# 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 

## , SO 2 

## , and/or PM 10 

## 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 SO 2 

## Exceeding 50 Tons .......... 12 Table 4. Refined List of Missouri Facilities with 2002 Emissions of PM 10 

## 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 PM 2.5 

## 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**  **............................... 2**  **0** Section 2.1 Sources Exempt by Date or Potential to Emit ................................ ................................ ...... 2 0 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 analyz e. 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 off

road mobile sources. In addition to these four factors, as described in our Long Term Strategy to meet our Reasona

ble 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 reas onable, 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 additi on , 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

- ye ar progress reports that have been committed to in this Plan. 

# Section 1.1 Reasonably Available Control Technology (RACT) The St. Louis PM 2.5 

## 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 PM 2.5 

## all RACT and Reasonably Achievable Control Measures (RACM). All non- EGU SO 2 

## and NO X 

## sources with actual emissions exceeding 25 tons per year were identified in the St. Louis PM 2.5 

## nonattainment area. These include d 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 PM 2.5 

## 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 inc luded 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 NO X 

## and SO 2 , 

## the

## 3



## facilities in the RACT process represented the largest, base

- ye ar emitters of NOx and SO 2 

## 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 c ontrol 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 b y 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 : **NO x**  With respect to oxides of nitrogen (NOx), the materials provided b y the facilities clearly indicate d 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 Cataly tic Reduction process installed on the exhaust of the natural gas

- fired inter nal 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, s everal facilities indicated that they had reduced NOx and/or SO 2 

## 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 l ed 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 s ystem. This scrubbing s ystem at MEMC was the only source to require a “new” enforceable mechanism for NOx RACT. **SO 2**  

## The non-utility sulfur dioxide sources were divided into three (3) groups. The first group was those sources that have clearly demonstrated that SO 2 

## 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 SO 2 

## sources, there were no previous RACT evaluations in the St. Louis area, and these determinations resulted inconsiderable additional emission control s 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 SO 2 

## contro ls for these facilities were not cost effective. The second group was made up of the single largest non

-utility source of SO 2 

## in the St. Louis nonattainment area. 10 CSR 10

- 6.260, Restriction of Emission of Sulfur Compounds, currently limits SO 2 

## 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 ye ar emissions utilized in the attainment demonstration were 44,300 tons per ye ar for Doe Run ’s facility . Based on Doe Run’s high emissions the operation of an SO 2 

## scrubbing s ystem would be cost effective on a per ton basis. However, the overall capital costs of installing and maintain a scrubbing s ystem for the various gas streams at this facility

would be considerable. In an effort to significantly reduce emissi ons 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 SO 2 

## per year in 2012 as RACT. The emission limit will be reduced to sixteen thousand three

hundred

- fifty (16,350) tons SO 2 

## per year in 2014, and zero (0) tons SO 2 

## 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 SO 2 

## emissions. Following the completion of RACT process, a federal consent decree was signed b y 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 b y the stakeho lders, a new regulation that limits the large industrial boilers to 1.0 pounds of SO 2 

## 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 regulati on without installation of add

- on control equipment for SO 2 

## (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 SO 2 

## 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 b y Anheuser Busch, translates to an overall average of 3.5 lb SO 2

## /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, preclude d 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 SO 2 

## 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 Pro gram 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 ty pes of coal available for use as fuel. This optimization led to an initial proposed regulation that limited SO 2 

## 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. B ased on current production projections, if no controls had been required, the facility was projected to emit over 7,200 tons per year SO 2 

## in 2012. This nearly 60 percent reduction in SO 2 

## 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 PM 2.5 

## 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 NO X 

## and SO 2 

## in the St. Louis PM 2.5 

## 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 signi ficant modification of existing major sources. Missouri has been delegated full authority to implement the PSD program by the EPA.

