WW\v.dnr. mo. gov



## JUL 1 9 

## 2011

Mr. Karl Brooks Regional Administrator U.S. Environmental Protection Agency Region VII 901 North Fifth Street Kansas City, KS 66101

Dear Mr. Brooks:

In June 2010, the U.S. Environmental Protection Agency (EPA) promulgated a revision
to the National Ambient Air Quality Standards for sulfur dioxide (S02), which established a new one-hour standard of75 parts per billion. The form of the standard is the three-year average of annual 99th percentile of one-hour daily maximum concentrations. This new standard replaced both the 24

... hour and annual standards. Implementation of the new one-hour standard requires that states make recommendations
to EPA regarding designation of areas as being in attainment, nonattainment or unclassifiable. This letter and enclosures constitute that recommendation from Missouri, which is based on EPA's boundary recommendation guidance.

Since refined dispersion modeling is not yet available, no areas are currently recommended as attainment. Based on the existing S02 monitoring network and other evaluation criteria, areas that monitor or that likely contribute to violations are recommended as one of three non attainment areas in portions of Greene, Jackson and Jefferson Counties. All other areas of the state are recommended as unclassifiable.

In order to comply with Attachment A of the "Regional Consistency for the Administrative Requirements of State Implementation Plan Submittals and the Use of 'Letter Notices'" memo dated April 6, 2011, a searchable pdf version of this document 

### will be emailed to the EPA Regional Office and will be posted on our website at http://dnr.mo.gov/env/apcp/stateplans.htm

Thank you for the opportunity to provide this recommendation. If you have questions about this letter or the enclosure, please contact Ms. Kyra Moore, the Interim Director of



# o

Rl'CYcloo P;lpt'r

### Mr. Karl Brooks Page Two

the Department's Air Pollution Control Program, at P.O. Box 176, Jefferson City MO 65102

or by telephone at (573) 751-4817.

Sincerely,

DEPARTMENT OF NATURAL RESOURCES

Sara Parker Pauley Director

SPP:brk

Enclosures:

County recommended classifications Commission signature page certifYing Missouri Air Conservation Commission adoption Summary of recommendation Technical support documentation Public hearing newspaper notice Public hearing transcript introductory statement Public comments and responses

c: Mr. Joshua Tapp, U.S. EPA Region VII Missouri Air Conservation CommissionMissouri Sulfur Dioxide Area Designation Recommendation June 2011

County Recommended Classification Adair Unclassifiable Andrew Unclassifiable Atchison Unclassifiable Audrain Unclassifiable Barry Unclassifiable Barton Unclassifiable Bates Unclassifiable Benton Unclassifiable Bollinger Unclassifiable Boone Unclassifiable Buchanan Unclassifiable Butler Unclassifiable Caldwell Unclassifiable Callaway Unclassifiable Camden Unclassifiable Cape Girardeau Unclassifiable Carroll Unclassifiable Carter Unclassifiable Cass Unclassifiable Cedar Unclassifiable Chariton Unclassifiable Christian Unclassifiable Clark Unclassifiable Clay Unclassifiable Clinton Unclassifiable Cole Unclassifiable Cooper Unclassifiable Crawford Unclassifiable Dade Unclassifiable Dallas U nclassifiabl e Daviess Unclassifiable DeKalb Unclassifiable Dent Unclassifiable Douglas Unclassifiable Dunklin Unclassifiable Franklin Unclassifiable Gasconade Unclassifiable Gentry Unclassifiable Greene Nonattainment (portion of Greene County bounded by county line

on the south, U.S. 65 on the east, U.S. 60 on the north and U.S. 160 [South Campbell Ave] on the west)County Recommended Classification Greene Unclassifiable (remaining portion of county) Grundy Unclassifiable Harrison Unclassi fi able Henry Unclassifiable Hickory Unclassifiable Holt Unclassifiable Howard Unclassifiable Howell classifiable Iron classifiable Jackson Nonattainment (portion of Jackson County bounded by county line on north, Kansas state border on west, Interstate-435 on the east, and the following southern boundary line that part of Jackson County north of Interstate-670 from the Kansas border to the intersection with Interstate-435) Jackson Unclassifiable (remaining portion of county) Jasper Unclassifiable Jefferson Nonattainment (Herculaneum and Festus townships and the Missouri portions of Valmeyer and Selma townships west of Illinois state border) Jefferson Unclassifiable (remaining portion of county) Johnson Unclassifiable Knox Unclassifiable Laclede Unclassifiable Lafayette Unclassifiable Lawrence Unclassifiable Lewis Unclassifiable Lincoln Unclassifiable Linn Unclassifiable Livingston Unclassifiable McDonald Unclassifiable Macon Unclassifiable Madison Unclassifiable Maries Unclassifiable Marion Unclassifiable Mercer Miller Unclassifiable 

# I Unclassifiable Mississippi Moniteau TT • 

### . "" 

# .. Monroe 

## I Unclassifiable Montgomery Unclassifiable Morgan Unclassifiable New Madrid U nclassifiable Newton· Unclassifiable Nodaway UnclassifiableCounty Recommended Classification Oregon Unc1assifiable Osage Unc1assifiable Ozark Unc1assifiable Pemiscot Unclassifiable Perry Unclassifiable Pettis Unclassifiable Phelps Unclassifiable Pike Unc1assifiable Platte Unc1assifiable Polk Unc1assifiable Pulaski Unc1assifiable Putnam Unclassifiable Ralls Unc1assifiable Randolph Unclassifiable Ray Unclassifiable Reynolds Unclassifiable Ripley Unclassifiable St. Charles Unclassifiable St. Clair Unclassifiable St. Francois Unc1assifiable Ste. Genevieve Unclassifiable 

## st. Louis Unclassifiable St. Louis City Unc1assifiable Saline Unclassifiable Schuyler Unclassifiable Scotland Unclassifiable Scott Unclassifiable Shannon Unclassifiable Shelby Unclassifiable Unclassifiable

### ~ard Unclassifiable Sullivan Unclassifiable Taney Unclassifiable Texas Unclassifiable Vernon Unclassifiable Warren Unclassifiable Washington Unclassifiable Wayne Unclassifiable Webster Unclassifiable Worth Unclassifiable Wricl1t Unclassifiable

### Pursuant to 643.055 RSMo, the Missouri Air Conservation Commission has determined that this action is required under Section 107 of the Clean Air Act.

The 2010 I-Hour Sulfur Dioxide Boundary Designation Recommendation is hereby adopted by the Missouri Air Conservation Commission this 30th day of June, 2011.

# ""'7'i~:.,......:=**~<_L_.Q3~~_'** ..

# ~=-" _____ , Member

________________ , Member

________________ , Member

### 2010 Sulfur Dioxide National Ambient Air Quality St andard

Summary of Recommendation of Nonattainment and Uncl assifiable Boundaries in Missouri

**In June 2010, the U.S. Environmental Protection Age ncy (EPA) promulgated a revision to the**  **National Ambient Air Quality Standards (NAAQS) for sulfur dioxide (SO**  **2** 

### ), which established **“a new 1-hour SO 2**  

### standard at a level of 75 parts per billion (ppb), **based on the 3-year average of the annual 99**  **th** 

### percentile of 1-hour daily maximum concentrations. **” This new standard replaced both the 24-hour and annual standards.** 

**As provided under Clean Air Act Subparagraph 107(d) (1)(A), the governor of each**  **state is required to submit a recommendation to the EPA regarding the attainment status of all**  **areas within that state. This recommendation is du e to EPA by June 2, 2011. Each area of the**  **state shall be recommended for designation as:**

• **nonattainment for areas that do not meet the NAAQS or contain sources that contribute to**  **nonattainment in a nearby area,**

• **attainment for areas that meet the NAAQS, or**

• **unclassifiable for areas that cannot be classified as attainment or nonattainment based on**  **available information.**

**The EPA has chosen a different approach to determin e attainment status for the 1-hour SO**  **2** 

### NAAQS. Unlike other criteria pollutants, SO **2** 

### is almost exclusively a point source-emitted **pollutant. A monitoring network large enough to ad equately cover all large sources would be**  **prohibitively expensive and an affordable network w ould leave large gaps in coverage.**  **Therefore, EPA has decided to use a hybrid monitori ng-modeling approach for SO**  **2** 

### . This hybrid **approach involves a modest monitoring network and e xtensive use of refined air dispersion**  **modeling.**

• **Nonattainment areas will be determined by either mo nitoring or modeling data which**  **show a violation, or likely violation, of the stand ard.** 

• **Both monitoring and modeling are required to show a ttainment.** 

• **Areas without either monitoring or modeling data wi ll be designated unclassifiable.** 

**Since the final SO 2**  

### rule states that modeling is not required for init **ial nonattainment determinations and EPA’s modeling guidance was not**  **available in time for the Department to take these recommendations through its public proce**  **ss and meet the June 2, 2011 deadline, at this time the boundary recommendations are based on**  **factors other than modeling. Therefore, in this initial round of recommendations, no areas can**  **be recommended as attainment; areas that monitor or that likely contribute to violations wil**  **l be recommended as nonattainment; and all other areas of the state will be recommended as unc**  **lassifiable. As the SO 2**  

### modeling guidance is **released and finalized, the Department intends to c onduct refined dispersion modeling of SO**  **2** 

### sources in accordance with EPA’s guidelines and pro **vide additional technical justification as needed for recommended nonattainment area boundarie**  **s.**

