Missouri Department of Natural Resources’ 

Air Pollution Control Program

Technical Supplement to the Missouri Regional Haze

State Implementation Plan

1

Missouri Department of Natural Resources’ 

Air Pollution Control Program

January 30, 2012
1

Table of Contents

Chapter 1 – Four Factor Analysis and Reasonable Progress Goal....2

Section 1.1 Reasonably Available Control Technology (RACT).............................................................2

Section 1.2 Missouri DNR’s Permitting Process......................................................................................5

Table 1. Missouri Facilities with 2002 Emissions of NOX, SO2, and/or PM10 Exceeding 50 Tons......8

Table 2. Refined List of Missouri Facilities with 2002 Emissions of NOX Exceeding 50 Tons ........11

Table 3. Refined List of Missouri Facilities with 2002 Emissions of SO2 Exceeding 50 Tons..........12

Table 4. Refined List of Missouri Facilities with 2002 Emissions of PM10 Exceeding 50 Tons........13

Table 5. Sum of 2002 Missouri point source emissions from sources that are non-EGU, non-BART 

screened, and located outside the St. Louis PM2.5 nonattainment area ...............................................16

Table 6. 2002 Summary of Missouri Point, Area, On-Road Mobile, and Off-Road Mobile Source 

Emissions............................................................................................................................................16

Section 1.3 Q/D Analysis for Refined List of Sources...........................................................................16

Table 7. Q/D Analysis for Refined List of Missouri Sources.............................................................17

Table 8. Refined List of Sources with Q/D Value Greater than 10 ....................................................19

Chapter 2 – Best Available Retrofit Technology ...............................20

Section 2.1 Sources Exempt by Date or Potential to Emit......................................................................20

Section 2.2 Additional BART Evaluation...............................................................................................21

Table 9. Facilities Requiring Further Review for BART....................................................................21

Table 10. Q/D Analysis - Total Emissions over Distance .................................................................22

Table 11. Screening Modeling Impacts with Individual Species Contributions.................................22

Section 2.3 Modeling Analysis for Doe Run-Buick ...............................................................................24

Table 12. Screening Modeling for Doe Run Buick.............................................................................24

Table 13. Refined Modeling Analysis for Doe Run Buick.................................................................24

Chapter 3 – Natural Conditions on Best 20% Visibility Days .........25

Table 14. EPA Default Natural Visibility Conditions at Missouri’s Federal Class I Areas ...............25
2

Chapter 1 – Four Factor Analysis and Reasonable Progress Goal

When Missouri began developing its control strategy and Reasonable Progress Goal to meet the 

requirements necessary for the Regional Haze SIP, four factors were used to select sources to 

evaluate and what control strategies to analyze. These four factors include the cost of 

compliance, the time necessary for compliance, the energy and non-air quality environmental 

impacts of compliance, and the remaining useful life of existing sources that contribute to 

visibility impairment. These four factors were applied in determining control strategy options 

for all source categories including point sources, area sources, on-road mobile sources, and offroad mobile sources. In addition to these four factors, as described in our Long Term Strategy to 

meet our Reasonable Progress Goals, all other Clean Air Act related programs were evaluated to 

determine what effect these other programs have had or will have on existing and future sources, 

and if any other control strategies would be reasonable in terms of the four factors described 

above. For most sources, Clean Air Act Programs such as PSD permitting, NSPS standards, 

MACT standards, on-road and off-road engine standards, federal emission trading programs, fuel 

standards, and various state rules were deemed to be reasonable, and for these sources no other 

reasonable measures were deemed appropriate based on the four factors.

The Air Program has already stated its commitment to continue analyzing this Regional Haze 

SIP to address any deficiencies discovered. In addition, if other reasonable control strategies are 

identified for sources that contribute to visibility impairment, beyond those implemented through 

this plan, the Air Program would incorporate such strategies into future SIP revisions along with 

the five-year progress reports that have been committed to in this Plan.

Section 1.1 Reasonably Available Control Technology (RACT)

The St. Louis PM2.5 nonattainment area includes the counties of Franklin, Jefferson, St. Charles, 

St. Louis, and the City of St. Louis. As required by the Clean Air Act, in addition to the 

development of an attainment demonstration, the PM2.5 implementation rule required states to 

consider for point sources that emit PM2.5 all RACT and Reasonably Achievable Control 

Measures (RACM). All non-EGU SO2 and NOX sources with actual emissions exceeding 25 

tons per year were identified in the St. Louis PM2.5 nonattainment area. These included large 

boilers, stationary internal combustion engines, two glass melting furnaces, a biosolids 

incinerator, a cement kiln and a lead smelter. \ The implementation of RACT and RACM in 

these St. Louis area counties have been identified as reasonable measures that can be 

implemented and use the same four factors for analysis, including: taking into account cost, 

timing, energy and environmental impacts and the remaining useful life of equipment.

The determinations for the St. Louis Annual PM2.5 RACT resulted in a number of regulatory

actions. These determinations were based on a technical review of materials provided by

facilities that met certain emission criteria and were asked to participate in the RACT stakeholder 

process. The technical review materials contained at least two of the four-factor analysis in 

determining control options. Most facilities included cost of compliance, time necessary for 

compliance, energy and non-air quality environmental impact of compliance, and remaining 

useful life of potentially affected sources in their reviews. Excluding the electric generating 

units that are already subject to a federal emissions trading program for NOX and SO2, the 
3

facilities in the RACT process represented the largest, base-year emitters of NOx and SO2

located in the nonattainment area.

The Department’s Air Program sent a letter to EPA Region VII and the identified facilities 

inviting them to attend an informational meeting on August 23, 2007. This kick-off meeting 

allowed the Air Program to provide background information to the group, which included a 

discussion of the RACT evaluation process. Following these meetings, the Air Program sent a 

questionnaire to each facility that was designed to allow a better understanding of the emission 

processes along with an opportunity to provide control and cost feasibility for each potential 

control technology. A second meeting was held to answer questions about the questionnaire on 

November 16, 2007. After facilities submitted the responses and these were review by staff, the 

Air Program scheduled meetings with each facility to discuss their responses and provide 

preliminary RACT findings. These discussions led to the following conclusions regarding 

RACT:

NOx

With respect to oxides of nitrogen (NOx), the materials provided by the facilities clearly 

indicated that the construction of control equipment was not reasonable based on the expense. 

The annualized cost estimates ranged from approximately $4,200 per ton for a Selective 

Catalytic Reduction process installed on the exhaust of the natural gas-fired internal combustion 

engines at the Laclede Gas Building to $33,000 per ton for a similar technology applied to the 

landfill gas-fired boilers at Chrysler. The RACT findings for NOx are identical to those for the 

previous 8-hour ozone RACT findings for sources that were evaluated for both ozone and PM. 

Some additional sources were included in the PM RACT evaluations based on the lower 

emissions threshold chosen by the Air Program when compared to the threshold selected for the 

ozone RACT determinations.

During the PM RACT/RACM evaluation, several facilities indicated that they had reduced NOx 

and/or SO2 emissions or were planning changes at their facilities that would result in emission 

reductions. Coal-fired boilers at Washington University and Boeing have both been replaced 

with natural gas-fired boilers. New New Source Review (NSR) construction permits would be 

required to switch back to coal-fired boilers for these facilities.

The St. Louis Metropolitan Sewer District’s Coldwater Creek Wastewater Treatment Plant 

originally proposed to remove several internal combustion engines and replace them with electric 

engines. However, due to the final costs of compliance, the facility could not conduct the 

replacement and provided additional cost information that led to the Air Program’s finding that 

no additional control would be necessary at this facility. MEMC has committed to continuing to 

operate their scrubbers for the control of NOx from their acid bath process. A permanent and 

enforceable consent agreement with this company was signed on July 2, 2009, to mandate the 

continued use of this scrubbing system. This scrubbing system at MEMC was the only source to 

require a “new” enforceable mechanism for NOx RACT. 

SO2

The non-utility sulfur dioxide sources were divided into three (3) groups. The first group was

those sources that have clearly demonstrated that SO2 controls were not feasible because of cost. 
4

The second group was just the Doe Run Herculaneum facility, and the third group was made up 

of the industrial boilers. For SO2 sources, there were no previous RACT evaluations in the St. 

Louis area, and these determinations resulted inconsiderable additional emission controls for the 

area. 

The first group includes St. Gobain Containers, River Cement and the St. Louis Metropolitan 

Sewer District. These sources have provided annualized cost estimates for control technology

that range from approximately $10,000 to $23,000 per ton, demonstrating that additional or new 

SO2 controls for these facilities were not cost effective.

The second group was made up of the single largest non-utility source of SO2 in the St. Louis 

nonattainment area. 10 CSR 10-6.260, Restriction of Emission of Sulfur Compounds, currently 

limits SO2 emissions from the Doe Run Herculaneum facility to 20,000 pounds per hour. This 

facility operates an acid plant that converts strong acid gases from the front end of their sintering 

process into sulfuric acid, but the overall efficiency of the conversion is relatively poor. Even 

with the acid plant in operation, base year emissions utilized in the attainment demonstration 

were 44,300 tons per year for Doe Run’s facility. Based on Doe Run’s high emissions the 

operation of an SO2 scrubbing system would be cost effective on a per ton basis. However, the 

overall capital costs of installing and maintain a scrubbing system for the various gas streams at 

this facility would be considerable. In an effort to significantly reduce emissions from the plant 

and allow for continued operation of the facility, 10 CSR 10-6.260 was amended to establish a 

tiered approach which set an emission limit of twenty-five thousand one hundred (25,100) tons 

SO2 per year in 2012 as RACT. The emission limit will be reduced to sixteen thousand threehundred-fifty (16,350) tons SO2 per year in 2014, and zero (0) tons SO2 per year in 2017. Doe 

Run is currently considering an alternative process to replace the primary lead smelting operation 

at Herculaneum. This new process would completely eliminate SO2 emissions. Following the 

completion of RACT process, a federal consent decree was signed by Doe Run that contains an 

even more aggressive timeline for shut down of the current smelter than the State’s rule, which 

will eliminate SO2 emissions even sooner.

Industrial boilers in the St. Louis nonattainment area make up the third group. After a review of 

the literature, regulations in neighboring states, and a close review of the materials provided by 

the stakeholders, a new regulation that limits the large industrial boilers to 1.0 pounds of SO2 per 

million British Thermal Units (MMBTU) on a thirty-day (30) rolling average was adopted. This 

new regulation 10 CSR 10-5.570, Control of Sulfur Emissions From Stationary Boilers, was 

designed to limit emissions from all non-utility boilers greater than 50 MMBTU/hr that burn 

non-gaseous fuels. There were five total facilities that have boilers subject to this regulation: 

Chrysler, General Motors, Trigen, Mallinckrodt, and Anheuser Busch. Three of the five 

facilities can meet the new limit based on current operation and fuel mix (Chrysler, GM, and 

Trigen). One of the other facilities will also be able to meet the new limit using the averaging 

provisions of the regulation without installation of add-on control equipment for SO2

(Mallinckrodt).

