figure 29. El Dorado Springs – Mass Concentra tions 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-y ear progress report as specified in 40 CFR 51.308(g) and (h). The plan

includes a review of current regi onal 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 visibil ity 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 th e RHR which addressed regional haze impairment

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

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

reasonable progress toward meeting th e national goal of a return to natu ral visibility conditions by 2064.

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

the “glide path,” toward natural c onditions 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) am ong 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 Elect ric Generating Units (EGUs) portion of the 2009 RH

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

(CSAPR) was addressed in federal rulemaking fi nalized 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 (SO 2 

# ) emissions and oxides of

nitrogen (NO X 

# ) emissions, which are the largest contributor s to visibility impairm ent 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 s ource sector have reduced SO 2 

# and NO X 

# emissions during the 5-year period

evaluated for this report.

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

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

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

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

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

Missouri’s Class I areas can most lik ely be attributed to the realized and planned reductions in SO 2 

# and

NO X 

# emissions at EGUs, boilers, and other sources. C onsequently, the Air Program has determined that

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

emissions reductions. The Air Program submits to EP A a negative declaration th at further revision of

the 2009 RH plan is not needed at this time.

# 2 

# This page intentionally left blank.

# 3 

# I. Regional Haze Five-Year P rogress Report Review Requirements

A. Introduction

The Clean Air Act (CAA) establishes requirements for th e protection of visibilit y, especially in Federal

Class I areas. In 1999, the US Environmental Prot ection 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 establis hed a comprehensive visibility protec tion program for the 156 mandatory Class

I Federal Areas, consisting of nationa l parks and wilderness areas. Clas s I areas as defined by the Clean

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

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

States are required to develop stat e implementation plans (SIPs) to s ubmit 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 em issions, mobile source

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

emissions. These plans were developed with the expre ss intent that by 2064, the vi sibility 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 th ese SIPs. States used th e products of the RPOs to

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

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

visibility impairment in mandatory Class I areas.



# B. Background Summary

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

referenced as the 2009 RH plan 1 

# . With the help of the Central Regional Air Planning Association

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

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

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

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

(Hercules Glades), as part of th e Mark Twain National Forest. The area includes 12,413 acr es 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, th e IMPROVE (Interagency

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

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

third monitor, El Dorado Springs, located in Southwes t 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 establ ished to aid in determining impacts to portions of the country where no

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

1 

# State of Missouri Regional Haze Plan Re vision, August 5, 2009 (Available at:

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

# 4 

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

report’s technical analysis to bett er characterize visibility and conc entration 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 monito ring 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 Go als (RPG). The analys es 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) emissi on reductions resulting from the fe deral Clean Air Interstate Rule

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

the Missouri Oxides of Nitrogen (NO X 

# ) State Implementation Plan (SIP) call, Tier 2 vehicle emission

standards, other states’ SIP contro ls, Missouri’s and other states’ Be st 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)). Secti on 51.308(f) requires the states to subm it 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 SI P revisions every 5 years.

This plan addresses the require ments of 40 CFR 51.308(g) requiring periodic report s evaluating progress

towards the RPGs established for each mandatory Cl ass 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 doc ument entitled, “General Pr inciples for the 5-Year

Regional Haze Progress Reports for the Initia l Regional Haze State Implementation Plans 2 

# ,” released in

April 2013.

2 

# EPA’s General Principles Document for 5-Year Regional Haze Progress Repo rts, 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 desc ription of the status of implem entation of all measures included

in the implementation plan for ac hieving reasonable progress goals fo r Class I areas both within and

outside the State.”

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

plan and the associated m odeling efforts. This summary includes di scussions 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 em issions 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 th e 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 prog ress goal set in the 2009 RH plan.

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

demonstration to meet the RPG requirements. Meas ures 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 Intersta te Rule (CAIR), following a three-year modeling

study and cost analysis on SO 2 

# and NO X 

# controls (equivalent to a four-factor analysis).

As required by CAIR, Missouri promul gated state rules to implement CA IR. The rules were presented

for public hearing at the December 7, 2006, Miss ouri 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 NO X 

# and SO 2 

# emissions, and Missouri sources are in cluded in the national program. The

state rules are 10 CSR 10-6.362 Clean Air Interstate Rule Annual NO X 

# Trading Program and 10 CSR

10-6.366 Clean Air Interstate Rule SO X 

# 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 promul gated as of April 28, 2006

The controls in the state rules and the federal rules incorporated by reference ha ve 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 SO 2 

# , NO X 

# , and PM controls installed prio r 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, 2009 3 

# ), Missouri prepared a long-term

strategy and examined the possible a pplication of BART along with othe r programs in order to establish

reasonable progress goals (RPGs) fo r Mingo and Hercules Glades. A BA RT analysis was performed to

assure that the 2009 RH plan met the federal RHR re quirements. This analys is included BART source

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

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

result, Missouri identified one sour ce that is subject to BART.

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

Department of Natural Resources, which requires them to limit emissions of SO 2 

# and NO X 

# to:

 SO 2 

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

 NO X 

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

The emission limits are to be met as expeditiously as practicable, but no late r 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. Therefor e, Holcim – Clarksville has until June 26, 2016 to

comply with the emission limits.

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

cement manufacturing and hazardous waste fuel bur ning operations. Remaining operations at the

facility include receiving, st oring, 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 SO 2 

# and NO X 

# potential emissions are bo th zero tons per year.

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

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

necessary.

A.1.3. Tier 2

3 

# State of Missouri Regional Haze Plan Re vision, 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 reduc ing the emissions most responsible for the ozone

and PM impact from these vehicles – NO X 

# and non-methane organic gases, consisting primarily of

hydrocarbons and contributing VOCs. The Tier 2 standards reduce new vehicle NO X 

# levels to an

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

phased in starting in 2004, and the standards were fu lly 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 passenge r cars and light trucks not certified to the

primary Tier 2 standards had to meet an interim average standard of 0.30 g/mi NO X 

# . During the period

2004-2008, heavy trucks and similar vehicl es not certified to the final Ti er 2 standards phased in to an

interim program with an aver age standard of 0.20 g/mi NO X. 

# Those not covered by the phase-in must

meet a per-vehicle standard (i.e., an emissions “cap”) of 0.60 g/mi NO X 

# for trucks and 0.09 g/mi for

similar vehicles.

A.1.4. Tier 4

EPA's Clean Air Nonroad Diesel Rule (Tier 4) requi res stringent pollution cont rols on diesel engines

used in industries such as constr uction, agriculture, and mining, and it wi ll 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 co mbines cleaner engine

technologies with cleaner fuel – sim ilar to the on-highway diesel prog ram. The standards cut emissions

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

accounts for 47 percent of dies el PM and 25 percent of NO X 

# from mobile s ources nationwide.

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

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

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

technologies, similar to catalytic t echnologies used in passenger cars.

The Tier 4 emission limits are based on engine horsepow er 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. NO X 

# SIP Call

The NO X 

# SIP call was promulgated to assist downwind oz one areas in attaining the one-hour and 8-hour

ozone NAAQS by providing upwind NO X 

# emission control. This ru lemaking was developed through

# 9 

# the EPA’s interpretation of the Ozone Transpor t Assessment Group (OTAG) recommendations and

subsequent modeling and cost analysis of NO X 

# controls to reduce ozone transport. The final NO X 

# SIP

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

Missouri’s initial rule in response to the NO X 

# 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 NO X 

# /MMBtu heat input for el ectric generating units in

the eastern one-third of the stat e and a lower limit of 0.18 lbs NO X 

# /MMBtu heat input for Labadie, Rush

Island, and Meramec power plants. EGUs in the west ern two-thirds of the st ate were limited to an

emission rate of 0.35 lbs NO X 

# /MMBtu of heat input. Cyclone bo ilers (Sibley and As bury power plants)

that burn tire-derived fuels are allowed to meet 0.68 lbs NO X 

# /MMBtu heat input. Implementation of the

NO X 

# SIP Call began on May 1, 2004.

On April 21, 2004, the EPA finalized the second phase of NO X 

# SIP call. Phase II of the SIP call

excluded the portion known as the “coarse grid” (the western 2/3 of Missouri) from the NO X 

# SIP Call,

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

6.350, with the one exception of not including Phelps County, and revised the cap for NO X 

# emissions

from the previous statewide budget of 114,532 tons of NO X 

# per ozone season to a partial state budget of

61,406 tons of NO X 

# 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 pe rcent emissions reductions for large natural gasfired stationary internal combusti on engines, 90 percent emissions redu ctions for diesel and dual fuel

stationary internal combustion en gines, 60 percent emissions reduc tions for non-utility boilers and

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

units were excluded from the NO X 

# 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 Cont rol Program developed 10 CSR 10-6.360 Control of NO X 

# Emissions

from Electric Generating Units and Non-Electric Generating Boilers , 10 CSR 10-6.380 Control of NO X 

# Emissions from Portland Cement Kilns , and 10 CSR 10-6.390 Control of NO X 

# Emission from Large

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

EPA’s NO X 

# 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 in clude schedules for complia nce, 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 NO X 

# 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 stat e rules 10 CSR 10-6.380 Control of NO X 

# Emissions from Portland

Cement Kilns and 10 CSR 10-6.390 Control of NO X 

# Emission from Large Stationary Internal

Combustion Engines are not superseded by CAIR or CSAPR.

# 10 

# Ongoing air pollution control programs, as describe d 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 demonstrati on in the 2009 RH plan but that

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

described below. These additional control measures include the 2010 SO 2 

# NAAQS Attainment

Demonstrations, Illinois Multi-Polluta nt Regulation, Federal Tier 3 vehi cle emission and fuel standards,

and the 2007 Federal Hea vy-Duty Highway Rule.

A.2.1. 2010 SO 2 

# NAAQS Attainment Demonstrations

Missouri is in the process of prep aring implementation plans or attain ment demonstrations to bring the

portions of Jackson and Jefferson counties de signated as nonattain ment under the 2010 SO 2 

# NAAQS

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

performed to evaluate nearby SO 2 

# 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 expect ed that significant reductions in SO 2 

# emissions will be achieved

prior to the attainment date for this st andard, October 4, 2018. Any reductions in SO 2 

# emissions will

greatly benefit visibility conditi ons throughout Missouri and nearby area s; as mentioned previously, SO 2 

# is a large contributor to visibility impairment.

A.2.2. Illinois Multi-Pollutant Regulation

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

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

mercury, SO 2 

# , and NO X 

# emissions. The rule targeted the three largest coal-fired pow er plant companies

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

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

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

three power companies is 233,600 tons per year of SO 2 

# and 61,434 tons per year of NO X 

# . These

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

A.2.3. Tier 3

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

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

trucks, medium-duty passenger vehicles, and some h eavy-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 standard s are scheduled to start in 2017.