### Because all areas of the state are evaluated withou **t modeling at this time, only those areas with**

**violating monitors and areas immediately surroundin g them are addressed in this document. For**  **2007-2009, the four violating monitors are Troost i n Kansas City, Main Street in Herculaneum,**  **and James River & South Charleston in Springfield. Sources in these three counties (Greene,**  **Jackson, and Jefferson) and surrounding areas (neig hboring counties and states) were considered**  **in the analysis to determine their likely impact on the violating monitors. If emissions from a**  **particular area in Missouri are determined to have a substantial impact on the violating monitor,**  **that area is included in the recommended nonattainm ent area.** 

**As stated in the preamble of EPA’s final SO 2**  

### rule, county lines are the presumptive boundaries **for SO 2**  

### nonattainment areas. Therefore, county boundaries **were the starting point for this analysis. The information contained in this docume**  **nt demonstrates why a smaller area (less than countywide) for nonattainment boundary recommendati**  **ons is appropriate for all three counties containing monitors that do not meet the 1-hour SO**  **2** 

### NAAQS.

**EPA expects to issue final designations by June 201 2. If the EPA intends to modify the state’s**  **recommendations or needs additional technical justi fication to support the designation, they will**  **notify the Department 120 days prior to finalizing the designations. For the SO**  **2** 

### standard, these **“120-day” letters are expected to be released aroun d February 2012. The Department will then**  **be required to submit attainment state implementati on plans (SIPs) for nonattainment areas to**  **EPA by February 2014 outlining actions that will be taken to meet the standard.** 

**The Department expects that some SO 2**  

### emission sources located in the recommended **unclassifiable areas may contribute to violations o f the 1-hour SO**  **2** 

### standard. These sources will **be evaluated with refined modeling analyses when EP A provides official modeling guidance.**  **Any sources located in unclassifiable areas later f ound to contribute to SO**  **2** 

### violations will be **addressed in the Infrastructure SIP due June 2013.**

**A summary of the implementation timeline for the 1- hour SO**  **2** 

### standard is below:

**June 2010 EPA establishes new primary 1-hour SO 2**  

### standard of 75 ppb **June 2011 States must submit designation recommenda tions**  **Feb 2012 EPA notifies states if they intend to modi fy recommendations (120-day letters)**  **June 2012 EPA finalizes initial area designations June 2013 States must submit infrastructure SIPs fo**  **r unclassifiable areas Feb 2014 States must submit attainment SIPs for non**  **attainment areas Aug 2017 Initial attainment date for all areas** 

**On February 17, 2011, a preview of EPA’s draft Boun dary Recommendation guidance was**  **released. In that document, EPA lists a number of different factors to be considered when**  **establishing boundaries for nonattainment areas:**

• **Monitoring data**

• **Emissions, including growth, controls, and regiona l emission reductions** 

• **Meteorology**

### • **Topography**

• **Jurisdictional boundaries**

**The Department developed this boundary recommendati on based on a review of the available**  **technical information as required by EPA. Based on 2007-2009 monitoring data, three distinct**  **areas of the state violate the 2010 1-hour SO 2**  

### NAAQS. The recommended boundaries for the 1- **hour SO 2**  

### NAAQS nonattainment areas in Missouri include the **following [** please reference attached maps indicating recommendation for SO 2 

### nonattainment area boundaries **]:**

**Jefferson County Nonattainment Area Jefferson County: Herculaneum and Festus townships**  **and the Missouri portions of Valmeyer and Selma townships west of the Mississipp**  **i River/Jefferson County line with the state of Illinois [see Figure 1].** 

**Jackson County Nonattainment Area Jackson County: The portion of Jackson County bou**  **nded by the county line on the north, the state of Kansas on the west, Interstate-435 on**  **the east and the following southern boundary line – that part of Jackson County north of Interst**  **ate-670 from the Kansas border to the intersection with Interstate-435 [see Figure 2].** 

**Greene County Nonattainment Area Greene County: The portion of Greene County bound**  **ed by the county line on the south, U.S. 65 on the east, U.S. 60 on the north, and U.S.**  **160 (South Campbell Ave) on the west [see Figure 3].** 

**The remaining counties in the state, as well as the remaining portions of Jackson, Jefferson and**  **Greene Counties, are recommended for designation as unclassifiable.** 

### Figure 1. Recommended SO **2** 

### Nonattainment Area for Jefferson County, Missouri

### Figure 2. Recommended SO **2** 

### Nonattainment Area for Jackson County, Missouri

### Figure 3. Recommended SO **2** 

### Nonattainment Area for Greene County, Missouri

# 2010 1-HOUR SULFUR DIOXIDE

BOUNDARY RECOMMENDATION

And

Technical Support Document for Recommendation of Nonattainment and Unclassifiable Boundaries in Missouri for the 2010 SO 2 

# National Ambient Air

Quality Standard

Prepared for the Missouri Air Conservation Commission Adoption: June 30, 2011

Division of Environmental Quality Air Pollution Control Program P.O. Box 176 1659 East Elm Street Jefferson City, Missouri 65102 Telephone (573) 751-4817

### ii



### This page intentionally left blank.

### iii 

### Table of Contents

LIST OF FIGURES....................................

................................................... ................................................... ........ IV

1.0 INTRODUCTION ...................................

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

2.0 METHOD OF DETERMINING ATTAINMENT STATUS AND BOU NDARIES ........................................2

3.0 MONITORING DATA ................................

................................................... ................................................... ...4

4.0 EMISSIONS DATA.................................

................................................... ................................................... ........7

**4.1 E**  **MISSIONS**

**................................................... ...................................................**  **................................................... ..7**  **4.2 E**  **MISSION C**  **ONTROLS**

**................................................... ...................................................**  **...................................13 4.3**  **R EGIONAL**  **E MISSION**  **R EDUCTIONS** 

**................................................... ...................................................**  **..............13 4.4**  **G ROWTH** 

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

5.0 METEOROLOGY....................................

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

**5.1 B**  **ACK T**  **RAJECTORIES**

**................................................... ...................................................**  **...................................16**

6.0 TOPOGRAPHY.....................................

................................................... ................................................... ........17

7.0 JURISDICTIONAL BOUNDARIES ......................

................................................... ........................................17

8.0 RECOMMENDED NONATTAINMENT BOUNDARIES...........

................................................... ................17

**8.1 G**  **REENE C**  **OUNTY**

**................................................... ...................................................**  **.........................................18 8.2**  **J ACKSON**  **C OUNTY** 

**................................................... ...................................................**  **.......................................21 8.3**  **J EFFERSON**  **C OUNTY** 

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

9.0 SUMMARY........................................

................................................... ................................................... ............25

APPENDIX 1 – SO 2 EMISSION DATA.....................................

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

APPENDIX 2 – WIND ROSES ...........................

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

APPENDIX 3 – BACK TRAJECTORIES ....................

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

### iv 

### List of Figures

**FIGURE 1. MISSOURI SO 2**  **MONITORING NETWORK, 2010..........................**

**................................................... ..5**  **FIGURE 2. THREE-YEAR AVERAGES FOR SO 2**  **CONCENTRATIONS.................................... ...........................6**  **FIGURE 3. EMISSION SOURCES AND MONITORING SITES IN GREENE COUNTY.....................................**  **.8 FIGURE 4. EMISSION SOURCES AND MONITORING SITES IN**  **JACKSON COUNTY..................................10 FIGURE 5. EMISSION SOURCES AND MONITORING SITES IN**  **JEFFERSON COUNTY ..............................12 FIGURE 6. RADIUS OF IMPACT FROM JAMES RIVER PLANT .** 

**................................................... ...................19**  **FIGURE 7. RECOMMENDED NAA FOR GREENE COUNTY .......**

**................................................... ...................20**  **FIGURE 8. RECOMMENDED NAA FOR JACKSON COUNTY......**

**................................................... ..................22**  **FIGURE 9. RECOMMENDED NAA FOR JEFFERSON COUNTY ....**

**................................................... ................24** 

### This page intentionally left blank.

### 1



## 1.0 Introduction

**In June 2010, the U.S. Environmental Protection Age ncy (EPA) promulgated a revision to the**  **National Ambient Air Quality Standard (NAAQS) for s ulfur dioxide (SO**  **2** 

### ), which establishes “a **new 1-hour SO 2**  

### standard at a level of 75 parts per billion (ppb), **based on the 3-year average of the annual 99**  **th** 

### percentile of 1-hour daily maximum concentrations. **” This new standard replaces both the 24-hour and annual standards.** 

**As provided under Clean Air Act Subparagraph 107(d) (1)(A), the governor of each**  **state is required to submit to the EPA a recommenda tion regarding the attainment status of all**  **areas within that state. This recommendation is du e to EPA by June 2, 2011. Each area of the**  **state shall be recommended for designation as:**

• **nonattainment for areas that do not meet the NAAQS or contain sources that contribute to**  **nonattainment in a nearby area,**

• **attainment for areas that meet the NAAQS, or**

• **unclassifiable for areas that cannot be classified as attainment or nonattainment based on**  **available information.**

**The purpose of this document is to provide the tech nical bases for the recommendations**  **described in the 2010 1-Hour Sulfur Dioxide Boundar y Recommendation.** 

**The primary source of SO 2**  

### emissions is the combustion of sulfur-bearing coal **for power generation, either by utilities or by industries.**  **As coal is burned, the elemental sulfur combines with oxygen to form gaseous SO**  **2** 

### . The sulfur content of coal varies widely, from l **ess than one percent to over three-and-one-half percent. The li**  **fe span of gaseous SO 2**  

### is limited because it is **quickly oxidized further into sulfate (SO 4**  **2-** 

### ). The sulfate binds to atmospheric ammonium **(NH 4**  **+** 

### ) to form ammonium sulfate, one of the major consti **tuents of another criteria pollutant Fine Particulate Matter (PM**  **2.5** 

