1 

### MISSOU RI Area Designations f

or the

20 08 Ozone National Ambient Air Q uality Standard s

The t able below identifies the areas and associated counties or parts of counties in Missouri that EPA intends to designate as no n attain ment for the 2008 o zone national ambient air quality standard s (20 08 NAAQS)

. In accordance with section 107(d) of the Clean Air Act, EPA must designate a n area ( county

or part of a county) in Missouri as “nonattainment” if it is violating the 2008 ozone NAAQS or if it is contributing to a violation of the 2008 ozone NAAQS in a nearby area. The technical analyses supporting the boundaries fo r the individual nonattainment areas are provided below.

Table 1: Intended Nonattainment Areas in Missouri

Area Missouri Recommended

Nonattainment Counties /Areas EPA’s Intended Nonattainment

Counties /Areas

St. Louis

- St Charles

Farmington, MO

- IL Franklin

Jefferson St. Louis City St. Louis County

St. Charles Franklin

Jefferson St. Louis City St. Louis County

St. Charles

St. Louis

- St. Charles

- Farm ington, MO

- IL is a multi

- state nonattainment area. Table 1 identifies the

counties in Missouri that EPA intends to designate as part of the nonattainment area

. EPA intends to designate the remaining counties in Missouri that are not listed in Table 1 as “unclassifiable/attainment” for the 2008 ozone NAAQS.

Note that counties in the Illinois portion of the St. Louis

- St. Charles

- Farmington, MO

- IL Combined Statistical Area ( CSA ) are discussed in the ozone designation technical support document for Illinois.

The analysis below provides the basis for the intended nonattainment area boundar ies . It relies on

EPA’s analysis of which monitors are violating the 20 08 o zone NAAQS

, based on certified air quality monitoring data from 2008

- 2010 and an evaluat ion of whether nearby areas are contributing to such

violations. EPA has evaluated contribution s from nearby areas based on a weight of evidence analysis considering the factors identified below. EPA issued guidance on December 4, 2008 that identified

these fac tors as ones EPA would consider in determining nonattainment area boundaries and

recommend ed that s tates consider these factors in making their designations recommendations to EPA

. 1

1. A ir quality data ( including the design value calculated for each Feder al Reference Method ( FRM ) or Federal Equivalent Method ( FEM ) monitor in the area ) ; 2. Emissions and emissions

- related data ( including location of sources and population , amount of

emissions and emissions controls , and urban growth patterns) ; 3. M eteorology (weat her/transport patterns) ; 4. G eography and topography (mountain ranges or other basin boundaries) ; 5. J urisdictional boundaries (e.g., counties, air districts, existing nonattainment areas, Indian

country , metropolitan planning organizations (MPOs))

1 The December 4, 2008 guidance m emorandum “Area Designations for the 2008 Revised Ozone National Ambient Air Quality Standards” refers to 9 factors. In this technical support document we have grouped the emissions

- related factors together under the heading of “Emissions and Emissions

- Re lated Data

, ” which results in 5 categories of factors.2

Ground

- level ozone is not emitted directly into the air, but is created by chemical reactions between oxides of nitrogen (NOx) and volatile organic compounds (VOC) in the presence of sunlight. Because

NOx and VOC emissions from a broad range of sources over a wide ar ea typically contribute to

violations of the ozone standard s , EPA believes it is important to consider whether there are contributing emissions from a broad geographic area. Accordingly, EPA chose to examine the 5 factors with respect

to the larger of the Combined Statistical Area (CSA) or Core Based Statistical Area (CBSA) associated with the violating monitor(s)

. 2 All data and information used by EPA in this evaluation are the latest available to EPA and/or provided to EPA by states or tribes.

In EPA’s designations guidance for the 2008 ozone NAAQS EPA recommend ed examining

CSA/C B SA s because certain factors used to establish CSAs and C B SAs are similar to the factors EPA is using in this technical analysis to determine if a nearby area is contributing to a violation of the 20 08

o zone NAAQS

. EPA used the same basic approach in the designation process for the 1997 o zone NAAQS. Where a violating monitor is not located in a CSA or C B S A, EPA ’s guidance recommend ed using the boundary of the county containing the violating monitor as the starting point for considering the nonattainment area’s boundary.

