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 ofthree non attainment areas in portions of Greene, Jackson and 

Jefferson Counties. All other areas ofthe state are recommended as unclassifiable. 

In order to comply with Attachment A ofthe "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 ofrecommendation 

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 Commission 
Missouri 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 ofGreene 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 Unclassifi able 

Henry Unclassifiable 

Hickory Unclassifiable 

Holt Unclassifiable 

Howard Unclassifiable 

Howell classifiable 

Iron classifiable 

Jackson Nonattainment (portion ofJackson 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 ofInterstate-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 

IUnclassifiable 

Mississippi 

Moniteau TT • ."" .. Monroe I Unclassifiable 

Montgomery Unclassifiable 

Morgan Unclassifiable 

New Madrid U nclassifiable 

Newton· Unclassifiable 

Nodaway Unclassifiable 
County 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 

~ard Unclassifiable

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 Standard 

Summary of Recommendation of Nonattainment and Unclassifiable Boundaries in 

Missouri

In June 2010, the U.S. Environmental Protection Agency (EPA) promulgated a revision to the 

National Ambient Air Quality Standards (NAAQS) for sulfur dioxide (SO2), which established 

“a new 1-hour SO2 standard at a level of 75 parts per billion (ppb), based on the 3-year average 

of the annual 99th 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 due 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 determine attainment status for the 1-hour SO2

NAAQS. Unlike other criteria pollutants, SO2 is almost exclusively a point source-emitted 

pollutant. A monitoring network large enough to adequately cover all large sources would be 

prohibitively expensive and an affordable network would leave large gaps in coverage. 

Therefore, EPA has decided to use a hybrid monitoring-modeling approach for SO2. This hybrid 

approach involves a modest monitoring network and extensive use of refined air dispersion 

modeling. 

• Nonattainment areas will be determined by either monitoring or modeling data which 

show a violation, or likely violation, of the standard. 

• Both monitoring and modeling are required to show attainment. 

• Areas without either monitoring or modeling data will be designated unclassifiable. 

Since the final SO2 rule states that modeling is not required for initial nonattainment 

determinations and EPA’s modeling guidance was not available in time for the Department to 

take these recommendations through its public process 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 will be recommended as nonattainment; and all 

other areas of the state will be recommended as unclassifiable. As the SO2 modeling guidance is 

released and finalized, the Department intends to conduct refined dispersion modeling of SO2

sources in accordance with EPA’s guidelines and provide additional technical justification as 

needed for recommended nonattainment area boundaries. 
Because all areas of the state are evaluated without modeling at this time, only those areas with 

violating monitors and areas immediately surrounding them are addressed in this document. For 

2007-2009, the four violating monitors are Troost in 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 (neighboring 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 nonattainment area. 

As stated in the preamble of EPA’s final SO2 rule, county lines are the presumptive boundaries 

for SO2 nonattainment areas. Therefore, county boundaries were the starting point for this 

analysis. The information contained in this document demonstrates why a smaller area (less than 

countywide) for nonattainment boundary recommendations is appropriate for all three counties 

containing monitors that do not meet the 1-hour SO2 NAAQS. 

EPA expects to issue final designations by June 2012. If the EPA intends to modify the state’s 

recommendations or needs additional technical justification to support the designation, they will 

notify the Department 120 days prior to finalizing the designations. For the SO2 standard, these 

“120-day” letters are expected to be released around February 2012. The Department will then 

be required to submit attainment state implementation 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 SO2 emission sources located in the recommended 

unclassifiable areas may contribute to violations of the 1-hour SO2 standard. These sources will 

be evaluated with refined modeling analyses when EPA provides official modeling guidance. 

Any sources located in unclassifiable areas later found to contribute to SO2 violations will be 

addressed in the Infrastructure SIP due June 2013. 

A summary of the implementation timeline for the 1-hour SO2 standard is below: 

June 2010 EPA establishes new primary 1-hour SO2 standard of 75 ppb 

June 2011 States must submit designation recommendations 

Feb 2012 EPA notifies states if they intend to modify recommendations (120-day letters) 

June 2012 EPA finalizes initial area designations 

June 2013 States must submit infrastructure SIPs for unclassifiable areas 

Feb 2014 States must submit attainment SIPs for nonattainment areas 

Aug 2017 Initial attainment date for all areas 

On February 17, 2011, a preview of EPA’s draft Boundary 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 regional emission reductions 

• Meteorology 
• Topography 

• Jurisdictional boundaries 

The Department developed this boundary recommendation 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 SO2 NAAQS. The recommended boundaries for the 1-

hour SO2 NAAQS nonattainment areas in Missouri include the following [please reference 

attached maps indicating recommendation for SO2 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 Mississippi River/Jefferson County line with the 

state of Illinois [see Figure 1]. 

