## Redesignation Demonstration
and
Maintenance Plan for the Missouri Portion of the
St. Louis Nonattainment Area for the 1997 8-Hour Ground-Level Ozone (O 3 

## ) National Ambient Air Quality Standard

Prepared for the
Missouri Air Conservation Commission



## Adoption October 27, 2011

Missouri Department of Natural Resources Division of Environmental Quality Air Pollution Control Program Jefferson City, Missouri**ii** 

### TABLE OF CONTENTS

EXECUTIVE SUMMARY ..................................

................................................... .......... 1

1. BACKGROUND/INTRODUCTION......................... .................................................. 2

**1.1 N ATIONAL**  **A MBIENT**  **A IR**  **Q UALITY**  **S TANDARD FOR**  **O ZONE**  **............................................ 2**
**1.2 O ZONE AND**  **I TS**  **F ORMATION** 

**................................................... ......................................... 3** 
**1.3 N EGATIVE**  **E FFECTS OF**  **O ZONE** 

**................................................... ..................................... 3** 
**1.4 G EOGRAPHICAL**  **D ESCRIPTION OF THE**  **S T** 

**. L**  **OUIS N**  **ONATTAINMENT A**  **REA ...................... 4** 
**1.5 S T** 

**. L**  **OUIS O**  **ZONE H**  **ISTORY**

**................................................... ........................................... 6** 
**1.6 C URRENT**  **S TATUS**  **/ B**  **ACKGROUND S**  **UMMARY**

**................................................... .............. 9** 



### 2. REDESIGNATION AND MAINTENANCE PLAN REQUIREMENTS .... ........ 10

**2.1 A TTAINMENT OF THE**  **S TANDARD** 

**................................................... ................................ 10** 
**2.2 I MPLEMENTATION**  **P LAN**  **A PPROVAL** 

**................................................... ........................... 11** 
**2.3 P ERMANENT AND**  **E NFORCEABLE**  **I MPROVEMENT** 

**................................................... ........ 12** 
**2.4 M AINTENANCE**  **P LAN**  **R EQUIREMENTS** 

**................................................... ........................ 12** 
**2.5 S ECTION**  **110 AND**  **P ART**  **D R**  **EQUIREMENTS**

**................................................... ................ 15** 



### 3. OZONE MONITORING...................................

................................................... ..... 16

**3.1 S T** 

**. L**  **OUIS O**  **ZONE M**  **ONITORING N**  **ETWORK**

**................................................... ................ 16** 
**3.2 A MBIENT**  **A IR**  **M ONITORING**  **D ATA** 

**................................................... .............................. 17** 
**3.3 S T** 

**. L**  **OUIS O**  **ZONE M**  **ONITORING D**  **ATA A**  **NALYSIS**

**................................................... ...... 22** 
**3.4 M ISSING**  **D ATA**  **U NDER THE**  **1997 8-H**  **OUR O**  **ZONE S**  **TANDARD ...................................... 22**  **3.5 Q UALITY**  **A SSURANCE**  **P ROGRAM** 

**................................................... ................................ 23** 
**3.6 C ONTINUED**  **M ONITORING**  **C OMMITMENT** 

**................................................... ................... 23** 
**3.7 C**  **LEAN D**  **ATA D**  **ETERMINATION**

**................................................... ................................... 23** 



### 4. REDESIGNATION REQUEST: EMISSION INVENTORY AND CONTR OLS
FROM 2002 - 2008 ...................................

................................................... ............... 24

**4.1 B ASE**  **Y EAR AND**  **A TTAINMENT**  **Y EAR**  **I NVENTORIES** 

**................................................... ... 24** 
**4.2 C ONTROLS**  **U SED TO**  **A TTAIN THE**  **S TANDARD** 

**................................................... ............. 26** 
**4.3 R EASONABLY**  **A VAILABLE**  **C ONTROL**  **T ECHNOLOGY**  **(RACT)........................................ 29**
**4.4 P ERMANENT AND**  **E NFORCEABLE**  **C ONTROLS** 

**................................................... .............. 30** 



### 5. MAINTENANCE PLAN DEMONSTRATION: EMISSION INVENTORY AND
CONTROLS FROM 2008 - 2022..........................

................................................... . 32

**5.1 B ASE**  **/A TTAINMENT**  **Y EAR**  **I NVENTORY AND**  **F UTURE**  **Y EAR**  **E MISSION**  **P ROJECTIONS**  **.... 32**
**5.2 I NTERIM**  **Y EAR**  **E MISSION**  **I NVENTORY**  **: 2017 ...............................................**  **.................. 35**
**5.3 C ONTROLS TO**  **R EMAIN IN**  **E FFECT** 

**................................................... ............................... 36** 
**5.4 F**  **UTURE F**  **EDERAL C**  **ONTROL M**  **EASURES**

**................................................... ..................... 36** 
**5.5 P ROVISIONS FOR**  **P ERMITTING**  **N EW OR**  **M ODIFIED**  **E MISSIONS**  **S OURCES**  **........................ 37**



### 6. TRANSPORTATION CONFORMITY........................ ......................................... 38

7. CONTINGENCY MEASURES.............................. ................................................. 41

8. CONCLUSION.........................................

................................................... ............... 44**iii** 

### L IST OF 

### T ABLES

**Table 3-1 2007-2010 St. Louis 8-Hour Design Values**

**Table 4-1 2002 VOC and NO X**  **Emissions for the Missouri Side of the 1997 St. Lo uis** 

**8-Hour Ozone Nonattainment Area (tons per ozone sea son day)** 

**Table 4-2 2008 VOC and NO X**  **Emissions for the Missouri Side of the 1997 St. Lo uis** 

**8-Hour Ozone Nonattainment Area (tons per ozone sea son day)** 

**Table 4-3 Comparison of 2002 and 2008 VOC and NO X**  **Emissions for the Missouri Side of**

**the 1997 St. Louis 8-Hour Ozone Nonattainment Area (tons per ozone season**  **day)**

**Table 5-1 2008 VOC and NO X**  **Emissions for the Missouri Side of the 1997 St. Lo uis** 

**8-Hour Ozone Nonattainment Area (tons per ozone sea son day)** 

**Table 5-2 2022 VOC and NO X**  **Emissions for the Missouri Side of the 1997 St. Lo uis** 

**8-Hour Ozone Nonattainment Area (tons per ozone sea son day)** 

**Table 5-3 Comparison of 2008 and 2022 VOC and NO X**  **Emissions for the Missouri Side of**

**the 1997 St. Louis 8-Hour Ozone Nonattainment Area (tons per ozone season**  **day)**

**Table 5-4 2017 VOC and NO X**  **Emissions for the Missouri Side of the 1997 St. Lo uis** 

**8-Hour Ozone Nonattainment Area (tons per ozone sea son day)** 

**Table 6-1 Historical VMT in the Missouri Portion of the 1997 St. Louis 8-Hour Ozone**  **Nonattainment Area (State Owned Roads Only)**

**Table 6-2 2008 and 2022 Annual VMT by County**

**Table 6-3 Motor Vehicle Emissions Budgets for the M issouri Portion of the 1997 St. Louis** 

**8-Hour Ozone Nonattainment Area**

**Table 7-1 Contingency Plan for the Missouri Portion of the 1997 St. Louis 8-Hour Ozone** 

**Maintenance Area**

**Table 7-2 Potential Contingency Measures for the Mi ssouri Portion of the 1997 St. Louis** 

**8-Hour Ozone Maintenance Area iv**  

## List of Figures

**Figure 1-1 1997 8-Hour Ozone Nonattainment Area for St. Louis (MO-IL) region** 

**Figure 3-1 St. Louis Ozone Monitoring Network**

**Figure 3-2 2001 – 2010 8-Hour Ozone Design Value Tr ends – MO** 

**Figure 3-3 2001 – 2010 8-Hour Ozone Design Value Tr ends – IL** 

**Figure 3-4 2001 – 2003 & 2008 – 2010 Design Value C omparison** **v** 

## List of Appendices

**Appendix A 2002 Emission Inventory Summary**

**Appendix B 2008 Emission Inventory Summary**

**Appendix C 2017 Emission Inventory**

**Appendix D 2022 Emission Inventory**

**Appendix E 2008 Base Year Emissions Inventory for the Missouri Portion of the** 

**St Louis Ozone Nonattainment Area Appendix E-1 List of Statewide Point Source Emiss**  **ions by Facility Appendix E-2 List of Onroad Emissions by SCC for F**  **ranklin and Jefferson**
**Counties Appendix E-3 List of Onroad Emissions by SCC for S**  **t. Charles and St. Louis Counties and St. Louis City**  **Appendix E-4 Nonroad Inventory Documentation Appendix E-5 Nonroad Emissions by SCC**  **Appendix E-6 Nonpoint ICI Combustion Methodology Appendix E-7 Temporal Allocation**  **Appendix E-8 EIQ Forms**

**Appendix F MEMC Agreement**

**Appendix G Retired Unit Exemption Forms for Trigen and Anheuser Busch** **1**



## EXECUTIVE SUMMARY

**This document outlines the State of Missouri’s Main tenance Plan for Missouri’s portion of the** 
**St. Louis ozone nonattainment area. Per the federa l Clean Air Act Amendments of 1990, a**  **maintenance plan is required before an area can be redesignated from nonattainment to**  **attainment of a National Ambient Air Quality Standa rd (NAAQS). This document provides**  **technical information required to support a request to redesignate the St. Louis nonattainment**  **area to attainment of the 1997 8-hour ozone NAAQS. This maintenance plan will become part**  **of the state’s redesignation request submittal to t he U.S. Environmental Protection Agency**  **(EPA). The Missouri Department of Natural Resource s has prepared this plan in consultation**  **with the Illinois Environmental Protection Agency a nd the U.S. EPA. The Illinois EPA has**  **prepared a similar plan for the Metro-East portion of the St. Louis nonattainment area.** 

**Ozone air quality has dramatically improved in the St. Louis region as a result of implementation** 
**of State and Federal control measures since the des ignation of the St. Louis area as** 
**nonattainment in 2004. The entire St. Louis nonatt ainment area has at least three consecutive**  **ozone seasons of complete, quality assured ambient air quality monitoring data for 2008-2010**  **demonstrating attainment with the 0.080 parts per m illion (ppm) 8-hour ozone NAAQS**  **promulgated in 1997. These air quality improvement s are due to permanent and enforceable** 
**emissions control measures.**

**This maintenance plan provides for continued attain ment of the 1997 8-hour ozone air quality** 
**standard for the St. Louis nonattainment area for a period of ten years after the EPA has formally**  **redesignated the area to attainment. The plan also provides assurances that, in the event of a**  **subsequent violation of the air quality standard, a dditional control options listed in this plan,**  **called contingency measures, can quickly be impleme nted to prevent any future violations. In**  **addition, this plan demonstrates the observed actua l emission reductions that have been achieved**  **through permanent and enforceable control measures that brought the area back into attainment**  **of the NAAQS. This plan also includes an emissions inventory analysis of the ozone precursors**  **- Nitrogen Oxides (NOx) and Volatile Organic Compou nds (VOCs) – for both the redesignation**  **demonstration period (2002- 2008) and the maintenan ce plan period (2008 – 2022). This**  **analysis includes on-road motor vehicle emissions b udgets for the 2008 and 2022 for use in**  **transportation conformity determinations to assure that any increases in emissions from this**  **sector do not jeopardize continued attainment of th e 1997 8-hour ozone standard during the ten**  **year maintenance period in the St. Louis nonattainm ent area.** **2**



## 1. BACKGROUND/INTRODUCTION

1.1 National Ambient Air Quality Standard for Ozone
**Congress first enacted the Clean Air Act (CAA) in 1 970. It was last amended in 1990. The**  **CAA requires the U.S. Environmental Protection Agen cy (EPA) to set National Ambient Air**  **Quality Standards (NAAQS) for pollutants considered harmful to public health and the**  **environment. There are two categories of NAAQS tha t are set by the EPA. The primary**  **standards are health-based standards and are design ed to establish limits to protect public health.**  **The secondary standards are commonly referred to as “welfare-based standards” and are meant**  **established to protect public welfare. These limit s are intended to protect against decreased**  **visibility, and damage to crops, animals, and build ings. Currently there are six pollutants with**  **established primary level NAAQS. These pollutants are carbon monoxide, lead, total suspended**  **particles, sulfur dioxide, nitrogen oxide, and ozon e. These pollutants are referred to as “criteria”**  **pollutants. The EPA establishes a standard for eac h criteria pollutant. If an area is found to**  **exceed this value, it is classified as a nonattainm ent area for that specific pollutant. The states**  **and/or tribes responsible for the affected area mus t then develop and carry out strategies and**  **measures to attain the NAAQS. The goal is for any areas designated as “nonattainment” to be**  **reclassified by the EPA to attainment for the pollu tant.** 

**The CAA requires that the EPA carry out a periodic review of NAAQS for the criteria pollutants.**  **This review must include the scientific basis for ( 1) changing or reaffirming the NAAQS and (2)**  **implementing the NAAQS. As required by the CAA, th e EPA reviewed the one-hour NAAQS** 
**for ozone in the 1990’s and determined that a new s tandard was needed. This new standard was**  **finalized in July of 1997. The replacement of the ozone NAAQS was pursuant to subpart 1 of**  **the CAA, Title I, Part D.**

**The 1997 ozone standard is based on an eight-hour a veraging period. This standard defines an** 
**area as in attainment of the 8-hour ozone standard when the three-year average of the annual**  **fourth highest daily maximum 8-hour ozone concentra tion is less than or equal to 0.08 parts**  **ppm) (or 80 parts per billion (ppb)). Due to round ing conventions in the 1997 standard, an 8-**  **hour average ozone concentration above 0.085 ppm is considered an exceedance of standard.**  **When the three-year average value is 0.085 ppm or g reater, a violation of the ozone NAAQS has**  **occurred. A violation of the eight-hour standard i s determined on a per monitor basis. Monitor**  **readings (and exceedances) at one location do not h ave any affect on the readings at another.** 