2 Lists of CBSAs and CSAs and their geographic components are provided at www.census.gov/population/www/metroareas/metrodef. html . The lists are periodically updated by the Office of Management and Budget. EPA used the most recent update, based on 2008 population estimates, issued on December 1, 2009 (OMB Bulletin No. 10

- 02).3

Technical A nalysis for St. Louis

- St. Charles

- Farmington, MO

- IL

Fi gure 1 is a map of the S t. Louis

- St. Charles

- Farmington, MO

- IL intended nonattainment area

. The

map provides other relevant information including the locations and design values of air quality

monitors , county and other jurisdictional boundaries, St. Louis

- St. Charles

- Farmington, MO

- IL CSA boundary, existing nonattainment boundary for 1997 ozon e NAAQS, and major transportation arteries.

Figure 1:

For purposes of the 1997 8

- hour ozone NAAQS, this area was de signated nonattainment. The boundary

for the nonattainment area for the 1997 o zone NAAQS included the entire counties of Franklin,

Jef ferson, St. Charles, St. Louis, and the City of St. Louis City in Missouri, and Monroe, Jersey, St. Clair, and Madison counties in Illinois.

In March 2009

, Missouri recommended that the above mentioned counties

, plus Lincoln C ounty

, in the

St. Louis a rea; Cass, Clay, Clinton, Jackson, and Platte counties in the Kansas City area; as well as Perry and St. Genevieve counties be designated as “nonattainment.” The state also recommended St.

Franc oi s and Cape Gira r deau counties as “unclassifiable” for th e 2008 ozone NAAQS b ased on air4

quality data from 2006

- 2008

. 3 In December 2011, Missouri submitted a revised recommend ation to

include the entire counties of Franklin, Jefferson, St. Charles, and St. Louis and the City of St. Louis as

“ nonattainment ” fo r the 200 8 ozone NAAQS based on air quality data from 2008

- 2010. The State recommended designating the remaining areas of the State as attainment/unclassifiable. In March 2009

, Illinois recommended that Madison, Monroe and St. Clair Counties be designate d as “nonattainment”

for the 2008 ozone NAAQS based on air quality data from 2006

- 2008

. 4 These recommendations from both Missouri and Illinois rely on data from FRM monitors or FEM monitors sited and operated in

accordance with 40 CFR Part 58

.

After co nsidering these recommendation s and b ased on EPA's technical analysis described below, EPA intends to designate the entire counties of Franklin, Jefferson, St. Charles, and St. Louis , and the City of

St. Louis in Missouri, and the entire counties of Monroe , Madison, and St. Clair in Illinois a s

“ nonattainment ” (as indicated in Table 2 below) for the 20 08 o zone NAAQS as the S t. Louis

- St.

Charles

- Farmington, MO

- IL multi

- state nonattainment area

.

Table 2 . State 's Recommended and EPA ’ s Intended Designated N onattainment Counties for S t. Louis

St. Charles

- Farmington, MO

- IL Area.

S t. Louis

- St. Charles

Farmington, MO

- IL State

- Recommended

Nonattainment Counties EPA Intended

Nonattainment Counties

Missouri Franklin

Jefferson

St. Charles St. Louis City

St. Louis County Franklin

Jefferson

St. Charles St. Louis City St. Louis County

Illinois Madison

Monroe

St. Clair Madison

Monroe

St. Clair

Factor Assessment



### Factor 1 : Air Q uality D ata

3 Missouri submitted its designation recommendations in a March 11, 2009 letter from Mark N. Templeton, Director of the Missouri Department of Natural Resources, which included enclosures containing an analysis of data supporting the State’s

recomm endations. Missouri revised its recommendations and MDNR requested EPA to act on the revisions in a letter dated December 5, 2011.