## 6



## When Missouri performs a BACT analys es for new sources, the state takes into account the same four factors that are require d for developing control strategies under a Regional Haze State Implementation Plan. In nearly all cases a BACT analys is would require more stringent controls than a RACT or RACM analys is. As all new stationary emission sources are required to obtain a construction permit prior to commencing construction, the state’s construction permit rule ensure s 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 source s 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 po int sources using the 4

- factor analys is, 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 : NO X 

## , SO 2 

## , or PM 10 

## . Fifty tons was selected to screen out less emitting sources that would not have a significant impact on visibility in federal Class Iareas . 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 analys is. Next , all facilities loc ated in the St. Louis PM 2.5 

## 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 NO X 

## , SO 2 

## , or PM 10 

## . 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 NO X 

## , SO 2 

## , and PM 10 

## , respectively. These three tables also include a list of a pplicable 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 S tate ’ 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 S tate’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 Iareas 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.

## 8

**Table 1 .**  **Missouri Fa cilities with 2002 Emissions of**  **NO X** 

## , SO **2** 

## , and/or PM **10** 

## Exceeding 50 Tons **County****** **Plant ID Facility**  **Name SIC**  **2002 NO X**  

### Emissions **2002 SO 2** 



### Emissions **2002 PM 10** 



### Emissions 043 - 0002 CLEVER STONE COMPANY INC- CLEVER 1422 0 0 53.9 027 - 0048 CHILES W ORKS LLC - FULTON 3295 0 0 54.9 186 - 0022 TOW ER ROCK STONE CO - STE. GENEVIEVE 1422 0 0 64.2 189 - 0017 FRED W EBER 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 - LOW E 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 POW ER 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 POW E 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

**County****** **Plant ID Facility**  **Name SIC**  **2002 NO X**  

### Emissions **2002 SO 2** 



### Emissions **2002 PM 10** 



### Emissions 145 - 0049 SOUTHERN STAR CENTRAL GAS PIPELINE - 4922 61.5 0 0.8 009 - 0005 HYDRO ALUMINUM W ELLS - 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 POWE R 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 -WAL KER 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 POWE R & 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 W OOD - 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 W OOD 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-TW ELVE 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 - GREEN WOOD ENERGY CENTER 4911 236.4 0.5 14.6 047 - 0096 INDEPENDENCE POW ER 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 -WEN TZVILLE CENTER 3711 301.1 695.2 9.7

## 10

**County****** **Plant ID Facility**  **Name SIC**  **2002 NO X**  

### Emissions **2002 SO 2** 



### Emissions **2002 PM 10** 



### 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 POW ER 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 POWE R & LIGHT CO - HAW THO 4911 2,380.30 3,844.40 369.1 151 - 0002 CENTRAL ELECTRIC POW ER 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 POWE R & 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 POWE R & 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 NO X**  

## Exceeding 50 Tons **C ou**  **nty****** **Plant ID Facility**  **Name SIC**  **2002 NO X**  

### Emissions **Control Requirements** 031 - 0053 PROCTER & GAMBLE PAPER

PRODUCTS CO 2676 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 INC SUMMERSVILLE 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 ENTERPRISES ELLSINORE DIV 2861 58.6 10 CSR 10 - 6.220 Restriction of Emission of Visible Air Contaminants 091 - 0038 GARNETT W OOD

PRODUCTS - CHARCOAL PLAN 2861 97.4 10 CSR 10 - 6.220 Restriction of Emission of Visible Air Contaminants 125 - 0001 KINGSFORD

MANUFACTURING CO BRIQUETT 2861 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 INC CAPE 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 -WAL KER

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 Su b part AAAAA, 40 CFR Part 60 Subpart Y, 40 CFR Part 60 Subpart HH, NOx rate/input permit limit (BACT) 139 - 0008 CHRISTY MINERALS CO HIGH 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 - PITTSBURGH 3296 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 W ELLS MONETT 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 Sub p art 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