Jackson County Nonattainment Area

 Jackson County: The portion of Jackson County bounded 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 Interstate-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 bounded 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 SO2 Nonattainment Area for Jefferson County, Missouri 
Figure 2. Recommended SO2 Nonattainment Area for Jackson County, Missouri 
Figure 3. Recommended SO2 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 SO2 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 

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iii 

Table of Contents 

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

1.0 INTRODUCTION .................................................................................................................................................1

2.0 METHOD OF DETERMINING ATTAINMENT STATUS AND BOUNDARIES ........................................2

3.0 MONITORING DATA .........................................................................................................................................4

4.0 EMISSIONS DATA...............................................................................................................................................7

4.1 EMISSIONS ...........................................................................................................................................................7

4.2 EMISSION CONTROLS.........................................................................................................................................13

4.3 REGIONAL EMISSION REDUCTIONS ....................................................................................................................13

4.4 GROWTH ............................................................................................................................................................15

5.0 METEOROLOGY...............................................................................................................................................16

5.1 BACK TRAJECTORIES .........................................................................................................................................16

6.0 TOPOGRAPHY...................................................................................................................................................17

7.0 JURISDICTIONAL BOUNDARIES .................................................................................................................17

8.0 RECOMMENDED NONATTAINMENT BOUNDARIES..............................................................................17

8.1 GREENE COUNTY...............................................................................................................................................18

8.2 JACKSON COUNTY .............................................................................................................................................21

8.3 JEFFERSON COUNTY ..........................................................................................................................................23

9.0 SUMMARY..........................................................................................................................................................25

APPENDIX 1 – SO2 EMISSION DATA....................................................................................................................1

APPENDIX 2 – WIND ROSES .................................................................................................................................1

APPENDIX 3 – BACK TRAJECTORIES ...............................................................................................................1
iv 

List of Figures 

FIGURE 1. MISSOURI SO2 MONITORING NETWORK, 2010...............................................................................5

FIGURE 2. THREE-YEAR AVERAGES FOR SO2 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
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1 

1.0 Introduction 

In June 2010, the U.S. Environmental Protection Agency (EPA) promulgated a revision to the 

National Ambient Air Quality Standard (NAAQS) for sulfur dioxide (SO2), which establishes “a 

new 1-hour SO2 standard at a level of 75 parts per billion (ppb), based on the 3-year average of 

the annual 99th 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 recommendation regarding the attainment status of all 

areas within that state. This recommendation is due 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 technical bases for the recommendations 

described in the 2010 1-Hour Sulfur Dioxide Boundary Recommendation. 

The primary source of SO2 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 SO2. The sulfur content of coal varies widely, from less than one 

percent to over three-and-one-half percent. The life span of gaseous SO2 is limited because it is 

quickly oxidized further into sulfate (SO4

2-). The sulfate binds to atmospheric ammonium 

(NH4

+

) to form ammonium sulfate, one of the major constituents of another criteria pollutantFine Particulate Matter (PM2.5). 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 standard, the EPA referred to studies that “infer a 

causal relationship between respiratory morbidity and short-term exposure to SO2.” On the basis 

of these studies, EPA dramatically reduced the averaging time of the standard in addition to 

lowering the level of the standard. 

EPA studies show that children, the elderly, and asthmatics are the most sensitive subpopulations 

to SO2 exposure. For these subpopulations, decreased lung function, increased respiratory 

symptoms, and more hospital admissions and emergency room visits all characterize their 

exposure to SO2. In particular, asthmatics exercising or playing while exposed to SO2 represent 

a high-risk group as they may experience bronchoconstriction, respiratory symptoms, and rapid 

swallow breathing in response to this exposure. In typical asthmatics, SO2 exposure enhances 

the effect of exercise, causing greater than usual increases in airway resistance and wheeze. This 

response occurs at concentrations only a fraction of those required to affect healthy people. 
2 

As mentioned previously, SO2 can also react with other compounds in the atmosphere to create 

small particles, collectively known as PM2.5. These particles can penetrate deeply into sensitive 

parts of the lungs and may cause or worsen respiratory 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 Boundaries 

The EPA has chosen to take a different approach to determine compliance with the 1-hour SO2

NAAQS. Unlike other criteria pollutants, SO2 is an almost exclusively point source emitted 

pollutant. A monitoring network large enough to adequately cover all large sources would be 

prohibitively expensive and an affordable network would leave large gaps in coverage. 