4 Illinois submitted its designation recommendations in a March 9, 2009 letter from Douglas P. Scott, Director of the Illin ois Environmental Protection Agency. The state also provided a Technical Support Document dated March 9, 2009, which included a nine factor analysis to support the State’s recommendations.5

For this factor

, EPA considered 8

- hour o zone design values (in ppm ) for air quality monitors in counties

in the S t. Louis

- St. Charles

- Farmington, MO

- IL area based on data for the 2008

- 2010 period (i.e., the 2010 design value, or DV) , which are the most recent years with fully

- certified air quality data

. A

monitor’s DV is the metric or statistic that indicates whether that monitor attains a specified air quality

standard. The 2008 o zone NAAQS are met when the annual f ourth

- highest daily maximum 8

- hour average concentration, averaged over 3 years is 0.075 ppm or less

. A DV is only valid if minimum data completeness criteria are met. See 40 CFR part 50 App endix P . Where several monitors are located in a county (or a designated nonattainment area or maintenance area ), the DV for the county or area is determined by the monitor w ith the highest level.

NOTE: Eligible monitors for providing design value data generally include State and Local Air Monitoring Stations (SLAMS) at population

- oriented locations with an FRM monitor. All data from Special Purpose Monitors (SPM) using an F RM are eligible for comparison to the relevant NAAQS, subject to the requirements given in the October 17, 2006 Revision to Ambient Air Monitoring Regulations (71 FR 61236). All monitors used to provide data must meet the monitor siting and eligibility re quirements given in 71 FR 61236 to 61328 in order to be accep table for comparison to the

2008 ozone NAAQS for designation purposes.

The 2010 DVs for the o zone NAAQS , where available, for counties in the S t. Louis

- St. Charles

Farmington, MO

- IL CSA are show n in Table 3

.

Table 3 . Air Quality Data

. County State Recommended

Nonattainment? 2008

- 2010 Design Value ( ppb )

Missouri:
Franklin, MO Yes Jefferson, MO Yes 72 Lincoln, MO No 72 St. Charles, MO Yes 77 St. Francois, MO No St. Louis, MO Yes 71

S t. Louis City, MO Yes 69
Warren, MO No Washington, MO No

Illinois:
Bond, IL No Calhoun, IL No Clinton, IL No Jersey, IL No 69 Macoupin, IL No 66 Madison, IL Yes 72
Monroe, IL Yes St. Clair, IL Yes 68

St. Charles C ounty in Missouri show s a violation of the 2008 o zone NAAQS , t herefore this is inclu ded

in the nonattainment area

. A county (or partial county) must also be designated nonattainment if it

contributes to a violation in a nearby area. E ach county without a violating monitor that is located near a county with a violating monitor has been evaluated based on the weight of evidence of the five factors to determine whether it contributes to the nearby violation

.6 

### Factor 2: Emissions and Emissions

- Related Data

EPA evaluated emissio ns of ozone precursors ( NO

x and VOC ) and other emissions

- related data that provide information on areas contributing to violating monitors.

Emissions Data

EPA evaluated county

- level emission data for NO

x and VOC derived from the 200 8 National Emissions

I nventory (NEI), version 1.5

. This is the most recently available NEI. (See http://www.epa.gov/ttn/chief/net/2008inventory.html ) Significant emissions levels in a nearby area

indicate the potential for the area to contribute to observed violations. EPA will also consider any additional information we receive on changes to emissions levels that are not reflected in recent inventories. These changes include emissions reductions due to perma nent and enforceable emissions controls that will be in place before final designations are issued and emissions increases due to new

sources.

Table 4 shows emissions of NO

x and VOC (given in tons per year) for violating and potentially contributing count ies in the S t. Louis

- St. Charles

- Farmington, MO

- IL CSA

.

Table 4

. Total 2008 NO

x and VOC Emissions.

County State Recommended

Nonattainment? NO x (tpy) VOC (tpy)

Missouri:
Franklin, MO Yes 14,094 4,939 Jefferson, MO Yes 11,769 6,729 Lincoln, MO No 1, 855 2,081 St. Charles, MO Yes 15,894 11,652 St. Francois, MO No 2,030 2,349
St. Louis, MO Yes 36,455 41,894 St. Louis City, MO Yes 17,576 14,027
Warren, MO No 1,749 2,064 Washington No 678 862

Missouri Total: 102,099 86,596

Illinois
Bond, IL No 1, 422 1,181 Calhoun, IL No 607 1,057
Clinton, IL No 4,409 2,515 Jersey, IL No 1,125 1,166 Macoupin, IL No 2,286 2,147 Madison, IL Yes 23,109 12,351
Monroe, IL Yes 2,410 1,551 St. Clair, IL Yes 10,804 8,719

