# Exhibit 1Calendar No. 1214

91ST CONGRESS I { REPORT

2d Session f SENATE 1 1196

NATIONAL AIR QUALITY STANDARDS
ACT OF 1970

REPORT

OF THE COMMITTEE ON PUBLIC WORKS
UNITED STATES SENATE

5-311 0 TOGETHER WITH INDIVIDUAL VIEWS

TO ACCOMPANY

S. 4358

SEPTEMBER 17, 1970.-Ordered to be printed

U.S. GOVERNMENT PRINTING OFFICE
WASHINGTON : 1970COMMITTEE ON PUBLIC WORKS
JENNINGS RANDOLPH, West Virginia, Chairman STEPHEN M. YOUNG, Ohio JOHN SHERMAN COOPER, Kentucky EDMUND S. MUSKIE, Maine J. CALEB BOGOS, Dlware B. EVERETT JORDAN, North Carolina HOWARD H. BAKER, JR., Tennessee BIRCH BAYH, Indiana ROBERT J. DOLE, Kansas JOSEPH M. MONTOYA, New Menico EDWARD J. GURNEY, Florida WILLIAM B. SPONG, JR., Virginia ROBERT W. PACKWOOD, Oregon THOMAS F. EAGLETON, Missouri MIKE GRAVEL, Alaska RICHARD B. ROYcE, Chief Clerk and Stag Diiedor J. B. Huye, Jr., Aeistat Chief Clerk and Assistant Staf Dieor BARRY MEYER, Counsel BAILEy GUAR, Aeeitaln Chief Clerk (Minority) TOM C. JoRLrNo, Minority Contel Professional Stag Members: JOSEPH F. VAN VLDRicKEN, LEON 0. BILLINGS, RICHARD D. GROUND, STEWART E. MCCLURE, ADeIEN WALLER, HAROLD H. BRAYMAN, RICHARD W. WILSON, JOHN YAO, and PHILIP T. CummnmoS (I)CONTENTS

Fag. G general statem ent ------------------------------------------------ I H ea rin g s --- ------------ ----. -. ---- ------------ ------------ - . . . . . . 4 D iscussion of in tent ----------------------------------------------- 4 Research relating to fuels and vehicles -------------------------- 4 Grants for support of air pollution programs ------------ 5 Interstate air quality agencies ---------------------------------- 6 Research relating to air pollution effects -------------------------- 7 Air quality control regions -- -- -- -- -- -- -- -- -- -- -- -- - 8 Air quality criteria and control techniques.------------ 9 National air quality standards and goals -------------- 9 Im plem entation plans ------------------------------------------ 11 State standards and plans to achieve greater air quality control ------ 15 New source standards of performance.-------------- 15 National emission standards-selected air pollution agents ---------- 18 National emission standards-hazardous air pollution agents -------- 20 Federal enforcem ent - - - - - - - - - - - - - - - - - - - - -- 21 Control of pollution from Federal facilities ------------- 23 Establishment of standards

- - - - -- - - - -- - - - -- - - - - 23 Prohibited acts-Injunction proceedings-Penalties ------------ 28 Certification and production model testing ------------- 28 Motor vehicle and motor vehicle engine compliance testing --------- 29 S ta te g ra n ts

------- ------ ----- - ---- -- -- ---- ------ ----- - 3 1 R ecords and reports ---------- --- .---- .- -------- .........- 3 1 State standards

- - - - - - - - - - - - - - - - - - - - - - -- 32 U sed v ehi cles ------ ---- - ----- ---- - ----- ----- ----- ----- 32 Registration and regulation of fuels and fuel additives

............... 33 Development of low-emission vehicles_--------------- 35 D efi n itio n s -- --- -- --- -- - -- ----- ---- -- --- ---- --- --- --- --- 3 5 A p p lica b ility ------- ------ ------ ------ --- --- ------ ----- - 35 E m ergency pow ers -------------------------------------------- 35 C itizen su its

-- ------------- - ---- -------- --- ---------- ----- 36 A p p ea ra n ce --- ---- -- ---- ----- - --- --- - -- ---- ---- - - -- -- -- 3 9 Federal procurem ent -------------- ------------- ------------- 39 E m ployee protection -------------- ------------- ------------- 40 Ju dicial review --------- --------- -------- ----- ---- -------- 40 M andatory licensing ------ ----- ----- ----- ----- ----- ----- 42 P olicy review --------- - -------- --------- --------- -------- 4 3 A u th orization s --------------- - -------------------------------- 44 N oise p ollu tion ----------- ----------- ---------------------- 4 5 Individual views: H on. R obert J. D ole ----- ---- ----- ---- ---- ----- ---- ---- 47 H on. Edward J. G urney ------------------- ------------------- 50 Section-by-section analysis ------------------------------------- 52 C hanges in existing law --------------------------------------- 68
(IM)

# Calendar No. 1214

91ST CONGRESS )SENATE REPORT

2d Session I No. 91-1196

NATIONAL AIR QUALITY STANDARDS ACT OF 1970

SEPTEMBER 17, 1970.-Ordered to be printed

Mr. BYRD of West Virginia (for Mr. MUsKIE, from the Committee

on Public Works, submitted the following

REPORT
together with

INDIVIDUAL VIEWS

[To accompany S. 4358]

The Committee on Public Works, to which the bill (S. 4358),
to amend the Clean Air Act as amended, was referred having considered the same, reports favorably thereon without amendment. An original bill (S. 4358) is reported in lieu of S. 3229, S. 3466, and S. 3546 which were considered by the Committee.