**The EPA was challenged in court on the new 8-hour s tandard, and the one-hour standard was**  **reinstated. The Supreme Court upheld the constitut ionality of 8-hour standard, but ruled that the**  **EPA could not implement the new standard under subp art 1 of the CAA without considering the**  **CAA’s subpart 2 requirements. Subpart 2 specifies area classification for nonattainment areas**  **with additional control strategy requirements for e ach classification. The rule was remanded to**  **the EPA in order to develop a reasonable approach t o implement the new standard while**  **considering the roles of subparts 1 and 2 in the im plementation.** 

**Phase I of the Final Rule to Implement the 8-Hour O zone National Ambient Air Quality**  **Standard was released on April 30, 2004 and became effective on June 15, 2004. Phase II of the**  **rule was published on November 29, 2005 and became effective on January 30, 2006. These two** **3**

**rules provided specific obligations for state ozone plan revisions. Under these rules, the St.**  **Louis 8-hour Ozone Nonattainment Area was subject t o a number of obligations. All these**  **obligations have been met and all required submitte d revisions of the State Implementation Plan**  **(SIP) for the St. Louis nonattainment area have bee n submitted to the EPA.** 



### 1.2 Ozone and Its Formation
**Ozone is a reactive chemical compound. It is made up of three oxygen atoms and is identified**  **by the chemical symbol O 3**  **. Ozone is a gas that occurs both in the Earth’s u pper atmosphere and**  **at ground level. Depending on where ozone is found , it can be good or bad. When it occurs**  **naturally in the upper atmosphere, ozone acts as a shield from the sun’s harmful ultraviolet rays.**  **However, ground-level ozone is a concern during the summer months when the weather**  **conditions are favorable for producing ozone.**

**Unlike most other pollutants, ozone is not emitted directly into the air by specific sources, but is**  **formed by a photochemical reaction. This reaction occurs between NOx and VOCs in the**  **presence of sunlight and elevated ambient temperatu res. There are numerous sources of NOx**  **and VOC pollutants. These sources are divided into four types, including point, area, mobile and**  **natural. Point sources include larger permitted in dustries and power plants. Area sources are**  **small, stationary, non-transportation sources that collectively as a group can have a significant**  **contribution to air pollution. Examples of area so urces include gas stations, automotive shops**  **and dry cleaners. Mobile sources are divided into two categories: on-road and off-road.**  **Examples of on-road mobile sources include cars, tr ucks and buses. Off-road sources include**  **trains, ships, boats, airplanes, lawn equipment, an d construction equipment. Natural sources for**  **VOCs are released from vegetation, such as trees. Natural NOx sources are rare, but include**  **lightning, soil and some decomposition. Ozone is m ost commonly an urban air issue, but high**  **ozone readings can also be found in rural areas. T his is due to the fact that emissions of NOx**  **and VOC from motor vehicles and stationary sources can be carried hundred of miles from their**  **origins, and contribute to high ozone concentration s over very large, multi-state regions.** 



### 1.3 Negative Effects of Ozone
**Ozone is a strong oxidizing agent, with the potenti al to damage or impair lung airways and cause**  **inflammation. Sensitive populations such as childr en, the elderly, and people with respiratory**  **problems are the most vulnerable to its effects, bu t even healthy people that are active outdoors**  **can be affected when the quantity of ground level o zone is high. Even relatively low amounts of**  **ozone can cause chest pain, shortness of breath, an d coughing. Ozone can also worsen asthma,**  **bronchitis, and emphysema. Repeated exposure to oz one pollution for several months may cause**  **permanent lung damage.**

**Children are at a higher risk from exposure to ozon e because they breathe more air per pound of**  **body weight that adults do, and because children’s respiratory systems are still developing.**  **Children also often spend more time out of doors du ring periods of high concentration than**  **adults. Adults most at risk from ozone exposure ar e outdoor workers, people who exercise out of**  **doors, and individuals suffering with respiratory d iseases.** 

**Ground level ozone can also have negative effects o n plants and other vegetation by interfering**  **with their ability to produce and store food. It c an also reduce agricultural productivity and** **4**

**forest yields. Ozone also affects manufactured pro ducts. It causes or accelerates the**  **deterioration of building materials, surface coatin gs, rubber, plastic products and textiles.** 



### 1.4 Geographical Description of the St. Louis Nonat tainment Area

**The St. Louis Ozone Area is a bi-state nonattainmen t area that violated the 1997 8-Hour Ozone**  **Standard (see Figure 1-1). The following is a list of the counties contained in the St. Louis** 
**Missouri-Illinois 8-hour ozone nonattainment area:**

• **St. Louis County, MO**

• **St. Louis City, MO**

• **St Charles, MO**

• **Jefferson County, MO**

• **Franklin County, MO**

• **Madison County, IL**

• **St. Clair County, IL**

• **Monroe County, IL**

• **Jersey County, IL**

**As a result of the nonattainment designation and th e accompanying classification as moderate,**  **the St. Louis area was subject to new requirements, including development of a plan**  **demonstrating that the area would meet the federal 8-hour ozone NAAQS by June 15, 2010.** **5**



### Figure 1-1 1997 8-Hour Ozone Nonattainment Area for St. Louis (MO-IL) Region**6**



### 1.5 St. Louis Ozone History

1.5.1 One Hour Ozone Standard
**The Clean Air Act Amendments of 1990 required state s with nonattainment areas like St. Louis**  **to develop revisions to the SIP to bring those area s into compliance. St. Louis was classified as a** 
**moderate ozone nonattainment area for the 1-hour st andard. The Clean Air Act Amendments**  **included very specific requirements for areas under each classification. The most important**  **requirement for moderate areas was that attainment was to be achieved by 1996. Under the**  **Amendments, failure to attain by the assigned date would result in reclassification to the more**  **demanding classification of “serious.” Serious area s were subject to an additional set of**  **requirements.**

**St. Louis was required to achieve a minimum of 15 p ercent reduction in emissions of VOCs, and**  **submit this Rate of Progress (ROP) plan for achievi ng that reduction. On November 15, 1993 the**  **Missouri Department of Natural Resources’ Air Pollu tion Control Program submitted an initial**  **ROP plan. Subsequent amendments to the ROP plan we re made in 1994, 1995, and 1996. These** 
**amendments were the result of refinements to invent ory calculations and improvements in the** 
**documents.**

**Although the ROP requirement was one of the key obl igations of the Clean Air Act**  **Amendments, the primary obligation was to develop a plan to achieve the national ozone**  **standard in St. Louis. This plan is referred to as an attainment demonstration. An attainment**  **demonstration was prepared and submitted to the EPA on October 25, 1995, which showed that**  **the area would attain the air quality standard by 1 996. The St. Louis area, however, failed to**  **attain the 1-Hour ozone standard by 1996. The State s of Missouri and Illinois proceeded with a**  **request to extend the attainment deadline.**

**To qualify for an attainment deadline extension, Mi ssouri and Illinois had to demonstrate three**  **requirements: that the area was significantly affec ted by ozone or ozone precursors transported**  **from upwind sources; that all necessary local contr ol measures have been implemented; and that**  **the states had made the necessary administrative su bmittals. As part of this attainment date**  **extension, additional photochemical grid modeling w as conducted. This modeling included a**  **number of regional control measures, in addition to the 15 percent ROP controls such as**  **Reformulated Gasoline (RFG) and the enhanced Vehicl e Inspection/Maintenance (I/M)**  **programs. The attainment demonstration submitted as part of the 1-hour extension request** 
**focused on the evaluation of emission reductions th at were expected from electric generating**  **utilities resulting from EPA’s regional NOx SIP cal l. This SIP call resulted from EPA’s**  **determination that ozone transport from one region to another interfered with some states’ ability**  **to attain their ozone air quality goals. The NOx S IP call applied to twenty-two states in the**  **eastern United States, and included emission reduct ions from sources located in the eastern one**  **third of Missouri. The study showed that both regio nal NOx controls and local VOC controls**  **were necessary for attainment of the 1-hour standar d, and that St. Louis was significantly**  **affected by ozone transport and emissions from othe r states, and therefore, qualified for the**  **attainment date extension. St. Louis was granted th e extension, and subsequently attained the 1-** 
**hour ozone standard. 7** 



### 1.5.2 8-Hour Ozone Standard



### 1.5.2.1 8-Hour Ozone Designation
**EPA promulgated the 8-hour ozone standard in June 1 997. The new standard was set 0.08 parts**  **per million (ppm) averaged over 8 hours and replace d the 1-hour ozone standard. An exceedance** 
**of the 8-hour ozone standard occurs when a monitor measures ozone above 0.084 ppm (per the**  **rounding convention). A violation of the standard o ccurs when the average of the annual fourth**  **highest daily maximum 8-hour ozone values over thre e consecutive years is greater than or equal**  **to 0.085 ppm. This three-year average is called the design value for the monitor. The three-year**  **period from 1997-1999 were used for the purposes of designation. The design value for the St.**  **Louis Area was based on the monitor in the region w ith the highest design value. This monitor**  **is located in West Alton, MO and had a three year d esign value of 0.95 ppm. Areas such as St.**  **Louis which had design values that ranged from 0.92 to 0.107 ppm were classified as moderate** 
**ozone nonattainment areas.**

**Boundary designation recommendations under the 1997 standard were developed using guidance**  **published by EPA on March 28, 2000 and titled “** Boundary Guidance on Air Quality Designations for the 8-Hour Ozone National Ambient Air Quality Standards **.” The boundary**
**recommendation for the 8-hour standard was identica l to the old 1-hour boundary. It included**  **the City of St. Louis and the counties of St. Louis , Franklin, Jefferson, and St. Charles. This**  **recommendation was based on an in-depth technical e valuation based on EPA guidance. The**  **Department sought stakeholder input. During the wor kgroup process, many complex issues were** 
**raised and discussed.**

**In July 2000, on behalf of the Governor, the Depart ment sent the original recommendation**  **regarding the classification of counties under the revised ozone standard. These**  **recommendations were based on EPA guidance released on June 25, 1999 and March 28, 2000.**  **Based on 1997-1999 air quality data, the Department recommended the same boundary for the 8-**  **hour ozone nonattainment area as was used for the p revious one-hour ozone nonattainment area.**  **Based on the litigation surrounding the 1997 NAAQS (discussed in section 1.1) no formal action**  **was taken on the initial boundary designation submi ttal. EPA requested updated, revised, or new**  **designation recommendations and documentation from each state governor be submitted to the**  **Regional Administrator by July 15, 2003. These rec ommendations were to be based on 2000-**  **2002 quality assured air quality monitoring data.**

**Based on the input from stakeholders and the techni cal review, the Department’s Air Pollution**  **Control Program presented a proposed boundary recom mendation to the Missouri Air**  **Conservation Commission on June 26, 2003, and it wa s adopted on July 24, 2003. The**  **nonattainment area boundary recommended remained un changed from the 2000**  **recommendation and the 1-hour ozone designations. T he Department submitted the**  **recommendation to EPA on August 2, 2003.**

**In letters received December 4 and 12, 2003, the EP A stated that they intend to modify the**  **boundary recommendations for eight-hour ozone nonat tainment areas. The EPA intended to**  **modify the recommendation to include St. Genevieve County. In response to this EPA**  **comment, the Department offered an alternative, inv olving addressing upwind NOX emissions** **8**

**rather than including all of Ste. Genevieve County. On March 25, 2004, the MACC signed a**  **resolution committing the Department to promulgate a rule controlling emissions from large**  **NOx sources upwind and outside of the St. Louis non attainment area. This rule, 10 CSR 10-** 
**6.345** Control of NOx Emissions From Upwind Sources, **was subsequently promulgated and became effective on December 30, 2006.** 

**On April 15, 2004, EPA classified the St. Louis are a as a moderate nonattainment area for the**  **new eight-hour ozone standard. The area’s boundarie s were designated as recommended and**  **excluded Ste. Genevieve County. The state then had three years to develop the St. Louis** 
**nonattainment area 8-Hour Ozone SIP Revision.**



### 1.5.2.2. 8-Hour Ozone Implementation Plan
**The EPA’s 8-hour ozone implementation rule required a number of elements for an approvable** 
**SIP revision. These elements included: an emission s inventory; attainment demonstration;**  **Reasonably Available Control Technology (RACT) requ irements; a ROP demonstration; a**  **demonstration that New Source Review (NSR) permitti ng met all EPA requirements; motor**  **vehicle emissions budgets to meet both the rate of progress and attainment; a discussion of**  **specific individual area controls; and identificati on of contingency measures in case the area was** 
**not able to meet its attainment deadline.**

**Extensive work, effort and resources were required to develop all elements of the**  **implementation plan within the time frame establish ed by EPA. The final result of the**  **evaluations and the modeling of available data show ed that the St. Louis Nonattainment Area**  **would attain the 1997 standard by the 2010 deadline**

**.**

**Per the implementation rule, the RACT demonstration was required to be completed prior to** 
**other elements of the SIP revision. It was submitte d to EPA following adoption by the MACC on**  **December 6, 2006. All other required elements of t he revision were submitted as part of, or**  **concurrent with, the 2007 revision to the SIP. The I/M portion of the SIP was resubmitted as a**  **separate revision at a later date due to subsequent changes that were made in the program as the** 
**result of new state laws.**

**A public hearing of the 8-Hour ozone nonattainment plan SIP revision was held on April 26,**  **2007, before the MACC. Comments were received from the EPA and the East-West Gateway** 
**Council of Governments. A number of document edits were made in response to these**  **comments, but no substantive changes to control str ategies were needed. These revisions were**  **presented on May 31, 2007, and adopted by the Commi ssion.** 

**The eight-hour ozone plan was submitted to the EPA on June 13, 2007, meeting the June 15,**  **2007 federal deadline. The plan showed that the St . Louis non-attainment area will attain the**  **1997 NAAQS for ozone by the 2010 deadline.**

**Attainment of the 1997 NAAQS 8-Hour Ozone Standard was achieved following the 2009 ozone**  **season, allowing for the development of a request f or redesignation and maintenance plan.** **9**