Compared to current standards, the non-methane organic gases (NMOG) and NO X 

# , presented as

NMOG+NO X 

# , tailpipe standards for light-duty vehicles re present approximately an 80% reduction from

# 11 

# today’s fleet average and a 70% redu ction in per-vehicle particulate ma tter (PM) standards. Heavy-duty

tailpipe standards represent about a 60% reduction in fleet average NMOG+NO X 

# and per-vehicle PM

standards.

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

to all light-duty and onroad gasoli ne 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 NO X 

# and non-methane hydrocarbons (NMHC) of 0.20 g/bhp-hr and 0.14

g/bhp-hr, respectively. Th ese diesel engine NO X 

# 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 su lfur content of highway diesel fuel -- from levels of 500 ppm (low sulfur

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

timeline in the regulation.

A.3. Facilities with Expected Emissi on 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 Ai r Program’s permit, planning, and enforcement staff,

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

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

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

demonstration, as they are not yet permanent a nd 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 estima ted 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 Hil l 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

P M Estimated PM/HAP emission

reductions ~ 10 tons.

175-

0002 Thomas Hil l 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 p ro j ect did not re q uire a p ermit. 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

re q uire a p ermit. 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. -

Asbur y

Plan t 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

o p erate Last reported emissions were

6,200 tons of SO2 in 2012,

with an SO2 reduction

estimate of ~4,000 tons in

2014 after the chan g e

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

Statio n P06 - Boiler Unit 1 will be retired in

2016 p er 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

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

Boiler 2 will be retired in 2017 per

the EI A 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

b oilers in 2014 Estimate around 100 tons per

year increase in emissions (the

ma j orit y

bein g 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 b y 2015

095-

0017 Fol g ers 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

Herculaneu m 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 startin g in 2014. The facility reported 2,800

tons of SO2 emissions in

2012. The expected reduction

estimate is 2,000 tons.

023-

0062 Nordyne -

Po p lar 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.

htt p ://www.nord y neinfo.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 y ear 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 par agraph (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 SO 2 

# emissions have decreased in Missouri. The main source

category related to SO 2 

# emissions is electric ge nerating 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 redu ctions in emissions from units

not required to operate CEMS.

The reductions in SO 2 

# emissions from EGUs during this period resulted from many factors, including

installation of controls, units switching to cleaner fuels, load shif ting 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 SO 2 

# 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, fr om EPA’s Clean Air Markets Division (CAMD)

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

Figure 2 depicts the trends for Mi ssouri’s Acid Rain Program units that report annua l 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 2013lbs/MMBtutons/yearand1000MMBtuHeatInput



# 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 SO 2 

# 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 SO 2 

# emission rate from these units decreased from 0.637 lbs SO 2 

# /

MMBtu in 2007 to 0.361 lbs SO 2 

# / 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 si gnificant reduction to overall SO 2 

# emissions occurred due to the installation

of controls and the use of cleaner burning fuels.

During the period of 2009-2011, SO 2 

# emissions fell from 240,201.92 tons to 196,255.62 tons,

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

MMBtu to 838,655,089 MMBtu, indicating SO 2 

# emission reductions a nd power demand were not

influenced by changing economic conditions during this period.

As indicated in Table 3, NOx em issions 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 st ringent requirements of the Cross State Air Pollution

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

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

sulfates have been shown to be the predominant sp ecies of concern to visibi lity 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 SO 2 

# and NO X 

# have declined over the past 5 years

and are expected to continue declining as more fede ral regulations are implemen ted in the future. This

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

timeframe. 

# Yea r 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 ar ea within the State, the State mu st assess the follo wing visibility

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

year averages of these annual values.

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

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

and baseline visibility conditions;

(iii) The change in visibility im pairment for the most impaired and le ast impaired days over the past 5

years.

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

identified in the 1977 CAA Amendments. For each Cla ss I area, there are three me trics of visibility that

are part of the determina tion 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 reasonabl e 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 a pplication of BART along with othe r programs in order to establish

RPGs for Mingo and Hercules Glades.

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

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

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

all visibility projections using th e revised IMPROVE algorithm. The na tural conditions (for 2064) were

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

Rule,” as released September 2003. 5 

# The natural visibili ty conditions for both Class I areas for the

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

in the 2009 RH plan is a uniform rate of progress g lidepath, 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 th ese calculations and the model predicti ons that Missouri developed RPGs for

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

4 

# State of Missouri Regional Haze Plan Re vision, August 5, 2009 (Available at:

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

5 

# EPA’s “Guidance for Tracking Prog ress 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 conditio ns, and the established 2018 RPGs, are detailed in Table 4. Sitespecific data analysis was performe d to evaluate reasonable progress and to predict whether RPGs for

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

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

Partnership’s (WRAP) Technica l Support System (TSS) website,

http://vista.cira.co lostate.edu/tss/Resu lts/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 m easured using the unit of deciview. A deciview is a measurement of

haze that gauges the impact air pollutants have on visi bility. 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 me thod 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 pe r unit length, the unit for this is an inverse Megameter (Mm -1 

# ). A higher

measured extinction coefficient means a hi gher level of visibility impairment.

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

however, the emission reductions and visibility impr ovements that have alr eady been achieved and

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

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

reductions from Missouri sources ar e great enough for Missouri’s Cl ass I areas to achieve their

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

areas and therefore woul d not hinder the attainment of their RPGs.

Table 4. Established 20% Worst Days Visibi lity 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 ar ea, a baseline condition mu st be established as a

starting point. The IMPR OVE 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, PM 2.5 

# ) at Mingo that was not no ticed at any neighboring

# 18 

# sampling sites. It was later discove red that there was a monitor inlet clogging problem associated with a

particular inlet design that was di fficult to clean. Because of the cl ogged Module C Inlet, carbon data

was not available from June 2000 to January 200 2. The resolution was a substitution protocol

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

mass carbon (OMC). Data filling was used to obtain su fficient data so that th ree 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 cond ition for the twenty percent be st days is 13.76 dv. The natural

condition for the worst days is set at 11.3 dv using EP A 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 visi bility conditions from the baseline, and the available monitored data for

this first planning period show no degrad ation, and in fact sh ow improvement.

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

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

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

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

planning period, which breaks out the i ndividual 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 av ailable on the WRAP TSS. These trends are also

depicted graphically in the figures following the corresponding tables.

Table 5. Mingo Visibility Conditions Reasonabl e 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

PeriodLightExtinction,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: D eciviews - 5-Year Averages-Worst 20% Days

Figure 5. Mingo’s Reasonable Progress Summary: Tota l 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

PeriodDeciviews 

# 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

PeriodLightExtinction,Bext(Mm‐1) 

# Mingo: Reasonable Progress Summary

Total Light Extinction

‐ 5

‐ Year Averages

‐ Worst 20% Days

# 21 

# Table 6. Mingo Visibility Conditions Reasonabl e 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 PeriodLightExtinction,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: D eciviews – 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

PeriodDeciviews 

# 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

PeriodLightExtinction,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 Mon itoring Data for Worst 20% Days. 0 5 10 15 20 25 30 35

1999 2004 2009 2014 2019Deciviews 

# 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 2011LightExtinction,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 Mon itoring 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 2011LightExtinction,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 2011MassConcentrations(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 Nati onal Wilderness Area

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

IMPROVE monitor located in the Hercules Glad es 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 fo r 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 wa s adopted as the RPG for Hercules Glades at

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

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

sampling days is to show no degradation in visibili ty 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 vi sibility on the best and

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

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

Hercules Glades.

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

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

This table depicts the downward trends in sulfate m easurements 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 2011MassConcentrations(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 T SS. These trends are also depicted graphically in

the figures following the corresponding tables.

Table 7. Hercules Glades Visi bility Conditions Reasonable Progre ss 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 Pr ogress Summary Chart for Worst 20% Days

Figure 15. Hercules Glades’ Re asonable 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 PeriodLightExtinction,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

PeriodDeciviews 

# Hercules Glades: Reasonable Progress Summary

‐

Deciviews

‐ 5

‐ Year Averages

‐ Worst 20% Days

# 28 

# Figure 16. Hercules Glades’ Reas onable Progress Summary: Total Ligh t Extinction – 5-Year AveragesWorst 20% Days

Table 8. Hercules Glades Visi bility Conditions Reasonable Progre ss 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

PeriodLightExtinction,Bext(Mm‐1) 

# Hercules Glades: Reasonable Progress Summary

Total Light Extinction

‐ 5

‐ Year Averages

‐ Worst 20% Days

# 29 

# Figure 17. Hercules Glades’ Reasonable Pr ogress Summary Chart for Best 20% Days

Figure 18. Hercules Glades’ Re asonable Progress Summary: Decivi ews 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 PeriodLightExtinction,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

PeriodDeciviews 

# Hercules Glades

‐ Reasonable Progress Summary:

Deciviews 5

‐ Year Averages

‐ Best 20% Days

# 30 

# Figure 19. Hercules Glades’ Reas onable Progress Summary: Total Ligh t Extinction – 5-Year AveragesBest 20% Days

Figure 20. Hercules Glades’ Annual Monitored Visibi lity 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

PeriodLightExtinction,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 2019Deciviews 

# 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 Extinc tion Monitoring Data for Worst 20% Days.

Figure 22. Hercules Glades – Light Extinc tion 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 2012LightExtinction,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 2012LightExtinction,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 Concentra tions Monitoring Data for Worst 20% Days.