GENERAL STATEMENT

The committee bill would restructure the methods available to attack a critical and growing national problem of air pollution.

The legislation reported by the committee is the result of deep

concern for protection of the health of the American people. Air pollution is not only an aesthetic nuisance. The Committee's concern with direct adverse effects upon public health has increased since the publication of air quality criteria documents for five major pollutants (oxides of sulfur, particulates, carbon monoxide, hydrocarbons and oxidants). These documents indicate that the air pollution problem is

more severe, more pervasive, and growing at a more rapid rate than

was generally believed.

The new information that carbon monoxide concentrations at levels damaging to public health occur in Chicago more than 22 percent of the time, and that other cities have similar problems with carbon monoxide and other pollutants, intensified the committee's concern to authorize a massive attack on air pollution. This bill is designed to provide the basis for such an attack.Although the nature of the attack will differ from region to region,

one objective will be the same: Air quality standards protective of the health of persons must be achieved within the 3-year period of the approval of plans to implement ambient air quality standards. The right of States to set more stringent standards of air quality has been preserved. Maintenance of existing high quality air is assured through provision for maximum control of new major pollution sources.

The protection of public health-as required by the national ambient air quality standards and as mandated by provision for elimination of emissions of extremely hazardous pollution agentswill require major action throughout the Nation. Many facilities will require major investments in new technology and new processes. Some facilities will need altered operating procedures or a change of fuels. Some facilities may be closed.

The requirements for State action will be broadened. And the obligation on polluters will be greatly increased. What has been a program focused on uniquely critical areas, underfunded and inadequately manned, will become truly national in scope and will require an immediate increase in personnel and funding.

Implementation of standards will require other changes in public policy: Land use policies must be developed to prevent location of facilities which are not compatible with implementation of national standards.

Transportation policies must be developed or improved to assure that the impact of pollution from existing moving sources is reduced to the minimum compatible with the needs of each region. Construction of urban highways and freeways may be required to take second place to rapid and mass transit and other public transportation systems. Central city use of motor vehicles may have to be restricted.

Fuel policies must be developed to provide for use of clean fuels in urban areas. Development of control technology for fuel combustion byproducts must be accelerated. Greater use of natural gas for electric power generation may be required. And, to the extent that low sulfur coal and oil are available, they may be required for generating stations and home heating units in critical areas. Fuel import policies may need to be reevaluated. If the Nation is to continue to depend on individual use motor vehicles, such vehicles must meet high standards. The bill recognizes that a generation-or ten years' production-of motor vehicles will be required to meet the proposed standards. During that time, as much
as seventy-five percent of the traffic may have to be restricted in certain large metropolitan areas if health standards are to be achieved within the time required by this bill.

In the Committee discussions, considerable concern was expressed regarding the use of the concept of technical feasibility as the basis of ambient air standards. The Committee determined that 1) the health of people is more important than the question of whether the early achievement of ambient air quality standards protective of health is technically feasible; and, 2) the growth of pollution load in many areas, even with application of available technology, would still be deleterious to public health.Therefore, the Committee determined that existing sources of pollutants either should meet the standard of the law or be closed down, and in addition that new sources should be controlled to the maximum extent possible to prevent atmospheric emissions.

The committee also was concerned that public participation, a unique feature of the Air Quality Act of 1967, should be preserved. The national air quality standards concept should not restrict effective citizen action. Not only does the bill assure an opportunity for a region to adopt standards more restrictive than the national standard, but public hearings on implementation plans also must be held. More importantly, the committee believes that public participation should not be limited to the development of standards and plans.

The proposed legislation emphasizes the need to accelerate enforcement action. To assure that Federal and State agencies aggressively pursue their responsibilities and to supplement their capacities, the bill provides a right of citizen action to seek enforcement of the provisions of the act. Actions to abate violations of timetables, of implementation schedules, of emission requirements, of performance and emission standards and of prohibitions can be initiated by the public.

The bill would provide other important tools to protect public health and to assure effective implementation of the purposes of the Act. By providing authority to prohibit the emission of pollutants which present a clear hazard to health, the bill shifts the burden of proof to the polluter to identify safe emission levels.

Extensive research must be carried out to accelerate knowledge of pollution effects and control methods. New motor vehicle engines must represent substantial improvements over existing systems. The sale of fuels which would hinder effective, economic emission control systems can be prohibited.

Under the provision which would require mandatory licensing of pollution control techniques, technology (not otherwise available) that is developed to control emissions from either moving sources on new or hazardous sources would be available to any polluter.

The extent of Federal involvement in the development and maintenance of air pollution control programs would be broadened. The pace and degree of enforcement will be quickened.