The last facility was more closely evaluated due to its emission rate when compared to the other 

facilities in the group. Anheuser Busch emitted over six thousand tons of SO2 in 2002 due to the 

use of Midwestern medium to high-sulfur coal (2%-3.5% sulfur) at several non-utility boilers. 
5

The sulfur content, even with lower sulfur content fuels used by Anheuser Busch, translates to an 

overall average of 3.5 lb SO2/MMBTU for the whole facility. Anheuser Busch considered a 

variety of emission reduction options such as wet or dry scrubbers. Anheuser Busch also noted

some technical feasibility issues with the installation of wet scrubbing equipment including space 

constraints at the brewery power house, structural/safety concerns, and vendors for this type of 

technology would not quote for the existing boiler configuration at Anheuser Busch. The 

company also provided a cost estimate for the installation of dry scrubbers (~90% control) on all 

four coal-fired boilers of $3,000 per ton reduced. However, the initial capital cost for the 

installation of the dry scrubbing equipment would be nearly $80 million. Anheuser Busch 

claimed that capital cost, along with the existing space constraints at the power house, precluded

the installation of this technology. 

Anheuser Busch’s suggested RACT approach was a proposed 40% reduction in emissions, 

relying on fuel switching at a cost of nearly $2,000 per ton reduced. This would result in a 

sizable reduction of SO2 from this facility, at an annualized cost of approximately $20 million. 

Based on current fuel costs, the 40% percent proposal from Anheuser Busch cost nearly $6 

million per year in additional expenditure. The Department’s Air Program evaluated this 

proposal and asked that Anheuser Busch provide additional information regarding the 

methodology used to derive the fuel costs. This additional data allowed the Department’s Air 

Program to optimize the fuel mix vs. cost using additional types of coal available for use as fuel. 

This optimization led to an initial proposed regulation that limited SO2 emissions to 370 lb/1000 

barrels produced. During the regulatory process, this limit was later changed to a cap of 3,050 

tons per year. Based on current production projections, if no controls had been required, the 

facility was projected to emit over 7,200 tons per year SO2 in 2012. This nearly 60 percent 

reduction in SO2 emissions with a cost of slightly over $6 million in increased fuel expenditure 

(~$1,400/ton) was determined to be RACT for this facility.

This summary of the PM2.5 RACT process for the St. Louis area shows that all reasonably 

available control technology and reasonably available control measures have been implemented 

for large sources of NOX and SO2 in the St. Louis PM2.5 nonattainment area, and that these 

measures took into account and considered the four factors required for developing control 

strategies under a Regional Haze State Implementation Plan.

Section 1.2 Missouri DNR’s Permitting Process

In accordance with the Clean Air Act, Missouri has a long-standing and fully implemented 

construction permitting program for new major sources and significant modifications of existing 

sources. In a nonattainment area, the construction permitting program is referred to as a New 

Source Review (NSR) permitting program. In Missouri NSR permitting occurs in the St. Louis 

Nonattainment Area. The construction permitting program in an attainment area is referred to as 

a Prevention of Significant Deterioration (PSD) permitting program. The remainder of the state 

is under the PSD program. One of the major components of the PSD program is the 

implementation of Best Available Control Technology (BACT) on new major sources or 

significant modification of existing major sources. Missouri has been delegated full authority to 

implement the PSD program by the EPA.
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When Missouri performs a BACT analyses for new sources, the state takes into account the same 

four factors that are required for developing control strategies under a Regional Haze State 

Implementation Plan. In nearly all cases a BACT analysis would require more stringent controls 

than a RACT or RACM analysis. As all new stationary emission sources are required to obtain a 

construction permit prior to commencing construction, the state’s construction permit rule 

ensures that no significant degradation to visibility in Federal Class I areas will occur as a result 

of new sources coming online. If a construction permit application models that degradation 

would occur to the visibility in a Class I area, then control requirements would be added to the 

construction permit prior to its issuance. It is these control measures that ensure via modeling 

that no degradation will occur.

For existing sources, the state has existing rules from previous SIP requirements that cover broad 

emission sources including but not limited to charcoal kilns, cement kilns, large stationary IC 

engines, smaller boilers, and other non-EGU categories. In an effort to determine if additional 

control requirements would be necessary for any existing point sources using the 4-factor 

analysis, the state performed the following exercise: First, the Air Program developed a list of 

point sources with actual emissions of 50 tons or more of one or more of the following air 

pollutants of concern: NOX, SO2, or PM10. Fifty tons was selected to screen out less emitting

sources that would not have a significant impact on visibility in federal Class I areas. Therefore it 

would be unlikely that any cost effective controls that could be implemented on these less 

emitting sources would result in any measureable improvement in visibility to Missouri’s federal 

Class 1 areas. Second, the Air Program removed all facilities from the list that had already

undergone a refined modeling BART analysis. Next, all facilities located in the St. Louis PM2.5

nonattainment area were removed because sources in these counties had recently been subject to 

a RACT/RACM analysis. Then three separate tables were created, one for each pollutant of 

concern, and sources still remaining were listed on each table if their actual emissions were 50 or 

more tons for that particular pollutant in 2002. Finally, each source’s operating permit was 

reviewed to determine the requirements that each facility was subject to that would offer control 

for the pollutant of concern in each table.

Table 1 lists every source in the state with 2002 actual emissions exceeding 50 tons for NOX, 

SO2, or PM10. The table also lists the 2002 actual emissions for each of these pollutants. This 

data was pulled from Appendix H of Missouri’s Regional Haze Plan. Tables 2, 3, and 4 give the 

refined lists of facilities with 2002 actual emissions of 50 tons or more for NOX, SO2, and PM10, 

respectively. These three tables also include a list of applicable rules and control requirements 

that help control the emissions of the pollutant of concern. Because 2002 emissions were used in 

the original Regional Haze Plan, those numbers were used in this evaluation to maintain 

continuity. It is important to note that some of the rules and control requirements listed in Tables 

2, 3, and 4 may have become effective after the 2002 emissions were reported. Therefore, more 

recent actual emissions may already have been reduced from the 2002 values due to the 

implementation of the measures listed.

As shown by these three tables, the State’s construction permit rule, 10 CSR 10-6.060, requires 

that all applicable state regulations, consent agreements, federal MACT rules, federal NSPS 

rules, and any control or emission rate requirements are incorporated into each facility’s

operating permit. The operating permit provides each facility every regulation and emission 
7

requirement that is applicable to the source. As Tables 2, 3, and 4 demonstrate, the State’s 

construction permit rule has ensured for decades that new stationary point sources or units added 

to previously existing stationary point sources that have come online in the state would not 

degrade visibility in Class I areas or significantly impact air quality in any area of the state, 

otherwise controls would have been required to minimize such impact before a construction 

permit would have been issued. This is shown by the control requirements listed in the Tables.
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Table 1. Missouri Facilities with 2002 Emissions of NOX, SO2, and/or PM10 Exceeding 50 Tons