Therefore, EPA has decided to use a hybrid monitoring-modeling approach for SO2. This hybrid 

approach involves a modest monitoring network and extensive use of refined air dispersion 

modeling. 

• Nonattainment areas will be determined by either monitoring or modeling data which 

show a violation, or likely violation, of the standard. 

• Both monitoring and modeling are required to show attainment. 

• Areas without either monitoring or modeling data will be designated unclassifiable. 

Since the final SO2 rule states that modeling is not required for initial nonattainment 

determinations and EPA’s modeling guidance was not available in time for the Department to 

take these recommendations through its public process 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 will be recommended as nonattainment; and all 

other areas of the state will be recommended as unclassifiable. As the SO2 modeling guidance is 

released and finalized, the Department intends to conduct refined dispersion modeling of SO2

sources in accordance with EPA’s guidelines and provide additional technical justification as 

needed for recommended nonattainment area boundaries. 

Because all areas of the state are evaluated without modeling at this time, only those areas with 

violating monitors and areas immediately surrounding them are addressed in this document. For 

2007-2009, the four violating monitors are Troost in 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 (neighboring counties) 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 nonattainment area. 

As stated in the preamble of EPA’s final SO2 rule, county lines are the presumptive boundaries 

for SO2 nonattainment areas. Therefore, county boundaries were the starting point for this 

analysis. The information contained in this document demonstrates why a smaller area (less than 

countywide) for nonattainment boundary recommendations is appropriate for all three counties 

containing monitors that do not meet the 1-hour SO2 NAAQS. 
3 

EPA expects to issue final designations by June 2012. If the EPA intends to modify the state’s 

recommendations or needs additional technical justification to support the designation, they will 

notify the Department 120 days prior to finalizing the designations. For the SO2 standard, these 

“120-day” letters are expected to be released around February 2012. The Department will then 

be required to submit attainment state implementation 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 SO2 emission sources located in the recommended 

unclassifiable areas may contribute to violations of the 1-hour SO2 standard. These sources will 

be evaluated with refined modeling analyses when EPA provides official modeling guidance. 

Any sources contributing to SO2 violations will be addressed in the Infrastructure SIP due June 

2013. 

As outlined in the final SO2 rule, the Infrastructure State Implementation Plan (SIP) for the 1-

hour SO2 NAAQS will be similar to the conventional attainment SIP for nonattainment areas in 

that they must include emission inventories, enforceable emission limits, timetables for 

compliance, refined dispersion modeling demonstrating 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 to develop such an Infrastructure SIP as an 

enforceable tool to ensure all areas of the state, including unclassifiable areas, comply with 1-

hour SO2 NAAQS no later than August 2017. Missouri also expects the development and 

implementation of the Infrastructure SIP will eliminate the need to reclassify any additional areas 

as nonattainment, besides the initial boundary recommendations to be approved by EPA in June 

2012, prior to the August 2017 deadline to demonstrate attainment. 

On February 17, 2011, a preview of EPA’s draft Boundary 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 regional 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 violating monitors. 

There is a limit to the influence an emission source has on downwind SO2 concentrations. This 

limit is determined by several factors, the most important of which are the rate of SO2 emissions, 

the conversion rate from SO2 to SO4

2-, stack height, and wind speed. Maximum emission rates 

are determined by a facility’s construction or operating permit, or by the size of its boilers if 

there is no permit limit. Stack parameters, such as height, width, and exit gas temperature and 

velocity, can greatly affect SO2 concentrations. Higher stack heights, temperatures, and exit 

velocities all lead to increased dispersion and lower concentrations. Higher wind speeds have 

the effect of diluting SO2 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 emission source influences the SO2 concentration at 
4 

nearby locations. All these considerations are also taken into account when determining the 

recommended boundaries. 

3.0 Monitoring Data 

Sulfur dioxide was monitored at nine locations in Missouri 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 the new NAAQS, was temporarily discontinued 

in September 2010 with the approval of US EPA Region VII. Figure 1 shows the locations of 

these sites as well as the location of the Blair Street site in St. Louis, where SO2 monitoring 

began in January 2011. The final SO2 rule included minimum monitoring requirements that are 

currently met for St. Louis, Kansas City, and Springfield. However, to better characterize the 

spatial distribution of SO2 in the Kansas City area, the Department may add at least one 

additional site in the Kansas City area beginning in January 2013. Additional SO2 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 SO2 monitoring network, 2010 

Figure 2 and the embedded table show additional 1-hour SO2 design values, which are 

determined by the three-year average of 99th percentile of daily maximum one-hour SO2

concentrations. These design values were measured in recent years (2003-2010) at monitoring 
6 

sites in Missouri and are compared to the level of the 1-hour SO2 NAAQS, 75 ppb. The Main 

Street site in Herculaneum, the Troost site in Kansas City, and the industry-operated Wildwood 

Lane and James River South sites in Springfield consistently 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 SO2

level at the Main Street site is about four times the standard. The SO2 level at the Troost site is 

about twice the standard. The SO2 levels at the Springfield sites are slightly above the standard. 