The bill, for the first time, would establish a Federal capability to evaluate the problems of environmental noise and requires legislative recommendations to the Congress. While noise is not an "air pollutant" in the classic sense, it is a growing environmental problem which is national in scope and requires intensified evaluation and greater understanding. By authorizing the establishment of an Office of Noise Abatement Control, the bill would provide the proposed Environmental Protection Agency with a capacity to deal with this growing problem.

The committee emphasizes that the act, the deadlines proposed, and the new programs authorized will be without meaning unless supplemental manpower (doubling present staffing of National Air Pollution Control Administration) and supplemental funding (an increase of at least $44 million over the present budget request) are provided in this fiscal year.

Failure by the Executive Branch to request and Congress to approve these needed increases will substantially impair implementation of thislegislation and make both the executive and legislative branches subject to charges of lack of commitment.

Within a short period, the pressures for additional staff and funds will also be felt by the States. Should the States fail to respond to that pressure, the deadlines established by the Act would require broader Federal involvement in regional and State programs.

In sum, this bill would extend the Clean Air Act of 1963 as amended in 1965, 1966, and 1967 to provide a much more intensive and com- prehensive attack on air pollution. It would establish that the air is a public resource, and that those who would use that resource must protect it from abuse, to assure the protection of the health of every American.

HEARINGS

Following enactment of the Air Quality Act of 1967, the Subcommittee on Air and Water Pollution held 13 days of oversight hearings in 1968 and 1969 on the progress and problems associated with the control of air pollution. The subjects covered included interstate air pollution com pacts, air quality criteria, and a field hearing on air pollution problems in St. Louis, Missouri. In addition, 2 days of joint hearings were held with the Senate Commerce Committee on alternatives to the internal combustion engine.

On December 10, 1969, Senator Muskie introduced S. 3229, the Air Quality Improvement Act and Senator Montoya introduced Amendment No. 501 on fuels regulation on February 18, 1970. The Administration bill, S. 3466, the Clean Air Act Amendments of 1970, was introduced by Senator Scott on February 18, 1970. Senator Muskie introduced S. 3546, the National Air Quality Standards Act on March 4, 1970. Subsequently, 11 days of hearings were held in Washington, D.C. Three additional days of hearings were held in joint session with the Commerce Committee on legislation related to low-emission alternatives to the internal combustion engine (S. 3072).

In total, the Subcommittee on Air and Water Pollution held 15 days of oversight hearings in 1968 and 1969, and 15 days of legislative hearings in 1970.
DISCUSSION OF INTENT

SECTION 104. RESEARCH RELATING TO FUELS AND VEHICLES The Air Quality Act of 1967 provided increased emphasis on re- search relating to fuels and vehicles. This provision included two special features not contained in the general research authority of section 103 of that act. First, appropriated funds were to remain available until expended, providing needed flexibility in the planning and scheduling of research and development and demonstration projects. Second, a legal basis was established for supporting demonstration projects involving the construction and installation of pollution con- trol equipment in profit making facilities in order to gain maximum benefit from expertise in the practical application of technology.

The amendments to section 104 contained in the bill, as reported, would provide increased emphasis on (1) fuel cleaning prior to com- bustion; (2) new and improved methods for combusting fuels which result in decreased atmospheric emissions; (3) methods for producing synthetic or new fuels which have a lower combustion potential forcreating air pollution; and (4) increased efforts to develop and demonstrate alternatives to the internal combustion engine.

The legislation also would provide authority to make fleet purchases of low emission vehicles for research, development, and testing purposes which would involve purchase of 300 or more cars of a particular design, subject to actual operation and testing. The National Air Pollution Control Administration has developed a 6-year plan (fiscal 1970 to 1975) which contemplates expenditures of $89.1 million for the development of low-emission alternatives to the internal combustion engine. This plan includes both the control of emissions from conventional motor vehicles, and the development of unconventional low pollution motor vehicles. New authority for purchase of cars for research, development, and testing is intended primarily to facilitate this program.

The current research and development effort for controlling emissions from stationary sources has emphasized flue gas treatment and fuel cleaning (removal of contaminants from fuels before use). Increased emphasis should be placed on fuel cleaning as a method for reducing atmospheric emissions.

The Committee also intends that increased emphasis be placed on improving fuel combustion efficiencies. Although flue gas control technology offers a potential for improvement, the long-term answers may lie in magnetohydrodynamics, fuel cells and other energy con- version processes which emit less pollution per unit of fuel or per unit of energy.

The Committee recognizes that variations in the choice of fuels among different regions may offer a potential for reducing air pollution levels. However, fuels with a minimal adverse impact on the environment-such as natural gas and low sulfur fuels-may only be available in limited quantities. The bill therefore would authorize the development and demonstration of methods to produce synthetic
or new fuels for both stationary and moving sources which will result in decreased atmospheric emissions.

The bill would authorize $450 million to carry out the provisions of this section: $125 million for fiscal year 1971; $150 million for fiscal year 1972; and $175 million for fiscal year 1973. Appropriations at that level could substantially accelerate the nation's capacity to reduce air pollution and to achieve and maintain high ambient air quality.