### ). Other significant emission sources in Missouri **include smelting of sulfur-bearing ores, such as lead sulfide.** 

**In establishing the form and level of the new stand ard, the EPA referred to studies that “infer a**  **causal relationship between respiratory morbidity a nd short-term exposure to SO**  **2** 

### .” On the basis **of these studies, EPA dramatically reduced the aver aging time of the standard in addition to**  **lowering the level of the standard.**

**EPA studies show that children, the elderly, and as thmatics are the most sensitive subpopulations**  **to SO 2**  

### exposure. For these subpopulations, decreased lun **g function, increased respiratory symptoms, and more hospital admissions and emergenc**  **y room visits all characterize their exposure to SO**  **2** 

### . In particular, asthmatics exercising or playing **while exposed to SO 2**  

### represent **a high-risk group as they may experience bronchocon striction, respiratory symptoms, and rapid**  **swallow breathing in response to this exposure. In typical asthmatics, SO**  **2** 

### exposure enhances **the effect of exercise, causing greater than usual increases in airway resistance and wheeze. This**  **response occurs at concentrations only a fraction o f those required to affect healthy people.** 

### 2

**As mentioned previously, SO 2**  

### can also react with other compounds in the atmosph **ere to create small particles, collectively known as PM**  **2.5** 

### . These particles can penetrate deeply into sensit **ive parts of the lungs and may cause or worsen respirat**  **ory diseases such as emphysema and bronchitis. They can also aggravate existing heart**  **disease, leading to increased hospital admissions and premature death.**  

## 2.0 Method of Determining Attainment Status and Bou ndaries

**The EPA has chosen to take a different approach to determine compliance with the 1-hour SO**  **2** 

### NAAQS. Unlike other criteria pollutants, SO **2** 

### is an almost exclusively point source emitted **pollutant. A monitoring network large enough to ad equately cover all large sources would be**  **prohibitively expensive and an affordable network w ould leave large gaps in coverage.**  **Therefore, EPA has decided to use a hybrid monitori ng-modeling approach for SO**  **2** 

### . This hybrid **approach involves a modest monitoring network and e xtensive use of refined air dispersion**  **modeling.**

• **Nonattainment areas will be determined by either mo nitoring or modeling data which**  **show a violation, or likely violation, of the stand ard.** 

• **Both monitoring and modeling are required to show a ttainment.** 

• **Areas without either monitoring or modeling data wi ll be designated unclassifiable.** 

**Since the final SO 2**  

### rule states that modeling is not required for init **ial nonattainment determinations and EPA’s modeling guidance was not**  **available in time for the Department to take these recommendations through its public proce**  **ss and meet the June 2, 2011 deadline, at this time the boundary recommendations are based on**  **factors other than modeling. Therefore, in this initial round of recommendations, no areas can**  **be recommended as attainment; areas that monitor or that likely contribute to violations wil**  **l be recommended as nonattainment; and all other areas of the state will be recommended as unc**  **lassifiable. As the SO 2**  

### modeling guidance is **released and finalized, the Department intends to c onduct refined dispersion modeling of SO**  **2** 

### sources in accordance with EPA’s guidelines and pro **vide additional technical justification as needed for recommended nonattainment area boundarie**  **s.**

**Because all areas of the state are evaluated withou t modeling at this time, only those areas with**  **violating monitors and areas immediately surroundin g them are addressed in this document. For**  **2007-2009, the four violating monitors are Troost i n Kansas City, Main Street in Herculaneum,**  **and James River & South Charleston in Springfield. Sources in these three counties (Greene,**  **Jackson, and Jefferson) and surrounding areas (neig hboring counties) were considered in the**  **analysis to determine their likely impact on the vi olating monitors. If emissions from a particular**  **area in Missouri are determined to have a substanti al impact on the violating monitor, that area is**  **included in the recommended nonattainment area.**

**As stated in the preamble of EPA’s final SO 2**  

### rule, county lines are the presumptive boundaries **for SO 2**  

### nonattainment areas. Therefore, county boundaries **were the starting point for this analysis. The information contained in this docume**  **nt demonstrates why a smaller area (less than countywide) for nonattainment boundary recommendati**  **ons is appropriate for all three counties containing monitors that do not meet the 1-hour SO**  **2** 

### NAAQS.

### 3

**EPA expects to issue final designations by June 201 2. If the EPA intends to modify the state’s**  **recommendations or needs additional technical justi fication to support the designation, they will**  **notify the Department 120 days prior to finalizing the designations. For the SO**  **2** 

### standard, these **“120-day” letters are expected to be released aroun d February 2012. The Department will then**  **be required to submit attainment state implementati on plans (SIPs) for nonattainment areas to**  **EPA by February 2014 outlining actions that will be taken to meet the standard.** 

**The Department expects that some SO 2**  

### emission sources located in the recommended **unclassifiable areas may contribute to violations o f the 1-hour SO**  **2** 

### standard. These sources will **be evaluated with refined modeling analyses when EP A provides official modeling guidance.**  **Any sources contributing to SO 2**  

### violations will be addressed in the Infrastructure **SIP due June 2013.** 

**As outlined in the final SO 2**  

### rule, the Infrastructure State Implementation Plan **(SIP) for the 1- hour SO**  **2** 

### NAAQS will be similar to the conventional attainme **nt SIP for nonattainment areas in that they must include emission inventories, enforc**  **eable emission limits, timetables for compliance, refined dispersion modeling demonstrati**  **ng timely attainment (by 2017), and contingency measures. Since each state is required**  **to submit an Infrastructure SIP for all areas not designated as nonattainment, Missouri intends t**  **o develop such an Infrastructure SIP as an enforceable tool to ensure all areas of the state,**  **including unclassifiable areas, comply with 1- hour SO**  **2** 

### NAAQS no later than August 2017. Missouri also ex **pects the development and implementation of the Infrastructure SIP will elimi**  **nate the need to reclassify any additional areas as nonattainment, besides the initial boundary reco**  **mmendations to be approved by EPA in June 2012, prior to the August 2017 deadline to demonstr**  **ate attainment.**

**On February 17, 2011, a preview of EPA’s draft Boun dary Recommendation guidance was**  **released. In that document, EPA lists a number of different factors to be considered when**  **establishing boundaries for nonattainment areas:**

• **Monitoring data**

• **Emissions, including growth, controls, and regiona l emission reductions** 

• **Meteorology**

• **Topography**

• **Jurisdictional boundaries**

**Each of these factors is discussed in the following sections to determine the extent they play in**  **contributing to the violations recorded at the viol ating monitors.** 

**There is a limit to the influence an emission sourc e has on downwind SO**  **2** 

### concentrations. This **limit is determined by several factors, the most im portant of which are the rate of SO**  **2** 

### emissions, **the conversion rate from SO 2**  

### to SO **4 2-**  

### , stack height, and wind speed. Maximum emission r **ates are determined by a facility’s construction or oper**  **ating permit, or by the size of its boilers if there is no permit limit. Stack parameters, such a**  **s height, width, and exit gas temperature and velocity, can greatly affect SO**  **2** 

### concentrations. Higher stack heights, temperature **s, and exit velocities all lead to increased dispersion and low**  **er concentrations. Higher wind speeds have the effect of diluting SO**  **2** 

### concentrations by increasing the distance traveled **from the source during the conversion process. Slower winds speeds**  **have the opposite effect. These factors combine to determine the extent to which an emissio**  **n source influences the SO 2**  

### concentration at

### 4

**nearby locations. All these considerations are als o taken into account when determining the**  **recommended boundaries.** 

## 3.0 Monitoring Data

**Sulfur dioxide was monitored at nine locations in M issouri by state and local agencies and two**  **additional sites operated by industry during recent years including most of 2010. Operation of**  **five of these sites, all of which were well below t he new NAAQS, was temporarily discontinued**  **in September 2010 with the approval of US EPA Regio n VII. Figure 1 shows the locations of**  **these sites as well as the location of the Blair St reet site in St. Louis, where SO**  **2** 

### monitoring **began in January 2011. The final SO 2**  

### rule included minimum monitoring requirements that **are currently met for St. Louis, Kansas City, and Sprin**  **gfield. However, to better characterize the spatial distribution of SO**  **2** 

### in the Kansas City area, the Department may add at **least one additional site in the Kansas City area beginning i**  **n January 2013. Additional SO 2**  

### monitors near **emission sources may also be added depending on the result of modeling and other analysis. The**  **locations of additional sites will be identified in Missouri’s July 2012 air monitoring plan.** 

### 5

Figure 1. Missouri SO 2 monitoring network, 2010



### Figure 2 and the embedded table show additional 1-h **our SO 2**  

### design values, which are **determined by the three-year average of 99 th**  

### percentile of daily maximum one-hour SO **2** 

### concentrations. These design values were measured i **n recent years (2003-2010) at monitoring**

### 6

**sites in Missouri and are compared to the level of the 1-hour SO**  **2** 

### NAAQS, 75 ppb. The Main **Street site in Herculaneum, the Troost site in Kans as City, and the industry-operated Wildwood**  **Lane and James River South sites in Springfield con sistently show violation of the standard,**  **though the Wildwood Lane 2007-2009 design value is 74 ppb. The South Charleston site in**  **Springfield shows violation of the standard for the 2006-2008 and 2007-2009 periods. The SO**  **2** 

### level at the Main Street site is about four times t **he standard. The SO 2**  

### level at the Troost site is **about twice the standard. The SO 2**  

### levels at the Springfield sites are slightly above **the standard. For areas with multiple violating monitors, the mon**  **itor with the highest design value is assigned as that area’s official design value. For Springfi**  **eld, the James River monitor is the area’s design value monitor.** 

**0 50**  **100 150**  **200 250**  **300 350**  **400**

**Margaretta 59 69 68 60 48 44** 
**South Broadway 59 63 57 58 45 41** 

**Ladue 53 54 49 48 46 42** 
**Maryland Heights 35 36 38 34** 
**Herc., Main 346 324 343 335 264** 

**Troost 155 156 156 169 171 162** 

**MSU 18 22 25 28 28 26** 

**S. Charleston 59 60 68 77 77 69** 

**Wildwood Lane  ** 69 74 82 78 74 77**

**James River-S  ** 73 81 91 96 87 87**

**MTSP 17 17 13 12 12 12** 

**New Standard 75 75 75 75 75 75**  **2003-2005 2004-2006 2005-2007 2006-2008 2007-2009 2008-**  **2010***

*** Data thro ugh 2 nd**  **quarter** *** * Indus trial mo nito r****SO2 Concentration (ppb)**

Figure 2. Three-year averages for SO 2 concentrations.