Figure 24. Hercules Glades – Mass Concentra tions Monitoring Data for Best 20% Days. 0 5 10 15 20 25 30

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012MassConcentrations(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 2012MassConcentrations(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 1 st 

# , 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 in consistencies across sampling data

for varying PM 2.5 

# species, therefore a different time period was chosen to repr esent the baseline

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

estimated baseline conditions for the worst 20% sa mpling 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 speciate d pollutants are analyzed by mass concentration and

light extinction, for the best and wors t days, in order to properly char acterize the conditions at El Dorado

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

visibility conditions across th e 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 Visi bility Data with Glidepath to 2018 RPGs 0 5 10 15 20 25 30 35

2000 2005 2010 2015 2020Deciviews 

# 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 Extinc tion Monitoring Data for Worst 20% Days.

Figure 27. El Dorado Springs – Light Extinc tion 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 2012LightExtinction,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 2012LightExtinction,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 Concentra tions Monitoring Data for Worst 20% Days.

Figure 29. El Dorado Springs – Mass Concentra tions Monitoring Data for Best 20% Days. 0 5 10 15 20 25 30 35 40

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012MassConcentrations(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 2012MassConcentrations(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 w ithin 250 km of the Missouri boundar y, Upper Buffalo and Caney Creek

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

summary of their visibility trends is included here. The reasonab le 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 cu rrent 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, in cluding five-year averages for this first planning

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

areas located in Arkansas. Both ta bles depict downward trends in su lfate 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 Visibili ty 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 co ntributing to visibility

impairment from all sources and activities within the St ate. Emissions changes s hould 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 an d 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: Stat e-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 fo llowing 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 th at affect visibility th e most include: sulfur

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

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

three NEI years, is shown in Figure 30. Generall y downward trends for th ese 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 controllab le and uncontrollable emissions. C ontrolling point sour ces provides a

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

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

decreasing trend in point source emissions of SO 2 

# and NO X 

# are of the greatest significance to visibility

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

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

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

power generation over this period. Point source PM 2.5 

# emission levels increased by 6% or 567.53 tons

between 2008 and 2011. Many point sour ces had significant changes in PM 2.5 

# emissions. The increases

in PM 2.5 

# emissions are due to both updated stack test emi ssion 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 thes e increases in emissions, the decrease in SO 2 

# and NO X 

# emissions from point sources and the corresponding improvement in vi sibility conditions are most

significant and therefore are the focus of this report.

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

2011NEIv1 Technical Support Docu ment from November 2013,

( http://www.epa.gov/ttn/chief/ne t/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. Th e events cited in the 2011 fire inventories include

several forest fires of over 1,000 acres within the Mark Twain National Fo rest 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 Ev aluation 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 bur ned 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 th eir goal of 45,000 acres

burned annually to meet forest management goals.

Biogenic emissions also change d between 2008 and 2011 with some pollutants increasing and some

decreasing. EPA used their Biogeni c Emissions Inventory System (BEI S) 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 do cuments for the 2008 and 2011 inventor ies do not explicitly describe

the changes to the vegetation datase t 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 para mount pollutants to visibility improvement, SO 2 

# and NO X 

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

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

visibility impacting pollutants have decreased and visibility has improved.40Table 11. 2011 Missouri Emission Inventory as reported to the NEI.CO NH3 NOX PM10‐PRI PM25‐PRI SO2 VOC113,272.261,642.3092,721.4116,726.619,834.40255,216.8914,502.546,931.821,716.57123.17106.55214.70397.44120,204.081,642.3094,437.9816,849.789,940.94255,431.5914,899.98577,332.7263,288.4645,214.614,521.46187,392.5737,478.18680,308.919,936.4211,274.5673,499.1459,444.476,003.95148,593.96115,151.42124,463.9414,402.7821,606.4719,375.72994.63105,932.32795,460.33134,400.3625,677.34905,045.51184,108.296,998.57254,526.27599,053.56 2,587.85 180,579.42 8,415.68 6,759.82 1,207.95 61,784.73316,737.16 50.76 41,970.54 4,133.56 3,952.02 106.81 45,082.965,331.3016.5736,093.551,194.791,104.83371.861,777.05322,068.46 67.33 78,064.09 5,328.35 5,056.85 478.67 46,860.01138,953.6528,310.971,168,254.451,975,740.08138,697.84407,069.79935,639.32205,865.91264,116.781,546,325.43AreaSourceTotal2011MissouriEmissionInventory‐StatewideTotalsintonsperyearPermittedFacilitiesAirportsPointSourceTotalPavedandUnpavedRoadsConstructionDustAgriculturalTillingFires(Agricultural,Prescribed,Wildland)AllotherareasourcesBiogenicTotalStatewideTotalsOnroadMobileMobileEquipmentfromNonroadModelCommercialMarine,LocomotiveOffroadMobileTotal41Table 12. 2008 Missouri Emission Inventory as reported to the NEI.CO NH3 NOXPM10-PRI PM25-PRISO2 VOC92,2391,655129,95318,3189,267367,37017,4205,215-1,7141184520242797,4541,655131,66718,4369,312367,57217,846545,853.9359,357.5942,840.094,284.01183,967.3236,793.16317,134.784,786.405,355.1133,515.3028,964.192,411.0471,128.8878,609.33125,959.1115,684.6421,876.7413,173.7644,212.74118,540.71395,744.12130,745.5121,039.75828,053.39142,572.7046,623.77189,669.59978,206.68 6,919.69 117,463.88 3,516.20 2,289.89 1,213.32 80,126.91366,432.23 48.12 47,584.00 4,626.39 4,427.17 888.00 51,452.135,654.5317.1938,156.921,269.451,175.73533.511,839.32372,086.76 65.32 85,740.93 5,895.84 5,602.90 1,421.50 53,291.46123,861.9429,967.34993,543.531,967,353.23139,385.97385,878.57855,901.84159,777.65416,830.381,334,477.86AreaSourceTotal2008MissouriEmissionInventory‐StatewideTotalsintonsperyearPermittedFacilitiesAirportsPointSourceTotalPavedandUnpavedRoadsConstructionDustAgriculturalTillingFires(Agricultural,Prescribed,Wildland)AllotherareasourcesBiogenicTotalStatewideTotalsOnroadMobileMobileEquipmentfromNonroadModelCommercialMarine,LocomotiveOffroadMobileTotal42Table 13. 2005 Missouri Emission Inventory as reported to the NEI.State DataCategory CO NH3 NOx PM10‐PRI PM25‐PRI SO2 VOCMO Event 5,848.2597.76171.01676.40573.2271.841,405.25MO Nonpoint 309,960.74115,064.35108,752.50968,551.08134,742.7551,161.18195,540.93MO Nonroad 3,223.1517.4463.5043.822.68115.71MO Onroad 1,249,014.537,061.16159,980.034,487.033,163.714,250.87100,847.02MO Point 85,276.361,005.39163,012.1922,200.2713,058.87355,440.9120,081.44MO Biogenic(duplicate2002)*** 134,123.4022,518.601,428,260.00StatewideTotal(tons) 1,787,446.43123,228.65454,451.78995,978.28151,582.36410,927.491,746,250.35**PointsourceemissionsintheNEIdonotmatchemissionsinMissouri'sdatabase.***EPAdidnotrunthebiogenicmodelin2005duetothereducedeffortyear,so2002emissionswerecopiedforward(aswasdonefornonpoint2005emissions)Seehttp://www.epa.gov/ttn/chief/net/2005inventory.htmlforanexplanationofthe2005reducedeffortinventory.DuetodifferencesinthepointsourcetotalsintheNEIandMoEIS,belowisadisplayofthefirst‐cutemissionsfromMoEISforcomparisonandreference.State DataCategory CO NH3 NOx PM10‐PRI PM25‐PRI SO2 VOCMO Point102,945.182,691.58169,128.5919,617.733,404.17397,226.2126,836.882005MissouriEmissionInventory‐StatewideTotalsintonsperyear43Figure 30. Missouri’s Point Source Total Emission Trends for Top Visibility Impairing Pollutants; 2005, 2008, 2011.y=‐11429x+2E+07y=‐16668x+3E+070500001000001500002000002500003000003500004000002004 2005 2006 2007 2008 2009 2010 2011 2012

Emissions in Tons Per YearYearMissouri'sPointSourceTotalEmissionsTrendsforTopVisibilityImpairingPollutants,From2005,2008,and2011NEI'sNOxPM10PM2.5SO2VOC

# 44 

# E. Assessment of Changes Im peding Visibility Progress

Section 51.308(g)(5)

An assessment of any significant changes in ant hropogenic 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 th ree monitoring sites indi cate an overall decreasing

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

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

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

Missouri) monitored an exceedance of PM 2.5 

# (35.7 μg/m 3 

# , 24-hour average) on March 6, 2010.

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

However, the PM 2.5 

# concentrations during the remainder of 2010 and in the preceding and

following years were measurably lower than th e 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 depart ment, 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 intr usions into populated areas; to prevent

deterioration of air quality a nd NAAQS violations; and to ad dress visibility impacts in

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

particularly sensitive receptors to smoke intrus ion and subsequent visibility impairment. The

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

If in the future there is a fire event that results in a NAAQS viol ation 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 con tinue in the coming years as more federal regulations are

implemented and as federal health-based standard s 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 th e downward trend as well.



# F. Assessment of Current Strategy

Section 51.308(g)(6)

An assessment of whether the current implementa tion plan elements and stra tegies are sufficient

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

from the State, to meet all es tablished 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. Th e realized reductions and improvements are

evidenced in the emissions trends and extensive vi sibility 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 anal yses contained in the preceding sections, the current relied upon

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

progress goals for 2018. Table 4 summarizes Mi ssouri’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 c onditions to the 2018 RPGs is compared to the

trend of monitored data for each area, and th e 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, de picted in Tables 9 and 10, respectively. The

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

strategy continues to be sufficien t in reducing visibility impair ment in Class I areas.



# G. Review of Visibility Monitoring Strategy

Section 51.308(g)(7)

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

necessary.

The Missouri Regional Haze monitoring strate gy 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 lo cated 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, fi ve more IMPROVE sites and 15 IMPROVE

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

sampler located at the El Dorado Springs ambien t 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 requireme nts of 40 CFR 51.308(d)(4)(iv).