Illinois total: 46,173 30,687

Areawide: 148,272 117,2847

The emission data in Table 4 indicate that for Missouri, the highest NO

x and VOC emissions reside in

St. L ouis County and the City of St. Louis

. In 200 8 these two areas accounted for 53 % and 65 % of NO

x and VO C emissions respectively for the Missouri portion of the area. In addition, Franklin and Jefferson

Count ies also ha ve comparatively high NO

x emissions (behind St. Louis and St. Charles Counties and the City of St. Louis) and form a contiguous area with th e three top emitting areas

. Together, the City of St. Louis, Franklin, Jefferson, and St. Louis Counties make up 78 % of both NO

x and VOC emissions in the Missouri portion of the area , and 54% of the NO

x emissions and 58% of the VOC emissions for the

entire St. Louis

- St. Charles

- Farmington, MO

- IL CSA.

The NO

x and VOC emissions are relatively low in Warren, Washington, and Lincoln counties. Together

in 2008 these counties account for 4% of NO

x and 6 % of VOC in the Missouri portion of the area.

Note th at the relative emissions levels in the Illinois portion of the St. Louis

- St. Charles

- Farmington,

MO

- IL CSA are discussed in the ozone designation technical support document for Illinois

.

P opulation density and degree of urbanization

EPA evaluated the p opulation and vehicle use characteristics and trends of the area as indicators of the probable location and magnitude of non

- point source emissions . These include ozone

- creating

emissions from on

- road and off

- road vehicles and engines, consumer products, residential fuel combustion, and consumer services. Areas of dense population or commercial development are an indicator of area source and mobile source NO

x and VOC emissions that may contribute to ozone formation. Rapid population or Vehicle Miles Trav eled ( VMT ) growth (see below) in a county on the urban perimeter signifies increasing integration with the core urban area, and indicates that the

associated area source and mobile source emissions may be appropriate to include in the nonattainment

area. T able 5 shows the population , population density, and population growth information for each county in the area.

Table 5 . Population and Growth. County State

Recommended

Nonattainment? 2010

Population 2010

Population Density (1000 po p/sq mi) Absolute

change in population (2000

- 2010) Population

% change (2000

- 2010)

Missouri:

Franklin, MO Yes 101,492 0.11 7,434 +8%
Jefferson, MO Yes

218 ,733 0.33 19,995 +10%
Lincoln, MO No 52,566 0.08 13,310 +34%
St. Charles, MO Yes 360,485 0.61 74,322 +26%
St. Francois, MO No 65,359 0.14 9,615 +17%
St. Louis, MO Yes 998,954 1.91 17,376

- 2% St. Louis City, MO Yes 319,294 4.83 27, 570

- 8%
Warren, MO No 32,513 0.07 7,793 +32%

Washin gton No 25,195 0.03 1,785 +8%8 Missouri total: 2,174,591 0.43 89,308 +4%
Illinois:

Bond, IL No 17,768 0.05 118 +1%
Calhoun, IL No 5,089 0.02 (1) 0%
Clinton, IL No 37,762 0.08 2,233 +6% Jersey, IL No 22,985 0.06 1,330 +6% Macoupin, IL No 47,765 0.06 (1,224)

- 2%
Madison, IL Yes 269,282 0.36 10,165 +4%
Monroe, IL Yes 32,957 0.08 5,193 +19%
St. Clair, IL Yes 270,056 0.40 13,852 +5%
Illinois total: 703,664 0.17 31,666 +5%
Areawide: 2,878,255 0.31 120,974 +4%

Source s : U.S. Census Bureau population estim ates for 20 10 as of August 4, 2011 ( http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_ 10_PL_GCTPL2.STO5&
prodType=table ) and U.S. Census Bureau GIS files for the county boundaries

In the Missouri portion of the St. Louis

- St. Charles

- Farmington, MO

- IL CSA

, St. Louis and St. Charles counties along with the City of St. Louis have comparatively high population and high population density. This also correlates to those three counties having the highest amount of NO

x and VOC

emissions in the area. Warren, Washington, and St. Francois Counties have relativ ely low population, population density, and lowest absolute change in population. Lincoln County has relatively low population for the area, as well as one of the lowest population densit ies (behind Warren and Washington Counties) among the Missouri Counti es in the CSA.