### 1.6 Current Status / Background Summary

**On June 9, 2011, EPA published a final clean data d etermination in the Federal Register stating** 
**that the St. Louis ozone nonattainment area coverin g both Missouri and Illinois has attained the** 
**1997 8-hour ozone standard based on three consecuti ve ozone seasons of quality assured ambient**  **air monitoring data (76 FR 33647, June 9, 2011). I nformation regarding the air monitoring**  **network and air quality monitoring data are include d in Section 3.0 of this document.** 

**Section 107 of the Clean Air Act (CAA) establishes specific requirements to be met in order for**  **a nonattainment area to be considered for redesigna tion. Clean air quality data is one of those**  **requirements. The state must demonstrate that the improvement in air quality is due to**  **permanent and enforceable reductions in emissions r esulting from implementation of the SIP and**  **other federal requirements. The development of a m aintenance plan is another. This document**  **addresses the maintenance plan requirements, and in cludes additional information on the**  **permanent and enforceable measures used to demonstr ate attainment and continued compliance**  **with the 1997 8-hour ozone NAAQS. 10** 



## 2. Redesignation and Maintenance Plan Requirements

**An area designated as nonattainment for a pollutant can be redesignated to attainment if specific** 
**conditions are met. Missouri has followed the EPA published Memorandum entitled,**  **“Procedures for Requests to Redesignate Areas to At tainment”, from John Calgani, Director, Air**  **Quality Management Division, dated September 4, 199 2, in preparing the redesignation**  **demonstration and the maintenance plan. The memora ndum provides guidance regarding the**  **processing of requests for redesignation of nonatta inment areas to attainment for ozone, carbon**  **monoxide, particulate matter, sulfur dioxide, nitro gen dioxide, and lead.** 

**Furthermore, the CAA, lists five (5) obligations t hat the EPA must meet during the**  **redesignation process. Section 107(d)(3)(E) states :** 

**The Administrator may not promulgate a redesignatio n of a nonattainment area (or portion thereof) to** 
**attainment unless –**

**(i) the Administrator determines that the area has attained the national ambient air quality standard;**  **(ii) the Administrator has fully approved the appli cable implementation plan for the area under sectio**  **n 110(k);**  **(iii) the Administrator determines that the improve ment in air quality is due to permanent and enforce**  **able reductions in emissions resulting from implementati**  **on of the applicable implementation plan and applicable Federal air pollutant control regulation**  **s and other permanent and enforceable reductions; (iv) the Administrator has fully approved a mainten**  **ance plan for the area as meeting the requirements of**  **section 175A; and (v) the State containing such area has met all requ**  **irements applicable to the area under section 110 a nd part** 

**D.**

**These five (5) obligations must be met before redes ignation to attainment status; however, a state**  **may submit both the redesignation request and the m aintenance plan at the same time so that**  **rulemaking on both may proceed on a parallel track. This document outlines Missouri’s**  **redesignation request and demonstrates how the stat e supports EPA’s promulgation obligations**  **towards the redesignation of the St. Louis nonattai nment area to attainment under the 1997 ozone**  **NAAQS.**



### 2.1 Attainment of the Standard
**Requirement (i) for redesignation states that EPA m ust determine that the area is attaining the**  **applicable NAAQS. For the 1997 8-hour ozone NAAQS, this determination must be**  **demonstrated using the design value based on the av erage of the last three (3) years’ 4**  **th highest**  **maximum daily 8-hour average concentrations. This design value must be lower than the level**  **of the NAAQS, 0.08 ppm. The state submitted a Clea n Data Request to the EPA on December 4,**  **2009. On June 9, 2011, EPA published a final clean data determination in the Federal Register**  **stating that the St. Louis ozone nonattainment area covering both Missouri and Illinois has** 
**attained the 1997 8-hour ozone standard based on th ree years of quality assured ambient air**  **monitoring data (76 FR 33647, June 9, 2011). Secti on 3 presents information that demonstrates** 
**the St. Louis nonattainment area has attained the 1 997 8-hour ozone NAAQS. This** 
**demonstration is based on three consecutive ozone s easons of quality assured monitoring data as**  **specified in 40 CFR 58. 11** 



### 2.2 Implementation Plan Approval
**Requirement (ii) for redesignation states that the EPA administrator must have fully approved**  **the applicable implementation plan for the area und er section 110(k) of the CAA.**  The 2007 Revision of the State Implementation Plan for the S t. Louis 8-HOUR Ozone Nonattainment Area **was proposed for public hearing on April 26, 2007; was adopted by the Missouri Air**  **Conservation Commission (MACC) on May 31, 2007 and was submitted to the EPA on June 13,**  **2007. This ozone SIP was deemed to be complete on December 21, 2007.** 

**As stated earlier, EPA has published a final rule i n the Federal Register stating that the St. Louis**  **ozone nonattainment area covering both Missouri and Illinois has attained the 1997 8-hour ozone**  **standard based on three years of quality assured am bient air quality data (76 FR 33647, June 9,**  **2011). Once an area attains the standard for a cri teria pollutant, certain SIP element**  **requirements that are developed to demonstrate and achieve attainment become unnecessary**  **because the area has already attained the standard. These SIP elements that are tied to**  **demonstration of attainment are no longer required as long as the area does not violate the**  **standard again. These particular SIP elements woul d never be required once the area is**  **redesignated to a maintenance area for the pollutan t. Guidance on this subject is found on page 6**  **of the EPA’s Memorandum,** Procedures for Requests to Redesignate Areas to Att ainment **, from John Calgani, Director, Air Quality Management Divi**  **sion, dated September 4, 1992 which states “requirements for reasonable further progress ... wil**  **l not apply for redesignations because they only have meaning for areas not attaining the stand**  **ard.”**

**This guidance is reaffirmed in EPA’s May 10, 1995 M emorandum from John S. Seitz, Director,**  **Office of Air Quality Planning and Standards, title d**  Reasonable Further Progress, Attainment Demonstration, and Related Requirements of Ozone No nattainment Areas Meeting the Ozone National Ambient Air Quality Standard. **Page 6 of the 1995 Seitz memo details that suspen sions**  **are only valid while the area is in compliance with the standard and how the suspended**  **requirements are relieved:**

Thus, a determination that an area need not submit one of the SIP submittals amounts to no more than a suspension of the requirement for so long as the area continues to attain the standard. If EPA ultimately redesignates the a rea to attainment, then the area will be entirely relieved of these requirements to the exte nt the maintenance plan for the area does not rely on them.

**As such, on June 21, 2011, the state withdrew the a bove mentioned 8-hour Ozone Attainment**  **Demonstration and Reasonable Further Progress Demon stration, because the area has already**  **attained the NAAQS. All controls and regulations t hat are included in Missouri’s approved SIP**  **will continue to remain in place to ensure that the air quality improvements that have resulted**  **from these controls remain permanent and enforceabl e. By withdrawing the attainment**  **demonstration, the EPA administrator will no longer be required to approve or disapprove this**  **plan. The attainment demonstration is no longer ap plicable because the area has attained the**  **standard and therefore, only SIP elements that incl ude permanent and enforceable control**  **measures, such as regulations and consent agreement s need to be approved in order to satisfy this**  **requirement for redesignation. Missouri has adopte d all other necessary provisions to ensure the**  **protection of the standard including the Prevention of Significant Deterioration Program (PSD),** **12**

**under State rule** 10 CSR 10-6.060, Construction Permits Required **. Additional information about**
**the control measures used to attain the 1997 8-hour ozone standard can be found in Section 4 of** 
**this document.**



### 2.3 Permanent and Enforceable Improvement
**Requirement (iii) for redesignation states that EPA must determine that the improvement in air**  **quality is due to permanent and enforceable reducti ons in emissions resulting from**  **implementation of the applicable implementation pla n and applicable Federal air pollutant**  **control regulations and other permanent and enforce able reductions. Therefore, EPA must show**  **that the improvement in air quality between the yea r violations occurred and the attainment year**  **is attributed to permanent and enforceable emission reductions. Section 4 of this document**  **presents the emission reductions that were achieved from federal and state measures in the St.** 
**Louis area. The emission reductions are not based on temporary shutdowns or adverse economic**  **conditions, but due to permanent and enforceable co ntrol measures. This maintenance plan and**  **redesignation request includes a state commitment t o continue to enforce all applicable**  **requirements of past revisions to the SIP after the St. Louis ozone nonattainment area is**  **redesignated to attainment.**



### 2.4 Maintenance Plan Requirements
**Requirement (iv) for redesignation states that EPA must have fully approved a maintenance plan**  **for the area as meeting the requirements of section 175A of the Clean Air Act. Under Section**  **175A of the Clean Air Act, this 8-Hour Ozone Mainte nance Plan is the state’s SIP revision to**  **provide for continued attainment of the 1997 8-hour ozone NAAQS for the St. Louis**  **nonattainment area for a period of at least ten yea rs after EPA has formally redesignated the area**  **to attainment. To be approvable, the state is requi red to have a public hearing on the maintenance**  **plan prior to adoption. The maintenance plan must contain the following elements:** 

• **A comprehensive emissions inventory of the precurso rs of ozone completed for**  **the “attainment year”;**

• **A projection of the emissions inventory forward to a year at least ten years after**  **redesignation and a demonstration that the projecte d level of emissions is**  **sufficient to maintain attainment of the ozone NAAQ S;** 

• **A commitment that, once redesignated, the state wil l continue to operate an**  **appropriate monitoring network to verify maintenanc e of the attainment status;** 

• **A demonstration of legal authority to implement and enforce all control measures**  **contained in the SIP;**

• **Provisions for future updates of the inventory to e nable tracking of emissions**  **levels, including an annual emissions statement fro m major sources;** 

• **Motor vehicle emissions budgets for transportation conformity for the ten-year**  **maintenance period; 13**  • **A commitment to submit a revised Maintenance Plan e ight years after**  **redesignation;**

• **A commitment to enact and implement additional cont ingency control measures**  **expeditiously in the event that future violations o f the NAAQS occur;** 

• **A list of potential contingency measures that would be implemented in such an** 

**event.**

**This Maintenance Plan and redesignation request has been prepared in accordance with the**  **requirements specified in U.S. EPA’s guidance docum ent and additional guidance received from**  **EPA staff. The following subsections of this docume nt describe how these requirements have** 
**been met.**



### 2.4.1 Public Participation

**In accordance with Section 110(a)(2) of the CAA, th e Missouri is required to hold a public**  **hearing prior to adoption of this maintenance plan and the subsequent submittal to the EPA.**  **The Department will notify the public and other interes**  **ted parties of an upcoming public hearing and comment period thirty (30) days prior to holding su**  **ch hearing for this maintenance plan as**
**follows:**

• **Notice of availability of the redesignation request and maintenance plan was posted on**  **the Department of Natural Resources’ Air Pollution Control Program website on August**  **26, 2011: http://www.dnr.mo.gov/env/apcp/stateplanrevisions.**  **htm**

• **The public hearing date to receive comments on the redesignation request and**  **maintenance plan is to be held on September 29, 201 1, beginning at 9:00 am at the**  **Holiday Inn Southeast, Grand Ballroom A, B and C, 9 103 East 39**  **th Street, Kansas City,** 
**MO 64133.**

• **A public comment period was open after the redesign ation request and maintenance plan**  **was posted on Department of Natural Resources’ Air Pollution Control Program website**  **on August 26, 2011, and closes on October 6, 2011, seven (7) days after the public**  **hearing.**

• **Notice of availability of the 2008 St. Louis Ozone Nonattainment Area Base Year**  **Inventory was posted on the Department of Natural R esources’ Air Pollution Control**  **Program website by August 9, 2011: http://www.dnr.mo.gov/env/apcp/stateplanrevisions.h**  **tm**

• **A public comment period was open after the 2008 St. Louis Ozone Nonattainment Area**  **Base Year Inventory was posted on the Department of Natural Resources’ Air Pollution**  **Control Program website by August 8, 2011, and allo wed for a public hearing to be held**  **in regards to the document if requested. The publi c comment period for this inventory**  **closes on September 7, 2011.**

• **No public hearing was requested for the 2008 St. Lo uis Ozone Nonattainment Area Base**  **Year Inventory 14** 



### 2.4.2 Comprehensive “Attainment Year” Emissions Inv entory of Ozone Precursors

**The state has developed a comprehensive emission in ventory for the St. Louis ozone** 
**nonattainment area which includes the emissions fro m the following four source categories:**  **point sources, area sources, on-road mobile sources and off-road mobile sources. The attainment**  **year emission inventory, as required in the mainten ance plan, is detailed in Section 5 of this** 
**document.**



### 2.4.3 Projected Emission Inventory for 2022

**The state has compiled a list of growth and control factors and developed a county level emission**  **inventory for the future year of 2022 for the Misso uri portion of the St. Louis nonattainment**  **area. These projected emissions show substantial d ecreases between 2008 and 2022 in**  **cumulative emissions that contribute to ground-leve l ozone concentrations in the ambient air.**  **This future year emission inventory is detailed in Section 5 of this document and the state asserts**  **that these projected future emission levels are suf ficient to maintain attainment of the 1997 8-**  **hour ozone NAAQS.**



### 2.4.4 Continued Monitoring Commitment

**The State of Missouri is committed to continue moni toring ground-level ozone concentrations in**  **the St. Louis area and throughout the state in acco rdance with 40 CFR Part 58 and EPA approved**  **Annual Monitoring Plans. Missouri will continue to quality assure the ambient air monitoring** 
**data in accordance with 40 CFR 58 and submit the da ta into the AQS in a timely fashion.**  **Detailed information about the ground-level ozone m onitoring network in the St. Louis**  **nonattainment area, along with further discussion a bout the state’s continued monitoring**  **commitment, can be found in Section 3 of this docum ent.** 



### 2.4.5 Legal Authority to Implement and Enforce

**The Missouri Air Conservation Commission has the le gal authority to develop, implement, and**  **enforce regulations regarding air pollution includi ng the requirements of this SIP submittal under**  **section 643.050 of the Revised Statues of Missouri, also known as the Missouri Air Conservation** 