IMPROVE Protocol monitoring wi ll continue at El Dorado Sp rings since this data can

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

regional transport of PM 2.5 

# air pollution regulated under the recently revised Annual PM 2.5 

# NAAQS. El Dorado Springs is classified as a regional transport site for PM 2.5 

# consistent with the

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

# 46 

# The three IMPROVE monitoring sites provide spat ial coverage for the Regional Haze program.

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

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

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

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

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

funding were reduced such that th e State of Missouri would be re quired to fund so me or all of

the sample analysis, serious consideration woul d 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 pr ogress report to the EPA in accordance with paragraph (g) of

this section, the State must al so take one of the following acti ons based upon the information

presented in the progress report:

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

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

emissions reductions, the State mu st provide to the Administrato r a negative declaration that

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

(2) If the State determines that the implemen tation 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 St ate must provide noti fication to the Admini strator and to the

other State(s) which participated in the regiona l planning process with th e 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 implem entation plan is or may be inadequate to ensure

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

notification, along with available in formation, to the Administrator.

(4) Where the State determines that the implem entation 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 pl an's deficiencies within one year.

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

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

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

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

additional controls or further re vision 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 EP A Region 7 to simplify general procedural

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

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

corresponding consultation and publ ic 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/airqua lity/urbanair/sipstatu s/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/sipstatu s/docs/FINALSIPGuide linesSubLtrsPN.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 th e core requirements pursu ant to 40 CFR 51.308(d).

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

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

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

years of the initial Missouri Regional Haze plan su bmittal 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 a nd 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 le ast 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 Pollu tion 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 Natu ral 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-Y ear 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 Conferen ce 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 relate d to consultation, the Ai r Program enlisted the

support of appropriate state and lo cal air pollution control agenci es 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 re port available to the

aforementioned agencies and sought their input. Co mments 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 cont inue to coordinate with othe r states, FLMs, EPA, CenSARA,

CENRAP, and other RPOs to maintain/improve the vi sibility 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 c onsultation meetings. It will also provide for

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

reducing the impairment of vi sibility in Class I areas.