CountyPlant ID Facility Name SIC 2002 NOX

Emissions

2002 SO2

Emissions

2002 PM10

Emissions

043-0002 CLEVER STONE COMPANY INC-CLEVER 1422 0 0 53.9

027-0048 CHILES WORKS LLC-FULTON 3295 0 0 54.9

186-0022 TOWER ROCK STONE CO-STE. GENEVIEVE 1422 0 0 64.2

189-0017 FRED WEBER INC-NORTH STONE 2951 0 0 88.1

510-0156 AMERICAN COMMERCIAL TERMINALS-AMERI 1221 0 0 219.7

510-0072 FEDERAL-MOGUL FRICTION PRODUCTS-FED 3321 2.5 0.3 55.4

021-0060 AG PROCESSING INC-ST. JOSEPH - LOWE 2075 4 0 60.3

087-0001 EXIDE TECHNOLOGIES-CANON HOLLOW 3341 6.3 323.5 16

091-0014 PEACE VALLEY CHARCOAL INC-PEACE VAL 2861 7.2 0 87.5

161-0003 MISSOURI HARDWOOD CHARCOAL-ROLLA PL 2861 7.3 0 88.8

213-0002 HORNER CHARCOAL CO INC-HORNER CHARC 2861 9.1 0 113.1

215-0045 H & K CHARCOAL-H & K CHARCOAL 2861 11.2 0 120.5

117-0007 GLEN GERY CORPORATION-GLEN GERY COR 3251 12.5 84.7 36.1

047-0132 AMERICAN ITALIAN PASTA COMPANY-AMER 2098 14 0.1 68.6

077-0001 MISSISSIPPI LIME CO-MISSISSIPPI LIM 3274 15.8 1 52.7

510-0040 WASHINGTON UNIV MEDICAL SCHOOL-BOIL 8062 15.8 50.7 116.6

215-0003 THOMASON CHARCOAL COMPANY-THOMASON 2861 19.5 0 235.8

213-0048 COLLEGE OF THE OZARKS-BRANSON 8221 20.1 128.9 10.3

037-0007 LIMPUS QUARRIES INC-HARRISONVILLE 1422 21.1 1.4 64.6

099-0003 DOE RUN COMPANY-HERCULANEUM SMELTER 3339 21.4 15,223.80 86.6

510-0118 ALUMAX FOILS INC-ALCOA FOIL PRODUCT 3497 27.9 1.3 61.9

065-0038 ROYAL OAK ENTERPRISES INC-SALEM BRI 2861 34.4 1.7 57.3

077-0004 CARLISLE POWER TRANSMISSION PRODUCT 3052 37 156.6 11.9

031-0010 SOUTHEAST MISSOURI STATE UNIVERSITY 8221 41.7 284.7 3.2

047-0002 NATIONAL STARCH & CHEMICAL CO-NATIO 2046 43 105 141.1

047-0002 NATIONAL STARCH & CHEMICAL CO-NATIO 2046 43 105 141.1

143-0008 NORANDA ALUMINUM INC-NORANDA ALUMIN 3334 45.3 5,279.50 608.1

183-0027 MEMC ELECTRONIC MATERIALS INC-ST. P 3677 50.1 0.1 48.4

203-0006 CRAIG INDUSTRIES INC-SUMMERSVILLE P 2861 50.4 0 630

097-0094 TAMKO ROOFING PRODUCTS INC-RANGELIN 2952 50.4 69.4 15.2

023-0050 POPLAR BLUFF MUNICIPAL UTILITIES-GE 4911 51.6 1.9 2.1

189-0217 METROPOLITAN ST. LOUIS SEWER DISTRI 4952 52.4 2.1 4.4

161-0006 UNIVERSITY OF MO - ROLLA-ROLLA POWE 8221 54.4 501 13.2

093-0009 DOE RUN COMPANY-BUICK SMELTER 3339 56.7 4,185.20 52.9

035-0004 ROYAL OAK ENTERPRISES-ELLSINORE DIV 2861 58.6 0 717.5

510-1407 SOUTHERN METAL PROCESSING-SOUTHERN 3433 60 7.6 0.1
9

CountyPlant ID Facility Name SIC 2002 NOX

Emissions

2002 SO2

Emissions

2002 PM10

Emissions

145-0049 SOUTHERN STAR CENTRAL GAS PIPELINE- 4922 61.5 0 0.8

009-0005 HYDRO ALUMINUM WELLS-MONETT 3351 62.8 0.2 6.6

097-0005 PCS PHOSPHATE COMPANY INC-JOPLIN PL 2874 63.8 34.5 51.3

063-0009 MAGELLAN PIPELINE COMPANY LLC-OSBOR 4613 65.6 0.5 2.6

037-0056 ARIES POWER PLANT-PLEASANT HILL 4911 66.5 2.3 15

113-0029 TOYOTA MOTOR CORPORATE SERVICES-BOD 3365 68 8.5 54.3

069-0066 ASSOCIATED ELECTRIC COOPERATIVE INC 4911 70.6 1.3 8.8

510-0053 METROPOLITAN ST. LOUIS SEWER DISTRI 9511 78.3 25.4 42.4

189-1210 METROPOLITAN ST. LOUIS SEWER DISTRI 4952 78.4 3.2 0.5

027-0001 HARBISON-WALKER REFRACTORIES-HARBIS 3255 79.5 190.2 27.5

189-1205 METROPOLITAN ST. LOUIS SEWER DISTRI 4952 88.2 1.8 0.3

095-0023 KANSAS CITY POWER & LIGHT CO-NORTHE 4911 92.3 29.4 1.3

139-0008 CHRISTY MINERALS CO-HIGH HILL 3295 94.1 225.4 70.1

169-0004 MANSCEN AND FORT LEONARD WOOD-MANSC 9711 94.4 3.5 29.4

047-0019 FORD MOTOR CO-KANSAS CITY ASSEMBLY 3711 96.2 5.8 82.9

091-0038 GARNETT WOOD PRODUCTS-CHARCOAL PLAN 2861 97.4 0 72.9

081-0010 MAGELLAN PIPELINE COMPANY LLC-RIDGE 4613 102.2 0.8 4

189-0231 CHRYSLER CORP-NORTH PLANT 3711 104.8 0.6 7.1

097-0110 CARTHAGE WATER & ELECTRIC-CARTHAGE 4911 110.4 1.4 1.7

023-0042 CENTERPOINT ENERGY-POPLAR BLUFF COM 4922 113.1 0 0.9

031-0053 PROCTER & GAMBLE PAPER PRODUCTS CO- 2676 128.6 0.8 72

510-0017 MALLINCKRODT INC.-MALLINCKRODT INC. 2869 135.7 283.2 23.4

189-0230 MCDONNELL DOUGLAS CORP./BOEING COMP 3721 142.8 138.7 28.7

125-0001 KINGSFORD MANUFACTURING CO-BRIQUETT 2861 145.7 41.3 111.2

123-0018 CENTERPOINT ENERGY-TWELVE MILE COMP 4922 152.5 0 0.6

097-0104 EMPIRE DISTRICT ELECTRIC CO-STATE L 4911 160.4 3.1 34.6

510-0038 TRIGEN-ST. LOUIS ENERGY CORP-ASHLEY 4911 178.6 60.7 9.6

510-0809 PQ CORPORATION (THE)-ST. LOUIS 2819 181.1 74.7 58.6

099-0068 SAINT-GOBAIN CONTAINERS LLC-PEVELY 3221 187.5 242.8 71.5

159-0009 PITTSBURGH-CORNING CORP-PITTSBURGH- 3296 204.3 80.7 42

187-0017 FLAT RIVER GLASS CO-PARK HILLS 3211 209.8 27.3 66.3

510-2378 LACLEDE TOWER ASSOCIATES LLC-LACLED 4911 218.2 0.1 3.9

093-0008 DOE RUN COMPANY-GLOVER SMELTER 3339 230.8 43,340.10 26.7

095-0139 AQUILA INC-GREENWOOD ENERGY CENTER 4911 236.4 0.5 14.6

047-0096 INDEPENDENCE POWER AND LIGHT-MISSOU 4911 259.3 1,261.60 11.3

195-0010 MARSHALL MUNICIPAL UTILITIES-MARSHA 4911 295.7 1,482.70 6.5

183-0076 GENERAL MOTORS-WENTZVILLE CENTER 3711 301.1 695.2 9.7
10

CountyPlant ID Facility Name SIC 2002 NOX

Emissions

2002 SO2

Emissions

2002 PM10

Emissions

201-0099 TEXAS EASTERN TRANSMISSION CORPORAT 4922 315.4 0.1 1.4

019-0002 COLUMBIA MUNICIPAL POWER PLANT-COLU 4911 319.3 936 3.4

127-0001 BASF AGRI CHEMICALS-HANNIBAL PLANT 2879 413.4 1,873.20 110.9

095-0021 TRIGEN ENERGY CORPORATION-GRAND AVE 4911 498.8 3,873.70 24

095-0050 INDEPENDENCE POWER AND LIGHT-BLUE V 4911 567 4,678.20 56.3

019-0004 UNIVERSITY OF MISSOURI - COLUMBIA-P 4911 742.5 9,948.80 34.2

163-0031 DYNO NOBEL INC-LOMO PLANT 2873 765.4 0 150.4

510-0003 ANHEUSER-BUSCH INC-ST. LOUIS 2082 848.4 6,383.40 57.8

017-0019 NATURAL GAS PIPELINE COMPANY-MARBLE 4922 969.6 0.1 8

147-0024 ANR PIPELINE COMPANY-MAITLAND COMPR 4922 981.5 0.3 13.9

163-0002 AQUALON DIV OF HERCULES INC-MISSOUR 2869 1,008.20 6,223.80 143.4

095-0030 LAFARGE NORTH AMERICA INC-INDEPENDE 3241 1,049.90 677.8 20.4

159-0047 PANHANDLE EASTERN PIPE LINE CO-HOUS 4922 1,477.50 0.4 23.6

031-0021 LONE STAR INDUSTRIES INC-CAPE GIRAR 3241 1,611.00 1,362.50 380.9

186-0035 CHEMICAL LIME COMPANY-STE. GENEVIEV 3274 1,669.30 72.1 141.9

173-0001 CONTINENTAL CEMENT COMPANY INC-ILAS 3241 1,863.50 530.8 271.7

077-0039 CITY UTILITIES OF SPRINGFIELD MISSO 4911 2,004.70 3,439.30 253.9

019-0077 PANHANDLE EASTERN PIPELINE-CENTRALI 4922 2,020.70 0.4 6

201-0017 SIKESTON POWER STATION-SIKESTON POW 4911 2,205.60 6,389.00 134.6

095-0022 KANSAS CITY POWER & LIGHT CO-HAWTHO 4911 2,380.30 3,844.40 369.1

151-0002 CENTRAL ELECTRIC POWER COOPERATIVE- 4911 2,567.60 4,236.80 12.3

186-0001 MISSISSIPPI LIME COMPANY-MISSISSIPP 3274 2,764.30 6,001.40 1,378.90

099-0016 AMERENUE-RUSH ISLAND PLANT 4911 3,997.30 23,827.20 528

021-0004 AQUILA INC-LAKE ROAD PLANT 4911 4,164.70 3,643.30 33.9

099-0002 RC CEMENT COMPANY INC-RIVER CEMENT 3241 4,954.60 555.3 725

077-0005 CITY UTILITIES OF SPRINGFIELD MISSO 4911 5,346.10 5,790.10 291.4

083-0001 KANSAS CITY POWER & LIGHT CO-MONTRO 4911 5,630.40 16,213.00 285.1

163-0001 HOLCIM (US) INC-CLARKSVILLE 3241 6,026.70 7,408.00 170.6

097-0001 EMPIRE DISTRICT ELECTRIC CO-ASBURY 4911 6,077.60 4,455.90 126

165-0007 KANSAS CITY POWER & LIGHT CO-IATAN 4911 7,350.40 15,216.80 304.6

071-0003 AMERENUE-LABADIE PLANT 4911 7,820.90 48,774.50 1,001.00

189-0010 AMERENUE-MERAMEC PLANT 4911 9,480.90 16,850.40 346.3

095-0031 AQUILA INC-SIBLEY GENERATING STATIO 4911 12,326.60 12,071.00 36.6

183-0001 AMERENUE-SIOUX PLANT 4911 14,122.60 47,083.30 166.1

175-0001 ASSOCIATED ELECTRIC COOPERATIVE INC 4911 18,023.10 15,593.90 288.8

143-0004 ASSOCIATED ELECTRIC COOPERATIVE INC 4911 36,882.70 16,154.40 238.4
11

Table 2. Refined List of Missouri Facilities with 2002 Emissions of NOX Exceeding 50 Tons

CountyPlant ID Facility Name SIC 2002 NOX

Emissions Control Requirements

031-0053 PROCTER & GAMBLE PAPER 

PRODUCTS CO2676 128.6

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

40 CFR 60 Subpart Dc, 40 CFR 63 Subpart ZZZZ, low NOx burners 

required, NOx permit emission rate (BACT)

203-0006 CRAIG INDUSTRIES INCSUMMERSVILLE P 2861 50.4

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

10 CSR 10-6.330, Restriction of Emissions from Batch-Type Charcoal 

Kilns, NOx Permit Limit, 

035-0004 ROYAL OAK ENTERPRISESELLSINORE DIV 2861 58.6 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants

091-0038

GARNETT WOOD 

PRODUCTS-CHARCOAL 

PLAN

2861 97.4 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants

125-0001

KINGSFORD 

MANUFACTURING COBRIQUETT2861 145.7

NOx permit emission rate. NOx concentration permit limit, 40 CFR 60 

Subpart Dc, Low NOx Burners Required, 40 CFR 60 Subpart Y, 40 

CFR 63 Subpart ZZZZ

163-0002 AQUALON DIV OF HERCULES 

INC-MISSOUR 2869 1,008.20

40 CFR 63 Subpart F, 40 CFR 63 Subpart H, 40 CFR Subpart FFFF, 

40 CFR 60 Subpart Dc, 40 CFR 63 Subpart G, 10 CSR 10-6.220 

Restriction of Emission of Visible Air Contaminants, 40 CFR 63 

Subpart ZZZZ

097-0005 PCS PHOSPHATE COMPANY 

INC-JOPLIN PL 2874 63.8 Basic OP permit. 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 10 CSR 10-3.060