For areas with multiple violating monitors, the monitor with the highest design value is assigned 

as that area’s official design value. For Springfield, 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 2nd quarter

* * Indus trial mo nito r SO2 Concentration (ppb)

Figure 2. Three-year averages for SO2 concentrations. 

Measurement results at the Springfield monitoring sites give some indication of the limited 

spatial extent of elevated SO2 concentrations. The Wildwood Lane and James River monitoring 

sites operated by City Utilities are 0.5 and 0.6 kilometers respectively from the James River 

Plant. These two sites have been fairly consistent in recent years in measuring SO2

concentrations above the level of the standard. The South Charleston monitoring site, 2.2 

kilometers north-northwest of the James River Plant, has measured SO2 concentrations near the 

standard, sometimes above and sometimes below. The more distant Missouri State University 

(MSU) monitoring site, located 10.6 kilometers north-northwest of the James River Plant, has 

consistently measured SO2 concentrations below the level of the standard. 
7 

In addition to Missouri monitoring sites, the state of Kansas operates one SO2 monitor in Kansas 

City, KS, at their JFK site. The JFK site’s 2007-2009 design value is 46 ppb. This site is located 

approximately five kilometers west of the Troost site. The state of Illinois operates three SO2

monitoring sites in the St. Louis metropolitan statistical area, including the South Roxana site 

with a 2007-2009 design value of 100 ppb. The South Roxana site is located approximately 70 

kilometers north-northeast of the Herculaneum, Main Street monitoring site. 

4.0 Emissions Data 

Although SO2 emission sources are distributed throughout the state, the most and largest sources 

are along the Mississippi and Missouri Rivers. These include both electric generating and 

industrial facilities. A list of all sources in the state with emissions greater than 10 tons per year 

(tpy) is in Appendix 1. 

The rate of SO2 emissions from a source is the single most important factor in the SO2

concentration surrounding the source. 

4.1 Emissions 

Greene County – City Utilities of Springfield operates two coal-fired power plants in Greene 

County: James River Plant to the south and Southwest Plant to the southwest. A second large 

coal-fired boiler at the Southwest Plant began operating in late 2010. Boiler 2 more than doubles 

the location’s production of electricity; however, SO2 emissions (as well as other emissions) 

from boiler 2 are well controlled. Boiler 2 utilizes flue gas desulfurization (FGD) technology to 

control SO2, a baghouse to control particulate matter (PM), and selective catalytic reduction to 

control nitrogen oxides (NOx), all with corresponding emission limits. The existing boiler 1 at 

Southwest Plant utilizes low sulfur coal to control SO2. Overall City Utilities’ SO2 emissions 

were down about 14% in 2009 compared to 2007 (see table below). This was due mainly to 

reductions in electricity demand during a mild summer. 

 

Minor SO2 sources are scattered throughout the city limits of Springfield, but are less than 10 

tpy. There are few sources in Greene County outside of Springfield city limits (see Figure 3). A 

list of all sources greater than or equal to 10 tpy is found in Appendix 1. 

SO2 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 SO2 sources in Jackson County are located along 

the Missouri River. Overall SO2 emissions were down about 35% from 2007. This was 

primarily due to scrubber controls installed at Kansas 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 scrubber. 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 Independence, 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. 

SO2 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 SO2 sources in Jefferson County are located along the Mississippi 

River. Overall SO2 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 Interstate 55 (see Figure 5). A list of all sources 

greater than or equal to 10 tpy is found in Appendix 1. 

SO2 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 SO2 is the use of low-sulfur bearing coal, mainly from the 

western U.S. Operating permits often include SO2 emission limits, often expressed in pounds 

(mass) SO2 per million British thermal units (mmBtu) - a measure 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 that 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 transportation costs to Missouri, while high sulfur 

coal is typically less expensive and often originates from nearby states. Many facilities mix coal 

from different sources to achieve their required emission limits at the lowest possible cost. 