# LIST OF APPENDICES

Appendix A: Underl ying Data Tables

Appendix B: Online Public Noti ce Screenshot with Date Stamp

Appendix C: Written Comments and Res ponses and Consultation Correspondence

Appendix D: MACC Adoption Signature PageAppendix A: Underlying Data TablesMissouri’s CAMD Acid Rain Program Unit Data:StateYearSO2 (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 769110993.1Visibility 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 through the WRAPTSS website,http://vista.cira.colostate.edu/tss/Results/HazePlanning.aspx.Extinction (Mm-1) and Deciviews for Worst 20% Days:SiteMethodYearNDeciviewTotalExtinctionSO4ExtinctionNO3ExtinctionOMCExtinctionECExtinctionSoilExtinctionCMExtinctionSeaSaltExtinctionMING1NIA20012329.5200.2591.5839.2738.478.951.558.40.03MING1NIA200213141.3118.351.735.140.14MING1NIA200319113.3129.71.14.460MING1NIA20042172.0921.541.27.830.7MING1NIA2005MING1NIA20062327.3158.68101.779.4317.056.192.719.160.37MING1NIA20072329.1195.08120.9510.7532.328.092.128.450.41MING1NIA20082226.8147.2187.9214.420.135.561.675.230.3MING1NIA20092025.1126.2864.0215.3520.735.81.446.650.29MING1NIA20102125.7135.0248.4829.5629.336.072.27.160.22MING1NIA20112025.2125.9953.5629.6218.755.061.15.480.42HEGL1NIA20022527.2156.8104.1514.618.164.961.042.880HEGL1NIA20032426.6149.3387.0214.9927.365.590.822.550HEGL1NIA20042526.5147.5872.6424.1530.285.120.892.920.58HEGL1NIA20052429.5200.64139.1615.2722.826.710.694.140.85HEGL1NIA20062425.9138.5476.7820.2919.515.621.53.290.55HEGL1NIA20072526.2146.1992.611021.875.590.843.880.4HEGL1NIA20082225125.0173.0419.4113.843.570.773.150.22HEGL1NIA20092523.6107.2651.8721.9714.293.960.723.190.25HEGL1NIA20102423.6107.0942.2427.3116.484.330.914.760.06HEGL1NIA20112324.1115.1247.0930.3516.693.90.595.130.37HEGL1NIA20122521.286.0837.6511.916.254.150.634.210.3ELDO1NIA20032427.9168.4375.4139.9426.146.411.278.260ELDO1NIA20042326.6149.2258.8237.2730.324.81.055.340.63ELDO1NIA20052328.6185.3109.6730.5316.245.681.7110.20.27ELDO1NIA20062026.1138.2566.6330.7414.065.021.638.740.42ELDO1NIA20072126.1140.6269.4730.7315.495.11.566.830.45ELDO1NIA20082524.5117.7455.3623.7915.544.30.966.490.28ELDO1NIA20092324.1114.8646.1933.2712.564.450.936.180.27ELDO1NIA20102324.7121.7937.7750.7413.193.990.694.160.27ELDO1NIA20112125.2127.4142.8544.4916.664.30.796.710.6ELDO1NIA20122423.4106.0838.7425.4711.23.872.7512.620.43Mass Concentrations (μg/m3) for Worst 20% Days:SiteMethodYearNammSO4ammNO3OMCECSoilCMSeaSaltMING1NIA2001238.783.858.390.91.55140.01MING1NIA20021312.421.761.738.570.02MING1NIA20031910.893.151.17.440MING1NIA2004217.362.231.213.050.11MING1NIA2006239.681.094.630.622.7115.270.06MING1NIA20072311.151.267.440.812.1214.080.07MING1NIA2008228.691.515.110.561.678.720.05MING1NIA2009206.581.595.310.581.4411.090.05MING1NIA2010215.262.976.760.612.211.930.03MING1NIA2011205.883.054.980.511.19.130.07HEGL1NIA2002259.931.454.890.51.044.80HEGL1NIA2003248.711.656.40.560.824.240HEGL1NIA2004257.422.516.870.510.894.870.1HEGL1NIA20052412.561.475.710.670.696.910.14HEGL1NIA2006247.832.214.960.561.55.480.09HEGL1NIA2007259.071.135.630.560.846.470.07HEGL1NIA2008227.571.893.90.360.775.250.04HEGL1NIA2009255.592.293.860.40.725.320.04HEGL1NIA2010244.82.834.320.430.917.930.01HEGL1NIA2011235.262.984.550.390.598.560.06HEGL1NIA2012254.331.294.050.410.637.010.05ELDO1NIA2003247.793.976.180.641.2713.760ELDO1NIA2004236.253.726.680.481.058.890.1ELDO1NIA20052310.43.124.360.571.7117.010.04ELDO1NIA2006207.093.283.840.51.6314.560.07ELDO1NIA2007217.263.224.260.511.5611.380.08ELDO1NIA20082562.524.120.430.9610.820.05ELDO1NIA2009235.113.313.580.450.9310.30.05ELDO1NIA2010234.365.133.540.40.696.930.04ELDO1NIA2011214.954.44.520.430.7911.190.1ELDO1NIA2012244.462.593.280.392.7521.030.07Extinction (Mm-1) and Deciviews for Best 20% Days:SiteMethodYearNDeciviewTotalExtinctionSO4ExtinctionNO3ExtinctionOMCExtinctionECExtinctionSoilExtinctionCMExtinctionSeaSaltExtinctionMING1NIA20012213.739.8113.165.084.992.10.372.10.01MING1NIA20021215.814.290.563.230MING1NIA20031813.984.050.463.20MING1NIA20042012.454.360.284.090.25MING1NIA20062314.242.114.154.065.012.420.613.490.36MING1NIA20072215.146.0814.56.115.792.580.724.060.32MING1NIA20082213.941.02144.515.091.820.472.980.16MING1NIA20091912.334.6211.792.124.241.620.292.410.15MING1NIA20102113.539.0414.072.884.861.780.642.750.05MING1NIA20111912.535.739.052.744.951.910.524.060.49HEGL1NIA20022413.639.2811.696.095.472.370.32.360HEGL1NIA20032412.234.449.254.325.261.830.342.270.16HEGL1NIA20042412.736.0211.64.274.61.830.322.120.29HEGL1NIA20052313.640.2814.834.164.792.190.392.820.12HEGL1NIA20062313.338.313.723.914.892.510.31.770.19HEGL1NIA2007241337.310.215.995.11.920.322.540.22HEGL1NIA20082111.732.7410.482.854.131.410.332.490.05HEGL1NIA2009241130.49.522.363.651.410.262.040.16HEGL1NIA20102311.531.879.353.13.491.410.433.030.06HEGL1NIA20112211.431.498.6733.91.630.282.750.26HEGL1NIA20122410.930.187.282.73.621.780.393.220.19ELDO1NIA20032413.438.849.55.665.92.370.43.960.05ELDO1NIA20042212.736.499.784.095.42.040.553.370.26ELDO1NIA20052213.840.5312.326.114.522.230.533.710.11ELDO1NIA20061914.241.8113.415.754.732.470.443.910.1ELDO1NIA20072113.740.0311.685.44.51.870.674.710.21ELDO1NIA20082411.832.92103.493.751.480.352.730.12ELDO1NIA20092311.933.159.734.783.631.480.292.010.23ELDO1NIA20102311.833.049.043.633.81.580.493.470.04ELDO1NIA20112012.736.189.544.294.281.60.474.740.26ELDO1NIA20122311.531.97.113.713.721.480.594.040.25Mass Concentrations (μg/m3) for Best 20% Days:SiteMethodYearNammSO4ammNO3OMCECSoilCMSeaSaltMING1NIA2001221.680.611.610.210.373.50MING1NIA2002121.890.480.565.380MING1NIA2003181.740.480.465.340MING1NIA2004201.540.50.286.810.04MING1NIA2006231.720.471.60.240.615.810.06MING1NIA2007221.80.711.840.260.726.760.05MING1NIA2008221.740.531.630.180.474.960.02MING1NIA2009191.50.261.390.160.294.020.02MING1NIA2010211.770.341.570.180.644.580.01MING1NIA2011191.160.331.580.190.526.770.08HEGL1NIA2002241.50.721.750.240.33.940HEGL1NIA2003241.170.51.690.180.343.790.03HEGL1NIA2004241.460.491.490.180.323.530.05HEGL1NIA2005231.870.511.540.220.394.70.02HEGL1NIA2006231.670.441.590.250.32.940.03HEGL1NIA2007241.270.691.640.190.324.240.03HEGL1NIA2008211.340.331.330.140.334.150.01HEGL1NIA2009241.230.291.20.140.263.390.03HEGL1NIA2010231.180.371.150.140.435.050.01HEGL1NIA2011221.090.351.280.160.284.580.04HEGL1NIA2012240.940.321.190.180.395.370.03ELDO1NIA2003241.20.661.870.240.46.60.01ELDO1NIA2004221.280.51.710.20.555.620.05ELDO1NIA2005221.590.741.460.220.536.180.02ELDO1NIA2006191.670.671.530.250.446.510.02ELDO1NIA2007211.480.631.460.190.677.850.03ELDO1NIA2008241.280.431.230.150.354.550.02ELDO1NIA2009231.270.581.20.150.293.350.04ELDO1NIA2010231.180.451.240.160.495.780.01ELDO1NIA2011201.230.511.40.160.477.90.04ELDO1NIA2012230.940.451.230.150.596.740.04Mingo’s Reasonable Progress Chart of5-Year Averages for Worst and Best 20% Days – from TSS:Class I Area Visibility Summary:Mingo NWRW, MO Class I areaVisibility Conditions:Worst 20% DaysReasonable Progress Summary2000-04BaselineConditions(Mm-1)2005-09ProgressPeriod(Mm-1)2006-10ProgressPeriod(Mm-1)2007-11ProgressPeriod(Mm-1)2008-12ProgressPeriod(Mm-1)Sulfate104.6 93.7 84.6 75.0 63.5Nitrate27.2 12.5 15.9 19.9 22.2OrganicCarbon20.5 22.6 23.9 24.3 22.2ElementalCarbon5.5 6.4 6.3 6.1 5.6Fine Soil1.4 2.0 2.0 1.7 1.6CoarseMaterial6.5 7.4 7.3 6.6 6.1Sea Salt0.2 0.3 0.3 0.3 0.3Total LightExtinction177.9 156.8 152.5 145.9 133.6Deciview28.02 27.1 26.8 26.4 25.7Class I Area Visibility Summary:Mingo NWRW, MO Class I areaVisibility Conditions:Best 20% DaysReasonable Progress Summary2000-04BaselineConditions2005-09ProgressPeriod2006-10ProgressPeriod2007-11ProgressPeriod2008-12ProgressPeriodSulfate13.8 13.6 13.7 12.7 12.2Nitrate4.4 4.2 3.9 3.7 3.1OrganicCarbon6.3 5 5 5 4.8ElementalCarbon2.3 2.1 2 1.9 1.8Fine Soil0.4 0.5 0.5 0.5 0.5CoarseMaterial3.2 3.2 3.1 3.3 3Sea Salt0.1 0.2 0.2 0.2 0.2Total LightExtinction42.5 41 40.6 39.3 37.6Deciview14.3 13.9 13.8 13.5 13.1Hercules Glades’ Reasonable ProgressChart of 5-Year Averages for Worst and Best 20% Days – from TSS:Class I Area Visibility Summary:Hercules-Glades W, MO Class I areaVisibility Conditions:Worst 20% DaysReasonable Progress Summary2000-04 BaselineConditions(Mm-1)2005-09 ProgressPeriod(Mm-1)2006-10 ProgressPeriod(Mm-1)2007-11 ProgressPeriod(Mm-1)2008-12 ProgressPeriod(Mm-1)Sulfate87.9 86.7 67.3 61.4 50.4Nitrate17.9 17.4 19.8 21.8 22.2OrganicCarbon25.3 18.5 17.2 16.6 15.5ElementalCarbon5.2 5.1 4.6 4.3 4.0Fine Soil0.9 0.9 0.9 0.8 0.7CoarseMaterial2.8 3.5 3.7 4.0 4.1Sea Salt0.2 0.5 0.3 0.3 0.2Total LightExtinction151.2 143.5 124.8 120.1 108.1Deciview26.7 26.0 24.9 24.5 23.5Class I Area Visibility Summary:Hercules-Glade W, MO Class I areaVisibility Conditions:Best 20% DaysReasonable Progress Summary2000-04BaselineConditions2005-09ProgressPeriod2006-10ProgressPeriod2007-11ProgressPeriod2008-12ProgressPeriodSulfate10.8 11.8 10.7 9.6 9.1Nitrate4.9 3.9 3.6 3.5 2.8OrganicCarbon5.1 4.5 4.3 4.1 3.8ElementalCarbon2 1.9 1.7 1.6 1.5Fine Soil0.3 0.3 0.3 0.3 0.3CoarseMaterial2.3 2.3 2.4 2.6 2.7Sea Salt0.2 0.1 0.1 0.1 0.1Total LightExtinction36.6 35.8 34.1 32.8 31.3Deciview12.8 12.5 12.1 11.7 11.3Arkansas – Upper BuffaloClass I Area Visibility Summary:Upper Buffalo W, AR Class I areaVisibility Conditions:Worst 20% DaysReasonable Progress Summary2000-04 BaselineConditions(Mm-1)2005-09 ProgressPeriod(Mm-1)2006-10 ProgressPeriod(Mm-1)2007-11 ProgressPeriod(Mm-1)2008-12 ProgressPeriod(Mm-1)Sulfate83.290.070.062.150.7Nitrate13.311.913.014.414.4OrganicCarbon22.519.818.718.714.9ElementalCarbon4.74.74.24.13.7Fine Soil1.21.21.31.11.1CoarseMaterial6.84.95.55.15.4Sea Salt0.20.40.50.40.4Total LightExtinction142.9143.9124.1117.0101.6Deciview26.325.924.724.122.9Arkansas – Caney CreekClass I Area Visibility Summary:Caney Creek W, AR Class I areaVisibility Conditions:Worst 20% DaysReasonable Progress Summary2000-04 BaselineConditions(Mm-1)2005-09 ProgressPeriod(Mm-1)2006-10 ProgressPeriod(Mm-1)2007-11 ProgressPeriod(Mm-1)2008-12 ProgressPeriod(Mm-1)Sulfate87.187.063.453.951.9Nitrate13.89.511.212.612.5OrganicCarbon23.416.414.814.113.3ElementalCarbon4.84.23.53.33.3Fine Soil1.11.21.51.31.4CoarseMaterial3.74.04.34.34.2Sea Salt0.20.30.30.40.5Total LightExtinction145.1133.6110.1100.997.9Deciview26.425.323.723.022.72013 EGU Control Summary for Units Subject to CAIR (queried from CAMD):FacilityNameFacilityID(ORISPL)UnitIDYearUnitTypeFuelType(Primary)FuelType(Secondary)SO2Control(s)NOxControl(s)PMControl(s)Asbury207612013CycloneboilerCoalOverfireAir<br>SelectiveCatalyticReductionElectrostaticPrecipitatorAudrainPowerPlant55234CT12013CombustionturbinePipelineNaturalGasDryLowNOxBurnersAudrainPowerPlant55234CT22013CombustionturbinePipelineNaturalGasDryLowNOxBurnersAudrainPowerPlant55234CT32013CombustionturbinePipelineNaturalGasDryLowNOxBurnersAudrainPowerPlant55234CT42013CombustionturbinePipelineNaturalGasDryLowNOxBurnersAudrainPowerPlant55234CT52013CombustionturbinePipelineNaturalGasDryLowNOxBurnersAudrainPowerPlant55234CT62013CombustionturbinePipelineNaturalGasDryLowNOxBurnersAudrainPowerPlant55234CT72013CombustionturbinePipelineNaturalGasDryLowNOxBurnersAudrainPowerPlant55234CT82013CombustionturbinePipelineNaturalGasDryLowNOxBurnersBlueValley213232013Tangentially‐firedCoalPipelineNaturalGasLowNOxBurnerTechnologyw/Closed‐coupledOFAElectrostaticPrecipitatorChamoisPowerPlant216922013CycloneboilerCoalDieselOilElectrostaticPrecipitatorChillicothe2122GT1A2013CombustionturbinePipelineNaturalGasDieselOilChillicothe2122GT1B2013CombustionturbinePipelineNaturalGasDieselOilChillicothe2122GT2A2013CombustionturbinePipelineNaturalGasDieselOilChillicothe2122GT2B2013CombustionturbinePipelineNaturalGasDieselOilColumbia212362013StokerCoalBaghouseColumbia212372013StokerCoalBaghouseColumbia212382013Drybottomwall‐firedboilerPipelineNaturalGasColumbiaEnergyCenter(MO)55447CT012013CombustionturbinePipelineNaturalGasDryLowNOxBurnersColumbiaEnergyCenter(MO)55447CT022013CombustionturbinePipelineNaturalGasDryLowNOxBurnersColumbiaEnergyCenter(MO)55447CT032013CombustionturbinePipelineNaturalGasDryLowNOxBurnersColumbiaEnergyCenter(MO)55447CT042013CombustionturbinePipelineNaturalGasDryLowNOxBurnersDogwoodEnergyFacility55178CT‐12013CombinedcyclePipelineNaturalGasSelectiveCatalyticReductionDogwoodEnergyFacility55178CT‐22013CombinedcyclePipelineNaturalGasSelectiveCatalyticReductionEmpireDistrictElecCoEnergyCtr622312013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionEmpireDistrictElecCoEnergyCtr622322013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionEmpireDistrictElecCoEnergyCtr62233A2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionEmpireDistrictElecCoEnergyCtr62233B2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionEmpireDistrictElecCoEnergyCtr62234A2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionEmpireDistrictElecCoEnergyCtr62234B2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionEssexPowerPlant774912013CombustionturbinePipelineNaturalGasDryLowNOxBurnersFairgrounds2082CT012013CombustionturbineDieselOilGreenwoodEnergyCenter607412013CombustionturbinePipelineNaturalGasDieselOilGreenwoodEnergyCenter607422013CombustionturbinePipelineNaturalGasDieselOilGreenwoodEnergyCenter607432013CombustionturbinePipelineNaturalGasDieselOilGreenwoodEnergyCenter607442013CombustionturbinePipelineNaturalGasDieselOilHawthorn20795A2013Drybottomwall‐firedboilerCoalDryLimeFGDLowNOxBurnerTechnologyw/OverfireAir<br>SelectiveCatalyticReductionBaghouseHawthorn207962013CombustionturbinePipelineNaturalGasOtherHawthorn207972013CombustionturbinePipelineNaturalGasOtherHawthorn207982013CombustionturbinePipelineNaturalGasOtherHawthorn207992013CombinedcyclePipelineNaturalGasSelectiveCatalyticReductionHigginsvilleMunicipalPowerPlant21314A2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionHigginsvilleMunicipalPowerPlant21314B2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionHoldenPowerPlant784812013CombustionturbinePipelineNaturalGasDieselOilDryLowNOxBurners<br>WaterInjectionHoldenPowerPlant784822013CombustionturbinePipelineNaturalGasDieselOilDryLowNOxBurners<br>WaterInjectionHoldenPowerPlant784832013CombustionturbinePipelineNaturalGasDieselOilDryLowNOxBurners<br>WaterInjectionHowardBend2102CT1A2013CombustionturbineDieselOilHowardBend2102CT1B2013CombustionturbineDieselOilIatan606512013Drybottomwall‐firedboilerCoalWetLimeFGDLowNOxBurnerTechnologyw/OverfireAir<br>OverfireAir<br>SelectiveCatalyticReductionBaghouseIatan606522013Drybottomwall‐firedboilerCoalWetLimeFGDLowNOxBurnerTechnologyw/OverfireAir<br>OverfireAir<br>SelectiveCatalyticReductionBaghouseJamesRiver2161**GT12013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionJamesRiver2161**GT22013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionJamesRiver216132013Drybottomwall‐firedboilerCoalPipelineNaturalGasLowNOxBurnerTechnologyw/OverfireAirElectrostaticPrecipitatorJamesRiver216142013Drybottomwall‐firedboilerCoalPipelineNaturalGasLowNOxBurnerTechnologyw/OverfireAirElectrostaticPrecipitatorJamesRiver216152013Drybottomwall‐firedboilerCoalPipelineNaturalGasLowNOxBurnerTechnologyw/OverfireAirElectrostaticPrecipitatorJohnTwittyEnergyCenter619512013Drybottomwall‐firedboilerCoalDieselOil,PipelineNaturalGasOther<br>SelectiveCatalyticReductionElectrostaticPrecipitatorJohnTwittyEnergyCenter619522013Drybottomwall‐firedboilerCoalPipelineNaturalGasFluidizedBedLimestoneInjectionSelectiveCatalyticReductionBaghouseJohnTwittyEnergyCenter6195CT1A2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionJohnTwittyEnergyCenter6195CT1B2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionJohnTwittyEnergyCenter6195CT2A2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionJohnTwittyEnergyCenter6195CT2B2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionLabadie210312013Tangentially‐firedCoalLowNOxBurnerTechnologyw/Closed‐coupled/SeparatedOFAElectrostaticPrecipitatorLabadie210322013Tangentially‐firedCoalLowNOxBurnerTechnologyw/Closed‐coupled/SeparatedOFAElectrostaticPrecipitatorLabadie210332013Tangentially‐firedCoalLowNOxBurnerTechnologyw/Closed‐coupled/SeparatedOFAElectrostaticPrecipitatorLabadie210342013Tangentially‐firedCoalLowNOxBurnerTechnologyw/Closed‐coupled/SeparatedOFAElectrostaticPrecipitatorLakeRoad209862013CycloneboilerCoalPipelineNaturalGasOverfireAirElectrostaticPrecipitatorLakeRoad2098GT52013CombustionturbinePipelineNaturalGasDieselOilMcCartneyGeneratingStation7903MGS1A2013CombustionturbinePipelineNaturalGasWaterInjectionMcCartneyGeneratingStation7903MGS1B2013CombustionturbinePipelineNaturalGasWaterInjectionMcCartneyGeneratingStation7903MGS2A2013CombustionturbinePipelineNaturalGasWaterInjectionMcCartneyGeneratingStation7903MGS2B2013CombustionturbinePipelineNaturalGasWaterInjectionMeramec210412013Tangentially‐firedCoalLowNOxBurnerTechnologyw/SeparatedOFAElectrostaticPrecipitatorMeramec210422013Tangentially‐firedCoalLowNOxBurnerTechnologyw/SeparatedOFAElectrostaticPrecipitatorMeramec210432013Drybottomwall‐firedboilerCoalLowNOxBurnerTechnologyw/OverfireAirElectrostaticPrecipitatorMeramec210442013Drybottomwall‐firedboilerCoalLowNOxBurnerTechnologyw/OverfireAirElectrostaticPrecipitatorMeramec2104CT012013CombustionturbineDieselOilMeramec2104CT2A2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionMeramec2104CT2B2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionMexico6650CT012013CombustionturbineDieselOilMoberly6651CT012013CombustionturbineDieselOilMontrose208012013Tangentially‐firedCoalElectrostaticPrecipitatorMontrose208022013Tangentially‐firedCoalOverfireAirElectrostaticPrecipitatorMontrose208032013Tangentially‐firedCoalOverfireAirElectrostaticPrecipitatorMoreau6652CT012013CombustionturbineDieselOilNewMadridPowerPlant216712013CycloneboilerCoalDieselOilSelectiveCatalyticReduction<br>OverfireAirElectrostaticPrecipitatorNewMadridPowerPlant216722013CycloneboilerCoalDieselOilSelectiveCatalyticReduction<br>OverfireAirElectrostaticPrecipitatorNodawayPowerPlant775412013CombustionturbinePipelineNaturalGasDryLowNOxBurnersNodawayPowerPlant775422013CombustionturbinePipelineNaturalGasDryLowNOxBurnersNortheastGeneratingStation2081112013CombustionturbineDieselOilNortheastGeneratingStation2081122013CombustionturbineDieselOilNortheastGeneratingStation2081132013CombustionturbineDieselOilNortheastGeneratingStation2081142013CombustionturbineDieselOilNortheastGeneratingStation2081152013CombustionturbineDieselOilNortheastGeneratingStation2081162013CombustionturbineDieselOilNortheastGeneratingStation2081172013CombustionturbineDieselOilNortheastGeneratingStation2081182013CombustionturbineDieselOilPenoCreekEnergyCenter7964CT1A2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionPenoCreekEnergyCenter7964CT1B2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionPenoCreekEnergyCenter7964CT2A2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionPenoCreekEnergyCenter7964CT2B2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionPenoCreekEnergyCenter7964CT3A2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionPenoCreekEnergyCenter7964CT3B2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionPenoCreekEnergyCenter7964CT4A2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionPenoCreekEnergyCenter7964CT4B2013CombustionturbinePipelineNaturalGasDieselOilWaterInjectionRalphGreenStation209232013CombustionturbinePipelineNaturalGasWaterInjectionRushIsland615512013Tangentially‐firedCoalLowNOxBurnerTechnologyw/Closed‐coupled/SeparatedOFAElectrostaticPrecipitatorRushIsland615522013Tangentially‐firedCoalLowNOxBurnerTechnologyw/Closed‐coupled/SeparatedOFAElectrostaticPrecipitatorSibley209412013CycloneboilerCoalOverfireAir<br>SelectiveNon‐catalyticReductionElectrostaticPrecipitatorSibley209422013CycloneboilerCoalOverfireAir<br>SelectiveNon‐catalyticReductionElectrostaticPrecipitatorSibley209432013CycloneboilerCoalOverfireAir<br>SelectiveCatalyticReductionElectrostaticPrecipitatorSikeston676812013Drybottomwall‐firedboilerCoalOtherOilSelectiveNon‐catalyticReduction<br>LowNOxBurnerTechnology(DryBottomonly)ElectrostaticPrecipitatorSioux210712013CycloneboilerCoalWetLimestoneOverfireAir<br>OtherElectrostaticPrecipitatorSioux210722013CycloneboilerCoalWetLimestoneOverfireAir<br>OtherElectrostaticPrecipitatorSouthHarperPeakingFacility5615112013CombustionturbinePipelineNaturalGasSouthHarperPeakingFacility5615122013CombustionturbinePipelineNaturalGasSouthHarperPeakingFacility5615132013CombustionturbinePipelineNaturalGasSt.FrancisPowerPlant760412013CombinedcyclePipelineNaturalGasDryLowNOxBurners<br>SelectiveCatalyticReductionSt.FrancisPowerPlant760422013CombinedcyclePipelineNaturalGasDryLowNOxBurners<br>SelectiveCatalyticReductionStateLine(MO)729612013CombustionturbinePipelineNaturalGasDieselOilDryLowNOxBurners<br>WaterInjectionStateLine(MO)7296416712013CombinedcyclePipelineNaturalGasSelectiveCatalyticReductionStateLine(MO)7296416722013CombinedcyclePipelineNaturalGasSelectiveCatalyticReductionThomasHillEnergyCenter2168MB12013CycloneboilerCoalDieselOilOverfireAir<br>SelectiveCatalyticReductionElectrostaticPrecipitatorThomasHillEnergyCenter2168MB22013CycloneboilerCoalDieselOilOverfireAir<br>SelectiveCatalyticReductionElectrostaticPrecipitatorThomasHillEnergyCenter2168MB32013Drybottomwall‐firedboilerCoalDieselOilOverfireAir<br>LowNOxBurnerTechnology(DryBottomonly)<br>SelectiveCatalyticReductionElectrostaticPrecipitator