**C ou**  **nty****** **Plant ID Facility**  **Name SIC**  **2002 NO X**  

### Emissions **Control Requirements** 145 - 0049 SOUTHERN STAR CENTRAL

GAS PIPELINE 4922 61.5 40 CFR 60 Subpart GG 023 - 0042 CENTERPOINT ENERGYPOPLAR BLUFF COM 4922 113.1 Operating Hours Permit Limit 123 - 0018 CENTERPOINT ENERGYTW ELVE 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 POW E 8221 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 W OOD - 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 SO**  **2** 

## Exceeding 50 Tons **C ou**  **nty****** **Plant ID Facility**  **Name SIC**  **2002 SO**  **2** 

### 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 LA FARGE 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 -WAL KER

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 Su b part 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 prod uction Permit Limit (BACT)

## 13

**C ou**  **nty****** **Plant ID Facility**  **Name SIC**  **2002 SO**  **2** 

### Emissions **Control Requirements** 139 - 0008 CHRISTY MINERALS CO HIGH 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 - PITTSBURGH 3296 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 Permi t Limit 213 - 0048 COLLEGE OF THE OZARKS BRANSON 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, SO X em issions 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 POW E 8221 501 10 CSR 10 - 6.260 Restriction of Emissions of Sulfur Compounds, Sulfur Emissions Rate Permit Limit, Coal Throughput Permit Limit, Multi cyclone control required, coal sulfur content permit limit 

## Table 4 **. Refined List of Missouri Facilities with 2002 Emissions of PM**  **10** 

## Exceeding 50 Tons **C ou**  **nty****** **Plant ID Facility**  **Name SIC**  **2002 PM 10**  

### Emissions **Control Requirements** 043 - 0002 CLEVER STONE COMPANY

INC - CLEVER 1422 53.9 40 CFR 60 Subpart OOO (Basic Operating Permit) 186 - 0022 TOW ER ROCK STONE CO STE. 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 INC HARRISONVILLE 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 Transfe r , 10 CSR 10 - 2.210, Control of Emissions from Solvent Metal Cleaning

021 - 0060 AG PROCESSING INC - ST.

JOSEPH - LOW E 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 Con centrations 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 PROCT ER & GAMBLE

PAPER PRODUCTS CO 2676 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 W OOD

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

**C ou**  **nty****** **Plant ID Facility**  **Name SIC**  **2002 PM 10**  

### 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 CO BRIQUETT 2861 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 INC SUMMERSVILLE 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 ENTERPRISES ELLSINORE 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/Maintenan ce 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 CO PARK 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 Efficien cies 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 Su b part 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 W ORKS LLC FULTON 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

**C ou**  **nty****** **Plant ID Facility**  **Name SIC**  **2002 PM 10**  

### Emissions **Control Requirements** 139 - 0008 CHRISTY MINERALS CO HIGH 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 SERVICES BOD 3365 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 Sub p art 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 o ff

road 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 NO X 

## , SO 2 

## , and PM 10 

## , 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 anthropogeni c emissions in 2002 from these source categories for NO X 

## , SO 2 

## , and PM 10 

## , respectively. Although the refined list includes a high percentage of PM 10 

## emissions, as mentioned in the original Regional Haze Plan, PM 10 

## emissions do not significantly contribute to visibility issues for Missouri’s Class Iareas 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 Iareas. 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 NO X 

## and SO 2 

## source emissions) , if we round up to assume that this list of sources contribute 3% of all anthropogenic SO 2 

## and NO X 

## 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 NO X 

## and SO 2 

## 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 Iareas.

## 16

**Table 5 .**  **Sum of 2002**  **Missouri point source emissions from sources that are**  **non -**  **EGU, non**   ** BART screened,** **and located outside the St. Louis PM**  **2.5** 

## nonattainment area 

## NO X 

## (Tons/y r.) SO 2 

## (Tons/y r.) PM 10 

## (Tons/y r.) 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**  

## NO X 

## (Tons/y r.) SO 2 

## (Tons/y r.) PM 10 

## (Tons/y r.) 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 s ource 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 analys is f or 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 County** **** **Plant ID Facility** 