### Measurement results at the Springfield monitoring s **ites give some indication of the limited spatial extent of elevated SO**  **2** 

### concentrations. **The Wildwood Lane and James River monitoring sites operated by City Utilities are 0.5 and 0.6 ki**  **lometers respectively from the James River Plant. These two sites have been fairly consistent**  **in recent years in measuring SO 2**  

### concentrations above the level of the standard. Th **e South Charleston monitoring site, 2.2 kilometers north-northwest of the James River Plant**  **, has measured SO 2**  

### concentrations near the **standard, sometimes above and sometimes below. The more distant Missouri State University**  **(MSU) monitoring site, located 10.6 kilometers nort h-northwest of the James River Plant, has**  **consistently measured SO 2**  

### concentrations below the level of the standard.

### 7

**In addition to Missouri monitoring sites, the state of Kansas operates one SO**  **2** 

### monitor in Kansas **City, KS, at their JFK site. The JFK site’s 2007-2 009 design value is 46 ppb. This site is located**  **approximately five kilometers west of the Troost si te. The state of Illinois operates three SO**  **2** 

### monitoring sites in the St. Louis metropolitan stat **istical area, including the South Roxana site with a 2007-2009 design value of 100 ppb. The Sout**  **h Roxana site is located approximately 70 kilometers north-northeast of the Herculaneum, Main**  **Street monitoring site.**



## 4.0 Emissions Data **Although SO 2**  

### emission sources are distributed throughout the st **ate, the most and largest sources are along the Mississippi and Missouri Rivers. The**  **se include both electric generating and industrial facilities. A list of all sources in th**  **e state with emissions greater than 10 tons per yea r**  **(tpy) is in Appendix 1.**

**The rate of SO 2**  

### emissions from a source is the single most importa **nt factor in the SO 2**  

### concentration surrounding the source.



### 4.1 Emissions **Greene County – City Utilities of Springfield opera tes two coal-fired power plants in Greene**  **County: James River Plant to the south and Southwes t Plant to the southwest. A second large**  **coal-fired boiler at the Southwest Plant began oper ating in late 2010. Boiler 2 more than doubles**  **the location’s production of electricity; however, SO**  **2** 

### emissions (as well as other emissions) **from boiler 2 are well controlled. Boiler 2 utiliz es flue gas desulfurization (FGD) technology to**  **control SO 2**  

### , a baghouse to control particulate matter (PM), an **d selective catalytic reduction to control nitrogen oxides (NOx), all with correspondi**  **ng emission limits. The existing boiler 1 at Southwest Plant utilizes low sulfur coal to control**  **SO 2**  

### . Overall City Utilities’ SO **2** 

### emissions **were down about 14% in 2009 compared to 2007 (see t able below). This was due mainly to**  **reductions in electricity demand during a mild summ er.** 

**Minor SO 2**  

### sources are scattered throughout the city limits o **f Springfield, but are less than 10 tpy. There are few sources in Greene County outsid**  **e of Springfield city limits (see Figure 3). A list of all sources greater than or equal to 10 tpy**  **is found in Appendix 1.**



### SO **2** 

### emissions (tpy) Facility 2007 2008 2009 **City Utilities – James River 4,702 5,288**  **3,780 City Utilities – Southwest 4,229**  **3,301 3,780**  Total 8,931 8,590 7,561

### 8

Figure 3. Emission Sources and Monitoring Sites in Greene County

### 9

**Jackson County – All but one of the significant SO 2**  

### sources in Jackson County are located along **the Missouri River. Overall SO 2**  

### emissions were down about 35% from 2007. This was **primarily due to scrubber controls installed at Kan sas City Power & Light’s (KCP&L) Iatan**  **Plant and also related to reductions in electricity demand during a mild summer (see table**  **below). The KCP&L Hawthorn plant has installed a s crubber. There are two large sources in**  **nearby Wyandotte County, KS: Nearman and Quindaro. There are minor sources scattered**  **throughout the city limits of Kansas City and Indep endence, but most have emissions below 10**  **tpy (see Figure 4). A list of all sources greater than or equal to 10 tpy is found in Appendix 1.** 



### SO **2** 

### emissions (tpy) Facility 2007 2008 2009 Jackson County, MO **KCP&L – Sibley 11,796 9,181**  **11,787 Veolia – Grand Avenue 6,077**  **6,295 7,201**  **IP&L – Blue Valley 9,185 10,658**  **6,177 KCP&L – Hawthorn 1,923**  **1,725 2,017**  Platte County, MO **KCP&L – Iatan 14,290 15,077**  **1,923** Clay County, MO **IP&L – Missouri City 5,040 2,592**  **920** Total 48,311 45,528 30,025 Wyandotte County, KS **Public Utilities – Nearman na na**  **5,932 Public Utilities – Quindaro na**  **na 3,612**  Grand Total 39,569

### 10

Figure 4. Emission Sources and Monitoring sites in Jackson County

### 11

**Jefferson County – All major SO 2**  

### sources in Jefferson County are located along the **Mississippi River. Overall SO**  **2** 

### emissions were down about 24% from 2007-08. This **was due to a new, more accurate method of measurement at the Doe Run’**  **s Herculaneum smelter which resulted in a correction of almost minus 50% and reductions in**  **electricity demand due to the recession and a mild summer. There are few sources west of Interst**  **ate 55 (see Figure 5). A list of all sources greater than or equal to 10 tpy is found in Appendi**  **x 1.**



### SO **2** 

### emissions (tpy) Facility 2007 2008 2009 Jefferson County **Ameren Missouri – Rush Island 22,058 29,593 28,327 Doe Run – Herculaneum 32,904 35,998 18,842**  **River Cement – Selma 3,018 2,758 1,069** Total 57,980 68,349 48,238 St. Louis County **Ameren Missouri - Meramec 22,769 20,827 16,856** Grand Total 80,749 89,176 65,094

### 12

Figure 5. Emission Sources and Monitoring sites in Jefferson County

### 13



### 4.2 Emission Controls
**One of the best emission controls for SO 2**  

### is the use of low-sulfur bearing coal, mainly from **the western U.S. Operating permits often include SO**  **2** 

### emission limits, often expressed in pounds **(mass) SO 2**  

### per million British thermal units (mmBtu) - a meas **ure of the potential heat content of the coal burned that varies with coal type and mine**  **location.**

**Sulfur is a naturally occurring element in coal tha t also varies considerably with coal type and**  **geographic region of the coal mine. Coal delivered for use in Missouri typically has a sulfur**  **content ranging from approximately 0.2% sulfur to 5 % sulfur. Low sulfur coal is more**  **expensive because of demand and increased transport ation costs to Missouri, while high sulfur**  **coal is typically less expensive and often originat es from nearby states. Many facilities mix coal**  **from different sources to achieve their required em ission limits at the lowest possible cost.** 

**The most common post-combustion control for SO 2**  

### is flue gas desulfurization (FGD), also **known as a scrubber. FGD control requirements are included in a facility’s construction or**  **operating permit. Scrubbers operate by spraying a stream of lime-containing solution across the**  **stack through which the exhaust gas passes. The ga seous SO**  **2** 

### is absorbed by the alkaline **(lime/limestone) slurry. The sulfuric acid produce d is neutralized by the lime in the slurry. The**  **control efficiency is typically 90% or greater.**

**An alternate means of reducing sulfur emissions is switching to natural gas as a primary or**  **secondary fuel. Natural gas contains virtually no sulfur. Several plants in Missouri, including**  **the Independence Power & Light – Blue Valley Plant in Jackson County, the Kansas City Power**  **& Light – Lake Road Plant in Buchanan County, and b oth the James River and Southwest Plants**  **operated by City Utilities of Springfield in Greene County, are able to use both coal and natural**  **gas to fuel one or more of their boilers. There ar e also many small, natural gas-fired power**  **plants throughout the state that operate only when needed.** 


### 4.3 Regional Emission Reductions
**Federal Rules with sulfur and/or sulfur dioxide res trictions**  **Significant regional emission reductions are envisi oned in the proposed Transport Rule (75 FR**  **45210, August 2, 2010). Its primary purpose is to reduce emissions of SO**  **2** 

### and NO **x** 

### that **contribute to PM 2.5**  

### and ozone. The Transport Rule applies to any stati **onary, fossil-fuel-fired boiler or stationary, fossil-fuel-fired combustion**  **turbine serving a generator with a nameplate capacity of more than 25 megawatts producing energy**  **for sale. Proposed emissions reductions are to take effect beginning in 2012 with additiona**  **l reductions scheduled for 2014 lowering nationwide NO**  **x** 