**Law.**



### 2.4.6 Provisions for Future Updates to the Emission Inventory

**The State of Missouri is committed to provide futur e updates of the inventory to enable tracking**  **of emissions levels during the 10-year maintenance period. State Regulation**  10 CSR 10-6.110, Reporting Emissions Data, Emission Fees, and Proces s Information **, requires that all installations located in the state that are require**  **d to obtain air quality construction or operating permits must report their annual emissions to the d**  **epartment. The methods for calculating and reporting their emissions are detailed in each inst**  **allation’s applicable permit. The data collected on emissions inventory questionnaires from permitte**  **d sources form the basis of the point source emissions inventory that is compiled on an annual b**  **asis. In addition, in compliance with the 15** 

**Federal Air Emission Reporting Rule (73 FR 76539), the Air program develops a comprehensive**  **emissions inventory of point, area, and mobile sour ces every three years.** 



### 2.4.7 Motor Vehicle Emission Budgets

**The State of Missouri is has developed motor vehicl e emissions budgets that will be used in**  **Transportation Conformity Determinations in the St. Louis area through 2022. Section 6 of this**  **document details the Transportation Conformity Proc ess in the St. Louis area and specifies the**  **2022 motor vehicle emissions budgets for NO X**  **and VOC emissions.**



### 2.4.8 Commitment to Revise Plan

**Under Section 175A of the Clean Air Act, an area de signated as maintenance for a NAAQS is**  **required to submit a second maintenance plan eight (8) years after redesignation of any area as**  **an attainment area under Section 107(d). This seco nd maintenance plan is intended to maintain**  **the NAAQS for ten (10) years after the expiration o f the initial ten year period. The**  **Department’s Air Pollution Control Program recogniz es the importance of an up-to-date, current**  **maintenance plan, and commits to updating it as nec essary.** 



### 2.4.9 Contingency Measures

**The State of Missouri is committed to maintaining c ompliance with the 1997 8-hour ozone** 
**standard. If future violations of the standard tak e place, the state will enact contingency**  **measures as expeditiously as possible, that will al low for the area to come back in compliance**  **with the standard as quickly as feasible. Further information about this commitment to enact**  **contingency measures, and a potential list of conti ngency measures that would be evaluated if**  **the area falls out of compliance with this standard in the future are located in Section 7 of this** 
**document.**



### 2.5 Section 110 and Part D Requirements
**Requirement (v) for redesignation states that, all the requirements of the section 110 and part D**  **of the CAA that were applicable prior to submittal of a complete redesignation request must be**  **met. These requirements include an emissions inven tory for a representative base year.**  **However, certain requirements are suspended when a nonattainment area achieves the NAAQS**  **because these requirements are correlated to the at tainment of the air quality goal and thus the**  **intention of these requirements has been fulfilled with achievement of the NAAQS without the**  **necessity of further submittals as long as the area does not violate the standard again. The**  **requirements for reasonable further progress that a re needed for attainment are suspended for**  **redesignation requests as long as an area is in att ainment. Guidance on this subject is found on**  **page 6 of the EPA’s Memorandum,** Procedures for Requests to Redesignate Areas to Att ainment

**, from John Calgani, Director, Air Quality Management**  **Division, dated September 4, 1992 which states “requirements for reasonable further progres**  **s ... will not apply for redesignations because they only have meaning for areas not attaining the**  **standard.” Applicable section 110 and Part D requirements that specifically apply to the mainten**  **ance plan are addressed in this document. 16** 



## 3. OZONE MONITORING

**This section presents monitoring information that d emonstrates St. Louis has attained the 1997 8-**  **hour ozone standard of 0.08 ppm. This demonstratio n is based on three consecutive ozone**  **seasons of quality assured data monitored at the St . Louis ozone monitoring network as specified**  **in 40 CFR 58. The demonstration uses ambient air qu ality monitoring data to demonstrate that**  **the area is attaining the applicable NAAQS consiste nt with methods cited in the EPA guidance**  **document “Procedures for Processing Request to Rede signate Areas to Attainment”. The**  **following are requirements regarding the use of amb ient air monitoring data in demonstrating**  **that the area is attaining the applicable NAAQS, as one of the conditions:** 

• **Monitoring data must show that the non-attainment a rea is attaining the NAAQS.** 

• **The data should be collected and quality assured in accordance with 40 CFR 58 and**  **recorded in the U.S. EPA Air Quality System (AQS) d atabase in order for it to be**  **available to the public for review.**



### 3.1 St. Louis Ozone Monitoring Network
**There are currently 15 sites that monitor ozone in the St. Louis Region. 11 sites are located**  **within the St. Louis nonattainment area; 6 in Misso uri and 5 in Illinois. In addition, Missouri and**  **Illinois operate at least a monitor upwind and down wind of the nonattainment area. The upwind**  **monitors are located in Bonne Terre, Ste. Genevieve County, Missouri and in Hickory, Randolph**  **County, Illinois. Downwind monitors outside of the nonattainment area are located in Foley,**  **Lincoln County, Missouri and Nilwood, Macoupin Coun ty, Illinois. Figure 3-1 shows all**  **monitors in the St. Louis Ozone Monitoring Network. 17**  

### Figure 3-1 St. Louis Ozone Monitoring Network



### 3.2 Ambient Air Monitoring Data
**As previously mentioned, exceedances of the standar d are determined on a per monitor basis.**  **An exceedance of the standard occurs any time that an 8-hour average value is greater than 0.084**  **ppm. A monitor can exceed the 8-hour standard and not violate the standard. A violation of the**  **standard at a specific monitor is determined by tak ing the fourth-highest, eight-hour average**  **reading at a monitor for each of three consecutive years and averaging them together. The eight**  **hour ozone standard is 0.08 ppm and, due to roundin g, a monitor must have a fourth highest**  **eight-hour, three-year average reading of 0.085 ppm (85 parts per billion, or ppb) or higher for it** 
**to be considered a violation of the standard.**

**Design values are calculated by averaging the annua l fourth-highest daily maximum 8-hour**  **ozone concentrations over the three consecutive yea rs (40 CFR Part 50). The standard at a site is**  **met when the site’s design value is less than or eq ual to 0.084 ppm (84 ppb). Design values are**  **used as indicators of a region’s air quality. The higher a design value for a monitor, the poorer**  **the air quality is in that area. Along the same li nes, if an area shows an increasing design value**  **over a number of years, monitoring data is indicati ng that the air quality is worsening.** **18**

**Figures 3-2 and 3-3 show the design value trends fo r the monitors in the Missouri portion of the**  **St. Louis nonattainment area and the Illinois porti on of the St. Louis nonattainment area,**  **respectively. As indicated by the trends in the fig ures, ozone concentrations have decreased at all**  **monitors, indicating improved air quality throughou t the St. Louis region. Within the Missouri**  **portion of the St. Louis nonattainment area, there were a total of 11 sites that violated the 1997**  **standard according to 2001-2003 air monitoring data (Figure 3-2). During the same time period**  **of 2001-2003, two sites in the Illinois portion of the St. Louis nonattainment area also violated**  **the 1997 standard (Figure 3-3). All sites in the a rea, are now in compliance of the standard, as**  **shown by the design value data in Figures 3-2 and 3 -3, as well as the comparison maps in Figure** 
**3-4. Sites that have been discontinued or relocate d show design values below the standard at the**  **time of discontinuance or relocation (Figures 3-2 a nd 3-3).** **19**



### Figure 3-2 2001-2010 8-hour Ozone Design Value Tren ds - MO

**St. Louis Nonattainment Area, MO (1997 NAAQS = 8 4 ppb)** **20** 

### Figure 3-3 2001-2010 8-hour Ozone Design Value Tren ds - IL

**St. Louis Nonattainment Area, IL (1997 NAAQS = 84 ppb)** **21**



### Figure 3-4 2001-2003 & 2008-2010 Design Values Comp arison

**St. Louis Nonattainment Area 8-hour Ozone Design Va lues (1997 NAAQS = 84 ppb)** 

**2001-2003 Design Values**

**2008-2010 Design Values 22** 



### 3.3 St. Louis Ozone Monitoring Data Analysis
**The St. Louis area’s compliance with the 1997 ozone NAAQS is determined by comparing the**  **area’s calculated design values to the ozone standa rd. As described previously, design values are**  **calculated at each monitor by averaging the annual fourth-highest daily maximum 8-hour ozone**  **concentrations over the three consecutive years (40 CFR Part 50). The standard at a site is met**  **when the site’s design value is less than or equal to 84 ppb.** 

**The design value for the entire St. Louis nonattain ment area is determined by comparing all of**  **the design values for the monitors in the nonattain ment area. The area’s design value is**  **determined by the single highest individual monitor ’s design value for each three consecutive**  **ozone season averaging period. The area’s status o f attainment or nonattainment is determined**  **by this design value. For the eight-hour ozone sta ndard, the design value at all monitors for the**  **three-year time periods from 2008 through 2010 do n ot exceed 0.084 ppm, and thus achieve** 
**attainment for the St. Louis nonattainment area. T he calculated 2008-2010 8-hour design values**  **for sites in the St. Louis nonattainment area are p resented in Table 3-1. As shown in the table, all**  **sites three year design values are less than the 19 97 standard, demonstrating that the St. Louis**  **area has attained the 8-hour air quality standard. The St. Louis nonattainment area’s design**  **value monitor would be the West Alton monitor, due to its design value being the highest. The** 
**West Alton monitor is bold in Table 3-1.**



### Table 3-1 2007-2009 St. Louis 8-Hour Design Values

**(1997 NAAQS = 84 ppb)**

**County Monitoring Sites 2008** 
**4 th**  **High 2009** 

**4 th**  **High 2010** 

**4 th**  **High 2008-2010**  **Design Value**

**Missouri**

**St. Charles Orchard Farm 72 73 77 74**

St. Charles West Alton 76 71 84 77 **St. Louis City Blair Street 73 65 71 69 St. Louis Maryland Heights**  **69 70 76 71**

**St. Louis Pacific 64 64 69 65**

**Jefferson Arnold West 70 70 77 72**



### 3.4 Missing Data Under the 1997 8-Hour Ozone Standa rd
**Eight-hour ozone attainment is determined by a thre e-year average of the annual fourth highest**  **daily maximum. Missing days are of importance only in determining whether sufficient data**  **was sampled to determine compliance. A monitoring day must include 18 valid eight-hour**  **averages for a daily maximum to be determined. To calculate a design value, an average of 90%**  **of the possible daily maximums over a three year pe riod must be complete, with no single year**  **having less than 75% completeness. The final resul t is that no more than 53 missed days in one**  **year, or 64 missed days total for the three-year pe riod are allowed. If these criteria are not met,**  **then compliance with the 8-hour ozone standard cann ot be established. To date, acceptable** **23**

**monitoring has been maintained and exceeded in the Missouri portion of the St. Louis** 
**nonattainment area for the 8-hour ozone standard.**



### 3.5 Quality Assurance Program
**Ambient air monitoring data from the Missouri ozone network is quality assured in accordance**  **with 40 CRF Part 58 and the Missouri Quality Assura nce Project Plan (QAPP). The QAPP**  **outlines standard operating procedures for operatin g the network and validating the data. In**  **addition the network is reviewed annually through t he Annual Monitoring Plans, according to 40** 
**CFR Part 58.10. A site can either be discontinued o r relocated based on the annual review and**  **with an approval from the EPA. The quality assured data collected at the sites is submitted in the**  **Air Quality System (AQS) and is available for publi c review as outlined in 40 CFR Part 58.**  **Illinois EPA follows a similar quality assurance sy stem.** 



### 3.6 Continued Monitoring Commitment
**The State of Missouri is committed to continue oper ating the appropriate ozone network in the**  **St. Louis area, in accordance with 40 CFR 58 and ap proved Annual Monitoring Plans, to verify** 
**the attainment status of the area. Missouri will c ontinue to quality assure the ambient air**  **monitoring data in accordance with 40 CFR 58 and su bmit the data to AQS in timely fashion.**  **The St. Louis Metropolitan Statistical Area (MSA) s atisfies and exceeds the minimum**  **monitoring requirement for ozone (40 CFR 58 Appendi x D, Table 2), revisions to the Ambient**  **Air Monitoring Regulations (71 Federal Register 612 40, October 17, 2006) note “While the final**  **rule of regulations requires fewer monitors than ar e now operating for ozone and PM**  **2.5 , as did**  **the pre-existing monitoring rule, EPA does not inte nd to encourage net reductions in the number** 
**of ozone and PM 2.5**  **monitoring sites in the U.S. as a whole. The surpl us in the existing networks**  **relative to minimum requirements gives States more flexibility to choose where to apply**  **monitoring resources for ozone and PM 2.5**  **”. The State of Missouri commitment is to continue working with the EPA to ensure that the ozone monit**  **oring network is sufficiently meeting the monitoring requirement of 40 CFR 58 and its monitor**  **ing objectives.**



### 3.7 Clean Data Determination

**On June 9, 2011, EPA published a final clean data d etermination in the Federal Register stating** 
**that the St. Louis ozone nonattainment area coverin g both Missouri and Illinois has attained the**  **1997 8-hour ozone standard based on three years of quality assured ambient air monitoring data**  **(76 FR 33647, June 9, 2011). 24** 



## 4. Redesignation Request: Emission Inventory and C ontrols from
2002 - 2008

**A redesignation request must contain a demonstratio n that the improvement in air quality**  **between the year that violations occurred and the y ear that attainment was achieved is based on**  **permanent and enforceable emissions reductions. As described previously in Section 3, three**  **consecutive ozone season monitoring periods are use d to evaluate whether actual air quality**  **attainment has been achieved. In this section, the “attainment year” refers to the first year (2008)**  **of the three-year period (2008-2010) used to demons trate attainment, and the base year refers to**  **the mid-point year (2002) of the three year period used to determine the designation of the** 
**nonattainment area. The inventories detailed in th is section for 2002 and 2008 include data**  **categories for point, area, and mobile emissions fo r NO**  **X and VOC. Additional details for the**  **base and attainment year inventories for 2002 and 2 008 are found in Appendices A and B,**  **respectively.**



### 4.1 Base Year and Attainment Year Inventories

**Table 4.1 is a comprehensive emissions inventory fo r the Missouri side of the St. Louis**  **nonattainment area, including point, area, on-road mobile, and off-road mobile sources for**  **precursors of ground-level ozone (NO X**  **and VOC) for the base year, 2002. Table 4.2 is a comprehensive emissions inventory for the Missouri**  **side of the St. Louis nonattainment area for**
**NO X**  **, and VOC for the attainment year, 2008. Both the 2002 and 2008 inventories are based on**  **actual activity levels.**