097-0094 TAMKO ROOFING 

PRODUCTS INC-RANGELIN 2952 50.4 40 CFR 60 Subpart Dc, 40 CFR 60 Subpart UU, 10 CSR 10-6.220 Restriction of Emissions of Visible Air Contaminants

187-0017 FLAT RIVER GLASS CO-PARK 

HILLS 3211 209.8 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, NOx Permit Limit, 40 CFR 60 Subpart CC, Permit Operating Limit

095-0030 LAFARGE NORTH AMERICA 

INC-INDEPENDE 3241 1,049.90 10 CSR 10-6.220, Restriction of Emission of Visible Air Contaminants, 40 CFR 63 Subpart LLL

031-0021 LONE STAR INDUSTRIES INCCAPE GIRAR 3241 1,611.00

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

10 CSR 10-6.380 Control of NOX Emissions From Portland Cement 

Kilns, 40 CFR 63 Subpart LLL, 40 CFR 63 Subpart EEE, 40 CFR 60 

Subpart OOO, 40 CFR 60 Subpart F, 40 CFR 60 Subpart Y, 40 CFR 

61 Subpart FF, 40 CFR 60 Subpart Kb, throughput permit limits, 

capture efficiency permit limits for HAPs

027-0001 HARBISON-WALKER 

REFRACTORIES-HARBIS 3255 79.5 10 CSR 3.080 Restriction of Emission of Visible Air Contaminants, 40 CFR 60 Subpart OOO

186-0035 CHEMICAL LIME COMPANYSTE. GENEVIEV 3274 1,669.30 40 CFR Part 63 Subpart AAAAA, 40 CFR Part 60 Subpart Y, 40 CFR 

Part 60 Subpart HH, NOx rate/input permit limit (BACT)

139-0008 CHRISTY MINERALS COHIGH HILL 3295 94.1 40 CFR 60 Subpart OOO, 10 CSR 10-6.220 Restriction of Emission of 

Visible Air Contaminants

159-0009 PITTSBURGH-CORNING 

CORP-PITTSBURGH3296 204.3

40 CFR 63 Subpart SSSSSS, NOx Emissions Permit limit, 10 CSR 10-

6.220 Restriction of Emission of Visible Air Contaminants, Manganese 

Dioxide Permit Limit, NOx Emissions Permit Limit

009-0005 HYDRO ALUMINUM WELLSMONETT 3351 62.8 40 CFR 63 Subpart MMMM, 10 CSR 10-6.220 Restriction of Emission 

of Visible Air Contaminants, VOC Emissions Permit Limits

113-0029 TOYOTA MOTOR 

CORPORATE SERVICES-BOD 3365 68

NOx Emissions permit limit, 40 CFR 60 subpart IIII, 10 CSR 10-6.220 

Restriction of Emission of Visible Air Contaminants, Wet Scrubber 

Required

047-0019 FORD MOTOR CO-KANSAS 

CITY ASSEMBLY 3711 96.2

40 CFR 63 Subpart IIII, 40 CFR 60 Subpart MM, 10 CSR 10-6.220 

Restriction of Emission of Visible Air Contaminants, 40 CFR 63 

Subpart DDDDD, 40 CFR 63 Subpart EEEE, NOx Emissions Permit 

Limit

063-0009 MAGELLAN PIPELINE 

COMPANY LLC-OSBOR 4613 65.6 40 CFR 63 Subpart BBBBBB

081-0010 MAGELLAN PIPELINE 

COMPANY LLC-RIDGE 4613 102.2 40 CFR 63 Subpart BBBBBB

023-0050 POPLAR BLUFF MUNICIPAL 

UTILITIES-GE 4911 51.6

10 CSR 10-6.390 Control of NOx Emissions from Large stationary 

Internal Combustion Engines, 10 CSR 10-6.270 Acid Rain Source 

Permits Required, NOx Emissions Permit Limit

097-0110 CARTHAGE WATER & 

ELECTRIC-CARTHAGE 4911 110.4 Operating Permit currently under Technical Review
12

CountyPlant ID Facility Name SIC 2002 NOX

Emissions Control Requirements

145-0049 SOUTHERN STAR CENTRAL 

GAS PIPELINE4922 61.5 40 CFR 60 Subpart GG

023-0042 CENTERPOINT ENERGYPOPLAR BLUFF COM 4922 113.1 Operating Hours Permit Limit

123-0018 CENTERPOINT ENERGYTWELVE MILE COMP 4922 152.5 Operating Hours Permit Limit

201-0099 TEXAS EASTERN 

TRANSMISSION CORPORAT 4922 315.4 Operating Hours Permit Limit

017-0019 NATURAL GAS PIPELINE 

COMPANY-MARBLE 4922 969.6 See Section 1.3

147-0024 ANR PIPELINE COMPANYMAITLAND COMPR 4922 981.5 40 CFR 63 Subpart ZZZZ

159-0047 PANHANDLE EASTERN PIPE 

LINE CO-HOUS 4922 1,477.50 40 CFR 63 Subpart ZZZZ, NOx Rate Permit Limits, Throughput permit limits

019-0077 PANHANDLE EASTERN 

PIPELINE-CENTRALI 4922 2,020.70 40 CFR 60 Subpart KKKK, Low NOx Burners Required, Operating Hours Permit Limit

161-0006 UNIVERSITY OF MO - ROLLAROLLA POWE8221 54.4 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

Coal throughput permit limit, HAP Emissions Permit Limit

169-0004 MANSCEN AND FORT 

LEONARD WOOD-MANSC 9711 94.4

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

Permit Requirements render inoperable several emission units, fuel 

consumption permit limit, 40 CFR 60 Subpart Dc, 40 CFR 60 Subpart 

OOO

Table 3. Refined List of Missouri Facilities with 2002 Emissions of SO2 Exceeding 50 Tons

CountyPlant ID Facility Name SIC 2002 SO2

Emissions Control Requirements

047-0002 NATIONAL STARCH & 

CHEMICAL CO-NATIO 2046 105 10 CSR 10-6.260 Restriction of Emission of Sulfur Compounds

163-0002 AQUALON DIV OF 

HERCULES INC-MISSOUR 2869 6,223.80

40 CFR 63 Subpart F, 40 CFR 63 Subpart H, 40 CFR 63 Subpart 

FFFF, 40 CFR 60 Subpart Dc, 40 CFR 63 Subpart G, 10 CSR 10-

6.220 Restriction of Emission of Visible Air Contaminants, 40 CFR 63 

Subpart ZZZZ, Wet Scrubber Required

097-0094 TAMKO ROOFING 

PRODUCTS INC-RANGELIN 2952 69.4

10 CSR 10-6.220 Restriction of Emissions of Visible Air Contaminants, 

40 CFR 60 Subpart Dc, 40 CFR 60 Subpart UU, HCl and 

Formaldehyde Emissions Permit Limit, Natural Gas Required Fuel in 

Boiler 5

077-0004 CARLISLE POWER

TRANSMISSION PRODUCT 3052 156.6

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

CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 40 

CFR 63 Subpart ZZZZ, HAP Emission Permit Limits, Production permit 

limit

095-0030 LAFARGE NORTH AMERICA 

INC-INDEPENDE 3241 677.8

10 CSR 10-6.220 Restriction of Emissions of Visible Air Contaminants, 

10 CSR 10-6.260 Restriction of Emission of Sulfur Compounds, 40 

CFR 63 Subpart LLL, 40 CFR 60 Subpart Kb, Sulfur Content of Waste 

Substitute for Material, kiln feed, and coke permit limit.

031-0021 LONE STAR INDUSTRIES 

INC-CAPE GIRAR 3241 1,362.50

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

10 CSR 10-6.260 Restriction of Emissions of Sulfur Compounds, 40 

CFR 63 Subpart LLL, 40 CFR 63 Subpart EEE, 40 CFR 60 Subpart 

OOO, 40 CFR 60 Subpart F, 40 CFR Subpart Y, 40 CFR 61 Subpart 

FF, 40 CFR 60 Subpart Kb, Fuel Consumption Permit Limits for certain 

fuels

117-0007

GLEN GERY 

CORPORATION-GLEN GERY 

COR

3251 84.7 Operation Shutdown February 2004

027-0001 HARBISON-WALKER 

REFRACTORIES-HARBIS 3255 190.2

10 CSR 10-6.260 Restriction of Emissions of Sulfur Compounds, 40 

CFR 60 Subpart OOO, 10 CSR 10-3.080 Restriction of Emission of 

Visible Air Contaminants

186-0035 CHEMICAL LIME COMPANYSTE. GENEVIEV 3274 72.1

40 CFR Part 63 Subpart AAAAA, 40 CFR Part 60 Subpart Y, 40 CFR 

Part 60 Subpart HH, Permitted Fuel Restrictions (Natural Gas), SO2 

Rate Permit Limit (BACT), SO2 Rate per production Permit Limit 

(BACT) 
13

CountyPlant ID Facility Name SIC 2002 SO2

Emissions Control Requirements

139-0008 CHRISTY MINERALS COHIGH HILL 3295 225.4

10 CSR 10-6.260 Restriction of Emissions of Sulfur Compounds, 40 

CFR 60 Subpart OOO, 10 CSR 10-6.220 Restriction of Emission of 

Visible Air Contaminants

159-0009 PITTSBURGH-CORNING 

CORP-PITTSBURGH3296 80.7

10 CSR 10-6.260 Restriction of Emissions of Sulfur Compounds, 40 

CFR 63 Subpart SSSSSS, SO2 Emissions Permit limit, 10 CSR 10-

6.220 Restriction of Emission of Visible Air Contaminants, Manganese 

Dioxide Permit Limit, Aluminum Sulfate Charging Process Permit Limit 

213-0048 COLLEGE OF THE OZARKSBRANSON 8221 128.9

10 CSR 10-6.260 Restriction of Emissions of Sulfur Compounds, 40 

CFR 60 Subpart DC, fuel sulfur content permit limits, opacity permit 

limits, SOX emissions permit limit based on fuel consumption permit 

limits, operating hour permit limits 

031-0010 SOUTHEAST MISSOURI 

STATE UNIVERSITY 8221 284.7 10 CSR 10-6.260 Restriction of Emissions of Sulfur Compounds, 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants

161-0006 UNIVERSITY OF MO -

ROLLA-ROLLA POWE

8221 501

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

Emissions Rate Permit Limit, Coal Throughput Permit Limit, Multicyclone control required, coal sulfur content permit limit

Table 4. Refined List of Missouri Facilities with 2002 Emissions of PM10 Exceeding 50 Tons

CountyPlant ID Facility Name SIC 2002 PM10

Emissions Control Requirements

043-0002 CLEVER STONE COMPANY 

INC-CLEVER 1422 53.9 40 CFR 60 Subpart OOO (Basic Operating Permit)

186-0022 TOWER ROCK STONE COSTE. GENEVIEVE 1422 64.2

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

40 CFR 60 Subpart OOO, PM Emissions Permit Limit, Water 

Application to Fugitive PM Emission Sources Required, Moisture 

Content Permit Limit

037-0007 LIMPUS QUARRIES INCHARRISONVILLE 1422 64.6

Restriction of Emission of Particulate Matter From Industrial Processes 

10 CSR 10-6.400, Restriction of Emission of Visible Air Contaminants 

10 CSA 10-6.220, PM Emissions Permit Limit, Moisture Content Permit 

Limit

047-0002 NATIONAL STARCH & 

CHEMICAL CO-NATIO 2046 141.1

Restriction of Emission of Particulate Matter From Industrial Processes 

10 CSR 10-6.400, Restriction of Emission of Visible Air Contaminants 

10 CSA 10-6.220, 10 CSR 10-2.260 Control of Petroleum Liquid 

Storage, Loading and Transfer, 10 CSR 10-2.210, Control of Emissions 

from Solvent Metal Cleaning 

021-0060 AG PROCESSING INC-ST. 