SECTION 105. GRANTS FOR SUPPORT OF AIR POLLUTION PLANNING AND

CONTROL PROGRAMS
The Committee expects that the grantmaking authority in section 105 will be used to make three-to-one support (three-to-two in the
case of maintenance support) grants available to States where the States are initiating or operating regional air pollution control programs. The intent is to enable States to qualify for the same degree of Federal support now available to intermunicipal and interstate agencies engaged in regional air pollution control activities. Stateoperated regional programs should supplant municipal or intermunicipal programs only in those cases where it is clearly advantageous, from the standpoint of effective air pollution control and efficient utilization of resources.There are a number of ways a State agency could establish such regional programs, and States should use their own administrative and organizational structure to achieve this purpose in a manner most suitable to their respeQ tive needs. In at least one State, Massachusetts, State supported regional programs are operating for the Boston and Springfield metropolitan areas. The Federal grant support to these programs would, however, be made to the State agency which in turn would fund the regional program; the employees of such regional programs are to be considered State employees.

Acting under section 301 (a) of the Clean Air Act, the administration has formulated a plan for assigning Federally-employed personnel to State air pollution control agencies for periods of up to two years. The purpose of the plan is to help States build up their manpower resources. After a two-year assignment, each Federal employee in this program would be available for State employment, presumably in the
same agency to which he had been detailed. The authority for the Department to make such personnel assignments would be retained; the additional provision in section 105 would authorize the Department to make such assignments in lieu of cash awards under a grant.

It is the intent of the Committee, that as a condition for Federal grant support, air pollution control agencies either applying for, or receiving such support shall vigorously attack air pollution problems within their area of jurisdiction and effectively coordinate their efforts with those of the Federal air pollution control program. In order to achieve such performance inprograms receiving Federal support, the Secretary would be authorize to suspend or deny such assistance until the performance of such program is adequate.

SECTION 106. INTERSTATE AIR QUALITY AGENCIES Section 106 of the 1967 act authorized Federal support of up to 100 percent of the costs of interstate air quality planning programs for 2 years in order to expedite the development of regional control programs in interstate areas. The purpose of this provision was to provide a mechanism for planning in a coordinated fashion throughout regions where, except for State boundaries, the problems of air quality control are common.

It was hoped that planning agencies such as Councils of Government and regional planning commissions would be used. These agencies now function in some areas to provide consistency of approach between States and among local jurisdictions on a number of common problems, and were expected to perform

. similar function for air quality planning.

The Uommittee is disappointed that the provisions of Section 106 have never been implemented, and that no interstate planning agency has been activated. The success of future regional efforts in air quality control requires sound planning and coordination of planning efforts
on a comprehensive, regional basis. The bill, therefore, would retain the planning provision, but would delete the authority for the Secretary to establish Federal regional commissions to plan for imple- mentation of air quality standards. The rigid timetables proposed by this legislation would obviate the value of this authority.SECTION 107. RESEARCH RELATING TO AIR POLLUTION EFFECTS
The Committee believes increased research is needed on the public health and welfare effects of air pollution agents-particularly longterm effects. This effort should be directed toward the accelerated development of more comprehensive air quality criteria.

The protection of the public health and welfare requires definitive knowledge of the causal relationships between exposure to air pollution agents-singly or in combinations-and health or welfare under varying environmental conditions. Knowledge of the relationship between the exposure to many air pollution agents and acute and chronic health effects is sufficient to develop air quality criteria related to such effects. Our knowledge of some of the chronic effects involving extended exposure over a period of years is limited. Increased research activities should concentrate in this area.

Concern for health effects must extend beyond "normal" segments of the population to effects on the very young, the aged, the infirm, and other susceptible individuals. Research efforts also must be directed toward improving knowledge of the causal relationships involving impacts on socio-econoic conditions, vegetation, and materials.

The legislation would provide for an accelerated research program to improve knowledge of the contribution of air pollution agents to the

occurrence of adverse effects on health.

The Committee anticipates that attention will be given to the following areas: (1) The contribution of air pollution agents to the etiology of disease, including the health significance of physiological, toxicological, and biochemical effects;

(2) The additive and synergistic effects of exposure to air pollution agents;

(3) The health and welfare significance of the storage and accumulation of air pollution agents and their metabolites in human organs and tissues;

(4) The influence of air pollution agents on the impairment of human functions, increased accidents or absenteeism;

(5) The contribution of age, ethnic, social, occupational, smoking and other factors to susceptibility to air pollution agents; and

(6) The development of models to predict the public health and welfare effects of exposure to air pollution agents, singly
or in combination. The bill also would provide for the furtherance of knowledge on welfare effects, including effects on vegetation, animals, wildlife, buildings, structures, and materials. This research effort should extend into welfare effects and aesthetics in their broadest definition, including the economy, visibility, weather, and climate.

Because prospective studies on the long-term effects of air pollution often extend beyond normal contract periods, and in order to maintain

a continuity with respect to such epidemiological, clinical, and laboratory studies, the bill would provide contract authority for periods up to 10 years. For the purpose of carrying out this specific contract research, the bill provides an authorization of $15,000,000.