# Appendix B: Online Public Noti ce Screenshot with Date Stamp

# Appendix C: Written Comments and Res ponses and Consultation Correspondence

In order to fulfill the 60-day required consultatio n 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 Serv ice, and National Park Se rvice, 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. Co mments 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 th e Air Program via email

and comment letters. These are in cluded in this appendix as well.

The draft report was shared with the following FLM agency contacts, the same contacts all

participated in the aforemen tioned conference call as well.

Fish & Wildlife Service: Tim Allen

Forest Service: Claire O’Dea and Bret Anders on (the report was forwarde d to Bret after it was

sent officially to Claire)

National Park Service: Patricia Brewer



# Emails from Air Program Direct or 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 (atta ched 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 C onsultation 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 Pr ogress Report for

the two federal Class I Areas: Hercules Glades National Wild erness Area and Mingo National

Wildlife Refuge.

The Missouri Department of Natural Resources (d epartment) has prepared the enclosed report

to meet the requirements at 40 CFR 51.308(g), which address the ne ed 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 he aring on a RHR SIP or SIP revision (40 CFR

51.308(i)).

State periodic reports for this first implementa tion period are due to the U.S. Environmental

Protection Agency (EPA) no later than five years after the state’s initial SI P submittal to EPA.

The department submitted its initial Region al Haze SIP to the EPA on August 5, 2009.