**Name SIC**  **2002 NO X**  

### Emissions **2002 SO 2** 



### Emissions **2002 PM 10** 



### Emissions **Total**

**Emi ssions**  **D**

**Mingo (km)**  **D**

**HERC (km)**  **Q/D**

**Mingo Q/D** 

**Herc**

037 - 0007 LIMPUS QUARRIES INC HARRISONVILLE 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 TOW ER ROCK STONE CO STE. 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 - LOW E 2075 4 0 60.3 64.3 505 372 0.1 0.2 047 - 0132 AM ERICAN ITALIAN PASTA

COMPANY-AMER 2098 14 0.1 68.6 82.7 437 313 0.2 0.3 031 - 0053 PROCTER & GAMBLE

PAPER PRODUCTS CO 2676 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 W OOD

PRODUCTS - CHARCOAL PLAN 2861 97.4 0 72.9 170.3 132 105 1.3 1.6 125 - 0001 KINGSFORD

MANUFACTURING CO BRIQUETT 2861 145.7 41.3 111.2 298.2 190 194 1.6 1.5 161 - 0003 MISSOURI HARDW OOD

CHARCOAL - ROLLA PL 2861 7.3 0 88.8 96.1 164 159 0.6 0.6 203 - 0006 CRAIG INDUSTRIES INC SUMMERSVILLE 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

**County****** **Plant ID Facility** 

**Name SIC**  **2002 NO X**  

### Emissions **2002 SO 2** 



### Emissions **2002 PM 10** 



### Emissions **Total**

**Emi ssions**  **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 POW ER

TRANSMISSION PRODUCT 3052 37 156.6 11.9 205.5 273 58 0.8 3.5 187 - 0017 FLAT RIVER GLASS CO PARK 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

AM ERICA 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 -WA LKER

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 W ORKS LLC FULTON 3295 0 0 54.9 54.9 259 257 0.2 0.2 139 - 0008 CHRISTY MINERALS CO HIGH HILL 3295 94.1 225.4 70.1 389.6 230 273 1.7 1.4 159 - 0009 PITTSBURGH - CORNING

CORP - PI TTSBURGH 3296 204.3 80.7 42 327 327 221 1 1.5 009 - 0005 HYDRO ALUMINUM

WE LLS - MONETT 3351 62.8 0.2 6.6 69.6 324 86 0.2 0.8 113 - 0029 TOYOTA MOTOR

CORPORATE SERVICES BOD 3365 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 MOTORS WE NTZVILLE 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 - RI DGE 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

**County****** **Plant ID Facility** 

**Name SIC**  **2002 NO X**  

### Emissions **2002 SO 2** 



### Emissions **2002 PM 10** 



### Emissions **Total**

**Emi ssions**  **D**

**Mingo (km)**  **D**

**HERC (km)**  **Q/D**

**Mingo Q/D** 

**Herc**

123 - 0018 CENTERPOINT ENERGYTW ELVE MILE COMP 4922 152.5 0 0.6 153.1 44 240 3.5 0.6 145 - 0049 SOUTHERN STAR

CENTRAL GAS PIPELINE 4922 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 TEX

AS 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 POW E 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 W OOD - 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**  **County****** **Plant ID**  **Facility**

**Name SIC**  **2002 NO X**  **Emissions 2002 SO**  **2**

**Emissions 2002 PM**  **10**

**Emissions Total** 

**Emissions Q/D** 

**Mingo Q/D** 

**Herc** 035 - 0004 ROYAL OAK ENTERPRISES ELLSINORE 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 INC CAPE 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

PM 10 

## 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 Iareas. Aqualon Division of Hercules is located more than 250 km from either of Missouri’s federal Class Iareas. A Compliance Agreement b etween 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 SO 2 