The ongoing research on health and welfare effects carried out under section 103 should not be replaced, but should be supplemented by thisauthority. It is important that health research activities authorized by this Act supplement research in other agencies. Careful evaluation of proposed research projects should precede funding to avoid duplication.
SECTION 108. AIR QUALITY CONTROL REGIONS

The Committee intends that the proposed revision of the procedure for the designation of air quality control regions will provide for early completion of this process. The new provisions would not eliminate the requirements for delineation of regional boundaries on the basis of factors that have a significant bearing on the implementation of air quality standards, such as meteorological, topographical, and urbanindustrial factors which influence the distribution and concentration of pollution agents.

Ambient air standards designed to protect the health of persons must be implemented throughout the entire territory of every State. However, to attempt to do so through application of a single imple- mentation plan for an entire State would overlook the fact that various sections of a State often may require substantially different emission control strategies. Each strategy must insure attainment of a quality of ambient air designed to protect the health of persons in all parts of the area to which the strategy is applied.

Accordingly, the bill would provide 90 days for the Secretary to complete designation of air quality control regions in interstate and major intrastate air pollution problem areas. This period is considered to be a sufficient time for completing the designation of air quality con- trol regions for the 91 areas already proposed for such designation. It is also considered to be sufficient time for the Secretary to designate additional air quality control regions covering interstate areas or any intrastate areas where there are major air pollution problems associated with particular concentrations of population and industry.

It should be noted that this 90-day period would produce no delay in the establishment and implementation of ambient air quality standards, since it would coincide with the period for the promulgation of national ambient air quality standards for pollution agents for which criteria have been issued. Moreover, any area of a State not included in an air quality control region designated by the Secretary during this period would automatically be considered an air quality control region for the purposes of the Act. In each State, the area not included in air quality control regions designated by the Secretary could be subdivided by the State into two or more air quality control regions. This step, which would take no additional time, would be accomplished as part of the State's plan for implementation of the national air quality standards and would be subject to review by the Secretary at the time that implementation plans are submitted for approval.

It should be emphasized that the provision for subdivision of States into regions is included in the bill to insure that factors bearing
on effective implementation of air quality standards such as meteotology, topography, and urban-industrial concentrations will take precedence over mere administrative convenience. In other words, while it is considered necessary that areas not covered by the Federal designation process shall be designated as air quality control regions without further delay, it is also considered essential that States, in cooperation with the Secretary, make a determination as to whethersuch areas ought to be subdivided to effectively implement air quality standards.

SECTION 109. AIR QUALITY CRITERIA AND CONTROL TECHNIQUES This proposed legislation would require acceleration of the issuance of air quality criteria and information on control techniques as an integral part of the system for adoption of ambient air quality standards and implementation plans.

Pollution agents which would be subject to the provisions of this section would be those which are emitted from widely distributed air pollution sources and generally present in the ambient air in all
areas of the Nation.

Air quality criteria for five pollution agents have already been issued (sulfur oxides, particulates, carbon monoxide, hydrocarbons, and photochemical oxidants). Other contaminants of broad national impact include fluorides, nitrogen oxides, polynuclear organic matter, lead, and odors. Others may be added to this group as knowledge in-
creases. The bill would require that air quality criteria for these and other pollutants be issued within 13 months from enactment. If the Secretary subsequently should find that there are other pollution agents for which the ambient air quality standards procedure is appropriate, he could list those agents in the Federal Register, and repeat the criteria process.

Reports on control techniques, as under existing law, would be issued simultaneously with the publication of criteria. The Committee recognizes that the States will continue to need this information to develop meaningful programs for implementation of ambient air quality standards on a regional basis.

The Committee believes that criteria and control technology documents should be periodically reviewed and re-issued to ensure currency. In addition, control techniques information should be periodically modified to reflect information developed under sections 104 and 113.

The Secretary would also be required to issue information on control techniques for air pollution agents for which emission standards are to be established under Section 114 and Section 115 and for which

new source standards of performance are to be established under Section 113. It is expected that the Secretary would provide documentation, as appropriate, on the control techniques, methods, processes, or systems available for the purpose of complying with such emission standards or standards of performance.

The Committee does not intend that the recommended control techniques documents should lock in existing technology. As was pointed out by Dr. Aaron Teller, "the inhibition of innovation is the most dangerous consequence of this language. Air pollution control requires a new and unique technology."

The Committee intends that the information provided pursuant to this section should serve as guidance to States, not as limitations on control technology innovation.

SECTION 110. NATIONAL AIR QUALITY STANDARDS AND GOALS This section would provide for publication and promulgation of na- tional ambient air quality standards at a level which will protect the health of persons. In setting such air quality standards the Secretaryshould consider and incorporate not only the results of research sum- marized in air quality criteria documents, but also the need for margins of safety. Margins of safety are essential to any health-related en- vironmental standards if a reasonable degree of protection is to be provided against hazards which research has not yet identified.