JOSEPH - LOWE

2075 60.3

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

10 CSR 10-6.400 Restriction of Emission of Particulate Matter from 

Industrial Processes, 10 CFR 63 Subpart GGGG, Leak Detection and 

Repair Program Permit Requirement, PM Emissions Rate Permit Limit, 

PM Emissions Concentrations Permit Limit, Cyclones Required, Bag

houses Required, Wet System Control Requirements, Enclosure 

Requirements, Condensers Required, Mineral Oil Absorption System 

Required 

047-0132 AMERICAN ITALIAN PASTA 

COMPANY-AMER 2098 68.6

10 CSR 10-2.030 Restriction of Emission of Particulate Matter from 

Industrial Processes, 10 CSR 10-2.060 Restriction of Emission of 

Visible Air Contaminants, 40 CFR 60 Subpart Dc, 40 CFR 60 Subpart 

Dc, Bag houses Required, Fuel Sulfur Content Permit Limit 

031-0053 PROCTER & GAMBLE 

PAPER PRODUCTS CO2676 72

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

10 CSR 10-3.060 Maximum Allowable Emissions of Particulate Matter 

From Fuel Burning Equipment Used for Indirect Heating, 10 CSR 10-

6.400 Restriction of Emission of Particulate Matter From Industrial 

Processes, 40 CFR 60 Subpart Dc, 40 CFR 63 Subpart ZZZZ, HAP 

Emissions Permit Limit, Bag houses Required, Drum Filters Required, 

Cyclonic Separator Required (BACT), Venturi Scrubber Required 

(BACT), Low NOx Burners Required (BACT), Low VOC Additives 

Required, Operating Hours Limited

065-0038 ROYAL OAK ENTERPRISES 

INC-SALEM BRI 2861 57.3

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

PM Emissions Permit Limit, 10 CSR 10-6.330 Restriction of Emissions 

from Batch Type Charcoal Kilns, Water Application Required, Road 

Paving and Maintenance Required

091-0038

GARNETT WOOD 

PRODUCTS-CHARCOAL 

PLAN

2861 72.9

10 CSR 10.6.400 Restriction of Emission of Particulate Matter from 

Industrial Processes, 10 CSR 10.6.220 Restriction of Emission of 

Visible Air Contaminants
14

CountyPlant ID Facility Name SIC 2002 PM10

Emissions Control Requirements

091-0014 PEACE VALLEY CHARCOAL 

INC-PEACE VAL 2861 87.5 10 CSR 10-6.330 Restriction of Emissions from Batch Type Charcoal Kilns,

161-0003 MISSOURI HARDWOOD 

CHARCOAL-ROLLA PL 2861 88.8 10 CSR 10-6.330 Restriction of Emissions from Batch Type Charcoal Kilns 

125-0001

KINGSFORD 

MANUFACTURING COBRIQUETT2861 111.2

10 CSR 10-6.400 Restriction of Emission of Particulate Matter from 

Industrial Processes, 10 CSR 10-6.220 Restriction of Emission of 

Visible Air Contaminants, 40 CFR 60 Subpart Dc, 40 CFR 60 Subpart 

Y, 40 CFR 63 Subpart ZZZZ, HAP Emissions Permit Limit, Fuel Oil 

Sulfur Content Permit Limit, PM Emission Rate Permit Limit, Opacity 

Permit Limit, Total Organic Carbon Emission Concentration Permit 

Limit, Cyclones Required, Fabric Filters Required, quantity of sawdust 

handling permit limit, VOC Emissions Permit Limit

213-0002 HORNER CHARCOAL CO 

INC-HORNER CHARC 2861 113.1 10 CSR 10-6.330 Restriction of Emissions From Batch-Type Charcoal Kilns (Basic)

215-0045 H & K CHARCOAL-H & K 

CHARCOAL 2861 120.5 10 CSR 10-6.330 Restriction of Emissions From Batch-Type Charcoal Kilns

215-0003 THOMASON CHARCOAL 

COMPANY-THOMASON 2861 235.8

10 CSR 10-6.330 Restriction of Emissions from Batch-Type Charcoal 

Kilns, 10 CSR 10-6.220 Restriction of Emission of Visible Air 

Contaminants, 10 CSR 10.6.400 Restriction of Emission of Particulate 

Matter from Industrial Processes, Hoods Required, Enclosures 

Required, Bag houses Required

203-0006 CRAIG INDUSTRIES INCSUMMERSVILLE P 2861 630

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

10 CSR 10-6.330, Restriction of Emissions from Batch-Type Charcoal 

Kilns, PM Emissions Permit Limit

035-0004 ROYAL OAK ENTERPRISESELLSINORE DIV 2861 717.5

PM Emissions Permit Limit, 10 CSR 10-6.330

Restriction of Emissions from Batch-Type Charcoal Kilns, 10 CSR 10-

6.220 Restriction of Emissions of Visible Air Contaminants, Water 

Application Required, Road Paving/Maintenance Required

163-0002 AQUALON DIV OF 

HERCULES INC-MISSOUR 2869 143.4

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

10 CSR 10-6.400 Restriction of Emission of Particulate Matter From 

Industrial Processes, 40 CFR 63 Subpart F, 40 CFR 63 Subpart H, 40 

CFR 63 Subpart FFFF, 40 CFR 60 Subpart Dc, 40 CFR 63 Subpart G, 

40 CFR 63 Subpart ZZZZ, Wet Scrubber Required, VOC Emissions 

Permit Limit, Methanol Emissions Permit Limit, Waste Heat Boiler 

Destruction Efficiency Permit Limit

097-0005 PCS PHOSPHATE COMPANY 

INC-JOPLIN PL 2874 51.3

10 CSR 10-3.060 Maximum Allowable Emissions of Particulate Matter 

From Fuel Burning Equipment Used for Indirect Heating, 10 CSR 10-

6.220 Restriction of Emission of Visible Air contaminants, 10 CSR 

10.6.400 Restriction of Emission of Particulate Matter from Industrial 

Processes, PM Emissions Permit Limit, Bag houses Required

187-0017 FLAT RIVER GLASS COPARK HILLS 3211 66.3

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

10 CSR 10-6.400 Restriction of Emission of Particulate Matter from 

Industrial Processes, PM Emission Rate Limit, Operating Hours Permit 

Limit, Throughput Rate Permit Limit

031-0021 LONE STAR INDUSTRIES 

INC-CAPE GIRAR 3241 380.9

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

40 CFR 63 Subpart LLL, 40 CFR 63 Subpart EEE, 40 CFR 60 Subpart 

OOO, 40 CFR 60 Subpart F, 40 CFR Subpart Y, 40 CFR 61 Subpart 

FF, 40 CFR 60 Subpart Kb, Fuel Consumption Permit Limits for certain 

fuels, Removal/Destruction Efficiencies Permit Limits, PM Emission 

Rate Permit limit, Bag houses Required, Number of Filters Cleaned 

Permit Limit, 10 CSR 10-6.400 Restriction of Emission of Particulate 

Matter from Industrial Processes, 

186-0035 CHEMICAL LIME COMPANYSTE. GENEVIEV 3274 141.9

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

10 CSR 10-6.400 Restriction of Emission of Particulate Matter from 

Industrial Processes, 40 CFR Part 63 Subpart AAAAA, 40 CFR Part 60 

Subpart Y, 40 CFR Part 60 Subpart HH, Permitted Fuel Restrictions 

(Natural Gas), Enclosure Requirements, Bag house Requirements, 

Chemical Dust Suppressant/Water Application Requirements, PM 

Emission Concentration Permit Limit, PM Emissions Permit Limit

027-0048 CHILES WORKS LLCFULTON 3295 54.9

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

Bag houses Required, Cyclones Required, Dust Collectors Required, 

Ambient PM Concentration Requirement, Chemical Dust Suppressant 

Application Requirements
15

CountyPlant ID Facility Name SIC 2002 PM10

Emissions Control Requirements

139-0008 CHRISTY MINERALS COHIGH HILL 3295 70.1

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants, 

40 CFR 60 Subpart OOO, Opacity Permit Limit, PM Emissions Permit 

Limit, Bag house Required

113-0029

TOYOTA MOTOR 

CORPORATE SERVICESBOD3365 54.3

10 CSR 10.6.400 Restriction of Emission of Particulate Matter from 

Industrial Processes, 10 CSR 10-6.220 Restriction of Emission of 

Visible Air Contaminants, 40 CFR 60 subpart IIII, Bag houses 

Required, Wet Scrubbers Required, PM Emissions Limit, VOC 

Emissions Limit, PM Emission Rate Limits

047-0019 FORD MOTOR CO-KANSAS 

CITY ASSEMBLY 3711 82.9

10 CSR 10.6.400 Restriction of Emission of Particulate Matter from 

Industrial Processes, 10 CSR 10-6.220 Restriction of Emission of 

Visible Air Contaminants, 40 CFR 63 Subpart IIII, 40 CFR 60 Subpart 

MM, 40 CFR 63 Subpart DDDDD, 40 CFR 63 Subpart EEEE, VOC 

Permit Limits

Table 5 lists the summed emissions for the pollutants of concern in the refined lists in Tables 2, 

3, and 4. Table 6 lists the summary of 2002 emissions from point, area, on-road mobile, and offroad mobile source emissions for these pollutants of concern. Comparing these two tables, the 

refined list of sources only contribute 7.3%, 2.8%, and 19.8% of all Missouri point source 

emissions in 2002 for NOX, SO2, and PM10, respectively. Furthermore, comparing the emissions 

from the refined list of sources to the annual 2002 emissions from all four source categories 

listed in Table 6, the refined list of sources only contribute 2.8%, 2.4%, and 5.7% of the total 

anthropogenic emissions in 2002 from these source categories for NOX, SO2, and PM10, 

respectively. Although the refined list includes a high percentage of PM10 emissions, as 

mentioned in the original Regional Haze Plan, PM10 emissions do not significantly contribute to 

visibility issues for Missouri’s Class I areas as they are often fugitive and therefore tend to 

remain very close to their emission source. 