**The emissions inventories listed in this section ar e listed in tons/ozone season day. In order to**  **calculate the emissions in tons/ozone season day fo r the Missouri portion of the ozone**  **nonattainment area, the Air Program followed the me thods listed in Appendix E of this**  **document. Briefly, for point sources ozone season day emissions are calculated on the EIQ form**  **2.0Z, Ozone Season Information. The facility report ed maximum daily throughput during the**  **ozone season is multiplied by the pollutant emissio n factor and reduced by control device to**  **reach the ozone season daily emissions. For area s ources, ozone season day emissions were**  **calculated from (Emissions Modeling Clearinghouse) EMCH temporal allocation profiles that**  **are SCC-specific. Ozone season day emissions are ty pical of a Tuesday in July. See Appendix E**  **7 for the temporal allocation method and calculatio n tables. Appendix E-7 outlines this**  **procedure for area sources, and gives an example. Off-Road ozone season day emissions were**  **calculated by EPA Region 7, and additional informat ion can be found in Appendix E-4. Finally,**  **for on-road mobile sources, emissions were calculat ed using mobile emission models for the**  **months of April-October, and then divided by 214 (t he number of days in the ozone season) to**  **get the average ozone season day emissions.**

**The 2002 base year inventory includes emissions fro m point, area, on-road mobile and off-road** 
**mobile emissions. Table 4.2 states the 2002 emissi ons in tons/ozone season day, and**  **summarizes the emissions by major source category a nd by pollutant for the St. Louis**  **nonattainment area. On May 31, 2007, EPA approved Missouri’s 2002 Base Year Inventory for** 
**the Missouri Portion of the 1997 St. Louis Ozone No nattainment area. Some minor corrections**  **have been made to this inventory since EPA approved it in 2007. The revised 2002 base year** **25**

**inventory was adopted by the Missouri Air Conservat ion Commission on May 31, 2007 and**  **submitted to EPA on June 13, 2007. This revised in ventory, which details all of the changes**  **from the original 2002 base year inventory, is now being resubmitted to EPA along with this**  **redesignation request and maintenance plan. Summar y tables of the 2002 anthropogenic**  **emissions inventory for the St. Louis ozone nonatta inment area may be found in Appendix A.** 

**For the 2008 “attainment year” emissions inventory, the documentation of the development of**  **the emissions inventories for point, area, and off- road mobile categories are described in detail in**  **Appendix E, and also summarized in Appendix B. Poi nt source emissions for the pollutants of**  **concern were compiled from Missouri’s Air Emissions Database. Area source emissions were**  **calculated using the most recently available method ologies and emissions factors from U.S. EPA**  **along with activity data (typically population, emp loyment, fuel use, etc.) specific to 2008. Off**  **road mobile source emissions were developed by EPA Region VII staff, who utilized the** 
**NONROAD 2008a model in order to estimate the off-ro ad mobile source emissions for an ozone**  **season day. Biogenic emissions were not included in these summaries.** 

**For Section 4 of this document, the 2008 mobile emi ssions were created using Mobile6.2 via the**  **National Mobile Inventory Model (NMIM) with 2008 ve hicle miles traveled (VMT) data**  **provided by the East West Gateway Council of Govern ments in coordination with the**  **Interagency Council of Governments. The 2008 VMT d ata was generated from East-West**  **Gateway's Traffic Demand Model and then compared to Highway Performance Monitoring**  **System (HPMS) data. Through this comparison, calib ration factors were developed and then**  **applied to the VMT data from the Traffic Demand Mod el in order to estimate the actual 2008** 
**VMT for the St. Louis nonattainment area. The NMIM National County Database (NCD) was**  **updated with Missouri specific data. Please see Ap pendix B-2 for additional details regarding**  **the 2008 on-road mobile emissions calculated using Mobile 6.2 via NMIM.** 

**The EPA’s Mobile6.2 emissions model was used to gen erate the mobile source emissions in this**  **section in order to allow for a useful comparison b etween 2002 and 2008 mobile emissions. The**  **mobile emissions generated for the 2002 emissions i nventory used Mobile6.2, and it was**  **necessary to use the same mobile emission model to compare the base and attainment year**  **mobile source emissions. However, in Section 5 of this document, the 2008 and 2022 mobile**  **source emissions were generated using EPA’s Motor V ehicle Emissions Simulator (MOVES)** 
**2010a. More information about the use of these two different emission models can be found in**  **Section 5 and Appendix B of this document.**

**Tables 4-1 and 4-2 summarize the 2002 and 2008 aver age daily ozone season NO**  **X and VOC** 
**emissions from the Missouri side of the St. Louis o zone nonattainment area, respectively. Table** 
**4.3 shows the differences in inventories between th ese two years for each source category and**  **pollutant of concern. As seen in Table 4-3, emissi ons of NO**  **X emissions decreased by 138 tons**  **per ozone season day, while VOC emissions remained relatively stable. The substantial** 
**reduction in NO X**  **emissions between 2002 and 2008, along with other regional controls have**  **resulted in the improved monitored ground-level ozo ne concentrations in the St. Louis** 
**nonattainment area. 26** 

Table 4-1. 2002 VOC and NO X Emissions for the Missouri Side of the 1997 St. Lo uis 8-Hour Ozone Nonattainment Area (tons per ozone sea son day)

Source Category NO X VOC

**Point Sources 127.2 32.7**
**Area Sources 19.4 71.3**
**On-Road Mobile Sources 159.0 68.1**
**Off-Road Mobile Sources 60.7 47.0**

Total 366.3 219.1

Table 4-2. 2008 VOC and NO X Emissions for the Missouri Side of the 1997 St. Lo uis 8-Hour Ozone Nonattainment Area (tons per ozone sea son day)

Source Category NO X VOC

**Point Sources 88.8 18.0**
**Area Sources 6.5 98.7**
**On-Road Mobile Sources 96.2 57.9**
**Off-Road Mobile Sources 60.9 46.4**

Total 252.4 221.0

Table 4-3. Comparing 2002 and 2008 VOC and NO X Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattainment Area (ton s per ozone season day) Source Category NO X VOC

**Point Sources* - 38.4 - 14.7**
**Area Sources* - 12.9 + 27.4**
**On-Road Mobile Sources* - 62.8 - 10.2**
**Off-Road Mobile Sources*** **+0.2 - 0.6**

**Total*** - 113.9 + 1.9 ***Note: A negative value indicates a decrease in em issions from 2002 to 2008.**  **A positive value indicates an increase in emissions from 2002 to 2008.** 



### 4.2 Controls Used to Attain the Standard

**The St. Louis area was designated as nonattainment of the 1997 8-hour ozone NAAQS in 2004.**  **Since that time, the implementation of permanent an d enforceable reductions of NO**  **X and VOC**  **emissions have contributed to improvements in groun d level ozone concentrations and to the**  **attainment of the 1997 8-hour ozone NAAQS. The pri mary control measures used to attain the** 
**1997 8-hour ozone standard include:**

• **New Source Performance Standards (NSPS)**

• **National Emissions Standards for Hazardous Air Poll utants (NESHAPS)/Maximum**  **Achievable Control Technology (MACT) Standards**

• **Federal gasoline detergent additive rule**

• **NO X**  **SIP Call**

• **Clean Air Interstate Rule (CAIR)**

• **Heavy-Duty Diesel Engine Standards 27** 

• **Tier 2 Rule-Vehicle Standards**

• **Tier 4 Rule-Off Road Mobile Engine Standards**

• **Reformulated Gasoline (RFG)**

• **Gateway Vehicle Inspection Program**

• **National VOC Emission Standards for Consumer and Co mmercial Products (Part 59)** 

o **Automobile Refinishing Rule**

o **Architectural and Industrial maintenance coating ru le** 

o **Consumer Products solvent control rule**

• **Missouri State Rules (see Subsection 4.2.3)**

4.2.1 Federal Emission Trading Programs

**The NO X**  **SIP Call and CAIR are federal emission trading pro grams that were designed to reduce**  **the transport of emissions that have significant im pacts on downwind nonattainment and**  **maintenance areas. The first year in which sources were required to comply with the NO**  **X SIP**  **Call was 2003. In Missouri, the NO X**  **SIP Call only affected the eastern third of the st ate. The** 
**NO X**  **SIP Call greatly reduced ozone season NO X**  **emissions from large sources such as EGUs. According to data from CAMD’s Website, the total oz**  **one season NO X**  **emissions from EGUs**
**located in the St. Louis nonattainment area have re duced by 4,942 tons (approx. 32.3 tons/ozone**  **season day) from 2002 to 2008. These reductions ar e almost exclusively attributed to the NO**  **X SIP Call. Additionally, the NO**  **X SIP Call limited NO**  **X emissions from non-EGU boilers**  **including those located at Anheuser Busch and Trige n Ashley Street Station. From 2002 to**  **2008, the NO X**  **emission reductions from all point sources in the nonattainment area totaled 38.4**  **tons /ozone season day.**

**CAIR replaced the NO X**  **SIP Call and first became effective in 2009. CAIR limited the amount** 
**of annual and ozone season NO X**  **emissions from EGUs in the entire state of Missour i. In**  **regards to the EGUs located in the St. Louis nonatt ainment area, the requirements in CAIR were**  **no more stringent than the requirements under the N O**  **X SIP Call other than the fact that the** 
**annual NO X**  **emissions had to be controlled in addition to ozon e season NO**  **X emissions.**  **However, CAIR had a significant impact on the EGUs located in the western two-thirds of the**  **state, who were now required to significantly reduc e their annual and ozone season NO**  **X emissions. Some of the facilities in the western t**  **wo-thirds of the state installed controls earlier than 2009 in anticipation of CAIR. While the NO**  **X controls added in the western two-thirds of** 
**the state do not affect the NO X**  **emissions inventory for the St. Louis nonattainmen t area, they did**  **have a positive impact in reducing the regional con tribution of NO**  **X emissions to the ozone** 
**monitors located in the nonattainment area.**

4.2.2 Federal Mobile Source Emission Controls

**Federal and state regulations for mobile sources ha ve been phased in since 2002 have had a**  **positive impact on the emissions inventory in all t hree pollutant categories for both on-road and**  **off-road mobile sources. Mobile source regulations including Heavy-Duty Diesel Engine**  **Standards and Low-Sulfur Diesel, Tier 2 Rule-Vehicl e Standards, Tier 4 Rule-Off Road Mobile**  **Engine Standards, Reformulated Gasoline (RFG), and the Gateway Vehicle Inspection Program** **28**

**have reduced the NO X**  **and VOC emissions from the mobile sector in the St . Louis nonattainment** 

**area.**

**Overall, the retirement of older higher polluting v ehicles and the phasing in of federal on-road** 
**mobile source standards from 2002 to 2008 have cont ributed to a decrease of 62.8 tons/ozone**  **season day of direct NO X**  **emissions, and 10.2 tons/ozone season day of VOC e missions. These**  **on-road mobile source emission reductions have sign ificantly contributed to attainment of the**  **1997 8-hour ozone NAAQS in the St. Louis area.**

4.2.3 State Regulations

**Several new state regulations that have been adopte d since 2002 have resulted in reductions in** 
**both NO X**  **and VOC emissions. These include the restriction of heavy duty diesel engine idling,**  **the Gateway Vehicle Inspection Program, and the con trol of NO**  **X emissions from cement kilns**  **and stationary internal combustion engines. The Fe deral NO**  **X SIP Call Rule and the associated** 
**emission reductions are discussed in detail in Subs ection 4.2.1. State Regulation 10 CSR 10-** 
**6.360 was the rule written to address the NO X**  **SIP Call requirements, which has had a significant**
**effect on ozone season NO X**  **emissions from EGUs in the nonattainment area. St ate Regulation** 
**10 CSR 10-6.350 is the statewide NO X**  **rule, which limited emissions of NO X**  **both inside the St. Louis nonattainment area along with the rest of the**  **state. State Regulation 10 CSR 10-6.364 was written to comply with the ozone season NO**  **X portion of CAIR. Implementation of the seasonal** 
**NO X**  **portion of CAIR began in 2009 and replaced both th e NO**  **X SIP call and the statewide NO**  **X rule. These six rules are listed below along with**  **the dates they became effective.**

10 CSR 10-5.381 On-Board Diagnostics Motor Vehicle Emissions Inspection, **Original Effective Date: 8/30/07,**

10 CSR 10-6.350 Emission Limitations and Emissions Trading of Oxides of Nitrogen, **Original Effective Date: 9/30/00, Compliance Date: 5/1/04,** 

10 CSR 10-6.360 Controlling NO X Emissions From Electric Generating Units and Non-E lectric Generating Boilers, **Original Effective Date: 10/30/05,**

10 CSR 10-6.364 Clean Air Interstate Rule Seasonal NO X Trading program, **Original Effective Date: 5/30/07,**

10 CSR 10-6.380 Control of NO X Emissions From Portland Cement Kilns, **Original Effective Date: 10/30/05, and**

10 CSR 10-6.390 Control of NO X Emissions From Large Stationary Internal Combustio n Engines **Original Effective Date: 10/30/05 29** 



### 4.3 Reasonably Available Control Technology (RACT)

**Pursuant to Sections 172, 182(b) and (f) of the CAA , RACT is required for all existing major**  **sources of the applicable criteria pollutant and it s precursors located in nonattainment areas. The** 
**EPA defines RACT as the lowest emissions limitation that a particular source is capable of**  **meeting by the application of control technology th at is reasonably available considering**  **technological feasibility and economic reasonablene ss (70**  FR **71612; November 29, 2005). The major source threshold for moderate nonattainment a**  **reas is defined as 100 tons per year (tpy) of NOx or VOCs. A source generally consists of severa**  **l units that emit pollutants. The sum of**
**emissions from all units at the source determines i f a unit is major and thus subject to RACT**  **requirements. On April 20, 2011, the Air Program requested an exe**  **mption for sources of nitrogen oxides (NO**