Following the publication of any proposed national ambient air quality standard, the Secretary would provide up to 90 days for the receipt and evaluation of comments. Since the issuance of air quality criteria would precede the promulgation of such national standards, and since expert advisory committees would continue to be consulted in the preparation of air quality criteria, 90 days is considered sufficient time for the presentation and evaluation of additional information and opinions that may have a bearing on the national ambient air quality standards.

Although the option of adopting ambient air quality standards
more stringent than the national health minimum for any air quality control region is preserved for the States, the Secretary would be required to set a national minimum standard of air quality which will protect the health of persons regardless of where such persons reside. This mechanism is recommended by the committee to expedite the establishment and implementation of ambient air quality standards.

In requiring that national ambient air quality standards be es- tablished at a level necessary to protect the health of persons, the Committee recognizes that such standards will not necessarily provide for the quality of air required to protect those individuals who are otherwise dependent on a controled internal environment such as patients in intensive care units or newborn infants in nurseries. However, the Committee emphasizes that included among those persons whose health should be protected by the ambient standard are par- ticularly sensitive citizens such as bronchial asthmatics and emphyse- matics who in the normal course of daily activity are exposed to the ambient environment. In establishing an ambient standard necessary to protect the health of these persons, reference should be made to a representative sample of persons comprising the sensitive group rather than to a single person in such a group.

Ambient air quality is sufficient to protect the health of such persons whenever there is an absence of adverse effect on the health of a statistically related sample of persons in sensitive groups from ex- posur3 to the ambient air. An ambient air quality standard, therefore, should be the maximum permissible ambient air level of an air pollu- tion agent or class of such agents (related to a period of time) which will protect the health of any group of the population.

For purposes of this description, a statistically related sample is the number of persons necessary to test in order to detect a deviation in the health of any person within such sensitive group which is attributable to the condition of the ambient air.

Within 30 days after enactment the Secretary would be required to publish proposed national air quality standards for those pollutants covered by existing air quality criteria (sulfur oxides, particulate matter, carbon monoxide, hydrocarbons, and photochemical oxidants). Since these criteria have been available for some time, it is realistic to expect that proposed national standards for these five pollution agents would be published within the 30-day period. Proposed national air quality standards for pollutants for which criteria would be issuedsubsequent to enactment would be published simultaneously with the issuance of such criteria. These pollutants would include nitrogen oxides, lead, polynuclear organics, odors, and fluorides.

National air quality standards are authorized because the Committee has recognized that protection of health is a national priority, but the Committee also recognizes that man's natural and man-made environment must be preserved and protected. Therefore, the bill provides for the setting of national ambient air quality goals at levels necessary to protect public health and welfare from any known or anticipated adverse effects of air pollution-includ'ng effects on soils, water, vegetation, man-made materials, animals, wildlife, visibility climate, and economic values. To implement this provision the sections of existing law relating to the issuance of air quality criteria have been modified to require that air quality criteria documents include, to the extent practicable, information on any known or anticipated adverse effects of air pollution, including such effects on all the environmental and economic values listed above. Those criteria which have been issued as well as those planned for January of 1971 must be revised to include this information. Until such revisions are made, the Secretary should publish interim guidelines to assist the States in developing plans for the implementation of goals.

The Committee is aware that there are many gaps in the available scientific knowledge of the welfare and other environmental effects of air pollution agents. As indicated in the discussion of section 107, the Committee expects that the Department will intensify research on environmental and other economic effects of air pollution. A great deal of basic research will be needed to determine the long-term air quality goals which are required to protect the public health and welfare from any potential effects of air pollution. In the meantime, the Secretary will be expected to establish such national goals on the basis of the best information available to him.

The bill would not require the attainment of the air quality goals within a specified time period. Nevertheless, it is the Committee's view that progress in this direction should be made as rapidly as possible. In areas where air pollution levels are already relatively low, the attainment and maintenance of these goals should not require

an extended time period. In areas where current air pollution levels

are already equal to, or better than, the air quality goals, the Secretary should not approve any implementation plan which does not provide, to the maximum extent practicable, for the continued maintenance of such ambient air quality. Once such national goals are established, deterioration of air quality should not be permitted except under circumstances where there is no available alternative. Given the various alternative means of preventing and controlling air pollution-including the use of the best available control technology, industrial processes, and operating practices--and care in the selection of sites for new sources, land use planning and traffic controls-deterioration need not occur.

SECTION l. IMPLEMENTATION PLANS
The establishment alone of ambient air quality standards has little effect on air quality. Standards are only the reference point for the analysis of the factors contributing to air pollution and the impositionof control strategy and tactics. This program is an implementation

plan.

The Committee recognizes that the implementation plan is the principal component of control efforts for pollution agents for which national standards are established. It is this program which must be effective if the Nation is to achieve the quality of air which the bill would mandate in a relatively short period of time.

The implementation plan provision in the bill has its origin in existing law. The Committee recognized that because thelroposed bill would require a great deal in a short period of time anubecause the brevity of the provision in existing law has led to uneven and inadequate interpretation, the character of an implementation plan must be specified and the alternative methods of achievement listed. The Committee bill would require that a rigorous time sequence be met in the development of the implementation plan and would provide for the substitution of Secretarial authority if the State plan,

or a portion thereof, is inadequate to attain the quality of ambient air established by the nationally promulgated ambient air quality standard.