Therefore, Missouri’s complete d progress report is due to EP A no later than August 2014. In

order to facilitate this process and to continue our collective ef forts to develop a complete SIP

package for submittal in August of this year, th e department has tentatively scheduled a public

hearing for this report on May 29, 2014 and the subsequent adop tion 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 peri od. We would appreciate your

comments on or before April 18, 2014 . Should you have any furt her questions concerning

Missouri’s 5-Year Progress Report, please do not he sitate to contact Ashley Jurgensmeyer at

the Missouri Department of Natural Re sources’ Air Pollution Control Program,

P.O. Box 176, Jefferson City, Missouri 651 02, or by telephone at (573) 751-4817.

Sincerely,

AIR POLLUTION CONTROL PROGRAM

# Kyra L. Moore

Director

KLM:ajc

Enclosures: Copy of Missouri’s Draft Regi onal 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 C onsultation 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-Y ear Progress Report for the two

federal Class I Areas: Hercules Glades Nati onal Wilderness Area and Mingo National Wildlife

Refuge.

The Missouri Department of Natural Resources (dep artment) has prepared the enclosed report to

meet the requirements at 40 CFR 51.308(g), which address the need for pe riodic reports that

evaluate progress towards the reas onable progress goals establis hed in the State Implementation

Plan (SIP). The RHR also require s States to consult with the FLM agencies at least 60 days prior

to holding any public hearing on a RHR SI P or SIP revision (40 CFR 51.308(i)).

State periodic reports for this first implemen tation period are due to the U.S. Environmental

Protection Agency (EPA) no later than five years af ter 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 collec tive efforts to develop a complete SIP package for

submittal in August of this year, the department ha s 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 consul tation period. We would appreciate your

comments on or before April 18, 2014 . Should you have any furt her questions concerning

Missouri’s 5-Year Progress Report, please do not hesitate to contac t Ashley Jurgensmeyer at the

# Missouri Department of Natural Resources’ Air Pollution Control Pr ogram, 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 C onsultation 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-Y ear Progress Report for the two

federal Class I Areas: Hercules Glades Nati onal Wilderness Area and Mingo National Wildlife

Refuge.

The Missouri Department of Natural Resources (dep artment) has prepared the enclosed report to

meet the requirements at 40 CFR 51.308(g), which address the need for pe riodic reports that

evaluate progress towards the reas onable progress goals establis hed in the State Implementation

Plan (SIP). The RHR also requires states to cons ult with the FLM agencies at least 60 days prior

to holding any public hearing on a RHR SI P or SIP revision (40 CFR 51.308(i)).

State periodic reports for this first implemen tation period are due to the U.S. Environmental

Protection Agency (EPA) no later than five years af ter 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 collec tive efforts to develop a complete SIP package for

# submittal in August of this year, the department ha s 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 consulta tion period. We would appreciate your

comments on or before April 18, 2014 . Should you have any furt her questions concerning

Missouri’s 5-Year Progress Report, please do not hesitate to contac t Ashley Jurgensmeyer at the

Missouri Department of Natural Resources’ Air Pollution Control Pr ogram, 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 se nt to the National Park Service. We also sent

copies to the Forest Service and Fish & Wildlif e; let me know if you want me to forward those

emails to you for your records.) We’re aski ng for comments from the FLMs by April 18, 2014,

and we’d appreciate any feedback from you by th en 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 Fo rest 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 Mi ssouri State Implementa tion Plan Revision.”

We appreciated the opportunity to review th e document and the chan ce 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 Hercul es Glades Wilderness, a Federally mandated

Class I area. The current project ions of sulfur dioxide emissions from the electric generating

units in Missouri are significantly lower than we re originally projecte d for 2018 in the Regional

Haze State Implementation Plan. Therefore, we agree with your conclusion that no additional

controls are necessary for the fi rst 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 reco mmendations to enhance the cl arity 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 impair ed days expressed in terms of 5-year

averages of these annual values.” In th e 5-Year Progress Repo rt, Missouri assesses

visibility conditions and changes by calcu lating a rate of improvement comparing

baseline with current conditions. We, ther efore, recommend reca lculating visibility

improvements by expressing visibility conditi ons and changes in terms of 5-year

averages.

2. The Glide Path Projected 2018 Conditions va lue 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 stat ed, “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 lis ted 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 visibili ty 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, Miss ouri 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 clarific ation 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 SO 2 

# and NO

x 

# RACT in St.

Louis. From our understanding, St. Louis ha s not officially been designated by EPA

as nonattainment of the new PM 2.5 

# 12 μg National Ambient Air Quality Standard

(NAAQS) standard, and further has peti tioned EPA to not be included in the

nonattainment area due to the fact that vi olations have occurred only on the Illinois

side of St. Louis. We, therefore, recomme nd 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 PM 2.5 

# NAAQS.

5. The 5-Year Progress Report, Section C, iden tifies trends for visibi lity on the best and

worst 20% sampling days for the three lo cations with IMPROVE monitors. This

trends analysis focuses on sulfate and nitrat e 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 include d in the analysis.

6. The 5-Year Progress Report, Section C, cal culates 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 s upport a continued rate of

improvement. We recommend providing justif ication for this assertion, or removing

it from the analysis.

We look forward to our conti nued 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 & Wild life 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 agricu ltural burning activity is attributed to impeding

visibility progress. No discus sion is provided on current or future potential changes to smoke

management procedures that might resolve th is concern. Agricultural burning is a source

category that should be addresse d 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, da ta 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 ba seline for MINGO NWR in your Regi onal Haze SIP. Since this 5

year review addresses progress fr om 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 appropria tely 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 Na tional Park Service, re ceived 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 Gl ade and Mingo that are copied from the WRAP's

Technical Support System. http://vista.cira.colostate.ed u/tss/Results/HazePlanning.aspx

The tables of 5-year averages show the contri butions of different pollu tant species to light

extinction and help to u nderstand the dv trends.

The charts show the relative contributions of th e 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 a nd 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 us e 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 Servi ce, received April 17, 2014:

TRANSMITTED VIA ELECTRONIC MA IL - 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 comm ent 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 51.3 08(g) and (h), that the emissions reductions

under Missouri’s Regional Haze Plan are suffi cient for Missouri to meet the 2018 Reasonable

Progress Goals set in the State’s Regional Haze pla n. 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 bett er support Missouri’s demonstration:

 Executive Summary:

In response to comments on Section C, please re vise the discussion of expected visibility

improvements by 2018.

#  Section A: Status of Emi ssions 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 em ission reductions expected between 2012 and 2017

(Table 2) were included in the 2018 projection in ventory and modeling that was used to set 2018

reasonable progress goals.

 Section B: Emissions Reductions:

Please add brief summary of nitrogen oxide emissi on trends for electric generating units (EGU)

in Figure 2 and Table 3.

 Section C: Visibility Trends

We recommend using the same baseline data a nd natural condition assump tions 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 reco mmend that Missouri use IMPROVE data through

2011.

Missouri should not extrapolate fr om the rate of visibility im provement for 2006-2012 to 2018 or

beyond (Figures 3, 11, 19.) Regional EGU contro ls between 2006 and 2012 significantly reduced

sulfur dioxide emissions and sulfate concentra tions 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 visi bility (measured in de civiews) for the 20%

worst ad 20% best visibility days for the 2000-2004

Baseline, Natural Conditions, 2018 Reasonable Progress Goals (fro m the Regional Haze Plan),

and 2007-2011 5-year averages. In cluding pollutant contributions to light extinction would

further identify the bases for the obs erved trends. These latter data are

available on the WRAP Technical Support System website

(http://vista.cira.colostate.e du/tss/Results/HazePlanning.aspx.) W ith the evidence available,

Missouri can demonstrate that the state is on tr ack to meet the 2018 reasonable progress goals.

Redefining the 2018 goals would require regional em issions projections a nd regional air quality

modeling that are beyond the expectations for the five year progress reports.

 Section E. Changes Impe ding Visibility Progress

Missouri did not include IMPROVE data to support the discu ssion of the contribution of

prescribed fire in 2010 to visibi lity trends. You may want to ad d 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 Mi ssouri emissions to haze in Class I areas in

neighboring states. Source appor tionment 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 progr ess goals for Class I areas in ne ighboring states a nd therefore is

not impeding neighboring states from meeting their goals.

# Comment Letter from EPA Regi on 7 (Received June 2, 2014):

Response to Received Comments:

Response to Comments from Fish& W ildlife Service: (Emailed Comments

received March 17, 2014)

1. In response to comment 1., additional langu age 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 addi tion, Missouri’s current Smoke Management plan

(SMP) should aid in protecting these visual environm ents and in the event of a violation or other

extreme case the SMP may be evaluated and re vised in order to properly protect these

environments.

# 2. All available visibility data was added to Sect ion C. of the report in response to this comment

and comments from other FLMs.

3. Projections to 2018 and beyond were removed fr om the report in res ponse 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 visibili ty analysis of this report in Section C., were updated using the

Western Regional Air Partnershi p (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 tabl es and corresponding graphs were added to the

visibility analysis se ction of th e 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 Se rvice: (Letter received April 17,

2014)

1. The executive summary has been upda ted in response to this comment.

2. In response to this comment, a table summarizing all SO 2 

# , NO X 

# , 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 Mark ets Division (CAMD) database.

The expected facility changes included in Table 2 are new developments and are not yet

permanent and enforceable; ther efore, these changes were not included in the 2009 RH plan’s

modeling efforts and language has been added to cl arify 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 th e 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 a dded (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 tr end data for the two nearby Class I areas in

Arkansas were added to the visi bility progress section of the repor t to reinforce the claim that

Missouri will not prevent nearby areas from ach ieving their RPGs in 2018. Additional clarifying

language was also added to Section F to fully address this comment.



# Response to Comments from Forest Servi ce (Letter received March 21, 2014):

1. All available 5-Year Average su mmary tables and graphs were a dded to the visibility analysis

section of the report. The ‘reas onable progress’ tables were ava ilable 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 diffe rent from the initial RH SIP. Therefore, the

RPGs are indeed the same as adopted in the initi al RH SIP and the data used for comparison and

analysis was accessed (via the TSS) in final be st/worst percent format to avoid any slight

assumption differences due to external manipula tion. The differences in data manipulation and

assumptions as well as data availability at tim e of calculation can be accounted for the slight

differences in values as disc ussed in Comment 3. Both comments are addressed by the

replacement of data as described above.