**x )**  **in the Missouri portion of the St. Louis metropolit an 8-hour ozone nonattainment area from the**  **Clean Air Act (CAA) for NO**

**x Reasonably Available Control Technology (RACT) for**  **purposes of attaining the 1997 8-hour ozone National Ambient**  **Air Quality Standard (NAAQS). The**
**waiver demonstrates that additional reductions of N O** 
**x emissions in the area would not contribute**  **to attainment of the 1997 8-hour ozone (NAAQS). E PA published this exemption as a direct**  **final rule and received no comments on this rule (7 6 FR 43598). The rule became effective**  **September 19, 2011. This NO X**  **waiver alleviates the requirements for a demonstra tion that NO**  **X RACT obligations have been met. Therefore, only VO**  **C RACT demonstration requirements will be necessary for redesignation.** 

**Also Sections 172, 182(b)(2), and 182(f) of the CAA require implementation of RACT for**  **sources that are subject to Control Techniques Guid elines (CTGs) documents that are**  **promulgated by the EPA. The EPA has issued CTGs de fining presumptive RACT for those**  **categories of sources that emit the greatest amount s of VOC emissions. In 2006-2008, the EPA**  **issued 12 new CTG’s in three groups. The 2006 CTG’s addressed industrial cleaning solven**  **ts, offset lithographic printing and letterpress printi**  **ng, flexible package printing, and flat wood paneling coatings. The 2007 CTG’s address paper, f**  **ilm, and foil coatings, large appliance coatings, and metal furniture coatings. The 2008 CT**  **G’s address miscellaneous metal and plastic parts coatings, fiberglass boat manufacturing mater**  **ials, miscellaneous industrial adhesives, and automobile and light-duty truck assembly coatings.**  **Per the CAA, CTG’s establish presumptive RACT for the VOC sources they cover. CTG RACT can**  **apply to sources at a level much lower than the 100 tpy threshold employed for other RACT**  **sources in moderate ozone nonattainment areas. In fact, some of these newly-issued CTGs ap**  **ply to sources with emissions as low as 2.5 tpy. Any state with moderate ozone nonattainment ar**  **eas must implement equivalent RACT for all promulgated CTGs prior to redesignation of thos**  **e areas. The Department developed**
**amendments to four VOC rules to address these new C TGs for which there are existing**  **applicable sources in the St. Louis nonattainment a rea.** 

**Three of the new rulemakings to address the new CTG s were proposed for public hearing March**  **31, 2011, and were adopted by the MACC on April 28, 2011. The adoption of these CTGs was a**  **necessary element to allow the St. Louis area to be redesignated to attainment for the 1997 ozone** 
**standard. The three rules that have been amended t o account for these new CTGs include:** 

• **10 CSR 10-5.330** Control of Emissions From Industrial Surface Coatin g Operations**30**

• **10 CSR 10-5.340** Control of Emissions From Rotogravure and Flexograp hic Printing

• **10 CSR 10-5.442** Control of Emissions from Lithographic Printing Ope rations

**The three rules listed above were submitted to EPA for inclusion in the state implementation**  **plan following their April 28, 2011 MACC adoption. One other rule is currently being amended**  **to address CTG requirements in the St. Louis area. 10 CSR 10-5.455**  Control of Emissions from Solvent Cleanup Operations **, is currently in the process of being amended. Th is rule is expected**  **to be adopted by the MACC in 2012 with an anticipat ed EPA SIP submittal in April of 2012.** 

**RACT is not a new requirement for the 1997 8-hour o zone NAAQS. Missouri has previously**  **addressed RACT requirements in the St. Louis nonatt ainment area in developing attainment**  **plans for the 1-hour ozone standard. For the 1997 8 -hour standard, the Department developed a** 
**RACT demonstration as an element to the ozone SIP r evision. Per the federal implementation**  **rule for the 1997 ozone standard, the RACT demonstr ation was to be submitted as a separate**  **element prior to the submittal of the attainment de mo and other elements of the SIP revision. On**  **September 28, 2006, the MACC held a public hearing for the proposed RACT demonstration.**  **The RACT plan was adopted on December 7, 2006 and s ubmitted to the EPA on January 5,** 
**2007.**

**Since these new CTGs were not considered in the 200 6 RACT demonstration, and in an effort to** 
**ensure that RACT determinations for the St. Louis n onattainment area are ongoing and**  **continuous, the Department developed an update to t he 2006 RACT demonstration to support**  **this redesignation request. This updated RACT demo nstration will show how RACT has been**  **upgraded as appropriate since the last RACT submitt al. This updated RACT document was**  **adopted by the MACC on April 28, 2011 and submitted to EPA on May 25, 2011.** 

**For a more detailed discussion of RACT issues, plea se refer to the updated RACT demonstration**  **adopted April 28, 2011, which can be found at http://dnr.mo.gov/env/apcp/sips.htm#ozone** 



### 4.4 Permanent and Enforceable Controls
**The Air Program provides assurance that all of the control measures adopted by state rules and** 
**listed in this document that have been used to atta in the 1997 8-hour ozone standard are**  **permanent and enforceable. Any revisions to the co ntrol measures included in this document**  **will be submitted as a SIP revision to EPA for appr oval.** 

**The NO X**  **SIP Call included rules for the control of NO X**  **emissions from four different source groups including electric generating units, non-ele**  **ctric generating boilers, Portland cement kilns, and stationary internal combustion engines. The ru**  **le written to comply with the NO X**  **SIP Call requirements for EGUs and was**  10 CSR 10-6.360 Controlling NO X Emissions From Electric Generating Units and Non-Electric Generating Boiler s **, however this rule was replaced when implementation of the Clean Air Interstate Rule (CA**  **IR) began in 2009 and CAIR will be replaced by the federal Cross-State Air Pollution R**  **ule (CSAPR) in 2012 as discussed in the following paragraph. CSAPR does not include regula**  **tions for non-EGU boilers, specifically Trigen Units 5 and 6 and Anheuser Busch Unit 6. Ho**  **wever these three units have all been 31** 

**retired, and received retired unit exemptions that prohibit these units from operating. The signed**  **EPA retired unit exemption forms for these three un its are included in this document as**  **Appendix G. The rules written to comply with the N O**  **X SIP Call requirements for Portland**  **cement kilns, and stationary internal combustion en gines are**  10 CSR 10-6.380 Control of NO X Emissions From Portland Cement Kilns, 10 CSR 10-6.3 90 Control of NO X Emissions From Large Stationary Internal Combustion Engines **, both of which currently remain permanent and**
**enforceable in Missouri’s SIP.**

**EPA issued the Clean Air Interstate Rule (CAIR) on May 12, 2005 and the CAIR federal**  **implementation plans on April 26, 2006. In 2008, t he US Court of Appeals for the DC Circuit**  **remanded CAIR to EPA. EPA’s CSAPR will replace the 2005 CAIR in 2012 using new**  **approaches consistent with the court’s opinion. A supplement to CSAPR was proposed on July**  **6, 2011, which adds Missouri and five other states to the ozone season NO**  **X trading program**  **established through CSAPR. The supplemental propos al is expected to be finalized in November** 
**2011. Both CAIR and CSAPR establish ozone season N O**  **X emissions caps for large electric**  **utilities in Eastern states throughout the country. The CAIR requirements for ozone season NO**  **X pollution reductions currently remain in effect and**  **the CAIR regional control programs will continue operating until January 2012, when impleme**  **ntation of CSAPR begins. When the supplemental proposal is final, CSAPR will ensure t**  **hat ozone season NO X**  **emission reductions established by CAIR are permanent and enforceable o**  **ver the life of this maintenance plan.**

**Federal regulations for the control of mobile sourc es are expected to be tightened in the future.** 
**The mobile source control measures have resulted in the significant reductions in both NO**  **X and**  **VOC emissions. The continued tightening of federal mobile source standards and phase out of**  **older higher polluting vehicles will continue to co ntribute to maintenance of the 1997 8-hour**  **ozone NAAQS**

**Additionally, there are numerous other rules that p rovide permanent and enforceable controls for** 
**NO X**  **and VOC emissions in the St. Louis nonattainment a rea. The rules in Title 10 Division 10**  **Chapters 5 and 6 of the Missouri Code of State Regu lations include permanent and enforceable**  **control measures for ozone precursor emissions in t he St. Louis nonattainment area. These**  **controls include control technique guidelines for n umerous VOC sources, open burning**  **restrictions, and emission standards for incinerato rs. For additional information on state**  **regulations to control VOC emissions in the St. Lou is area, see the 2011 Reasonably Available**  **Control Technology Demonstration Update for the 199 7 8-Hour Ozone Standard in the St. Louis** 
**Area. 32** 



## 5. Maintenance Plan Demonstration: Emission Invent ory and
Controls from 2008 - 2022

**This section provides a detailed emissions inventor y for 2008 and a projected emission inventory** 
**for 2022. This section also includes a discussion of regulations that have become effective since**  **2008, and a list of expected future regulations tha t will help to continue to control NO**  **X and VOC**  **emissions in the St. Louis area. The Air Program c ommits to keeping all previously adopted**  **control measures in effect after redesignation. In addition, Prevention of Significant**  **Deterioration (PSD) requirements will apply to cons truction of new major sources and to**  **significant modifications of existing sources. Fut ure transportation plans will also be required to**  **conform to the conformity plan budgets. These exis ting and future control measures identified in**  **the maintenance plan are relied upon to maintain th e 1997 8-hour ozone NAAQS.** 



### 5.1 Base/Attainment Year Inventory and Future Year Emission Projections

**A Maintenance Plan must contain a demonstration tha t the levels of emissions projected for the**  **ten-year period following redesignation are suffici ent to maintain the NAAQS. Accordingly, the**  **Air Program has projected NO X**  **and VOC emissions for the St. Louis nonattainment area for**  **2022. Emissions for this projection year are compa red to emissions levels in 2008 to determine** 
**if emissions levels are sufficient to maintain the NAAQS during this period.** 

**For the purposes of this section, a modified 2008 e mission inventory was developed. The 2008**  **inventory in this section will act as the base year compared to the 2022 inventory detailed in this**  **section. The alternative 2008 inventory will inclu de all point, area, on-road mobile, and off-road**  **mobile source categories. The emissions from point , area, and off-road mobile source categories**  **are identical to the attainment year inventory list ed in the previous section. However, the on**  **road mobile source inventory is dramatically differ ent. This is due to the fact that a different**  **mobile emission model was used to develop the inven tory in this section of the document.** 

**For this Section of this document, on-road motor ve hicle emissions were estimated using U.S.** 
**EPA’s MOVES 2010A motor vehicle emissions model and VMT data from East-West Gateway** 
**Council of Government in coordination with the St. Louis Transportation Conformity**  **Interagency Consultation Group. MOVES 2010A is a c ompletely redesigned model, not just an**  **updated version of the previous mobile model. The w ay MOVES calculates emissions has**  **changed to reflect EPA’s more current understanding of the emissions produced by vehicles and** 
**the various factors that affect the emissions. NO X**  **emissions were found to be higher because of the larger portion that extended idling of heavy du**  **ty vehicles contributes to the emissions total. VOC emissions calculated with MOVES are comparable**  **to VOC emissions calculated with Mobile 6.2, however they are slightly higher. As a**  **result of these changes to the model, MOVES produced higher emissions estimates for both 2008 a**  **nd 2022 than were originally created with Mobile 6.2 via NMIM. Therefore, in addition to run**  **ning a projected emissions budget for 2022 for on-road emissions, 2008 base year emissions wer**  **e also run using MOVES. This allows for a meaningful comparison in emissions from 2008 to 202**  **2. By using MOVES to calculate the 2008 and 2022 mobile emission inventories, a smooth**  **transition can occur to new the mobile model that must be used in future SIPs and transpor**  **tation conformity determinations. Additional 33** 

**details about the development of the 2008 and 2022 on-road mobile emissions inventories are**  **located in Appendices B and C of this document, res pectively.** 

**The projected point and area source emissions in th e St. Louis area for 2022 were estimated**  **using the 2008 base year inventory and growth facto rs appropriate for each source category. The**  **2008 and 2022 emissions from point, area, on-road m obile, and off-road mobile source**  **categories are listed in Tables 5-1 and 5-2. Growt h factors were created from the EGAS model**  **( http://www.epa.gov/ttnecas1/egas5.htm**  **) using economic growth projections from the Policy Insight® Model for Regional Economic Model, Inc (RE**  **MI). An adjustment was made for a consent agreement between the Air Program and MEMC**  **Electronics Materials Incorporated for the company to continue to operate their scrubbers**  **for the control of NO X**  **from their acid bath/etching process. This consent agreement has b**  **een submitted to EPA for inclusion in Missouri’s SIP. Finally, based on a review of the**  **Federal CSAPR and consultation with Ameren UE, the owner of the four largest point source emit**  **ters of NO X**  **in the nonattainment area, future projections of NO**  **X emissions from these sources were determined by us**  **ing the allowances listed in the proposed supplement to CSAPR along with a 21**  **% variability factor, which was included in the final CSAPR for the ozone season trading pro**  **gram. CSAPR was finalized July 6, 2011, and the supplement to CSAPR, which adds Missouri in**  **to the ozone season NO X**  **trading program, is expected to be finalized in November 20**  **11. Using a 21% variability factor is very conservative and not expected to be reached in any**  **year by these four facilities combined. Detailed information about the development of the p**  **oint and area source inventories for the future year, 2022, can be found in Appendix D of th**  **is document.**

**Off-road emissions projections for 2022 were develo ped using the growth factors contained in** 
**U.S. EPA’s NONROAD model. The NONROAD model also i ncludes control factors for federal**  **controls that have been promulgated. The on-road m obile source emissions listed in Tables 5-1**  **and 5-2 were calculated using MOVES 2010A. The VMT data was provided by East-West**  **Gateway Council of Government in coordination with the St. Louis Transportation Conformity**  **Interagency Consultation Group. The figures assume the continued use of reformulated gasoline,**  **the continued phase-in of the Tier 2 motor vehicle emissions standards, and the continuing**  **operation of a basic vehicle inspection and mainten ance program. Total VMT for 2022 were**  **assumed to increase at a rate of 1.5 percent per ye ar from 2008, as provided by East West**  **Gateway Council of Governments in coordination with the St.**  **Louis Transportation Conformity Interagency Consultation Group. Detailed informati**  **on about the development of the on-road and off-road mobile source inventories for future year,**  **2022, can be found in Appendix C of this**
**document.**