No model runs were performed for any of these sources individually, and therefore it is difficult 

to determine the precise impact that this list of sources or any single source on this list has in 

terms of visibility for Class I areas. However as described in Missouri’s Regional Haze Plan, the 

baseline visibility conditions for the 20% worst days are 28.02 dv and 26.75 dv for Mingo and 

Hercules Glades, respectively. Furthermore, the natural visibility conditions for the 20% worst 

days are 12.40 dv and 11.30 dv for Mingo and Hercules Glades, respectively. Taking the 

difference between baseline conditions and natural conditions for the worst 20% days gives the 

anthropogenic visibility impact of 15.62 dv and 15.54 dv for Mingo and Hercules Glades, 

respectively. Noting that ammonium sulfate and ammonium nitrate make up the majority of PM 

speciation data at each of these sites (which can be attributed to NOX and SO2 source emissions), 

if we round up to assume that this list of sources contribute 3% of all anthropogenic SO2 and 

NOX emissions and we then assume that these emissions are all that affect visibility at Mingo 

and Hercules Glades, the emissions from these three lists of sources combined would only

account for an impact of 0.47 dv at both Mingo and Hercules Glades. Based on these 

estimations, even if 100% of the NOX and SO2 emissions from these three tables of refined 

sources were eliminated it would not result in even a 0.5 dv visibility improvement. Therefore, 

researching and analyzing new control requirements for these lists of sources would not be 

noticeably beneficial to visibility in either of Missouri’s Class I areas.
16

Table 5. Sum of 2002 Missouri point source emissions from sources that are non-EGU, nonBART screened, and located outside the St. Louis PM2.5 nonattainment area

NOX

(Tons/yr.)

SO2

(Tons/yr.)

PM10

(Tons/yr.)

Refined Point Source Emissions 13,318 10,163 3,805

Table 6. 2002 Summary of Missouri Point, Area, On-Road Mobile, and Off-Road Mobile 

Source Emissions

NOX

(Tons/yr.)

SO2

(Tons/yr.)

PM10

(Tons/yr.)

Point Source Emissions 181,581.7 369,245.1 19,185.3

Area Source Annual Emissions 31.337.8 48,510.9 29,975.9

On-Road Mobile Source Emissions 189,852.3 5,353.5 4,486.6

Off-Road Mobile Source Emissions 99,305.6 9,350.5 13,063.5

Totals 470,739.6 432,460.0 66,711.3

Section 1.3 Q/D Analysis for Refined List of Sources

In their Phase I Report-Revised (2010), the Federal Land Managers’ Air Quality Related Values 

Group (FLAF) stated that “Experience with the FLAG 2000 recommendations in dealing with 

many new source review applications led the Agencies to believe that an initial screen that would 

exempt a source from air quality related values (AQRV) impact review based on its annual 

emissions (Q) and distance (D) from a Class I area may be appropriate in most situations.” The 

following is an excerpt form the report which describes the screening criteria:

As part of its Regional Haze Regulation, the EPA has introduced a screening criteria in

its BART guidelines based on a source’s annual emission strength and distance from a 

Class I area. The EPA stated that it would be reasonable to conclude that the following 

sources would not be considered to cause or contribute to visibility impairment:

--those located more than 50 km from any Class I area that emit less than 500 tons per 

year of NOx or SO2 (or combined NOx and SO2), and 

--those located more than 100 km from any Class I area that emit less than 1,000 tons per 

year of NOx or SO2 (or combined NOx and SO2).

In both cases, the annual emissions over distance factor equates to 10.

The Agencies have concluded that a similar approach has merit with respect to new 

source impacts at Class I areas, for air pollution sources with relatively steady emissions 

throughout each year. However, the Agencies are modifying the size criteria to also 

include Particulate Matter less than 10 microns in size (PM10) and sulfuric acid mist 

(H2SO4) emissions because those pollutants also impair visibility and contribute to other 

resource impacts. In addition, rather than the two-step BART test, the Agencies are using 

a fixed Q/D factor of 10 as a screening criteria for sources locating/located greater than 
17

50 km from a Class I area. Furthermore, the Agencies are expanding the screening 

criteria to include all AQRVs, not just visibility. Therefore, the Agencies will consider a 

source locating greater than 50 km from a Class I area to have negligible impacts with 

respect to Class I AQRVs if its total SO2, NOx, PM10, and H2SO4 annual emissions (in 

tons per year, based on 24-hour maximum allowable emissions), divided by the distance 

(in km) from the Class I area (Q/D) is 10 or less. The Agencies would not request any 

further Class I AQRV impact analyses from such sources.

The refined lists of sources in Tables 2, 3, and 4 have been further evaluated to determine if it is 

reasonable to assume a visibility impact from any of these sources for either of Missouri’s 

federal Class I areas. For each source listed in these three tables above, the Air Program 

determined the Q/D value for each source. Any source with a Q/D value over 10 was further 

researched to determine if reasonable controls were being implemented at source. Table 7 below 

shows the results of the Q/D analysis for the list of refined sources, and Table 8 shows the 

sources with Q/D values greater than 10.

Table 7. Q/D Analysis for Refined List of Missouri Sources

CountyPlant ID Facility Name SIC 2002 NOX

Emissions

2002 SO2

Emissions

2002 PM10

Emissions

Total 

Emissions

D 

Mingo 

(km)

D 

HERC 

(km)

Q/D 

Mingo

Q/D 

Herc

037-0007 LIMPUS QUARRIES INCHARRISONVILLE 1422 21.1 1.4 64.6 87.1 409 251 0.2 0.3

043-0002 CLEVER STONE COMPANY 

INC-CLEVER 1422 0 0 53.9 53.9 284 57 0.2 0.9

186-0022 TOWER ROCK STONE COSTE. GENEVIEVE 1422 0 0 64.2 64.2 108 283 0.6 0.2

047-0002 NATIONAL STARCH & 

CHEMICAL CO-NATIO 2046 43 105 141.1 289.1 447 301 0.6 1

021-0060 AG PROCESSING INC-ST. 

JOSEPH - LOWE

2075 4 0 60.3 64.3 505 372 0.1 0.2

047-0132 AMERICAN ITALIAN PASTA 

COMPANY-AMER 2098 14 0.1 68.6 82.7 437 313 0.2 0.3

031-0053 PROCTER & GAMBLE 

PAPER PRODUCTS CO2676 128.6 0.8 72 201.4 76 309 2.6 0.7

035-0004

ROYAL OAK 

ENTERPRISES-ELLSINORE 

DIV

2861 58.6 0 717.5 776.1 50 184 15.5 4.2

065-0038 ROYAL OAK ENTERPRISES 

INC-SALEM BRI 2861 34.4 1.7 57.3 93.4 141 162 0.7 0.6

091-0014

PEACE VALLEY 

CHARCOAL INC-PEACE 

VAL

2861 7.2 0 87.5 94.7 131 103 0.7 0.9

091-0038

GARNETT WOOD 

PRODUCTS-CHARCOAL 

PLAN

2861 97.4 0 72.9 170.3 132 105 1.3 1.6

125-0001

KINGSFORD 

MANUFACTURING COBRIQUETT2861 145.7 41.3 111.2 298.2 190 194 1.6 1.5

161-0003 MISSOURI HARDWOOD 

CHARCOAL-ROLLA PL 2861 7.3 0 88.8 96.1 164 159 0.6 0.6

203-0006 CRAIG INDUSTRIES INCSUMMERSVILLE P 2861 50.4 0 630 680.4 126 121 5.4 5.6

213-0002 HORNER CHARCOAL CO 

INC-HORNER CHARC 2861 9.1 0 113.1 122.2 243 10 0.5 12.6
18

CountyPlant ID Facility Name SIC 2002 NOX

Emissions

2002 SO2

Emissions

2002 PM10

Emissions

Total 

Emissions

D 

Mingo 

(km)

D 

HERC 

(km)

Q/D 

Mingo

Q/D 

Herc

215-0003 THOMASON CHARCOAL 

COMPANY-THOMASON 2861 19.5 0 235.8 255.3 150 112 1.7 2.3

215-0045 H & K CHARCOAL-H & K 

CHARCOAL 2861 11.2 0 120.5 131.7 158 129 0.8 1

163-0002 AQUALON DIV OF 

HERCULES INC-MISSOUR 2869 1,008.20 6,223.80 143.4 7375.4 275 341 26.8 21.7

097-0005 PCS PHOSPHATE 

COMPANY INC-JOPLIN PL 2874 63.8 34.5 51.3 149.6 386 158 0.4 0.9

097-0094 TAMKO ROOFING 

PRODUCTS INC-RANGELIN 2952 50.4 69.4 15.2 135 374 139 0.4 1

077-0004 CARLISLE POWER 

TRANSMISSION PRODUCT 3052 37 156.6 11.9 205.5 273 58 0.8 3.5

187-0017 FLAT RIVER GLASS COPARK HILLS 3211 209.8 27.3 66.3 303.4 96 243 3.2 1.2

031-0021 LONE STAR INDUSTRIES 

INC-CAPE GIRAR 3241 1,611.00 1,362.50 380.9 3354.4 61 301 55 11.1

095-0030 LAFARGE NORTH 

AMERICA INC-INDEPENDE 3241 1,049.90 677.8 20.4 1748.1 437 297 4 5.9

117-0007

GLEN GERY 

CORPORATION-GLEN 

GERY COR

3251 12.5 84.7 36.1 133.3 425 340 0.3 0.4

027-0001 HARBISON-WALKER 

REFRACTORIES-HARBIS 3255 79.5 190.2 27.5 297.2 255 250 1.2 1.2

186-0035 CHEMICAL LIME 

COMPANY-STE. GENEVIEV 3274 1,669.30 72.1 141.9 1883.3 107 285 17.6 6.6

027-0048 CHILES WORKS LLCFULTON 3295 0 0 54.9 54.9 259 257 0.2 0.2

139-0008 CHRISTY MINERALS COHIGH HILL 3295 94.1 225.4 70.1 389.6 230 273 1.7 1.4

159-0009 PITTSBURGH-CORNING 

CORP-PITTSBURGH3296 204.3 80.7 42 327 327 221 1 1.5

009-0005 HYDRO ALUMINUM 

WELLS-MONETT 3351 62.8 0.2 6.6 69.6 324 86 0.2 0.8

113-0029

TOYOTA MOTOR 

CORPORATE SERVICESBOD3365 68 8.5 54.3 130.8 224 299 0.6 0.4

047-0019 FORD MOTOR CO-KANSAS 

CITY ASSEMBLY 3711 96.2 5.8 82.9 184.9 445 305 0.4 0.6

183-0076 GENERAL MOTORSWENTZVILLE CENTER 3711 301.1 695.2 9.7 1006 205 294 4.9 3.4

063-0009 MAGELLAN PIPELINE 

COMPANY LLC-OSBOR 4613 65.6 0.5 2.6 68.7 470 356 0.1 0.2

081-0010 MAGELLAN PIPELINE 

COMPANY LLC-RIDGE 4613 102.2 0.8 4 107 500 420 0.2 0.3

023-0050 POPLAR BLUFF 

MUNICIPAL UTILITIES-GE 4911 51.6 1.9 2.1 55.6 23 220 2.4 0.3

097-0110 CARTHAGE WATER & 

ELECTRIC-CARTHAGE 4911 110.4 1.4 1.7 113.5 358 128 0.3 0.9

017-0019 NATURAL GAS PIPELINE 

COMPANY-MARBLE 4922 969.6 0.1 8 977.7 44 275 22.1 3.6

019-0077 PANHANDLE EASTERN 

PIPELINE-CENTRALI 4922 2,020.70 0.4 6 2027.1 289 275 7 7.4

023-0042 CENTERPOINT ENERGYPOPLAR BLUFF COM 4922 113.1 0 0.9 114 25 214 4.5 0.5
19

CountyPlant ID Facility Name SIC 2002 NOX

Emissions

2002 SO2

Emissions

2002 PM10

Emissions

Total 

Emissions

D 

Mingo 

(km)