## and NO X 

## emissions from the facility.

## 20



## Lone Star Industries installed an oxygen injection system in 2006 to control their SO 2 

## and NO X 

## emissions. This control system reduced their actual SO 2 

## emissions by over 90%. The control system also reduced NO X 

## emissions by over 30%. The addition of this control equipment, which was included in their construction permit #112006

- 012, satisfies the four factor analys is for this facility . Chemical Lime Company was issued their original construction permit in 1994 at which time they underwent a BACT analys is for PM 10 

## , NO X 

## , and SO 2 

## . 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 NO X 

## 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. 

# C **hapter 2 –**  **Best Available Retrofit Technology Se**  **ction 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 marke d 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 o f this technical supplement includes the updated table with enhanced supporting justification for exempting these sources from BART . First a search was done on the ty pe 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 s ources 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 ex amination . The majority of these sources have relatively recent operating permits. The Air Program reviewed these sources to determine BART applicability b ased 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 . Inaddition, 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 re cently 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 Iof 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, Dy no 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, PM 10 

## emissions from several facilities were not modeled. In addition, Table 9 also shows that Exide Technologies’ SO 2 

## emission and Dy no 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 SO 2 

## PM 10 

## NOx SO 2 

## PM 10 

### 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 mo delers, 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 Iareas. Q is total potential emissions in tons for total of NOx , PM 10 

## , and SO 2 

## , and D is the distance in kilometers from the fac ility to the nearest receptor in the Class IArea. As a rule of thumb, EPA advised that i f Q/D is greater than 10, the percentage of Q/D from PM 10 

## can be examined to determine if further impact modeling analys es are needed. As mentioned previously, PM 10 

## 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 b y pollutants that originate from NOx and SO 2 

## emission. Table 10 summarizes the Q/D analys is. **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 SO 2 

### PM 10 

### 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 , 1 09.8 104 284 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**  **Impact s**  **with Individual**  **Species Contributions** Facility Year Day Delta (DV) %_SO 4 

## %_NO 3 

## %_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 IAreas, and its Q/D values for both Class I Areas are less than 10. Its hi ghest screen modeling impact on Hercules was 0.024 deciviews . Even if the additional 192.3 tons of SO 2 

## 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 PM 10 

## 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 (SO 4

## ) (99.59%) as shown in Table 11 . The impact from fine particulate matter (PMF) is 0.0%. Since PM 10 

## was speciated (modeled) as PMF in Calpost, this indicates that PM 10 

## does not have significant impact and these additional emissions would not have a measure impact on Doe Run’s dV on either Class IArea. Dy no 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 PM 10 

## , 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 0.3 67 deciviews . Adding 133.3 tons of PM 10 

## , 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 c ame from PMF and most of the impact was from NO 3 

## ( 83.56% ) . As mentioned above , s ince PM 10 

## was speciated as PMF in Calpost, this minimal impact of PMF in the modeling results indicates that PM 10 

## does not have significant impact on Mingo . Noranda Aluminum’s highest refined modeling impact using method 6 was 0.43 5 deciviews . Adding 9.1 tons PM 10 

## would not result in impacts above the 0.5 deciview since SO 4 

## had the dominant imp act on Mingo as shown in T able 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 analys is 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 1 2**  **. Screen**  **ing 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 analys es and the previous screening evaluation was the use of meteorological observations in the development of the CALMET fi les used in the CALPUFF evaluations. The emission rates were consistent between the screening analyses and the refined analys es, as were the meteorological ye ars for the evaluation (2001

- 2003). Table 1 3 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 98 th 

## percentile as per the refined modeling guidance. It is clear that the facility does not have impacts on both Class IAreas above 0.5 deciview. **Table 1 3**  **. 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 Iareas. 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 1 4 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 1 4**  **. 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 Iareas. 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 1 4 . CENRAP did not perform the calculations based on the New IMPROVE algorithm for Missouri’s two federal Class Iareas for the 20% best visibility days . , Instead, the CENRAP analysis focused on the requirement that no degradation to vis ibility 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% vis ibility 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 ye ar (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.