### emissions by 52 percent from 2005 levels and SO **2** 

### emissions by 71 percent. To **comply with the Transport Rule and other regulation s, at least six Missouri units have already**  **installed (prior to January 2011) FGD control devic es. FGD control devices have been installed**  **on two units at both the Ameren Missouri – Sioux Pl ant and Kansas City Power & Light – Iatan**  **Plant, as well as one unit each at Kansas City Powe r & Light – Hawthorn Plant and City Utilities**  **of Springfield – Southwest Plant. A final Transpor t rule is expected to be presented in summer**  **2011.**

**EPA is also currently in the process of promulgatin g three new Maximum Achievable Control**  **Technology (MACT) regulations that could lead to di rect SO**  **2** 

### reductions and co-benefit **reductions.**

### 14

**On March 21, 2011, EPA published final rules in the Federal Register that will reduce emissions**  **of air pollutants from existing and new boilers. C ompliance is required for existing boilers in**  **2014. One of the two boiler rules reduces emission s from existing and new industrial,**  **commercial, and institutional boilers located at ar ea source facilities. This Generally Available**  **Control Technology (GACT) reduces a number of air p ollutants including mainly mercury,**  **metals, and dioxins. The second boiler rule reduce s emissions from new and existing industrial,**  **commercial and institutional boilers and process he aters residing at major source facilities that**  **burn natural gas, fuel oil, coal, biomass, refinery gas and other gas to produce steam. The intent**  **of this MACT is to reduce mainly mercury, metals, a nd organic toxins. The co-benefits of**  **reducing mercury and other air pollutants from the Boiler GACT & MACT also lower SO**  **2** 

### emissions.

**The proposed Utility MACT (signed by the EPA Admini strator on March 16, 2011) targets**  **emissions of hazardous air pollutants (HAPs) [inclu ding mercury, arsenic, acid gases, toxic**  **metals & other toxics] from new and existing coal- and oil-fired electric generating units (EGUs).**  **Per a settlement deadline, EPA is required to sign a notice of final rulemaking establishing**  **MACT standards for EGUs no later than November 16, 2011. Mercury reductions can be**  **achieved through SO 2**  

### , NO **x** 

### , and/or particulate matter (PM) controls. The eff **ectiveness of these controls depend on the characterization of coal or**  **oil burned and the configuration of the power plant, as controls for SO**  **2** 

### serve as a co-benefit to reduce mercury. As propo **sed, once the final rule is issued, existing sources have up to four ye**  **ars to comply with these standards; all existing sources must comply in three years, but individual**  **sources can obtain an additional year if technology cannot otherwise be installed in time.** 

**On February 21, 2011, EPA finalized revisions to th e New Source Performance Standards**  **(NSPS) and emission guidelines for new and existing commercial and industrial solid waste**  **incineration units as well as for new and existing sewage sludge incineration units. Both of these**  **NSPS standards establish emission limits for nine p ollutants emitted from the regulated units,**  **including sulfur dioxide and mercury emissions.**

**Other federal regulations that restrict SO 2**  

### emissions include NSPS, 40 CFR 60 subpart D **(Standards of Performance for Fossil-Fuel-Fired Ste am Generators for Which Construction is**  **Commenced after August 17, 1971), subpart Da (Stand ards of Performance for Electric Utility**  **Steam Generating Units for Which Construction is Co mmenced after September 18, 1978),**  **subpart Db (Standards of Performance for Industrial -Commercial-Institutional Steam Generating**  **Units), and subpart Dc (Standards of Performance fo r Small Industrial-Commercial-Institutional**  **Steam Generating Units).**

**State Rules with sulfur and/or sulfur dioxide restr ictions**  **10 CSR 10-5.130, Certain Coals to be Washed This rule provides that specified coals be cleaned**  **by washing prior to their sale or use. Coal may not be used at facilities located in the St. Louis**  **metropolitan area that is in excess of 2 percent sulfur, or 12 percent ash, unless the coal has been**  **cleaned and provides no more than 12 percent ash on a dry basis. Any facility that emits SO**  **2** 

### at a rate of 2.3 pounds / mmBtu or less is the **exception to this rule.**

**10 CSR 10-5.240, Additional Air Quality Control Mea sure May be Required When Sources Are**  **Clustered in a Small Land Area**

### 15

**This rule provides that more restrictive air qualit y control requirements may be prescribed for**  **areas in which the sum of particulate matter and/or SO**  **2** 

### emissions from existing and proposed **sources exceed specified limits.**

**10 CSR 10-5.570, Control of Sulfur Emissions from S tationary Sources**  **This rule limits SO 2**  

### emissions from industrial boilers in the St. Louis **PM 2.5**  

### nonattainment area. **By reducing SO 2**  

### emissions released into the atmosphere, emissions **of PM 2.5**  

### are reduced. This **rule is intended to curb emissions in the St. Louis nonattainment area in compliance with the**  **federal Clean Air Fine Particle Implementation Rule to reduce the risk of PM**  **2.5** 

### violations. The **rule applies to industrial, commercial, or institut ional boilers or process heaters greater than 55**  **mmBtu per hour with compliance beginning January 1, 2011. Breweries are limited to 3,050**  **tons SO 2**  

### per year and other installations limited to 1.0 lb **SO 2**  

### / mmBtu of actual heat input.

**10 CSR 10-6.060, Construction Permits Required This rule defines sources which are required to obt**  **ain permits to construct. The rule also establishes that certain requirements be met before**  **modification or construction of a facility. This rule includes maximum allowable increases to a**  **mbient air concentrations for Class I, II, and III areas, significant monitoring concentrations, a**  **nd significant SO 2**  

### air quality impact levels.

**10 CSR 10-6.260, Restriction of Emission of Sulfur Compounds**  **This rule establishes sulfur limits for indirect he ating, lead smelting and refineries, and all other**  **new and existing sources. Indirect heating sources outside the St. Louis metropolitan area may**  **not exceed 8 lbs of SO 2**  

### / mmBtu with additional limits to the various utili **ty units. Indirect heating sources located in the St. Louis metropolit**  **an area and greater than 2,000 mmBtu /hour may not exceed 2.3 lbs SO**  **2** 

### / mmBtu with one utility limit of 4.8 lbs SO **2** 

### / mmBtu. Sources in **this area which are less than 2,000 mmBtu /hour mus t have an emission rate of 2.3 lbs SO**  **2** 

### / **mmBtu or lower, or may only burn 2 percent or less sulfur coal from October through March and**  **4 percent or less from April through September. Le ad smelters and refinery SO**  **2** 

### emissions are **limited by a table outlined in the rule. An update to this table not yet incorporated into the rule i**  **s an EPA proposed consent decree for the Doe Run Herc**  **ulaneum smelter which establishes a shutdown date of December 31, 2013. All other exis**  **ting sources may not exceed SO 2**  

### limits of **2,000 parts per million volume (ppmv) or 70 milligr ams (mg) per cubic meter (m**  **3** 

### ) of sulfuric **acid or sulfur trioxide. All other new sources may not exceed 500 ppmv or 35 mg/m**  **3**



### . **10 CSR 10-6.270, Acid Rain Source Permits Required This rule establishes certain general provisions an**  **d operating permit program requirements for affected sources and affected units under the feder**  **al Acid Rain Program (ARP). This program pertains to existing utility units serving generato**  **rs with a nameplate capacity greater than 25 megawatts and all new utility units. Missouri requ**  **ired affected units to participate in the EPA administered ARP cap and trade program. Phase I of**  **the program reduced SO 2**  

### emissions by **approximately 50 percent, and Phase II reductions b y 67 percent from 1980 levels.** 



### 4.4 Growth **Despite projections of increased electricity demand of 1.0% per year, the U.S. Department of**  **Energy projects a substantial decrease in nationwid e SO**  **2** 

### emissions to 2035 due to increased **controls required by a variety of new regulations ( see**  

### http://www.eia.gov/forecasts/aeo/early_elecgen.cfm **).**

### 16



## 5.0 Meteorology

**In general, winds in Missouri come from two directi ons: southeast and northwest. During the**  **months from late spring to early fall, southeast wi nds predominate with sizable fractions coming**  **from the southwest quadrant. During the late fall to late winter months, the winds shift**  **significantly to the northwest, though there is sti ll a considerable southern component. Winds**  **from the northeast are negligible throughout the ye ar. There is some variation between the major**  **metropolitan areas. The majority of winds have spe eds between 8 and 20 miles per hour (7 to 17**  **knots). Wind roses for each quarter for the three major metropolitan areas are shown in**  **Appendix 2.**

**Wind direction plays a critical role in the locatio n and concentration of SO**  **2** 

### in ambient air. **Areas located downwind of large sources will have h igher concentrations than those located**  **upwind. However, the changing direction of the win d means that downwind areas can be either**  **north or south of major sources. Areas to the east or west of major sources are less likely to have**  **high SO 2**  

### concentrations. Wind speed also plays a significa **nt role in ambient SO 2**  

### concentrations. Days with still or low wind speeds **are more likely to have high concentrations than days with moderate to high winds.** 

**Kansas City area – the greatest deviation from the statewide pattern is during the third quarter,**  **when the predominant wind direction is from the sou thwest.** 

**St. Louis area, including Jefferson County – the gr eatest deviation from the statewide pattern is**  **during the second quarter, when winds are almost eq ually distributed throughout the southeast to**  **northwest (112.5 degrees to 315 degrees).**

**Springfield area – the Springfield area is the clos est to the statewide pattern of all the major**  **metropolitan areas. The greatest deviation from th is pattern is during the fourth quarter, when**  **the single largest component remains from the south east.** 