Note that the ozone designation technical support document for Illinois addresses the population

- related

emission contributions from the Illinois portion of the St. Louis

- St. Charles

- Farmington, MO

- IL CSA.9

Traffic and commuting patterns

EPA evaluated the commuting patterns of residents in the area, as well as the total VMT for each

county . In combination with the population/population density data and the location of main transportation arteries (see Figure 1 above) , this information hel ps identify the probable location of non

point source emissions. A county with high VMT and/or a high num b er of commuters is generally an integral part of an urban area and indicates the presence of motor vehicle emissions that may contribute

to ozone form ation. Rapid population or VMT growth in a county on the urban perimeter signifies increasing integration with the core urban area, and indicates that the associated area source and mobile source emissions may be appropriate to include in the nonattainment area.

Table 6 shows traffic and commuting pattern data, including total 2008 VMT for each county, number of commuters in each county who drive to another county within the area

, and the percent of total commuters in each county who commute to other cou nties within the area.

Table 6 . Traffic and Commuting Patterns

.

County State

Recommended

Nonattainment? 2008 VMT*

(million miles) Number Commuting

to or within any violating counties** Percent Commuting to or within any violating counties**

Missouri:

Franklin, MO Yes 1,637 776 2%
Jefferson, MO Yes 1,885 1,337 1%
Lincoln, MO No 495 5,529 30%
St. Charles, MO Yes 2,728 70,282 47%
St. Francois, MO No 548 92 0%
St. Louis, MO Yes 11,925 13,513 3% St. Louis City, MO Yes 3,450 1,502 1%
Warren, MO No 525 2,967 25% Washington No 220 27 0%
Missouri total: 23,414 96,025 10%

Illinois:
Bond County No 284 20 0% Calhoun County No 40 109 5% Clinton County No 389 49 0% Jersey County No 192 125 1% Macoupin County No 415 36 0% Madison County Yes 2,839 1,126 1% Monroe County Yes 361 84 1% St. Clair County Yes 2,666 7 29 1%
Ill i nois total: 7,186 2,278 1%

Areawide: 30, 599 98,303 8 %

* MOBILE model VMTs are those inputs into the NEI version 1.5.

** U.S. Census Bureau estimates for 2000 County

- to

- County Worker Flow http://www.census.gov/hhes/commuting/data/commuting.html

.

For Missouri, the VMT data show that VMT levels in St. Louis City, St. Louis County, and St. Charles County are significantly higher than those in other Missouri counties in th e St. Louis

- St. Charles

-10

Farmington, MO

- IL CSA. Cumulatively , the VMT in these counties are a significant portion of the total

VMT for the St. Louis

- St. Charles

- Farmington, MO

- IL CSA

.

Note that the ozone designation technical support document for Illinois addresses the traffic and commuting patterns for the Illinois portion of the St. Louis

- St. Charles

- Farmington, MO

- IL CSA.



### Factor 3 : Meteorology (weather/transport patterns)

EPA evaluate d any available meteorological data to help determine how meteorolo gical conditions, such as weather, transport patterns and stagnation conditions, would affect the fate and transport of precursor emissions contributing to ozone formation. EPA examined the frequency distribution of wind directions during the summer by ave raging National Weather Service direction

- sorted wind directions for each county for a 30 year period. To apply the results of this data analysis to the St. Louis

- St. Charles

Farmington, MO

- IL CSA, we have considered the wind direction frequencies during the summer months (June

- August) for St. Charles County in Missouri, the only county with a recorded violation of the 2008 ozone NAAQS (see Table 2 ). The table below shows the summertime 30

- year averaged percentages of wind directions for St. Charles Coun ty in Missouri.