The bill would provide that within nine months after the date of romulgation of any national ambient air quality standard, each State would have to adopt and submit to the Secretary for each air quality control region or portion thereof in such State a plan which would provide for the attainment of the national ambient air quality standard within three years after the date of approval of such plan,

or after the date of promulgation if the Secretary established such plan

or any portion thereof.

The Committee bill, based upon experience gained under existing law, would require that each State, after reasonable notice and a public hearing, adopt a plan for the implementation of standards at least as stringent as the national ambient air quality standards. Any implementation plan could be developed for a region only after participation by the public. Public participation can only be meaningful if there is reasonable notice and full disclosure of information prior to public hearings. The Committee expects that appropriate Federal,

tate, and local officials, citizens and affected industry groups will consider the development of the implementation plan the central element of this aspect of the legislation.

The Committee bill would establish certain tools as potential parts of an implementation plan and would require that emission requirements be established by each State for sources of air pollution agents
or combinations of such agents in such region and that these emission requirements be monitored and enforceable.

In addition to direct emission controls, other potential parts of an implementation plan include land use and air and surface transportation controls. These should insure that any existing or future stationary
source of air pollution will be located, designed, constructed, equipped, and operated, and that moving sources will be located and operated

so as not to interfere with the implementation, maintenance, and enforcement of any applicable air quality standard or goal.

The Committee acknowledges that this would require each region to make difficult judgments about the siting of facilities which may emit pollution agents, including decisions to prohibit the location of new
sources which, although in compliance with Section 113, would con-tribute to a violation of a regional air quality standard. These factors would necessitate long-term decisions about the character of the growth and development of such region.

In air quality control regions where present air quality is below the standard, rigorous restrictions must be placed on existing sources to provide a margin for future growth, or only pollution-free growth, development and expansion will be possible.

This section would also provide for intergovernmental cooperation in the development of air quality programs which at the minimum must prevent facilities in one State from contributing to the violation of ambient air quality standards in an adjacent State, whether or not the adjacent State is part of the same air quality control region.

The Committee has added provisions that would require the States to develop enforceable information, recordkeeping, and monitoring requirements similar to those which the Secretary would be authorized to establish in the bill.

The Committee recognizes that during the next several years, the attainment of required ambient air quality in many of the metropolitan regions of this country will be impossible if the control of pollution from moving sources depends solely on emission controls.

he Committee does not intend that these areas be exempt from meeting the standards. Some regions may have to establish new transportation programs and systems combined with traffic control regulations and restrictions in order to achieve ambient air quality standards for pollution agents associated with moving sources.

The Committee realizes that changes or restrictions in transportation systems may impose severe hardship on municipalities and States, and it urges that agencies of the Federal Government make available any relevant program assistance to the States and regions to meet these obligations. The highway program, various housing and urban development programs and other sources of assistance should be examined in this connection.

The implementation plan section of the proposed bill would specifi- cally provide that, to the extent necessary, each region develop motor vehicle inspection and testing programs for which it is eligible to receive assistance under section 208 of the proposed bill. The Committee believes that this is an extremely important provision, because used vehicles, particularly those manufactured before 1970 are among the most significant sources of air pollution. It is also a class of air pollution sources for which the regions and States have better opportunities to control.

In considering alternative means of controlling emissions of air pollution agents from used vehicles, the Committee was unable to develop a feasible national system. The Committee rejected ideas ranging from the imposition of a retroactive installation obligation on automobile manufacturers to a Federal subsidy program.

Section 211 of the Act provides for Secretarial certification of used car emission control devices and systems in order to protect the public from sham or inadequate devices and systems. Following the certification of such devices, the regions and States would be encouraged in the development of implementation plans to adopt requirements for the installation of such devices. The Committee believes at this time that regulations relative to the retroactive application of emission control devices and methods is manageable on y at the State and regional

50-311 0-70---2level and expects and hopes that the regions and States will be innovative in this area.

As pointed out in the discussion of section 211, used vehicles contribute substantially to air quality deterioration. The States would be expected to act to improve used vehicle performance and should consider requiring the installation of certified control devices or systems or, at least, the tuning of used vehicles before resale.

Under this Section the Secretary would be required to approve the implementation plan only if it specified the boundaries of the region to which such plan applies. This requirement is necessary to provide review of the adequacy of implementation plans for regions which the Governor may have sub-divided pursuant to the air control region designation provisions of section 108.

In order to insure achievement of air quality necessary to protect the health of persons within the period specified in the bill, time constraints would be placed on the Secretary's review and approval authority. The bill recognizes that the Secretary must have the authority to replace all or any portion of any implementation plan submitted by a State where attainment of the nationally ambient air quality standard within the time required is not provided. The bill would provide that the Secretary must approve or reject any implementation plan submitted by a State within four months of the date required for its submission. If he rejected the plan or any portion of it he would have to promulgate an alternative plan or portion thereof within an additional two months.