Table 5-1. 2008 VOC and NO X Emissions for the Missouri Side of the 1997 St. Lo uis 8-Hour Ozone Nonattainment Area (tons per ozone sea son day) Source Category NO X VOC

**Point Sources 88.84 18.0**
**Area Sources 6.52 98.74**
**On-Road Mobile Sources 160.38 58.53**
**Off-Road Mobile Sources 60.85 46.44**

Total 316.59 221.71**34**

Table 5-2. 2022 VOC and NO X Emissions for the Missouri Side of the 1997 St. Lo uis 8-Hour Ozone Nonattainment Area (tons per ozone sea son day) Source Category NO X VOC

**Point Sources 92.81 25.79**
**Area Sources 6.77 121.19**
**On-Road Mobile Sources 44.57 21.20**
**Off-Road Mobile Sources 44.37 28.21**

Total 188.52 196.39

**Table 5-3 provides a comparison of emissions for th e years 2008 and 2022, using the 2008 on** 
**road mobile source emissions listed in Table 5-1 to reflect the MOVES values for consistent**  **comparison purposes. The table shows the differenc es by source category along with the total**  **changes in emissions for each pollutant listed. As shown in the table, both NO**  **X and VOC**  **emissions within the nonattainment area are expecte d to decrease significantly between 2008 and** 
**2022. Based on these emissions trends of NO X**  **and VOC it is expected that air quality will continue to meet the 1997 8-hour ozone NAAQS throug**  **hout the maintenance period.**

Table 5-3. Comparison of 2008 and 2022 VOC and NO X Emissions for the Missouri Side of
the 1997 St. Louis 8-Hour Ozone Nonattainment Area (tons per ozone season day)

Source Category NO X VOC

**Point Sources* + 3.97 + 7.79**
**Area Sources* + 0.25 + 22.45**
**On-Road Mobile Sources* - 115.81 - 37.33**
**Off-Road Mobile Sources*** **- 16.48 - 18.23**

Total* - 128.07 - 25.32 ***Note: A negative value indicates a projected decr ease in emissions from 2008 to 2022.**  **A positive value indicates a projected increase in emissions from 2008 to 2022.** 

**It should be noted that the projected increase in V OC emissions for area sources are based on**  **(EGAS) growth factors. Due to the use of these gro wth factors, emissions of VOC from area**  **sources are projected to increase significantly by 2022. However, these projected increases are**  **likely overstated and actual area source emissions of VOC are not expected to increase as much**  **as the growth factors suggest. EPA’s Regulatory Im pact Analysis (RIA) for the 2006 PM**  **NAAQS rule, Appendix D (http://www.epa.gov/ttn/ecas /regdata/RIAs/Appendix%20D--**  **Inventory.pdf), notes on pages D-29 to D-36, that t hough REMI data was used in their emission**  **forecasting method, the oversimplification of emiss ions growth based on economic factors likely**  **overestimates projected emissions. EPA’s recogniti on of the downward trend in emissions**  **during times of economic growth supports the conclu sion that the VOC increases for area**  **sources are likely an artifact of the growth method ology. From page D-36:** 

-While it is not clear that all of the factors that have served to produce this historical decline will continue to operate in the future, it appears unreasonable to assume that we currently have arrived at an ‘inflection point’ pas t which the trend will stop or reverse itself. Indeed, because the available data show tha t a number of large sources in the sectors of interest have no or limited pollution co ntrols, it is reasonable to expect emissions rates will be steady or decline. Continui ng to ignore this factor in future-year**35**

emission projections may increasingly skew the pred icted emissions increase, and the farther into the future the forecast the more drama tic the impact. The preceding and other explanations suggested that we need to reeval uate our emission forecasting approaches for stationary non-EGU sources to incorp orate factors not adequately considered in past methodologies.

**The projected decreases in NO X**  **and VOC emissions from 2008 to 2022 are primarily due to**  **decreases in the mobile source category. Average o zone season daily NO**  **X and VOC emissions** 
**in the St. Louis area from on-road and off-road mob ile sources are projected to decrease**  **approximately 132 tons/day and 56 tons/day, respect ively. That amounts to an over 40%** 
**reduction of total NO X**  **emissions and an over 25% reduction of total VOC e missions, while point** 
**and area source NO X**  **emissions are expected to remain relatively stable , and point and area**  **source VOC emissions are projected to increase slig htly.** 

**Additional details about the 2008 and 2022 emission inventories can be found in Appendices B**  **and D, respectively. It should also be noted that the emissions projections included here do not**  **reflect the reductions expected from a range of mea sures being implemented to reduce diesel** 
**emissions in the St. Louis nonattainment area. The se measures have been funded through** 
**sources such as the:**

• **U.S. EPA’s Midwest Clean Diesel Initiative**

• **Congestion Mitigation and Air Quality Improvement ( CMAQ) Program** 

• **Diesel Emissions Reduction Act (DERA)**

• **American Recovery and Reinvestment Act of 2009**

• **Heavy Duty Diesel Idling Rule,** 10 CSR 10-5.385

• **Various supplemental environmental projects**

**These projects include the installation of particul ate filters, diesel oxidation catalysts, closed**  **crankcase ventilation systems, and direct-fired hea ters on school and transit buses, and**  **municipally-owned utility vehicles, upgrading diese l construction engines with engines meeting**  **more stringent emissions standards, and installing auxiliary power units on over-the-road trucks**  **to reduce idling. It is anticipated that DERA and CMAQ funding will continue to support**  **additional diesel emissions reduction projects in t he near future.** 



### 5.2 Interim Year Emission Inventory: 2017

**The Air Program has developed an Interim Emission i nventory for the Missouri side of the St.**  **Louis nonattainment area. Interim year 2017 was de cided to be used as it is the midway point**  **between 2012, the year in which this plan is expect ed to be approved, and 2022, the last year in**  **the ten year maintenance plan period. All assumpti ons and controls used in developing the**  **project 2022 emission inventory in Section 5.1 of t his document were also used to project the**  **2017 inventory. Table 5.4 summarizes the emissions for point, area, on-road mobile, and off**  **road mobile sources that are projected for 2017 for the Missouri side of the St. Louis**  **nonattainment area. The Air Program commits to ana lyzing actual 2017 emissions for the** 
**Missouri side of the St. Louis nonattainment area a nd comparing the actual 2017 emissions to the** **36**

**projected 2017 emissions listed in Table 5.4 to ens ure the area keeps pace with the reductions**  **expected throughout the maintenance period. Additi onal details about the development of the**  **2017 interim year emission inventory can be found i n Appendix C of this document.** 

Table 5-4. 2017 VOC and NO X Emissions for the Missouri Side of the 1997 St. Lo uis 8- Hour Ozone Nonattainment Area (tons per ozone seaso n day)

Source Category NO X VOC

**Point Sources 91.20 22.79**
**Area Sources 6.68 112.60**
**On-Road Mobile Sources 61.91 26.97**
**Off-Road Mobile Sources 46.89 29.46**

Total 206.68 191.82



### 5.3 Controls to Remain in Effect

**The Air Program provides assurance that all of the control measures adopted by state rules and** 
**listed in this document that have been used to atta in the 8-hour ozone standard are permanent and**  **enforceable. Any revisions to the control measures included in this document will be submitted**  **as a SIP revision to EPA for approval. Additional information with respect to the ongoing** 
**control of NO X**  **and VOC sources in the St. Louis area can be found in subsection 4.4 of this** 
**document.**



### 5.4 Future Federal Control Measures

**There are currently several federal control measure s that have recently been proposed or**  **promulgated that are expected to greatly reduce the amount of NO**  **X and VOC emissions in the**  **St. Louis area. The control measures expected to h ave the greatest effect on NO**  **X and VOC** 
**emissions in the St. Louis area include the federal CSAPR, the National Emissions Standards for**  **Fossil-Fuel Fired Electric Utility Steam Generating Units (Utility MACT), National Emission**  **Standards for Hazardous Air Pollutants for Major So urces: Industrial, Commercial, and**  **Institutional Boilers and Process Heaters (Boiler M ACT), improved motor vehicle fuel efficiency**  **standards, and the phase in of tier 4 emission stan dards for nonroad engines.** 

**CSAPR and the improved federal mobile source regula tions were both considered when**  **developing the future emissions inventory in order to demonstrate continued maintenance with**  **the 1997 8-hour ozone standard. EPA projects that under CSAPR, annual NO**  **X emissions will be**  **100,000 tons lower nationwide in 2012, compared to baseline 2012 projections. As stated**  **earlier, federal motor vehicle and nonroad engine s tandards are only expected to be tightened in** 
**the future which will also contribute to NO X**  **and VOC emission reductions. These recent and anticipated future federal control measures are exp**  **ected to result in continued decreases in NO X**  **and VOC emissions both nationwide and in the St. Lo uis area. These measures will greatly**  **assist current and ongoing efforts in the St. Louis area to maintain compliance with the 1997 8-**  **hour ozone NAAQS. 37** 

**The Utility MACT and the Boiler MACT were both writ ten to address hazardous air pollutants,**  **and will therefore have the greatest reductions in pollutants such as PM**  **2.5 and SO**  **2 . However, if**  **owners of boilers and EGUs subject to these new rul es decide to improve plant efficiency or**  **switch to cleaner fuels for compliance strategies, then there is expected to be co-benefits for NO**  **X and VOC emissions from these sources. The Air prog**  **ram did not rely on the Utility MACT or the Boiler MACT when developing the future year emi**  **ssions inventory or to determine that the**
**St. Louis area would remain in attainment of the 19 97 8-hour ozone NAAQS; however the**  **anticipated reductions from these new rules may als o contribute to the future attainment of the**  **1997 8-hour ozone NAAQS in the St. Louis area.**



### 5.5 Provisions for Permitting New or Modified Emiss ions Sources

**In accordance with the Clean Air Act, Missouri has a long-standing and fully implemented New**  **Source Review (NSR) permitting program for new majo r sources and significant modifications**  **of existing sources. This NSR program in any attai nment area is referred to as a Prevention of**  **Significant Deterioration (PSD) permitting program. One of the major components of the PSD**  **program is the implementation of Best Available Con trol Technology (BACT) on new major**  **sources or significant modification of existing maj or sources. Missouri has been delegated full**  **authority to implement the PSD program by the EPA.**

**In this document, the Department is requesting rede signation to attainment under the 1997 8-**  **hour ozone standard. However, the St. Louis nonatt ainment area is expected to be designated as**  **nonattainment under either the 2008 Ozone NAAQS or its reconsideration. If this is case, the**  **State of Missouri is fully committed to continuing its NSR permitting program for nonattainment**  **areas which makes new major sources and significant modifications of existing sources subject**  **to the Lowest Achievable Emission Rate (LAER) as we ll as offsets and an alternate site analysis**  **pursuant to the CAA. 38** 



## 6. Transportation Conformity

**Transportation conformity is required under CAA sec tion 176(c) (42 U.S.C. 7506(c)) to ensure**  **that transportation plans, transportation improveme nt programs and federally supported highway**  **transit project activities are consistent with (“co nform to”) the purpose of the SIP. Conform to**  **the purpose of the SIP means that transportation ac tivities will not cause new air quality**  **violations, worsen existing violations, or delay ti mely attainment of the relevant NAAQS or any**  **interim milestones. These requirements are found i n Clean Air Act section 176(c)(B)(i), (ii), and**  **(iii): “That such activities will not cause or cont ribute to any new violation of any standard in**  **any area; increase the frequency or severity of any existing violation of any standard in any area;**  **or delay timely attainment of any standard or any r equired interim emissions reductions or other**  **milestones in any area.” Transportation conformity applies to areas that are designated**  **nonattainment, and those areas redesignated to atta inment after 1990 (“maintenance areas”) for**  **transportation-related criteria pollutants: Carbon monoxide (CO), ozone, nitrogen dioxide (NO**  **2 )**  **and particulate matter (PM 2.5**  **and PM 10**  **).**

**This section describes and establishes the St. Loui s nonattainment area motor vehicle emissions**  **budget associated with the ozone maintenance plan. Approval of the maintenance plan will** 
**establish new VOC and NOx motor vehicle emissions b udget for the maintenance year, 2022.**  **EPA requires motor vehicle emission budgets be esta blished for the last year of the maintenance**  **plan.**

**The budgets reflect an emissions level determined u sing 2008 VMT provided by East West**  **Gateway. The 2008 VMT data was generated from East -West Gateway's Traffic Demand Model**  **and then compared to Highway Performance Monitoring System (HPMS) data. Through this**  **comparison, calibration factors were developed and then applied to the VMT data from the** 
**Traffic Demand Model in order to estimate the actua l 2008 VMT for the St. Louis nonattainment**  **area. The budgets also reflect a VMT growth at an annual rate of 1.5 percent from year 2008**  **levels to 2022. The 1.5 percent growth rate for us e in projecting 2008 VMT to 2022 was**  **developed through a coordinated effort with MoDOT, Illinois Environmental Protection Agency,**  **the Federal Highway Administration, Illinois Depart ment of Transportation, and East-West**  **Gateway. Table 6-1 shows the actual historical annu al VMT on state owned roads for the** 
**Missouri Portion of the St. Louis nonattainment are a. In the past twenty-five years, VMT growth**  **has varied considerably for the Missouri side of th e St. Louis nonattainment area ranging as high**  **as 6.7 percent in 1988 and as low as negative 1.8 p ercent in 1991. The average annual growth**  **rate over the past twenty-five years is 1.9 percent . However, the traffic demand models used by**  **East-west Gateway projects approximately 1 percent annual VMT growth for the next 10 years.**  **The traffic demand model used by East-West Gateway uses current economic trends as a factor**  **to calculate projected growth rates. With such ext reme variations in a relatively short amount of**  **time, it is not reasonable to project VMT to a futu re year solely considering current economic**  **trends. In addition, emission plans for maintenance must be based on permanent and enforceable**  **reductions, such as federal emission standards. Du e to the worst economic downturn since the**  **Great Depression, the economy has been struggling i n the past few years, which has resulted in**  **lower projected VMT growth rates from the traffic d emand model. For the purposes of this**  **maintenance plan, the 1.5 percent VMT growth rate w as selected and agreed to by both states for**  **consistency and to account for the expected economi c rebound, which would result in higher**  **VMT than projected by the traffic demand model. On February 22, 2011, the Air Program** **39**