Averaged Summertime Wind Direction Percentages for St. Charles County, MO

Wind Direction Percentage

North

- Northeast 9.82%

East

- Northeast 7.24%

East

- Southeast 13.66%

South

- Southeast 14.41%

South

- Southwest 20.01%

West

- Southwest 14.64%

West

- Northwest 12.84%

North

- Northwest 7.39%

The table indicates that winds from the south

- southwest may be slightly more prevalent than winds from other directions during the summertime, and there is a southerly component 62.72% of the time . This

mean s that the location s of Franklin, St. Louis and Jefferson counties , as well as St. Louis city, are upwind when the southerly component occurs.



### Factor 4 : Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analy sis evaluates the physical features of the land that might affect the airshed and, therefore, the distribution of ozone over the area

.

T he S t. Louis

- St. Charles

- Farmington, MO

- IL area does not have any geographical or topographical barriers significantly limiting air pollution transport within its air shed. Therefore, this factor did not play a significant role in this evaluation

.11 

### F actor 5 : Jurisdictional boundaries

Once the general areas to be included in the nonattainment area were determined, EPA c onsider ed existing jurisdictional boundaries for the purposes of providing a clearly defined legal boundary and carrying out the air quality planning and enforcement functions for nonattainment areas. Examples of jurisdictional boundaries include existing /prior nonattainment areas for ozone or other urban

- scale pollutants, counties, air districts, townships, metropolitan planning organizations, state lines, Reservations, urban growth boundary, etc. Where existing jurisdictional boundaries are not adequate to describe the nonattainment area, other clearly defined and permanent landmarks or geographic

c oordinates were considered.

The St. Louis, MO

- IL area has previously established nonattainment boundaries associated with the 1

- hour and the 1997 8

- hour ozon e N AAQS. The Missouri portion of the St. Louis

- St. Charles

Farmington, MO

- IL CSA that EPA is intending to designate as nonattainment for the 2008 ozone NAAQS is the same area that EPA designated as nonattainment under the 1

- hour NAAQS, as well as

what was recommended by the state of Missouri and designated nonattainment for the 1997 8

- hour ozone NAAQS. Under the 1997 8

- hour ozone NAAQS for the Illinois portion of the St. Louis

- St.

Charles

- Farmington, MO

- IL CSA, Jersey County, IL was also included in the n onattainment area due to a monitored violation of the standard in that county. The state of Illinois has recommended designating Jersey County, IL as attainment for the 2008 ozone NAAQS. The monitor in Jersey County, IL is currently monitoring attainment and, as provided in the TSD for Illinois, we do not believe Jersey County is contributing to nonattainment at the violating monitors in the area. Thus, we do not intend to include Jersey County is the designated nonattainment area.



### Conclusion

Bas ed on the assessment of factors described above, EPA has preliminarily concluded that the following

Missouri areas meet the CAA criteria for inclusion in the St. Louis

- St. Charles

- Farmington, MO

- IL nonattainment area because they are either violating the 2 008 ozone NAAQS or contributing to a violation in a nearby area: Franklin County, Jefferson County, St. Charles County, St. Louis City, and St. Louis County

. This is consistent with the recommendation submitted by Missouri. These are the

same Missouri c ounties that were included in the St. Louis, MO

- IL nonattainment area for the 1

- hour ozone NAAQS as well as for the 1997 8

- hour ozone NAAQS. One air quality monitor in the Missouri counties (St. Charles) indicate d a violation of the 2008 ozone NAAQS based on 2010 design values, therefore this county is included in the nonattainment area. Franklin County, Jefferson County , St. Louis City, and St. Louis Count y are nearby counties that do not have violating monitors, but EPA has

concluded that these areas c ontribute to the ozone concentrations in violation of the 2008 ozone NAAQS in St. Charles County . This conclusion is based in part on relatively high NO

x and VOC emissions and relatively high VMT in those counties. Based on 2008 data, St. Louis County, S t. Louis City, Franklin County, and Jefferson County have the first, second, fourth, and fifth highest NO

x emissions respectively in the St. Louis

- St. Charles

- Farmington, MO

- IL CSA. These counties also have among the highest VOC emissions in the St. Louis

- St. Charles

- Farmington, MO

- IL CSA. St. Louis County and St.

Louis City ha ve the highest 2008 VMT, and Franklin and Jefferson has the fourth and fifth highest 2008

VMT in the St. Louis

- St. Charles

- Farmington, MO

- IL CSA.