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Region 7 Air Program

Serving Iowa, Kansas, Missouri, Nebraska and 9 Tribal Nations

St. Louis, Missouri, 15 Percent Rate-of-Progress Plan (ROPP)

Background of the Plan: The St. Louis area (encompassing Madison, Monroe and St. Clair Counties in Illinois; and Franklin, Jefferson, St. Charles, and St. Louis Counties, and the City of St. Louis, Missouri) was designated nonattainment with respect to the 1-hour ozone standard in 1978. After the Clean Air Act (CAA or Act) amendments of 1990, the area was classified as a moderate ozone nonattinment based upon its design value of 0.138 parts per million. The design value is based upon the ambient air quality as measured by ozone monitors in the area. A statutory attainment date of November 15, 1996, was established for all moderate nonattainment areas.

Section 182(b)(1)(A) of the Act requires that each state in which all or part of a moderate nonattainment area is located, submit, by November 15, 1993, a State Implementation Plan (SIP) revision providing for a 15 percent (net of growth) reduction in emissions of volatile organic compounds (VOCs) by November 15, 1996. The 15 percent reduction is to be measured from calendar year 1990 baseline emissions and be "net" of any growth that occurs in the nonattainment area after November 15, 1990. Reductions are generally creditable toward the 15 percent reduction requirement, with the exception of reductions achieved by the Federal Motor Vehicle Control Program (FMVCP) promulgated prior to 1990; reductions from requirements to lower the Reid Vapor Pressure (RVP) of gasoline promulgated prior to 1990 or required under section 211(h) of the Act which restricts gasoline RVP; reductions from corrections to an existing Vehicle Inspection and Maintenance Program (I/M); or reductions from corrections to certain Reasonably Available Control Technology (RACT) rules. This type of SIP is commonly know as a rate-of-progress plan or a ROPP.

On March 18, 1996, EPA proposed a limited approval and limited disapproval of Missouri's January 13 and July 11, 1995, ROPP submittals (61 FR 10968). In the same notice, EPA also proposed to conditionally approve the state's municipal solid waste landfill and clean-up solvent rules, two components of the ROPP. On July 2, 1997, EPA issued a subsequent proposal to approve Missouri's landfill and gasoline Reid Vapor Pressure rules.

On November 12, 1999, EPA received a revised ROPP and a request to amend the Missouri SIP. The revised plan is significantly different from the previous version. EPA proposed approval of the revised ROPP on February 17, 2000 (65 FR 8083) and approved it on May 18, 2000 (65 FR 31485).

Summary of the Plan: The ROPP established the 1996 target level of VOC emissions for the Missouri portion of the St. Louis ozone nonattainment area at 265.11 tons per day (tpd). This is the level of anthropogenic VOC emissions which must be reached in the St. Louis nonattainment area in order for the area to meet the 15 Percent Plan requirements of the Act. To meet the emissions target, VOC emissions must be reduced by 104.32 tpd. Of the required 104.32 tpd reduction, 64.38 are creditable towards the ROPP requirements of the CAA. Missouri achieved the required reductions through a combination of 19 state and 9 Federal control measures. With one exception for the rule for controlling emissions from solvent metal cleaning (10 CSR 10-5.300), EPA approved all applicable state regulations in separate rulemakings. EPA's May 18, 2000, action on the ROPP approved the solvent metal cleaning rule and the estimated reductions from all control measures.

Emission Reductions: The control measures and associated emission reduction credits for the ROPP are summarized in the table below.

VOC Control Strategies

Centralized Enhanced I/M          19.82
Reformulated Gasoline (RFG)          12.46
Nonroad RFG Benefits            2.62
Fuel Distribution Benefits            0.76
Tier I Standards            0.60
Transportation Control Measures (TCMs)            2.08
SUBTOTALS           39.06

Hazardous Organic NESHAPs            0.08
Solvent Cleaning            0.91
Petroleum Liquid Storage, Loading, and Transfer            4.20
Open Burning Ban            2.60
Voluntary Reductions            0.14
Landfill Gases            1.48
Alumax Foils, Inc.            3.00
Slay Bulk Terminal            0.74
Architectural and Industrial Maintenance (AIM) Coatings (pending)            3.05
Automobile Refinishing            0.78
Federal Nonroad Small Engine Standards            1.22
Consumer/Commercial Products Solvent Control            3.27
Permanent Plant Closings            3.48
Solvent Metal Cleaning            0.64
SUBTOTALS           25.59
TOTAL REDUCTIONS           64.65

Stationary Source Regulations: The following Missouri stationary source rules were approved in support of the ROPP:

Reductions from permanent plant closings were also creditable to the ROPP. Two sources within the nonattainment area, Leonard's Metal, Inc., and Mallinckrodt Specialty Chemical Company, have permanently reduced their VOC emissions such that they are creditable towards the ROPP.

Federal Control Measures: The following Federal control measures are also relied on in the SIP:

  • Control of VOC Emissions from Architectural and Industrial Maintenance (AIM) Coatings

  • Control of VOC Emissions from Autobody Refinishing Operations

  • Tier I Federal Motor Vehicle Control Program (FMVCP)

  • Hazardous Organic National Emission Standards for Hazardous Air Pollutants

  • Gasoline Detergent Additives

  • VOC Emissions Reductions from Federal Nonroad Small Engineer Standards

  • VOC Emission Reductions from Consumer and Commercial Products Solvent Control

Mobile Source Control Measures: Mobile source control measures approved in the plan include:

  • Centralized Enhanced Vehicle Inspection/Maintenance (I/M) program (10 CSR 10-5.380)

  • Federal Reformulated Gasoline (RFG) Onroad Mobile Sources Fuel Control Program

  • Federal RFG Nonroad Mobile Sources Fuel Control Program

  • Transportation Control Measures

The ROPP also established a motor vehicle emissions budgets (MVEB) used to ensure that transportation plans conform to the SIP, see 40 CFR 52.1321 (e). The budget is shown in the following table.

Missouri 2004 MVEB for Conformity Purposes

Pollutant MVEB (tons/day)
VOC 69.48
NOx none

EPA Region 7 Contact: Josh Tapp, (913) 551-7606, tapp.joshua@epa.gov

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