### 5.1 Back Trajectories **Back trajectories use a computer model called HYSPL IT (Hybrid Single Particle Lagrangian**  **Integrated Trajectory) to determine the path a parc el of air travels during the previous twenty**  **four hours to arrive at the selected time and locat ion. For this document, this information is used**  **to help determine the sources that contribute to th e four highest annual concentration days during**  **2007-9 at Missouri’s three violating monitor sites. These dates correspond to the values used in**  **calculating the design value for each site. The ba ck trajectory maps are located in Appendix 3.** 

**Greene County – of the twelve trajectories, four ea ch come from the west and south, and the**  **remaining four are scattered from the northwest to the northeast. These results are not**  **unexpected, considering that the monitor is located east of the City Utilities of Springfield –**  **James River Plant. Only the four trajectories from the west are from the direction of the**  **Southwest Plant, indicating that, while emissions f rom City Utilities of Springfield –**  **Southwest Plant may influence the James River monit or occasionally; more often than not the**  **winds are blowing the Southwest Plant’s emissions a way from the monitor.** 

### 17

**Jackson County – of the twelve trajectories, eight come from the northwest, the direction of the**  **nearest large source – Veolia’s Grand Avenue facili ty – and to a lesser extent from the two**  **power plants in Kansas – Nearman and Quindaro. The other trajectories were scattered from east**  **to west. These trajectories show that, on days whi ch have SO**  **2** 

### concentrations above the **standard, the winds are overwhelming from the direc tion of the nearest source. This indicates**  **that other large sources to the east are unlikely t o contribute to the violating monitor.** 

**Jefferson County – of the twelve trajectories, elev en come to the monitor from the south, up the**  **Mississippi River valley. The twelfth comes from t he west. These trajectories indicate that the**  **area likely to contribute to the violating monitor is limited to the area south of Herculaneum**  **along the Mississippi River Valley.** 

## 6.0 Topography

**In the context of this document, topography refers to the presence of air basin boundaries, such**  **as mountain ranges, or other features that affect t he movement of the air on a large scale. It does**  **not include micro effects such as building downwash . In general, the northern part of Missouri is**  **open plain and contains no features that impede or channel air speed or direction. The southern**  **part of Missouri is dominated by the Ozark Mountain s, which are not tall enough to create large**  **effects, but may lead to local channeling through s mall valleys. The remaining major features**  **are the two great rivers, the Mississippi and Misso uri, and their valleys. On a small scale, the**  **two river valleys seem to have the effect of increa sing the north-south or east-west wind**  **direction. This effect may not affect the concentr ation at any one particular monitor, but may**  **limit the number of sources that impact that monito r.** 


## 7.0 Jurisdictional Boundaries

**Nonattainment boundaries are typically defined by e asily definable features such as county,**  **municipal, or township boundaries. Large, immovabl e features such as rivers or highways can**  **also be used. The following considerations are tak en into account when considering which**  **features to use as boundaries:**

• **contains a violating monitor**

• **contains sources that likely contribute to a violat ing monitor** 

• **is easily recognizable by public**



## 8.0 Recommended Nonattainment Boundaries **Due to the hybrid monitoring/modeling approach to S O**  **2** 

### boundary determination selected by **EPA and the lack of timely modeling guidance prior to the boundary designation deadline, no**  **areas of the state, even those with valid monitorin g data below the standard, may be classified as**  **attainment. This approach also dictates that areas with neither monitoring nor modeling must be**  **labeled unclassifiable. Most of Missouri falls int o this category. The remaining areas are only**  **those that are determined to either contain or impa ct one of the four monitors that violate the**  **standard.**

### 18

**The Department is recommending three nonattainment areas for the state of Missouri, each of**  **which contains a violating monitor(s) and the surro unding area determined by the Department to**  **likely contribute to that violation. As noted in t he Section 2.0, the four violating monitors are in**  **Greene County (Springfield), Jackson County (Kansas City), and Jefferson County**  **(Herculaneum).**



### 8.1 Greene County **For 2007-2009, Greene County has two monitors that violate the 1-hour SO**  **2** 

### NAAQS. The **recommended nonattainment area includes the area bo unded by U.S. 65 on the east, U.S. 60 on**  **the north, U.S. 160 (South Campbell Ave) on the wes t, and the county line on the south (see**  **Figure 7). The boundaries of the recommended nonat tainment area include the two violating**  **monitors and the City Utilities of Springfield - Ja mes River Plant. The fact that there is a third**  **nearby site in Springfield that is well below the s tandard demonstrates the limited range of**  **influence of the James River Plant emissions. As s een in Figure 6, there is a linear relationship**  **between the SO 2**  

### concentration at a site and its distance from the **James River Plant. The line crosses the new standard at approximately 2.6 km.**  **This radius of influence justifies the small boundaries. In late 2010, City Utilities of Spring**  **field – Southwest Plant began operating a new coal-fired boiler that utilizes significant emissio**  **n controls including FGD technology to control SO**  **2** 

### , a baghouse to control particulate matter and sele **ctive catalytic reduction to control NOx, all with corresponding emission limits. The existing b**  **oiler 1 at Southwest Plant utilizes low Sulfur coal to control SO**  **2** 

### . Since the Southwest Plant has roughly the same t **otal emissions, it should have a similarly small radius of SO**  **2** 

### impact (similar to the James River Plant). The So **uthwest Plant is approximately 13 km from the James River m**  **onitor. At that distance, its impact on the James River monitor is negligible based on the cond**  **ucted analysis.**

### 19

Figure 6. Radius of impact from James River Plant Linear Decay Rate of SO2

0 10 20 30 40 50 60 70 80 90 100

0 2 4 6 8 10 12 14 Distance from James River power plant in km[SO2] in ppb NAAQS = 75 ppb

MSU monitor = 28 ppb S. Charleston monitor = 77 ppb James River monitor = 87 ppb

### 20

Figure 7. Recommended NAA for Greene County

### 21



### 8.2 Jackson County **Jackson County has one monitor that violates the 1- hour SO**  **2** 

### NAAQS. The recommended **nonattainment area includes the portion of Jackson County north of I-70/I-670and west of I-435.**  **(see Figure 8). The boundaries of the nonattainmen t area contain the violating monitor in**  **downtown Kansas City and the nearest large source – Veolia’s Grand Avenue facility. The**  **predominance of back trajectories on high exceedanc e days from the northwest indicates that the**  **sources in eastern Jackson County are unlikely to i mpact the Troost monitor. The rapid**  **conversion of SO 2**  

### to SO **4 2**  

### - and the presence of a non-violating monitor in Wy **andotte County, KS, indicate that the SO**  **2** 

### contributions from the two Public Utility power pl **ants, Nearman and Quindaro, likely do not have a significant impact o**  **n the violating Troost monitor. As mentioned in Section 4.1, the KCP&L - Hawthorn Plant has a sc**  **rubber installed which provides 80% control of SO**  **2** 

### emissions. This fact, in combination with the bac **k trajectories, led to the recommendation of I-435 as the eastern boundary.** 

**The southern portion of Jackson County contains no large sources and therefore has minimal**  **impact the violating monitor. The same is true for southern Clay and Platte counties. Interstate**  **70 was selected as the southern boundary because it is an easily recognizable, permanent feature**  **and encompasses the major source affecting the Troo st monitor. Interstate 435 was selected as**  **the eastern border for the same reasons: it is an e asily recognizable, permanent feature; includes**  **the Troost monitor; and excludes the sources to the east that have been determined to likely have**  **little impact on the violating monitor. Given the rapid conversion of SO**  **2** 

### to SO **4 2-**  

### and the back **trajectories on the highest exceedance days, the De partment determined that the KCP&L –**  **Iatan Plant in northern Platte County is not likely a significant contributor to the violation at**  **Troost. KCP&L also installed significant SO 2**  

### controls (specifically FGD) at Iatan when building **a second boiler there.**

### 22

Figure 8. Recommended NAA for Jackson County

### 23



### 8.3 Jefferson County **Jefferson County has one monitor that violates the 1-hour SO**  **2** 

### NAAQS. The recommended **nonattainment area includes both Herculaneum and Fe stus townships in Jefferson County as well**  **as the portions of Valmeyer and Selma townships in Jefferson County, Missouri (see Figure 9).**  **The boundaries of the recommended nonattainment are a include both large sources in Jefferson**  **County: the Doe Run lead smelter in Herculaneum and the Ameren Missouri – Rush Island**  **Plant. The wind direction roses and back trajector ies all indicate that emissions from these plants**  **are transported north along the Mississippi River v alley. That fact, combined with the lack of**  **sources in the western portion of the county, indic ate that the remainder of the county does not**  **contribute to the violation at the Main Street moni tor and justify the exclusion of the remainder**  **of the county. Townships were selected for the bou ndaries due to the lack of any other**  **significant north-south feature, such as a highway, that would include all sources. Interstate 55**  **was judged to be too close (in proximity) to establ ish an appropriate western boundary. The**  **Ameren Missouri – Meramec Plant in southern St. Lou is County was determined to not**  **contribute to the violation at the Main Street moni tor because of its location to the north of the**  **monitor and the fact that the back trajectories ind icate that the highest concentration days occur**  **when the winds are from the south, not the north.**

### 24

Figure 9. Recommended NAA for Jefferson County

### 25



## 9.0 Summary

**After reviewing the available monitoring, emission, and meteorological data, the Department has**  **recommended three areas, one each in Greene, Jackso n, and Jefferson counties, for designation**  **as nonattainment for the 2010 1-Hour SO 2**  