The most common post-combustion control for SO2 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 gaseous SO2 is absorbed by the alkaline 

(lime/limestone) slurry. The sulfuric acid produced 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 both 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 are 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 restrictions

Significant regional emission reductions are envisioned in the proposed Transport Rule (75 FR 

45210, August 2, 2010). Its primary purpose is to reduce emissions of SO2 and NOx that 

contribute to PM2.5 and ozone. The Transport Rule applies to any stationary, 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 additional reductions scheduled for 2014 lowering 

nationwide NOx emissions by 52 percent from 2005 levels and SO2 emissions by 71 percent. To 

comply with the Transport Rule and other regulations, at least six Missouri units have already 

installed (prior to January 2011) FGD control devices. FGD control devices have been installed 

on two units at both the Ameren Missouri – Sioux Plant and Kansas City Power & Light – Iatan 

Plant, as well as one unit each at Kansas City Power & Light – Hawthorn Plant and City Utilities 

of Springfield – Southwest Plant. A final Transport rule is expected to be presented in summer 

2011. 

EPA is also currently in the process of promulgating three new Maximum Achievable Control 

Technology (MACT) regulations that could lead to direct SO2 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. Compliance is required for existing boilers in 

2014. One of the two boiler rules reduces emissions from existing and new industrial, 

commercial, and institutional boilers located at area source facilities. This Generally Available 

Control Technology (GACT) reduces a number of air pollutants including mainly mercury, 

metals, and dioxins. The second boiler rule reduces emissions from new and existing industrial, 

commercial and institutional boilers and process heaters 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, and organic toxins. The co-benefits of 

reducing mercury and other air pollutants from the Boiler GACT & MACT also lower SO2

emissions. 

The proposed Utility MACT (signed by the EPA Administrator on March 16, 2011) targets 

emissions of hazardous air pollutants (HAPs) [including 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 SO2, NOx, and/or particulate matter (PM) controls. The effectiveness of these 

controls depend on the characterization of coal or oil burned and the configuration of the power 

plant, as controls for SO2 serve as a co-benefit to reduce mercury. As proposed, once the final 

rule is issued, existing sources have up to four years 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 the 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 pollutants emitted from the regulated units, 

including sulfur dioxide and mercury emissions. 

Other federal regulations that restrict SO2 emissions include NSPS, 40 CFR 60 subpart D 

(Standards of Performance for Fossil-Fuel-Fired Steam Generators for Which Construction is 

Commenced after August 17, 1971), subpart Da (Standards of Performance for Electric Utility 

Steam Generating Units for Which Construction is Commenced after September 18, 1978), 

subpart Db (Standards of Performance for Industrial-Commercial-Institutional Steam Generating 

Units), and subpart Dc (Standards of Performance for Small Industrial-Commercial-Institutional 

Steam Generating Units). 

State Rules with sulfur and/or sulfur dioxide restrictions

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 SO2 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 Measure May be Required When Sources Are 

Clustered in a Small Land Area 
15 

This rule provides that more restrictive air quality control requirements may be prescribed for 

areas in which the sum of particulate matter and/or SO2 emissions from existing and proposed 

sources exceed specified limits. 

10 CSR 10-5.570, Control of Sulfur Emissions from Stationary Sources 

This rule limits SO2 emissions from industrial boilers in the St. Louis PM2.5 nonattainment area. 

By reducing SO2 emissions released into the atmosphere, emissions of PM2.5 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 PM2.5 violations. The 

rule applies to industrial, commercial, or institutional boilers or process heaters greater than 55 

mmBtu per hour with compliance beginning January 1, 2011. Breweries are limited to 3,050 

tons SO2 per year and other installations limited to 1.0 lb SO2/ mmBtu of actual heat input. 

10 CSR 10-6.060, Construction Permits Required 

This rule defines sources which are required to obtain 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 ambient air concentrations for Class I, II, and 

III areas, significant monitoring concentrations, and significant SO2 air quality impact levels. 

10 CSR 10-6.260, Restriction of Emission of Sulfur Compounds 

This rule establishes sulfur limits for indirect heating, 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 SO2/ mmBtu with additional limits to the various utility units. Indirect 

heating sources located in the St. Louis metropolitan area and greater than 2,000 mmBtu /hour 

may not exceed 2.3 lbs SO2/ mmBtu with one utility limit of 4.8 lbs SO2/ mmBtu. Sources in 

this area which are less than 2,000 mmBtu /hour must have an emission rate of 2.3 lbs SO2/ 

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. Lead smelters and refinery SO2 emissions are 

limited by a table outlined in the rule. An update to this table not yet incorporated into the rule is 

an EPA proposed consent decree for the Doe Run Herculaneum smelter which establishes a 

shutdown date of December 31, 2013. All other existing sources may not exceed SO2 limits of 

2,000 parts per million volume (ppmv) or 70 milligrams (mg) per cubic meter (m3

) of sulfuric 

acid or sulfur trioxide. All other new sources may not exceed 500 ppmv or 35 mg/m3. 