**discussed the use of the 1.5 percent growth rate to be used in this Maintenance Plan with the**  **Interagency Council of Governments (IACG) group res ponsible for transportation conformity in** 
**the St. Louis nonattainment area. Illinois EPA sta ted that they too planned to use a 1.5 percent**  **growth rate in their maintenance plans for the St. Louis area for both PM**  **2.5 and Ozone, and the**  **members of the IACG agreed that a 1.5 percent growt h rate was reasonable to use for the**  **purposes of this plan. Table 6-2 summarizes the es timated 2008 and projected 2022 annual**  **VMT used for each county in the Missouri Portion of the St. Louis nonattainment area.** 

**Once the county level annual VMT numbers for 2022 w ere calculated MOVES 2010a was used** 
**and all months for 2022 were selected to create an annual emissions profile. The emissions for**  **the months of April through October were totaled an d divided by 214, the number of days in**  **those months, to give average ozone season day emis sions, which are reflected in the**  **transportation conformity budget in Table 6.2.**

Table 6-1. Historical VMT in the Missouri Portion o f the 1997 St. Louis 8-Hour Ozone

Nonattainment Area (State Owned Roads Only)

Year Annual VMT Annual Growth Rate **1985 8,308,235,850 1986 8,838,007,070 6.4%**  **1987 9,168,965,710 3.7% 1988 9,779,349,735 6.7%**  **1989 10,279,500,110 5.1% 1990 10,535,025,660 2.5%**  **1991 10,342,044,685 -1.8% 1992 10,745,357,640 3.9%**  **1993 11,013,078,205 2.5% 1994 11,670,927,195 6.0%**  **1995 11,960,972,985 2.5% 1996 12,112,134,815 1.3%**  **1997 12,463,661,570 2.9% 1998 12,593,954,160 1.0%**  **1999 12,562,808,345 -0.2% 2000 12,584,108,650 0.2%**  **2001 12,816,788,850 1.8% 2002 12,998,755,585 1.4%**  **2003 13,057,922,815 0.5% 2004 13,121,705,470 0.5%**  **2005 13,102,295,865 -0.1% 2006 13,114,079,525 0.1%**  **2007 13,473,086,955 2.7% 2008 13,334,059,915 -1.0%**  **2009 13,349,210,335 0.1% 2010 13,236,646,160 -0.8%** **40** Table 6-2. 2008 and 2022 Annual VMT by County County 2008 Annual VMT 2022 Annual VMT **Franklin 1,636,760,381 2,016,088,979**  **Jefferson 1,884,745,023 2,321,545,483**  **St. Charles 2,728,058,895 3,360,302,178**  **St. Louis 11,924,864,323 14,688,519,968**  **St. Louis City 3,450,450,085 4,250,111,666**  Totals 21,624,878,706 26,636,568,272

**In the Missouri portion of the St. Louis nonattainm ent area, transportation conformity for the**  **ground-level ozone standard will be based on these submitted motor vehicle budgets after EPA**  **determines that the budgets meet the adequacy crite ria of the transportation conformity rule.**  **This conformity budget replaces any and all previou s budgets used for ground-level ozone**  **conformity demonstrations in the Missouri portion o f the St. Louis ozone nonattainment area.** 
**Table 6-3 identifies the 2022 motor vehicle emissio ns budgets for the 1997 St. Louis 8-hour**  **ozone nonattainment area for use in transportation conformity analyses. The emissions budgets**  **were created using MOVES 2010A. All inputs used to create these budgets can be found in**  **Appendix D-3.**

Table 6-3. Motor Vehicle Emissions Budgets for the Missouri Portion of the St. Louis 8-Hour Ozone Nonattainment Area in Tons p er Ozone Season Day

Pollutants 2022 Mobile Source Budgets

(tons/ozone season day)
NO X **44.57**

VOC **21.20 41** 



## 7. Contingency Measures

**Section 175(A) of the Clean Air Act specifies the r equirements for maintenance plans. In**  **addition to providing a plan for the maintenance of the NAAQS for at least ten (10) years after**  **the redesignation, the plan shall also include a li st of contingency measures to correct any**  **violation of the fine particulate matter NAAQS afte r redesignation to attainment.** 

**Contingency measures are to be used to further redu ce emissions in the event that future**  **violations of the 1997 8-hour ozone NAAQS occur aft er redesignation to attainment. While**  **these measures do not need to be fully adopted by t he Missouri Air Conservation Commission**  **prior to the occurrence of a NAAQS violation, the c ontingency measures are expected to be**  **implemented as expeditiously as possible once a tri ggering event occurs. The maintenance plan**  **must identify the triggers that determine when cont ingency measures will be adopted, and the**  **measures that the Air Program will consider.**

**The Air Program has developed a contingency plan fo r the Missouri portion of the St. Louis**  **ozone maintenance area. The contingency plan which details the Level I and Level II triggers**  **and corresponding actions to be taken is summarized in Table 7-1. The potential contingency**  **measures, to be evaluated after a triggering event, are listed in Table 7-2. Consistent with this**  **contingency plan, the Air Program agrees to adopt a nd implement, as expeditiously as is**  **practicable, the necessary corrective actions in th e event that violations of the 1997 8-hour ozone**  **NAAQS occur anywhere within the St. Louis ozone mai ntenance area after redesignation to**  **attainment. The implementation of contingency meas ures under Level I or Level II triggers will**  **take place as expeditiously as practicable, but in no event later than twenty-four (24) months**  **after the Air Program makes a determination, based on quality-assured ambient data, that a**  **violation of the appropriate trigger has occurred.**

**The contingency plan provides for different levels of corrective responses should the ambient 8-**  **hour ozone levels exceed the NAAQS in any year. A Level I response would occur in the event**  **that the fourth highest 8-hour ozone concentration at any monitoring site in the St. Louis**  **maintenance area (including sites in Missouri and I llinois) exceeds 84 ppb in any year. The Air**  **Program will evaluate the air quality and determine if adverse emission trends are likely to**  **continue. If so, the Air Program will determine wh at and where controls may be required, as** 
**well as the level of emissions reductions needed to avoid a violation of the NAAQS. If controls**  **are required, the potential contingency measures li sted in Table 7-2 will be evaluated in addition**  **to other measures that may be identified through th e evaluation or that become available through**  **future advances in control technology and methods. It should be noted that the EPA does not**  **require a state to implement contingency measures w hen occasional exceedances are recorded.**  **The Department’s voluntary commitment to initiate a Level I response is intended to prevent**  **future violations of the NAAQS from ever occurring.**

**A Level II trigger occurs when a violation of the 1 997 8-hour ozone NAAQS at any monitoring** 
**station in the St. Louis maintenance area is record ed after it has been redesignated to attainment.**  **The Air Program will conduct a thorough analysis to determine appropriate measures to address**  **the cause of the violation. Contingency measures w ill be selected from those listed in Table 7.2** **42**

**or from any other measured identified and deemed ap propriate and effective at the time the**  **selection is made. Level II triggers are more seri ous than Level I triggers and cost effectiveness** 
**thresholds could be increased when determinations f or additional controls are made.** 

**The contingency measures listed in Table 7.2 are ex pected to be evaluated in the event of a Level**  **I or Level II trigger; however federal actions that require control measures may also be taken into**  **account when the analysis to determine the cause of a future violation occurs. These additional**  **federal actions, while not actual contingency measu res, may be evaluated in the event of a trigger**  **to determine their effect on the levels of expected emissions from sources in the area in order to** 
**determine whether or not additional local control m easures are necessary. The measures that**  **may be evaluated in the event of a future trigger i nclude future federal on-road vehicle standards,**  **future federal nonroad engine standards for marine and locomotive engines, any future federal**  **emission trading programs designed to address futur e ozone or PM NAAQS promulgations, the** 
**Commercial-Industrial-Institutional Boiler Maximum Achievable Control Technology (MACT)**  **requirements, and the Utility MACT requirements. F urthermore, the Air Program remains**  **committed to addressing future ozone NAAQS revision s through state implementation plans.**  **These plans could include other control techniques not included in Table 7.2. These and any**  **other newly identified potential control measures m ay also be considered in the analysis**  **following a future Level I or II triggering event.**

**The Air Program commits to compiling NO X**  **and VOC emissions inventories for the St. Louis maintenance area every three years for the duration**  **of the Maintenance Plan to facilitate the emissions trends analysis included in the contingen**  **cy plan under Levels I and II. Since St. Louis is a bi-state nonattainment area, the Air Program c**  **ommits to work with Illinois EPA to evaluate**
**emissions trends and the causes of Level I and Leve l II triggers to determine appropriate control** 
**measures needed to assure continued attainment of t he 1997 8-hour ozone NAAQS.** 

**Adoption of additional control measures is subject to necessary administrative and legal**  **processes. The Air Program will solicit input from all interested and affected persons in the area**  **prior to selecting appropriate control measures. N o contingency measures will be implemented**  **without providing the opportunity for full public p articipation. This process will include**  **publication of notices, an opportunity for public h earing, and other measures required by** 
**Missouri law. 43** 

Table 7-1. Contingency Plan for the Missouri Porti on of the 1997 St. Louis 8-Hour Ozone
Maintenance Area Contingency Measure Trigger Action to be Taken **Level I Trigger**

**Fourth highest monitored 8-hour average ozone**  **concentration exceeding 84 ppb in any year at any**  **monitoring station in the St. Louis, MO-IL** 
**maintenance area. The Air program will evaluate the air quality and d**  **etermine if adverse emission trends are likely to continue. If**  **so, the Air Program will determine what and where controls may**  **be required,**
**as well as the level of emissions reductions needed to avoid a**  **violation of the NAAQS. The evaluation shall be co mpleted as**  **expeditiously as possible and, if necessary, contro l measures shall be**  **adopted and implemented as expeditiously as practic able, taking into**  **consideration the ease of implementation and the te chnical and**  **economic feasibility of the selected measures. Thi s action will be**  **taken no later than 24 months after the Air Program has determined**  **that a Level I trigger has occurred. Level II Trigger** 

**A monitored violation of the NAAQS at any**  **monitoring station in the St. Louis, MO-IL** 
**maintenance area. The Air Program will conduct a thorough analysis to**  **determine appropriate measures to address the cause of the vi**  **olation. Analysis shall be completed within 6 months. Selected measu**  **res shall be implemented as expeditiously as practicable, taking**  **into consideration the ease of implementation and the te**  **chnical and economic feasibility of the selected measures. Thi**  **s action will be taken no later than 24 months after the Air Program**  **has determined that a Level II trigger has occurred.** 

Table 7-2. Potential Contingency Measures for the Missouri Portion of the 1997 St. Louis
8-Hour Ozone Maintenance Area Contingency Measure
Method List of Potential Contingency Measures to be Consid ered **Implement controls for**
**local individual sources with significant effects on** 
**the monitored violation** • **Identify local sources with significant NO X**  **and/or VOC emissions and develop controls through consent agreements** 

**Revise rules that control**
**NO X**  **and VOC emissions** • **Lower the applicability thresholds in existing rule s that control** 
**NO X**  **and VOC**

• **Lower the limits in existing rules**

• **Broaden the geographical area of existing rules**

• **Include new source categories under the applicabili ty of existing** 
**rules**
**New rules that control**
**NO X**  **and VOC emissions** • **Enhanced Heavy-Duty Diesel Anti-Idling Program (i.e . mandated**  **rest periods and locomotives)**

• **New Alternative Control Techniques (ACTs) for NO X**  **sources**

• **New CTGs for VOC sources**

• **Architectural/Industrial/Maintenance (AIM) Coatings similar**  **to Ozone Transport Commission (OTC) model rule 44** 



## 8. CONCLUSION

**The St. Louis nonattainment area has attained the 1 997 0.080 ppm 8-hour ozone NAAQS and**  **has complied with the applicable provisions of the CAA required of moderate ozone**  **nonattainment areas. Missouri has supported, with appropriate submittals, all of EPA’s**  **redesignation obligations under Section 107 of the CAA and has addressed all the applicable**  **maintenance plan requirements. This plan submissio n serves as the official redesignation request**  **for the Missouri portion of the 1997 St. Louis non- attainment area to be considered for approval**  **concurrently with the maintenance plan and other ce rtain necessary rule actions submitted to**  **EPA relating to new Control Techniques Guidelines.**

**The Missouri Department of Natural Resources’ Air P ollution Control Program has prepared this**  **maintenance plan to meet the requirement of the Cle an Air Act. This maintenance plan provides** 
**for the continued attainment of the 1997 8-hour ozo ne NAAQS for a period of ten years after**  **U.S. EPA has formally redesignated the area to atta inment and also supplies adequate**  **contingency measures for potential, additional emis sions reductions in the event that future**  **violations of the 1997 8-hour ozone NAAQS are obser ved in the area.** 

**The Department has prepared a comprehensive emissio ns inventory of the precursors of ozone**  **completed for the “attainment” year 2008, and has p repared projections of the emissions**  **inventory to 2022. These emissions projections indicate that em**  **issions levels in the St. Louis**
**nonattainment area will continue to decrease from a ttainment year 2008 levels, thereby**  **maintaining the ozone NAAQS in future years. The st ate commits to continue to operate an**  **appropriate air quality monitoring network to verif y the maintenance of the attainment status**  **once the area has been redesignated. The department has the legal authority to implement and** 
**enforce all control measures.**

**Finally, this maintenance plan includes year 2022 on-road motor vehicle emissions budgets for** 

**use in transportation conformity determinations to assure that any increases in emissions from**  **this sector do not jeopardize continued attainment of the 8-hour ozone standard during the ten**  **year maintenance period. This maintenance plan has been prepared in accordance with the**  **requirements of the CAA and in conjunction with the guidance provided by EPA documents and** 
**staff.**