### NAAQS. The recommended nonattainment area **boundaries were selected based on fixed, easily rec ognizable features and include the violating**  **monitor(s) and those nearby sources determined to l ikely impact the violating monitor.** **1**Appendix 1 – SO2Emission Data**(from 2009 Missouri Emission Inventory System)**County Plant#Parent Company**(* - non electric generating unit)**Site Name 2009 TotalSO2Emissions(tons/yr)**Franklin 0003 AMEREN MISSOURI LABADIE PLANT**61,681**St. Charles 0001 AMEREN MISSOURI SIOUX PLANT**46,456**Jefferson 0016 AMEREN MISSOURI RUSH ISLAND PLANT**28,327**Jefferson 0003 *DOE RUN COMPANY HERCULANEUM SMELTE****R**18,838**St. Louis 0010 AMEREN MISSOURI MERAMEC PLANT**16,856**Randolph 0001 THOMAS HILL ENERGY CENTER THOMAS HILL**16,628**New Madrid 0004 NEW MADRID POWER PLANT MARSTON**14,480**Henry 0001 KANSAS CITY POWER & LIGHT CO MONTROSE ST ATION** 12,791**Jackson 0031 KANSAS CITY POWER & LIGHT CO SIBLEY ST ATION** 11,787**Jasper 0001 EMPIRE DISTRICT ELECTRIC CO ASBURY PLA NT** 11,007**Boone 0004 UNIVERSITY OF MISSOURI POWER PLANT**7,459**Jackson 0021 *VEOLIA ENERGY GRAND AVENUE STATION**7,201**Jackson 0050 INDEPENDENCE POWER AND LIGHT BLUE VALL EY STATION** 6,177**Scott 0017 SIKESTON POWER STATION SIKESTON POWER ST ATION** 6,023**St. Louis City****0003 *ANHEUSER-BUSCH INC ST. LOUIS**4,991**Pike 0002 *ASHLAND INC MISSOURI CHEMICAL WORKS**4,890**Ste. Genevieve** **0001 *MISSISSIPPI LIME COMPANY STE. GENEVIEVE**4,419**Greene 0005 CITY UTILITIES OF SPRINGFIELD JAMES RIV ER POWER PLANT** 3,780**Greene 0039 CITY UTILITIES OF SPRINGFIELD SOUTHWEST POWER PLANT** 3,780**New Madrid 0008 *NORANDA ALUMINUM INC NEW MADRID**2,885**Osage 0002 CENTRAL ELECTRIC POWER COOPERATIVE** **CHAMOIS PLANT**2,728**Iron 0009 *DOE RUN COMPANY BUICK SMELTER**2,583**Buchanan 0004 KANSAS CITY POWER & LIGHT CO LAKE ROA D PLANT** 2,401**2****Marion 0001 *BASF CORPORATION HANNIBAL PLANT**2,371**Jackson 0022 KANSAS CITY POWER & LIGHT CO HAWTHORN STATION** 2,016**Platte 0007 KANSAS CITY POWER & LIGHT CO IATAN GENE RATING STATION** 1,923**Pike 0001 *HOLCIM (US) INC CLARKSVILLE**1,843**Saline 0010 MARSHALL MUNICIPAL UTILITIES MARSHALL M UNICIPAL** **UTILITIES**1,400**Jefferson 0002 *RIVER CEMENT CO. DBA BUZZI****UNICEM USA SELMA PLANT** 1,053**Clay 0096 INDEPENDENCE POWER AND LIGHT MISSOURI CIT Y STATION** 919**Boone 0002 CITY OF COLUMBIA MUNICIPAL POWER PLANT**908**Phelps 0006 MISSOURI UNIV. OF SCIENCE AND TECHNOLOGY** **POWER PLANT**465**Cape Girardeau** **0010 SOUTHEAST MISSOURI STATE UNIVERSITY** **POWER PLANT**373**St. Charles 0076 *GENERAL MOTORS LLC WENTZVILLE C****ENTER**314**Montgomery 0008 *CHRISTY MINERALS, LLC HIGH HILL**313**Jefferson 0068 *SAINT-GOBAIN CONTAINERS INC PEVELY**229**Jackson 0030 *LAFARGE NORTH AMERICA INC SUGAR CREE****K PLANT**192**Pettis 0009 *PITTSBURGH-CORNING CORP SEDALIA**168**St. Louis City****0017 *MALLINCKRODT INC N SECOND**133**Holt 0001 *EXIDE TECHNOLOGIES CANON HOLLOW**80**Ralls 0001 *CONTINENTAL CEMENT COMPANY****LLC ILASCO PLANT** 75**Ste. Genevieve** **0035 *CHEMICAL LIME COMPANY STE. GENEVIEVE**46**Jasper 0094 *TAMKO BUILDING PRODUCTS INC RANGELINE****PLANT**38**Jackson 0017 *FOLGERS COFFEE CO BROADWAY**38**Ste. Genevieve** **0044 *HOLCIM (US) INC STE. GENEVIEVE PLANT**33**Callaway 0001 *HARBISON-WALKER REFRACTORIES WESTMIN****STER AVE**29**Cape Girardeau** **0060 *Q. C. CORPORATION Q. C. CORPORATION**28**3****Pulaski 0004 *FT LEONARD WOOD INSTALLATION MANAGEME****NT**28**Cape Girardeau** **0021 *BUZZI UNICEM USA CAPE GIRARDEAU**26**Perry 0020 *ATLAS EPS PERRYVILLE**20**St. Louis 1521 *PACE CONSTRUCTION CO FLORISSANT**13**Clay 0002 *NATIONAL STARCH LLC NORTH KANSAS CITY**13**St. Francois 0017 *FLAT RIVER GLASS CO PARK HILL****S**12**Barry 0021 *SCHREIBER FOODS INC SCHREIBER FOODS IN****C - MONETT** 12**Maries 0001 *KINGSFORD MANUFACTURING CO BRIQUETTING****PLANT**10

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## Appendix 2 – Wind Roses

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## Appendix 3 – Back Trajectories **Greene County, MO area**

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### Greene County, MO area

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### Greene County, MO area

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### Jackson County, MO area

### 5



### Jackson County, MO area

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### Jackson County, MO area

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### Jefferson County, MO area

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### Jefferson County, MO area

### 9



### Jefferson County, MO area

# --------- 

# PUBLISHER'S AFFIDAVIT

STATE OF MISSOURI,) )ss. COUNTY OF COLE)

Mike Vivion being duly sworn, according to law, says he is Vice President of Central Missouri Newspapers, Inc., Publisher of the News Tribune, a newspaper printed and published in the County of Cole, and State aforesaid; that said newspaper has been published continuously for more than three years; and that the notice hereto attached was published in said paper in compliance with the provisions of Section 493.050

R.S. of Mo. For 2000 as amended for

___ 1....:.t_im_e

__ as follows:

1 st 

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Fee: $228.50

# ~/.I~ 30th Subscribed and sworn to before me this

March 20 11 

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________________ ,

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# 1J1W:JJi1

# ~f,7lJ1tlj- 

# ..... Notary Public,!,;,,"

My term as Notary Public expires

________________ _ " ,', ','MISSOURI AIR CONSERVATION

. COMMISSION WILL HOLD PUBLIC HEARING JEFFERSON CITY, MO

-- The MIssouri Air Conservation Commission will hold a public hearing on the 2010 1 -Hour Sulfur Dioxide Boundary Designation, Maintenance Plan· for the Annual Fine Particulate Matter (PM2.5) National Ambient Air Quality Standard (NAAQS), and Doe Run Herculaneum Facility-Modification to Corysent Judgement on Thursday, April**2~,** 2011. The Public Hearing Will begin at 9 a.m. at the Holiday Inn Hotel and Suites, Rainier Room, 2720**Nort~** Glenstone, Springfield, Missoun. The commission will hear testimony related to the following "em (s). * 2010 1-Hour Sulfur Dioxide Boundary Designation Recommendation In June 2010, the U.S. Environmental**P.r~ection** Agency (EPA) issued a re­ vIsion to the National Ambient Air Quality Standard for sulfur dioxide (S02) of 75 parts per billion measured over one hour. Release of this standard started a time clock with a deadline of June 2011 for the governor of .theState of Missouri to submit a recommendation 10 EPA as to which areas of the state should be designated as nonattainment for the
new S02 standard. Portions of Greene, Jackson, and Jefferson counties are recommended as nonattainment for this standard. * Redesignatlon· Demonstration and Maintenance Plan for the Missouri Portion of the St. Louis Area for the 1997 Annual Fine Particulate Matter (PM2.5) National Ambient Air QualitY Standard (NMQS) The Missouri counties of Franklin Jefferson, SI. Charles, and· 51.**Lou~** along with the City of SI. LOUis are part of a nonattalnment area lor the 1997 annual PM2.5 NAAQS.. Monitors located in this area have re- I cord.ed Ihree years of complete,. i quality assured ambient air quality monitoring data for 2007-2009 demonstrating attainment with**th~** 1997 annual PM2.5 NMQS. Now that the area has attained the standard, a maintenance plan for the· St. Louis area is being submitted to EPA as part of a request to redesignate the affected area to attainment for Ihls NMQS. * Missouri State Implementation Plan

-- The Doe Run Company Herculaneum Facility

-- Modification to Consent Judgment As part of the Consent Judgment entered into by Missouri Department of Natural Resources and The Doe**~un** C0l!lpany (Ode Run), the prOVision entitled "Fence line to Preclude Public Access" includes a statement that Doe Run will not construct any new lead emission sources between the existing fence line and any new fence line. The purpose of this**revi~** sion is to modify this statement to allow for the construction of a new lead. technological process, but continue to restrict the construction of traditional pyrometallurgical lead processes within this area. Documents lor the above Item(s} will be available for review at the Missouri Department of Natural Resources, Air Pollution Control Pro**g~am,** 1659 Elm Street, J efierson City, (573) 751-4817 and in the Public N,0tices section of the program web site www.dnr.mo.gov/env/apcp/in

_ dex.html. This information will be**i1v~ilable** at least 30 days prior to the

. .....