10 CSR 10-6.270, Acid Rain Source Permits Required 

This rule establishes certain general provisions and operating permit program requirements for 

affected sources and affected units under the federal Acid Rain Program (ARP). This program 

pertains to existing utility units serving generators with a nameplate capacity greater than 25 

megawatts and all new utility units. Missouri required affected units to participate in the EPA 

administered ARP cap and trade program. Phase I of the program reduced SO2 emissions by 

approximately 50 percent, and Phase II reductions by 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 nationwide SO2 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 directions: southeast and northwest. During the 

months from late spring to early fall, southeast winds 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 still a considerable southern component. Winds 

from the northeast are negligible throughout the year. There is some variation between the major 

metropolitan areas. The majority of winds have speeds 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 location and concentration of SO2 in ambient air. 

Areas located downwind of large sources will have higher concentrations than those located 

upwind. However, the changing direction of the wind 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 SO2 concentrations. Wind speed also plays a significant role in ambient SO2

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 southwest. 

St. Louis area, including Jefferson County – the greatest deviation from the statewide pattern is 

during the second quarter, when winds are almost equally distributed throughout the southeast to 

northwest (112.5 degrees to 315 degrees). 

Springfield area – the Springfield area is the closest to the statewide pattern of all the major 

metropolitan areas. The greatest deviation from this pattern is during the fourth quarter, when 

the single largest component remains from the southeast. 

5.1 Back Trajectories 

Back trajectories use a computer model called HYSPLIT (Hybrid Single Particle Lagrangian 

Integrated Trajectory) to determine the path a parcel of air travels during the previous twentyfour hours to arrive at the selected time and location. For this document, this information is used 

to help determine the sources that contribute to the 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 back trajectory maps are located in Appendix 3. 

Greene County – of the twelve trajectories, four each 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 from City Utilities of Springfield – 

Southwest Plant may influence the James River monitor occasionally; more often than not the 

winds are blowing the Southwest Plant’s emissions away 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 facility – 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 which have SO2 concentrations above the 

standard, the winds are overwhelming from the direction of the nearest source. This indicates 

that other large sources to the east are unlikely to contribute to the violating monitor. 

Jefferson County – of the twelve trajectories, eleven come to the monitor from the south, up the 

Mississippi River valley. The twelfth comes from the 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 the 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 Mountains, which are not tall enough to create large 

effects, but may lead to local channeling through small valleys. The remaining major features 

are the two great rivers, the Mississippi and Missouri, and their valleys. On a small scale, the 

two river valleys seem to have the effect of increasing the north-south or east-west wind 

direction. This effect may not affect the concentration at any one particular monitor, but may 

limit the number of sources that impact that monitor. 

7.0 Jurisdictional Boundaries 

Nonattainment boundaries are typically defined by easily definable features such as county, 

municipal, or township boundaries. Large, immovable features such as rivers or highways can 

also be used. The following considerations are taken into account when considering which 

features to use as boundaries: 

• contains a violating monitor 

• contains sources that likely contribute to a violating monitor 

• is easily recognizable by public 

8.0 Recommended Nonattainment Boundaries 

Due to the hybrid monitoring/modeling approach to SO2 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 monitoring 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 into this category. The remaining areas are only 

those that are determined to either contain or impact 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 surrounding area determined by the Department to 

likely contribute to that violation. As noted in the 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 SO2 NAAQS. The 

recommended nonattainment area includes the area bounded by U.S. 65 on the east, U.S. 60 on 

the north, U.S. 160 (South Campbell Ave) on the west, and the county line on the south (see 

Figure 7). The boundaries of the recommended nonattainment area include the two violating 

monitors and the City Utilities of Springfield - James River Plant. The fact that there is a third 

nearby site in Springfield that is well below the standard demonstrates the limited range of 

influence of the James River Plant emissions. As seen in Figure 6, there is a linear relationship 

between the SO2 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 Springfield – Southwest Plant began operating a new 

coal-fired boiler that utilizes significant emission controls including FGD technology to control 

SO2, a baghouse to control particulate matter and selective catalytic reduction to control NOx, all 

with corresponding emission limits. The existing boiler 1 at Southwest Plant utilizes low Sulfur 

coal to control SO2. Since the Southwest Plant has roughly the same total emissions, it should 

have a similarly small radius of SO2 impact (similar to the James River Plant). The Southwest 