D 

HERC 

(km)

Q/D 

Mingo

Q/D 

Herc

123-0018 CENTERPOINT ENERGYTWELVE MILE COMP 4922 152.5 0 0.6 153.1 44 240 3.5 0.6

145-0049 SOUTHERN STAR 

CENTRAL GAS PIPELINE4922 61.5 0 0.8 62.3 374 137 0.2 0.5

147-0024 ANR PIPELINE COMPANYMAITLAND COMPR 4922 981.5 0.3 13.9 995.7 546 426 1.8 2.3

159-0047 PANHANDLE EASTERN 

PIPE LINE CO-HOUS 4922 1,477.50 0.4 23.6 1501.5 343 238 4.4 6.3

201-0099 TEXAS EASTERN 

TRANSMISSION CORP 4922 315.4 0.1 1.4 316.9 47 289 6.7 1.1

031-0010 SOUTHEAST MISSOURI 

STATE UNIVERSITY 8221 41.7 284.7 3.2 329.6 64 303 5.1 1.1

161-0006 UNIVERSITY OF MO -

ROLLA-ROLLA POWE

8221 54.4 501 13.2 568.6 174 168 3.3 3.4

213-0048 COLLEGE OF THE 

OZARKS-BRANSON 8221 20.1 128.9 10.3 159.3 267 24 0.6 6.5

169-0004 MANSCEN AND FORT 

LEONARD WOOD-MANSC 9711 94.4 3.5 29.4 127.3 187 135 0.7 0.9

Table 8. Refined List of Sources with Q/D Value Greater than 10

CountyPlant ID Facility Name SIC 2002 NOX

Emissions

2002 SO2

Emissions

2002 PM10

Emissions

Total 

Emissions

Q/D 

Mingo

Q/D 

Herc

035-0004 ROYAL OAK ENTERPRISESELLSINORE DIV 2861 58.6 0 717.5 776.1 15.5 4.2

163-0002 AQUALON DIV OF HERCULES 

INC-MISSOUR 2869 1,008.20 6,223.80 143.4 7375.4 26.8 21.7

031-0021 LONE STAR INDUSTRIES INCCAPE GIRAR 3241 1,611.00 1,362.50 380.9 3354.4 55 11.1

186-0035 CHEMICAL LIME COMPANYSTE. GENEVIEV 3274 1,669.30 72.1 141.9 1883.3 17.6 6.6

017-0019 NATURAL GAS PIPELINE 

COMPANY-MARBLE 4922 969.6 0.1 8 977.7 22.1 3.6

Royal Oak Enterprises-Ellsinore Division has recently incorporated a 100 tpy PM10 facility wide 

emissions limit into its permit. Taking this into account, the Q/D value for this facility would 

drop well below 10 for both federal Class I areas.

Aqualon Division of Hercules is located more than 250 km from either of Missouri’s federal 

Class I areas. A Compliance Agreement between the Missouri Department of Natural 

Resources, the Missouri Office of Attorney General and Hercules, Incorporated (Aqualon’s 

parent corporation) required the shutdown of one of the three existing boilers on or before May

31, 2011. Once this boiler was retired, steam generation was not to exceed 125,000 pounds per 

hour. The Agreement allowed for compliance to be demonstrated by additional means, such as 

the shutdown of additional boilers or the plant itself. According to information obtained from 

the company, in compliance with the Agreement, two of the facility’s three coal-fired boilers 

were recently retired in May 2011, which is expected to drastically reduce actual SO2 and NOX

emissions from the facility.
20

Lone Star Industries installed an oxygen injection system in 2006 to control their SO2 and NOX

emissions. This control system reduced their actual SO2 emissions by over 90%. The control 

system also reduced NOX emissions by over 30%. The addition of this control equipment, which 

was included in their construction permit #112006-012, satisfies the four factor analysis for this 

facility.

Chemical Lime Company was issued their original construction permit in 1994 at which time 

they underwent a BACT analysis for PM10, NOX, and SO2. This BACT analysis and 

corresponding controls have been incorporated into the facility’s construction and operating 

permits in addition, as noted in 2, 3, and 4 Chemical Lime Company must also comply with the 

all current federal standards.

Natural Gas Pipeline Company is a Natural Gas Compressor Station. The majority of the NOX

emissions from this facility are the result of natural gas compressor engines. EPA has issued 

federal NSPS emission standards for newly manufactured natural gas compressor engines in 40 

CFR 60 Subpart KKKK. The compressor engines at this facility were installed from 1952 –

1966. At this time it would not be cost effective to implement control requirements for these 

existing engines that are nearing the ends of their expected useful lives. 

Chapter 2 – Best Available Retrofit Technology

Section 2.1 Sources Exempt by Date or Potential to Emit

The Air Program reexamined the emission points/units listed in Appendix I of the regional haze 

plan that were marked as having a potential to emit (PTE) less than 250 tons/year. This table was 

updated based on the results of this review to provide further documentation that these sources 

are not eligible for BART based on their PTE or date of installation. Appendix A of this 

technical supplement includes the updated table with enhanced supporting justification for 

exempting these sources from BART.

First a search was done on the type of operating permit the source has been most recently issued. 

Basic and intermediate sources do not have a PTE above 100 TPY for any pollutant in their 

permit. Intermediate sources agree to take limits in their permit to be below 100 TPY for all 

criteria pollutant they emit so they are not required to have a Part 70 (aka Title V) permit. 

Therefore, all sources with a Basic or Intermediate operating permit are immediately eliminated 

from BART consideration because their total plant wide PTE for any BART pollutant is well 

below 250 TPY. Columns were added to the spreadsheet to show which sources have basic 

(BAS) or intermediate (INT) permits. Intermediate permit numbers were listed in a separate 

column when available.

After this initial review, there were approximately 30 sources that have Part 70 (Title V) permits 

and required further examination. The majority of these sources have relatively recent operating 

permits. The Air Program reviewed these sources to determine BART applicability based on 

dates of the equipment as well as calculated PTE for the plant and/or BART eligible points/units. 

Notes of explanation were added to the “comment” column indicating if plant wide PTE showed 
21

that the pollutants of concern were each below 250 TPY. In addition, the dates for all of the 

units were verified to confirm exemption, a number of emission points/units were determined to 

not be emitters of the pollutants of concern, and finally only the BART-eligible units at sources 

were calculated for PTE. The most recent operating permit for each Title V permitted facility is 

listed in a column of the spreadsheet in Appendix A. If there is not a recently completed

operating permit available, there has been sufficient work done by Air permitting staff on draft 

permits for these sources to allow for the calculation of PTEs.

Section 2.2 Additional BART Evaluation 

Among the units listed in Appendix I of the regional haze plan that were initially eliminated from 

further BART analyses based on their individual PTE of less than 250 tons, there were six 

facilities identified as needing additional review. These six facilities required additional 

evaluation due to incorrect potential to emit calculations, the inadvertent exclusion of supporting 

emission points that were not considered during the initial analyses or having BART units that

were eliminated as a result of having gone through PSD permit exercises (Doe Run Buick). 

Table 9 lists these six facilities, the reason(s) for needing further evaluation, their initially

modeled pollutant values and the additional amounts of pollutants that needed to be evaluated. 

All emissions are based on potential to emit (PTE). Of these six facilities, screening modeling 

was done in the original Regional Haze SIP for Exide, Doe Run Herculaneum, Dyno Nobel, 

Mississippi Lime, and Noranda. Both screening and refined modeling was conducted for 

Noranda in the original Regional Haze SIP, and Doe Run Buick was not modeled at all. As Table 

9 shows, PM10 emissions from several facilities were not modeled. In addition, Table 9 also 

shows that Exide Technologies’ SO2 emission and Dyno Nobel’s NOx emission of 192.3 and 

157.5, respectively, were not modeled. 

Table 9. Facilities Requiring Further Review for BART

Facility ID Facility Name

Reason 

for 

Evaluation

Emissions Initially Modeled

(ton/yr)*

Emissions not Modeled

(ton/yr)*

NOx SO2 PM10 NOx SO2 PM10

290870001 EXIDE 

TECHNOLOGIES

Emission 

units 

excluded & 

Incorrect 

PTE

14.2 290.4 24.5 3.9 192.3 0.0

290990003

DOE RUN 

COMPANY 

Herculaneum

Emission 

units 

excluded

11.5 2,560.5 4.6 0.7 0.0 102.0

290930009 DOE RUN 

COMPANY Buick

Not 

modeled --- --- --- 16.3 6187.7 19.8

291630031 DYNO NOBEL 

INC

Emission 

units 

excluded

822.3 0.0 0.0 157.5 0.0 209.4

291860001 MISSISSIPPI 

LIME COMPANY

Emission 

units 

excluded

568.0 311.5 97.0 0.0 0.0 133.3

291430008 NORANDA 

ALUMINUM INC

Emission 

units 2.4 4137.6 445.8 0.0 0.1 9.1
22

excluded

*Emissions are based on potential to emit

After consulting with EPA modelers, it was suggested as a first step to apply a Q/D test to 

determine if screening or refined modeling was warranted. As mentioned in earlier in section 

1.3, in their Phase I Report-Revised (2010), the Federal Land Managers’ Air Quality Related 

Values Group (FLAF) determined that a Q/D test is a reasonable approach to determining 

impacts on Class I areas. Q is total potential emissions in tons for total of NOx, PM10, and SO2,

and D is the distance in kilometers from the facility to the nearest receptor in the Class I Area. 