### ~ea$ti~~~biJJtiel>**·r;~~fri ng~**  speCial servIces or accommodations" to attend the meeting can make s to attend the meeting can make arrangements by calling the Departmefl' directly at (573) 526-4679, the Department's toll· free number al (800) 334-6946, or by writing two weeks In advance of the meeting to: Missouri Department of Natural Resources, Air Conservation .Commission S:cretary, P.O. Box 176, Jefferson City, MO 65102. Hearing Impaired persons may contact the program through Relay Missouri, (800) 735-2966. The. commission holds public hearmgs under the provisions of chapter 643, RSMo. Citizens wiShing to speak at the public hearing should notify. the secretary to the Missouri Air Conservation CommiSSion, Misso.l!ri Department of Natural Re­ $ou·rces, Air Pollution Control Program, P.O. Box 176, Jefferson City Missouri 65102-0176, or**telephon~** (573) 526-4679. The Department requests persons intending to give**ve~bal** presentations also provide a**~@en** copy of their testimony to the**~t:lJmission** secretary at the time of the, public hearing. The Department also will accept written or email commEnltsforthe record until 5 p.m. on May 5, 2011; please send written comments to Chief, Afr Quality Planning Section, Air .Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102-0176. Email comments regarding rule actions shall be sent to apcpruhi!spn@dnr.mo.gov and email comments regarding plan actions shall

. be sent

. to apcpsppn@dnr.mo.go \(. All written and email comments and public hearing testimony will be equally considered. Public hearing items may be adopted by the Missouri Air Conservation Commission as provided for under authority of 643.050, RSMo. For

more information or a complete meeting agenda, including items being presented for adoption, contact the Missouri Department of Natural Resources' Air Fiollutlon Control Program at (573) 751-4817. N.T. March 29,2011

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# ([**I'I.~** H

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SERVICES

COURT REPORTING & VIDEO

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STATE OF MISSOURI DEPARTMENT OF NATURAL RESOURCES MISSOURI AIR CONSERVATION COMMISSION PUBLIC HEARING

TRANSCRIPT OF PROCEEDINGS

APRIL 28, 2011

NA T10NWI DE SCH ED U LI N G

MISSOURI Springfield Jefferson City Kansas City Columbia Rolla Cape Girardeau

- KANSAS Overland Park -ILLINOIS Springfield

HEADQUARTERS: 711 NORTH ELEVENTH STREET, ST. LOUI 5, 

### M 1550URI 63101


### 800.280.3376 www.midwe5tlitigation.comTRANSCRIPT OF PROCEEDINGS 4/28/2011

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7 STATE OF MISSOURI DEPARTMENT OF NATURAL

8 MISSOURI AIR CONSERVATION COMMISSION

9 PUBLIC HEARING

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TRANSCRIPT OF PROCEEDINGS

11 April 28, 2011

12 Springfield, MO

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REPORTED BY:

16 ERIKA SCHAFFER, CCR

MIDWEST LITIGATION SERVICES

17 1911 SOUTH NATIONAL, SUITE 402
SPRINGFIELD, "MO 65804

18 TEL: 417-877-9700

FAX: 417-877-9704

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MIDWEST LITIGATION SERVICES www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334

$X -"'TRANSCRIPT OF PROCEEDINGS 4/28/2011

1 I N D E X

2

3

4 Testimony of Jim Kavanaugh
Testimony of Bob Randolph

5 Testimony of Bern Johnson

Further testimony of Bob Randolph

6 Testimony of Joe Winkleman
Testimony of Paul Myers

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Court Reporter's Certificate

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MIDWEST LITIGATION SERVICES Www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.13345

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Page 5

1 lution control agencies, as well as copies of

2 receipts from the States ronmental Protection

3 Agency and the states of III s and Kansas. Chairman,

4 S conc my testimony.

MR. GARRETT: Thank you. Bob Randolph and

-­ is

6 it Vern or Bern?

7 MR. JOHNSON: Bern.

8 MR. GARRETT: Okay. And Bern Johnson.

9 BOB RANDOLPH AND BERN JOHNSON,

of lawful age, having been produced sworn, testified

11 as follows:

12 MR. RANDOLPH: Good morning. Mr. Chairman,

13 members of the Commis on. My name is Bob Randolph.

14 Bern Johnson and I will both be presenting testimony

t Bern and I are employed at

-­ with the Mi

16 Department of Natural Resources' as environmental

17 engineers. We both work at 1659 East Elm Street in

18 Jefferson City. We are here today to present testimony

19 for the Recommendation of Nonattainment and

Unclassi able Areas, per the 2010 One-Hour National

21 ent Air ity Standard for Sulfur Dioxide. A

22 summary of the recommendation starts on page 93 of the

23 April briefing document.

24 In June 2010, the U.S. Environmental Protection

Agency promulgated a sion to the National Ambient

MIDWEST LITIGATION SERVICES www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334TRANSCRIPT OF PROCEEDINGS 4/2812011

Page 6
1 Air ity Standard for sulfur dioxide which

2 established a new one-hour standard to 7S parts per

3 billion, based on the three year average of the

4 99th percentile, or the fourth highest per year, of the

S one-hour daily maximum concentrations. s new

6 standard aced all previous sulfur dioxide primary,

7 or healthy based standards, including the 24-hour and

8 annual standards.

9 Sulfur dioxide is primarily a point source

10 pollutant .directly emitted from fossil fuel combustion

11 at electric utilities and other industrial facilities.

12 By comparison, ground-level ozone is not directly

13 emitted, but rather is formed via reactions involving

14 volatile organic compounds and oxides of nitrogen.

lS Ozone pollution is emitt from a variety ·of large and

16 small point and area sources, as well as mobile sources.

17 Ozone is more regional in nature than suI dioxide.

18 Sulfur dioxide rapidly converts to sulfate, which

19 combines with atmospheric ammonia to form ammonium

20 sulfate, which is a or component of f Particular

21 Matter, another teria pollutant, so known as PM

22 2. S. The EPA has chosen a dif approach to

23 determine compliance th the one-hour sulfur dioxide

24 standard by emphasizing refined dispersion modeling as

2S primary evaluation tool, especially later in the

MIDWEST LITIGATION SERVICES www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.13345

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25 TRANSCRIPT OF PROCEEDINGS 4/2812011

Page 7

1 process. While monitoring remains another tool, it will

2 playa supplementary role. As of s increased

3 modeling emphasis, sulfur dioxide sources statewide will

4 be analyzed and modeled, regardless of individual source

locations within or outside the nonattainment areas.

6 The new approach also includes infrastructure state

7 implementation plan requirements for sulfur dioxide

8 unclassifiable areas. Sulfur dioxide infrastructure

9 plans are expected to include provisions for ssion

controls and other rements typically reserved for

11 attainment ans. In contrast, infrastructure ans

12 from other air quality standards have historically been

13 administrat only, by assuring the department has the

14 authority to implement and enforce standards.

Although model is a focus later in the process

16 the final rule

-­ f suI dioxide rule

- states

17 that model is not required for initial nonattainment

18 demonstrations. Missouri based its boundary

19 recommendations on factors other than modeling, per
designation guidance and evaluation a the

21 final sulfur dioxide rule. S an attainment

22 des ion initial requires both monitoring data and

23 modeling data indicating attainment status, we are not

24 recommending any areas as attainment. Areas that

monitor or likely contribute to olations are

MIDWEST LITIGATION SERVICES www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334COMMENTS AND RESPONSES

AND

RECOMMENDATION FOR ADOPTION

PROPOSED 2010 I-HOUR SULFUR DIOXIDE NATIONAL AMBIENT AIR QUALITY STANDARD BOUNDARY DESIGNATION RECOMMENDATION AND TECHNICAL SUPPORT DOCUMENT FOR THE DETERMINATION OF NONATTAINMENT AND UNCLASSIFIABLE BOUNDARIES IN MISSOURI

On April 28, 2011, the Missouri Air Conservation Commission held a public hearing concerning the 2010 I-Hour Sulfur Dioxide Boundary Recommendation, including the Technical Support Document for nonattainment and unclassifiable areas in Missouri. In June 2010, the U.S. Environmental Protection Agency (EPA) issued a revision to the National Ambient Air Quality Standard for sulfur dioxide (S02) of 75 parts per billion measured over one hour. Release of this standard started a time clock with a deadline of June 20 II for the Governor of the State of Missouri to submit a recommendation to EPA

as to which areas of the state should be designated as nonattainment for the new S02 standard. Portions of Greene, Jackson, and Jefferson counties are recommended as nonattainment for this standard. All remaining areas are recommended as unclassifiable. No written or verbal comments were received concerning this proposed recommendation during the public comment period.

The document has not been reprinted in the briefmg document as no changes were made from 

### the proposal, in addition to its volume. The entire document is available for review
at the Missouri Department of Natural Resources', Air Pollution Control Program, 1659 East Elm Street, Jefferson City, Missouri, 65101, (573)751-4817. It is also available online at http://dnr.mo.gov/env/apcp/stateplanrevisions.htm

The Missouri Department of Natural Resources' Air Pollution Control Program recommends the commission adopt the boundary recommendation as proposed. 

### If the commission adopts this recommendation, it will 

### be the department's intention to submit this recommendation to the U.S. Environmental Protection Agency.

SUMMARY OF COMMENTS: No written or verbal comments were received concerning this boundary recommendation.



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