Plant is approximately 13 km from the James River monitor. At that distance, its impact on the 

James River monitor is negligible based on the conducted 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 SO2 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 nonattainment 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 exceedance days from the northwest indicates that the 

sources in eastern Jackson County are unlikely to impact the Troost monitor. The rapid 

conversion of SO2 to SO4

2

- and the presence of a non-violating monitor in Wyandotte County, 

KS, indicate that the SO2 contributions from the two Public Utility power plants, Nearman and 

Quindaro, likely do not have a significant impact on the violating Troost monitor. As mentioned 

in Section 4.1, the KCP&L - Hawthorn Plant has a scrubber installed which provides 80% 

control of SO2 emissions. This fact, in combination with the back 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 Troost monitor. Interstate 435 was selected as 

the eastern border for the same reasons: it is an easily 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 SO2 to SO4

2- and the back 

trajectories on the highest exceedance days, the Department 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 SO2 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 SO2 NAAQS. The recommended 

nonattainment area includes both Herculaneum and Festus 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 area 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 trajectories all indicate that emissions from these plants 

are transported north along the Mississippi River valley. That fact, combined with the lack of 

sources in the western portion of the county, indicate that the remainder of the county does not 

contribute to the violation at the Main Street monitor and justify the exclusion of the remainder 

of the county. Townships were selected for the boundaries 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 establish an appropriate western boundary. The 

Ameren Missouri – Meramec Plant in southern St. Louis County was determined to not 

contribute to the violation at the Main Street monitor because of its location to the north of the 

monitor and the fact that the back trajectories indicate 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, Jackson, and Jefferson counties, for designation 

as nonattainment for the 2010 1-Hour SO2 NAAQS. The recommended nonattainment area 

boundaries were selected based on fixed, easily recognizable features and include the violating 

monitor(s) and those nearby sources determined to likely impact the violating monitor. 
1 

Appendix 1 – SO2 Emission Data (from 2009 Missouri Emission Inventory System)

County Plant 

# 

Parent Company (* - non electric generating unit)

Site Name 2

S

E(t

Franklin 0003 AMEREN MISSOURI LABADIE PLANT St. Charles 0001 AMEREN MISSOURI SIOUX PLANT Jefferson 0016 AMEREN MISSOURI RUSH ISLAND PLANT Jefferson 0003 *DOE RUN COMPANY HERCULANEUM SMELTER St. Louis 0010 AMEREN MISSOURI MERAMEC PLANT Randolph 0001 THOMAS HILL ENERGY CENTER THOMAS HILL 

New Madrid 0004 NEW MADRID POWER PLANT MARSTON 

Henry 0001 KANSAS CITY POWER & LIGHT CO MONTROSE STATION Jackson 0031 KANSAS CITY POWER & LIGHT CO SIBLEY STATION Jasper 0001 EMPIRE DISTRICT ELECTRIC CO ASBURY PLANT Boone 0004 UNIVERSITY OF MISSOURI POWER PLANT Jackson 0021 *VEOLIA ENERGY GRAND AVENUE STATION Jackson 0050 INDEPENDENCE POWER AND LIGHT BLUE VALLEY STATION Scott 0017 SIKESTON POWER STATION SIKESTON POWER STATION St. Louis City 0003 *ANHEUSER-BUSCH INC ST. LOUIS Pike 0002 *ASHLAND INC MISSOURI CHEMICAL WORKS Ste. Genevieve 

0001 *MISSISSIPPI LIME COMPANY STE. GENEVIEVE 

Greene 0005 CITY UTILITIES OF SPRINGFIELD JAMES RIVER POWER PLANT Greene 0039 CITY UTILITIES OF SPRINGFIELD SOUTHWEST POWER PLANT 

New Madrid 0008 *NORANDA ALUMINUM INC NEW MADRID 

Osage 0002 CENTRAL ELECTRIC POWER 

COOPERATIVE 

CHAMOIS PLANT 

Iron 0009 *DOE RUN COMPANY BUICK SMELTER Buchanan 0004 KANSAS CITY POWER & LIGHT CO LAKE ROAD PLANT 
2 

Marion 0001 *BASF CORPORATION HANNIBAL PLANT Jackson 0022 KANSAS CITY POWER & LIGHT CO HAWTHORN STATION Platte 0007 KANSAS CITY POWER & LIGHT CO IATAN GENERATING STATION Pike 0001 *HOLCIM (US) INC CLARKSVILLE Saline 0010 MARSHALL MUNICIPAL UTILITIES MARSHALL MUNICIPAL 