4. The reference to SO2 & NOx RACT in St. L ouis 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 comm ents, 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 languag e 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 chan ges were made to the report to correct any

errors of tense, grammar, or spelling.

# 3. In response to comment 3, additional explan ation was added to Section D of the report to

clarify referenced emissions trends and their co rrelation to overall visi bility 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

# ~~ ===========---- , Chairman

# ~7~..;;,o,JJ--**/ .** 

# ~ Vice Chairman

__ __ ____ J

_____ ,



# _________________________________ ,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

# ~~ ===========---- , Chairman

# ~7~..;;,o,JJ--**/ .** 

# ~ Vice Chairman

__ __ ____ J

_____ ,



# _________________________________ ,Member

_________________________________ ,Member

_________________________________ ,Member

# Jay Nixon, Governor

Sara Parker Pauley, Director



# Air Pollution Control Program

State Plan Actions

On Public Notice | Proposed fo r Adoption

On Public Notice

Missouri State Implementation Plan Revision – 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 demo nstrate reasonable prog ress toward meeting

the national goal of a return to natural visibility condit ions 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 vi sibility goals for the year

2018 for each of the state’s Class I areas in or der to make reasonable progress toward the

2064 goal. The purpose of this report is to asse ss 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 demonstr ates that both of Missouri’s Class I

areas are expected to meet their 2018 visibility goals based on contro l strategies currently

in place, which largely consist of sulfur di oxide and nitrogen oxides emission reduction

measures for utilities, industri al 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 accept ed through the close of business on June 5, 2014.

Missouri State Implementation Plan Re vision – Marginal Area Plan for the Missouri Portion of the St. Louis

Nonattainment Area for the 2008 8-Hour Ground Le vel 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 nonattainme nt area requirements pursuant to Clean Air

Act Section 182(a) for the Mi ssouri portion of the St. Louis nonattainment area under the

2008 8-hour ozone national ambient air quality standard (NAAQS). The Missouri portion of Pa g e 1 of 2 State Plan Actions on Public Notice - DN R

4/28/2014 htt p ://www.dnr.mo. g ov/env/a p c p /state p lanrevisions.htm

# 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-ho ur ozone NAAQS on May 21, 2012.

Marginal Area Plan for the Missouri Portion of the St. Louis Nonattai nment Area for the 2008

8-Hour Ground Level Ozone Nation al 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 accept ed through the close of business on June 5, 2014.

Proposed for Adoption

None at this time.



# Back to top Pa g e 2 of 2 State Plan Actions on Public Notice - DN R

4/28/2014 htt p ://www.dnr.mo. g ov/env/a p c p /state p lanrevisions.htm

# 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 No tices Update - Missouri Air Conservation

Commission Public Hearing, May 29, 2014



# This is a courtesy copy of an em ail 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 CONSER VATION COMMISSION

WILL HOLD PUBLIC HEARING

JEFFERSON CITY, MO -- The Missouri Air Conser vation Commission will hol d 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 co mmission will hear testimony related to the following

p roposed action(s):

* 10 CSR 10-5.220 (amendment) Control of Petroleum Liquid Storage, Loading and Transfer

This proposed amendment will remove the requireme nts for Stage II vapor recovery controls at

gasoline dispensing facilities (GDFs) in the St. L ouis area. Stage II systems control emissions of

volatile organic compounds during ve hicle refueling and have been an ozone-reduction measure in the

St. Louis area since the late 1980s. In May 2012, th e U.S. Environmental Protection Agency (EPA)

determined that Onboard Refueling Vapor Recove ry (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 c ontrolling the vapor displaced duri ng refueling that is built into

newer motor vehicles. ORVR makes Stage II c ontrols obsolete, and EPA’s widespread use

determination allows the removal of Stage II contro ls if Clean Air Act anti-backsliding requirements

are met to ensure air quality is not adversely impacted. EPA has al ready given verbal concurrence on

our technical analysis showing remo val of Stage II controls as propos ed in this rulemaking will not

adversely affect St. Louis air quality. The rule making 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 certif ied ASTs. Elimination of MOPETP requires

adding language to the rule to clarify that ASTs will continue to be prohibited.

- Permitting provisions will be revise d 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 establishe s requirements for the protection of visibility in Class I areas,

consisting of national parks and wilderness areas. St ates 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 Cl ass I areas by 2064. There are two Cl ass I areas in Missouri: Hercules

Glades Wilderness Area and Mingo National Wildlif e 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 Cla ss 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 fi ve years since Missouri’s regional haze SIP was

submitted to EPA. This 5-year progress report dem onstrates that both of Missouri’s Class I areas are

expected to meet their 2018 visibility goals base d on control strategies currently in place, which

largely consist of sulfur dioxide and nitrogen oxides emission re duction measures for utilities,

industrial boilers, a nd other sources.

* Missouri State Implementation Plan Revision – Marginal Area Plan for th e 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 th e emissions inventory and

other marginal ozone nonattainme nt area requirements pursuant to Clean Air Act Section 182(a) for

the Missouri portion of the St. Louis nonattain ment area under the 2008 8-hour ozone national

ambient air quality standard (NAAQS). The Missour i portion of the St. Louis nonattainment area

includes the City of St. Louis a nd the Counties of St. Louis, St. Charles, Franklin, and Jefferson,

which were designated as a marginal nonattain ment 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 met hods. 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 mi crons, 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 matte r and, at the same time, designated it as a new Federal Equivalency

Method.

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

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

otherwise noted above.

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

# 3 

# Resources, Air Pollution Control Progr am, 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 hear ing testimony will be equally considered.

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

Commission, Missouri Department of Natural Resour ces, Air Pollution Control Program, P.O. Box 176,

Jefferson City, Missouri 65102-0176, or telephone ( 573) 526-3420. The Department requests persons

intending to give verbal presenta tions also provide a wr itten copy of their testimony to the commission

secretary at the time of the public hearing.

Persons with disabilities requiring special services or accommodations to attend the meeting can make

arrangements by calling the Program di rectly at (573) 751-4817, the Divisi on of Environmental Quality's toll

free number at (800) 361-4827, or by writing two weeks in advance of the meeting to: Missouri Department

of Natural Resources, Air Conservation Commissi on Secretary, P.O. Box 176, Jefferson City, MO 65102.

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

You are subscribed to the Air Publ ic Notices topic for Missouri DNR. Th is information has recently been

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

Celebrating 40 years of taking ca re of Missouri's natural reso urces. 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 st op subscriptions at any time on your

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

p roblems with the subscription service, please contact subscriberhelp.govdelivery.com

.

This service is provide d 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 b y

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 t o

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, E PA

14 Promulgated Rule 40 CFR 51.102 for the purpose o f

15 hearing testimony related to: 10 CSR 10-5.220,

16 amendment, Control of Petroleum Liquid Storage,

17 Loading and Transfer; Missouri State Implementat ion

18 Plan Revision, Regional Haze Plan, 5-year Progre ss

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 Ambi ent

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 hav e

2 Missouri State Implementation Plan Revision,

3 Regional Haze Plan, 5-year Progress report. Emil y

4 Wilbur?

5 * * * * *

6 EMILY WILBUR,

7 Of lawful age, produced and sworn, depos es

8 and says:

9 MS. WILBUR: Mr. Chairman, members of the

10 Commission, my name is Emily Wilbur. I'm employ ed

11 as the State Implement Plan, or SIP, Unit Chief

12 with the Missouri Department of Natural Resource s

13 Air Pollution Control Program. I work at 1659 E ast

14 Elm Street, Jefferson City, Missouri. I am here

15 today to present testimony on the proposed Misso uri

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 t his

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 Co mmission 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 follo wing page. Revisions were made to the proposed plan as a

result of comments received.

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

revised plan is available for review at the Missouri Departme nt of Natural Resources’ Air

Pollution Control Program, 1659 East Elm St reet, Jefferson City, Missouri, 65101, (573)751-

4817. It is also available online at http ://dnr.mo.gov/env/apcp/stateplanrevisions.htm.

The Air Program recommends the commission adopt the plan as revised. If the commission

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

Protection Agency for inclusion in th e Missouri State Implementation Plan.

# COMMENTS AND RESPONSES ON

PROPOSED REVISION TO

MISSOURI STATE IMPLEMENTATION PLAN –

State of Missouri Regional Haze Plan 5-Year Progress Report

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

(SIP) for the Regional Haze Plan 5-Year Progr ess Report opened on April 28, 2014, and closed

on June 5, 2014. Revisions to the proposed pl an were made as a result of comments.

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

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

changes to the proposed plan are incl uded in the response to comments.

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

Air Program received three comments from EPA Region 7.

COMMENT #1: Under Section A .1.2 of the report, EPA Regi on 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 consen t agreement to satisfy Best Available Retrofit

Technology (BART) requirements.

RESPONSE AND EXPLANATION OF CHANGE: Th e Air Program added the language below

to Section A.1.2 explaining that Holc im-Clarksville has ceased all SO 2 

# and NO X 

# emitting

operations since the consent agreement and are now in compliance with the consent agreement.

“Since the consent agreement included in the 20 09 plan, Holcim (US) Inc., in Clarksville,

Missouri, has discontinued Portland cement ma nufacturing and hazardous waste fuel burning

operations. Remaining operations at the facility include receiving, stor ing, and shipping. The

facility’s operating permit (OP 2004-002) was reclassified from a Part 70 to a Basic operating

permit in 2010. The facility’s new SO 2 

# and NO X 

# 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, timefra mes, data values, and labels.

RESPONSE AND EXPLANATION OF CHANGE: Th e 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 tre nd values in the tabl es in Section D.

RESPONSE AND EXPLANATION OF CHANGE: Th e Air Program reviewed Section D and

added a discussion explaining the em issions trends depicted in th e tables. The decreasing trend

# in point source emissions of SO 2 

# and NO X 

# are of the greatest si gnificance to visibility

improvement, therefore, these trends are the focus of Section D. However, other pollutants and

source sectors show varying trends that warranted additional clar ification. 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 fact ors being used to estimate em issions values. Despite these

increases in emissions, the decrease in SO 2 

# and NO X 

# emissions from point sources and the

corresponding improvement in visibility conditions are most significant and are the focus of the

progress report.