As a rule of thumb, EPA advised that if Q/D is greater than 10, the percentage of Q/D from PM10

can be examined to determine if further impact modeling analyses are needed. As mentioned 

previously, PM10 emissions are generally fugitive emissions that do not impact far beyond their 

source. As the findings outlined in the original Regional Haze Plan discuss, Missouri’s Class I

areas are most significantly impacted by pollutants that originate from NOx and SO2 emission. 

Table 10 summarizes the Q/D analysis. 

Table 10. Q/D Analysis - Total Emissions over Distance 

Facility Name

Potential to Emit (ton/yr)

Q - Total 

Emissions 

(tons)

D -

Distance 

from 

Mingo 

(km)

D -

Distance 

from 

Hercules 

(km)

Q/D 

Mingo 

Q/D 

Hercules NOx SO2 PM10

EXIDE 18.1 482.7 24.5 525.3 549 416 1 1

DOE RUN Herc 12.2 2,560.5 106.6 2,679.3 137 278 20 10

DOE RUN Buick 16.3 6,187.7 19.8 6,223.8 108 184 58 34

DYNO NOBEL INC 979.8 0.0 209.4 1,189.2 275 340 4 3

MISSISSIPPI LIME 568.0 311.5 230.3 1,109.8 104 284 11 4

NORANDA 

ALUMINUM 2.4 4,137.7 454.9 4,595.0 73 294 63 16

Table 11 summarizes the highest screen modeling (method 6) impacts in deciviews from Table 

9.3 in the regional haze plan, along with the percent contributions from individual species. Note 

that all facilities from Table 9 are listed in Table 11 except Doe Run-Buick, which was not 

modeled in the original plan; Doe Run-Buick is addressed in section 2.3 of this technical 

supplement. The percentage contributions were taken from the output files of the original 

screening modeling that was conducted for the regional haze plan. The species are as follows: 

SO4 - sulfates; NO3 - nitrates; OC - organic carbon; EC - elemental carbon; PMC - coarse 

particulate matter; and PMF - fine particulate matter.

Table 11. Screening Modeling Impacts with Individual Species Contributions

Facility Year Day Delta (DV) %_SO4 %_NO3 %_OC %_EC %_PMC %_PMF

Exide 2001 8 0.010 85.88 9.95 0 0 0 5.77

Exide 2002 31 0.024 96.30 3.02 0 0 0 0.68

Exide 2003 309 0.021 97.30 1.82 0 0 0 0.88

DoeRunHerc 2001 202 0.399 99.99 0.10 0 0 0 0
23

DoeRunHerc 2002 73 0.487 99.59 0.41 0 0 0 0

DoeRunHerc 2003 331 0.231 99.69 0.31 0 0 0 0

Dyno Nobel 2001 46 0.081 0 100 0 0 0 0

Dyno Nobel 2002 30 0.093 0 100 0 0 0 0

Dyno Nobel 2003 98 0.049 0 100 0 0 0 0

Mississippi L 2001 18 0.246 15.71 78.52 0 0 0 5.77

Mississippi L 2002 2 0.367 9.37 83.56 0 0 0 7.07

Mississippi L 2003 300 0.136 11.59 79.28 0 0 0 9.13

Noranda 2001 12 1.118 98.82 0.15 0 0 0.21 0.92

Noranda 2002 31 1.555 98.63 0.16 0 0 0.13 1.08

Noranda 2003 212 1.816 99.45 0.01 0 0 0.06 0.49

Exide Technologies is the furthest from both Class I Areas, and its Q/D values for both Class I 

Areas are less than 10. Its highest screen modeling impact on Hercules was 0.024 deciviews. 

Even if the additional 192.3 tons of SO2 emissions missing from the initial screen modeling were 

included in the modeling, the facility would not exceed the 0.5 deciview modeling threshold.

Doe Run Herculaneum has a Q/D of 20 and 10 for Mingo and Hercules, respectively. It should 

be noted that 67 tons of PM10 emissions that were not modeled are fugitive in nature; and as 

discussed previously, the impacts would occur near the facility. In addition, when looking at the 

output files from the screen modeling, the greatest impact came from sulfate (SO4) (99.59%) as 

shown in Table 11. The impact from fine particulate matter (PMF) is 0.0%. Since PM10 was 

speciated (modeled) as PMF in Calpost, this indicates that PM10 does not have significant impact 

and these additional emissions would not have a measure impact on Doe Run’s dV on either

Class I Area.

Dyno Nobel’s Q/D values are both well below 10. Its highest screen modeling impact using 

method 6 was 0.093 deciviews as shown in Table 11. Based on these values, adding 157.5 tons 

and 209.4 tons of NOx and PM10, respectively, would not result in impacts above 0.5 deciviews

using the screen modeling let alone if refined modeling was used.

Mississippi Lime’s Q/D value for Hercules is below 10, and the highest screen modeling impact 

on Mingo using method 6 was 0.367 deciviews. Adding 133.3 tons of PM10, all of which are 

fugitive emissions, would not result in impacts above 0.5 deciview. In addition, the screen 

modeling showed that only 7.07% of the impact came from PMF and most of the impact was 

from NO3 (83.56%). As mentioned above, since PM10 was speciated as PMF in Calpost, this

minimal impact of PMF in the modeling results indicates that PM10 does not have significant 

impact on Mingo.

Noranda Aluminum’s highest refined modeling impact using method 6 was 0.435 deciviews. 

Adding 9.1 tons PM10 would not result in impacts above the 0.5 deciview since SO4 had the 

dominant impact on Mingo as shown in Table 11. 
24

Section 2.3 Modeling Analysis for Doe Run-Buick 

Doe Run Buick was not modeled initially as a result of having gone through two Prevention of 

Significant Deterioration (PSD) evaluations that determined the blast furnace units had installed 

Best Available Control Technology (BACT). For the purpose of this technical supplement to the 

regional haze plan, a screening modeling analysis of Doe Run Buick was conducted based on 

emissions submitted by facility in 2007. As summarized in Table 12, the screen modeling 

showed impacts greater that the 0.5 deciview threshold.

Table 12. Screening Modeling for Doe Run Buick

Class I Area Maximum Method 2 Impact Year

Mingo 1.143 2001

Mingo 0.880 2002

Mingo 0.855 2003

Hercules 0.444 2001

Hercules 2.072 2002

Hercules 1.860 2003

Since the screen modeling for the Buick facility showed impacts greater than 0.5 deciview, 

refined modeling was warranted. The fundamental difference between both sets of refined 

analyses and the previous screening evaluation was the use of meteorological observations in the 

development of the CALMET files used in the CALPUFF evaluations. The emission rates were 

consistent between the screening analyses and the refined analyses, as were the meteorological 

years for the evaluation (2001-2003). Table 13 shows the impacts from the facility on Mingo 

and Hercules Class I Areas using refined modeling methods 2 and 6. The impacts are based on 

the 98th percentile as per the refined modeling guidance. It is clear that the facility does not have 

impacts on both Class I Areas above 0.5 deciview.

Table 13. Refined Modeling Analysis for Doe Run Buick

Class I Area Year 8th Highest (98%) M6 Impact 8th Highest (98%) M2 Impact

Hercules 2001 0.245 0.227

Hercules 2002 0.274 0.294

Hercules 2003 0.351 0.407

Mingo 2001 0.428 0.449

Mingo 2002 0.295 0.382

Mingo 2003 0.305 0.446
25

Chapter 3 – Natural Conditions on Best 20% Visibility Days 

The goal of Regional Haze State Implementation Plans is to obtain natural visibility conditions in 

all federal Class I areas by 2064. In order to accomplish this, the Regional Haze State 

Implementation Plans must first determine what natural visibility conditions are in all federal 

Class I areas. EPA developed default values for natural visibility conditions on both the 20% 

worst visibility days and the 20% best visibility days. These default values are listed in 

Appendix B of a 2003 EPA guidance document titled: Guidance for Estimating Natural 

Visibility Conditions Under the Regional Haze Rule, which can be found at the following Web 

address: http://www.epa.gov/ttncaaa1/t1/memoranda/rh_envcurhr_gd.pdf. Table 14 lists the 

default natural visibility conditions at Mingo and Hercules Glades for the 20% best and 20% 

worst days as detailed in this guidance.

Table 14. EPA Default Natural Visibility Conditions at Missouri’s Federal Class I Areas

Best 20% Days (dv) Worst 20% Days (dv)

Hercules Glades 3.59 11.27

Mingo 3.59 11.27

States were given flexibility in the Regional Haze Rule for calculating natural visibility

conditions at federal Class I areas. Missouri’s two federal Class I areas were included in the 

CENRAP analysis listed as Appendix F in Missouri’s Regional Haze SIP. For Missouri’s two 

federal Class I areas, the CENRAP analysis focused on the worst 20% days and developed a 

glide path for these days. Section 8 of Missouri’s Regional Haze SIP lists this information in a 

graph showing the glide path from baseline conditions to natural visibility conditions on the 

worst 20% days in figures 8.1a and 8.2a for Hercules Glades and Mingo, respectively. As can be 

seen, the calculated natural condition values in the CENRAP analysis on the worst 20% days for 

these two federal Class I areas differed slightly from the EPA default values for natural 

conditions listed in Table 14. CENRAP did not perform the calculations based on the New 

IMPROVE algorithm for Missouri’s two federal Class I areas for the 20% best visibility days., 

Instead, the CENRAP analysis focused on the requirement that no degradation to visibility on the 

best 20% days could occur through 2018.

At the time of developing the Regional Haze SIP, Missouri had planned to calculate baseline and 

natural visibility conditions for both federal Class I areas in the State. However, because there 

was missing monitoring data on a significant number of days, Missouri decided not to pursue the 

refined calculations for baseline and natural visibility. Instead, Missouri deferred to the 

CENRAP calculations for baseline visibility conditions for both the worst 20% days and best 

20% days and also for the natural visibility conditions used to set the glide path for the worst 

20% days. For the best 20% days, Missouri chose to defer to the EPA default values listed in 

Table 14 for natural visibility conditions (3.59 dv for both areas).

The Regional Haze Rule requires that the initial Regional Haze SIPs report the values for natural 

visibility conditions for the best 20% visibility days. The EPA default values for natural 

visibility conditions on the best 20% visibility days will meet this requirement. The other 

requirement in the Regional Haze Rule for the initial Regional Haze SIP regarding the best 20% 
26

visibility days is that no degradation can occur between the baseline year (2002) and the interim 

year (2018). This has been demonstrated for Missouri through the CENRAP analysis, and is 

detailed in Missouri’s Regional Haze SIP in Figures 8.1b and 8.2b for Hercules Glades and 

Mingo, respectively.