UTILITIES 

Jefferson 0002 *RIVER CEMENT CO. DBA BUZZI 

UNICEM USA 

SELMA PLANT 

Clay 0096 INDEPENDENCE POWER AND LIGHT MISSOURI CITY STATION Boone 0002 CITY OF COLUMBIA MUNICIPAL POWER PLANT Phelps 0006 MISSOURI UNIV. OF SCIENCE AND 

TECHNOLOGY 

POWER PLANT 

Cape Girardeau 

0010 SOUTHEAST MISSOURI STATE 

UNIVERSITY 

POWER PLANT 

St. Charles 0076 *GENERAL MOTORS LLC WENTZVILLE CENTER Montgomery 0008 *CHRISTY MINERALS, LLC HIGH HILL Jefferson 0068 *SAINT-GOBAIN CONTAINERS INC PEVELY Jackson 0030 *LAFARGE NORTH AMERICA INC SUGAR CREEK PLANT Pettis 0009 *PITTSBURGH-CORNING CORP SEDALIA St. Louis City 0017 *MALLINCKRODT INC N SECOND Holt 0001 *EXIDE TECHNOLOGIES CANON HOLLOW Ralls 0001 *CONTINENTAL CEMENT COMPANY 

LLC 

ILASCO PLANT 

Ste. Genevieve 

0035 *CHEMICAL LIME COMPANY STE. GENEVIEVE 

Jasper 0094 *TAMKO BUILDING PRODUCTS INC RANGELINE PLANT Jackson 0017 *FOLGERS COFFEE CO BROADWAY Ste. Genevieve 

0044 *HOLCIM (US) INC STE. GENEVIEVE PLANT 

Callaway 0001 *HARBISON-WALKER REFRACTORIES WESTMINSTER AVE Cape Girardeau 

0060 *Q. C. CORPORATION Q. C. CORPORATION 
3 

Pulaski 0004 *FT LEONARD WOOD INSTALLATION MANAGEMENT Cape Girardeau 

0021 *BUZZI UNICEM USA CAPE GIRARDEAU 

Perry 0020 *ATLAS EPS PERRYVILLE St. Louis 1521 *PACE CONSTRUCTION CO FLORISSANT Clay 0002 *NATIONAL STARCH LLC NORTH KANSAS CITY St. Francois 0017 *FLAT RIVER GLASS CO PARK HILLS Barry 0021 *SCHREIBER FOODS INC SCHREIBER FOODS INC - 

MONETT 

Maries 0001 *KINGSFORD MANUFACTURING CO BRIQUETTING PLANT 
1 

Appendix 2 – Wind Roses 
2 
3 
1 

Appendix 3 – Back Trajectories 

 Greene County, MO area 
2 

 Greene County, MO area
3 

 Greene County, MO area
4 

 Jackson County, MO area 
5 

 Jackson County, MO area 
6 

Jackson County, MO area 
7 

 Jefferson County, MO area 
8 

 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. ofMo. For 2000 as amended for ___1....:.t_im_e__ as follows: 

1st insertion, No. --,-__ __2_9_th__day of___M~a_rc_h__....:._: 11 


2nd insertion, No. __~_,;....'____day of______--.;.-', 


3rd insertion, No. _________day of ,20____ 


4th .•InSertIOn, No. day 0 f , 20____ 


5th insertion, No. _________day of ,20____ 


Fee: $228.50 
 ~/.I~ 30th Subscribed and sworn to before me this 

March 20 11 dayof ________________, __~------

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 Prog~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 
--

I 

· 

([ I'I.~ H l~ITo N 

SERVICES 

COURT REPORTING 


& VIDEO 


N

= 


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.com 
TRANSCRIPT OF PROCEEDINGS 4/28/2011 

Page 1 

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7 STATE OF MISSOURI DEPARTMENT OF NATURAL 


8 MISSOURI AIR CONSERVATION COMMISSION 


9 PUBLIC HEARING 


10 

TRANSCRIPT OF PROCEEDINGS 

11 

April 28, 2011 

12 

Springfield, MO 

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14 

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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 


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TRANSCRIPT OF PROCEEDINGS 4/28/2011 

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: 314.644.1334 

TRANSCRIPT 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: 314.644.1334 
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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: 314.644.1334 

COMMENTS 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 ofthis standard started a time clock with a deadline of 

June 20 II for the Governor ofthe State ofMissouri to submit a recommendation to EPA 

as to which areas ofthe state should be designated as nonattainment for the new S02 

standard. Portions ofGreene, 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 ofNatural 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 ofNatural Resources' Air Pollution Control Program 

recommends the commission adopt the boundary recommendation as proposed. Ifthe 

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. 

107