The Committee recognizes that pursuant to provisions of the 1967 Act many States are developing or have developed implementation plans for designated air quality control regions. To the extent possible these plans should not be disrupted. Therefore, the bill would specifically provide that implementation plans and ambient standards developed under existing law shall remain in effect until such time as the Secretary determines that all or any portion of such standards or plans are inadequate to meet the new obligations placed upon these regions. If the Secretary made such a determination, he would be required to make recommendations to the appropriate State or States of changes needed to meet the additional requirements of the Act. If such State or States failed to make the proposed revisions in existing implementation plans, the Secretary would be required to promulgate the necessary changes.

The Committee also recognizes that it is possible that an implementation plan approved or promulgated by the Secretary may later be found inadequate to attain the national ambient air quality standard(s). Whenever information reveals that an approved or promulgated implementation plan is inadequate, the Secretary would be required to act to revise such plan. Because such revision may delay implementation beyond the three year deadline the Committee bill would provide that the Secretary may extend the period of time re- quired for attainment of the national ambient air quality standard for

one year.

Finally, the Committee would recognize that compliance with the national ambient air quality standards deadline may not be possible. If a Governor judges that any region or regions or portions thereof within his State will not meet the national ambient air quality standard within the time provided, the bill would authorize him-one yearbefore the deadline-to file a petition against the United States in the District Court of the United States for the district where such region

or portion thereof is located for relief from the effect of such expiration.

The Committee proposes to have such actions brought before the District Court constituted as a three-judge court with such actions taking precedence on the docket over all other causes and directing that they be expedited in every way.

The Committee expects that an extension of time would be granted only as a last alternative. Therefore, the bill would provide that the court could grant relief in the paramount interest of the United States and in the public interest and general welfare of the persons in such region only after finding that substantial efforts had been made to protect the health of persons in such regions, and that means to control emissions causing or contributing to the failure had not been available for sufficient time or that the failure was a result of a Federal facility operating Under an exemption granted by the President. The bill would restrict relief to one-year extensions of the deadline. Nothing in this subsection should affect any provision or obligation pursuant to any implementation plan which is not the subject of the request for extension. The Secretary would be required to make changes in the implementation plan to bring the region into compliance with the applicable standard or standards within the year extension granted by the court.

The severe time limitations in the bill for filing an implementation plan for ambient air quality standards may limit the capacity of States to act simultaneously on plans for national ambient air quality goals. The bill would provide that the Secretary may extend for 18 months the period for submission of any portion of any iml)lementation plan. The development of the portion of the implementation plan for the achievement of air quality goal requires different and more extensive analysis than that required to establish an implementation plan to achieve national ambient air quality standards. Therefore, the Committee bill would provide an additional period for such development for those regions where it is needed.

SECTION 112. STATE STANDARDS AND PLANS TO ACHIEVE GREATER AIR QUALITY CONTROL
Section 112 would restate the intent of Section 109 of the Air Quality Act of 1967 which provided assurance that States, localities, intermunicipal and interstate agencies may adopt standards and plans to achieve a higher level of ambient air qualty than approved by the Secretary. The section would be revised to provide that such States, localities, intermunicipal and interstate agencies may adopt such more restrictive standards and plans and may establish timetables which achieve standards in a shorter period of time than required by Section 111 of this Act. The authority preserved by this section would apply to all aspects of the legislation except where the Congress has specifically pre-empted authority to act.

SECTION 113. NEW SOURCE PERFORMANCE STANDARDS
rrhe provisions for new source )erformance standards are designed

to insure that new stationary sources are designed, built, equipped, operated, and maintained so as to reduce emissions to a minimum.

# P ages omi tted due to document size. Available upon request.

# Exhibit 2December 18, 1970 CONGRESSIONAL RECORD

- SENATE
craft, so that we finally ended up with

a good aircraft instead of a bad one, a? well as the cancellation of the Navy version, which then led to the Navy designing a plane that it could use. Certainly, billions of dollars were saved to the United States because of the actions taken and precipitated solely by the investigation undertaken by the senior Senator from Arkansas on the TFX. He, indeed, has rendered a great service to the Nation. It has resulted in a saving of billions of dollars, and we should all be grateful for it.

Mr. McCLELLAN. I thank the distinguished Senator, and I extend my appreciation for the cooperation he has given to the chairman not only in this investigation but in others as well since he became a member of the subcommittee.

I yield to the distinguished Senator from Mississippi.

Mr. STENNIS. Mr. President, as I have said before, the Senator from Arkansas and his colleagues on the com- mittee have rendered an outstanding service, a very timely service, and have been, as always, effective in developing the full facts.

With reference to the Navy plane to which the Senator from Arkansas has referred, the legislative branch of the Government declined to authorize more money for that plane. The Department of Defense was still asking for the money. The Navy was testifying in favor of the money, for the plane. At the Armed Services Committee hearings on the military authorization bill, we got two or three of the admirals before us at the same time and asked them a se- quence of questions about the plane; that led to the answers that caused us to strike out the plane entirely and to deny the requested funds. That is the only way it could have been stopped. Of course, the plane was not in production at that time, and we substituted the F-14, which is now in progress.

Mr. McCLELLAN. The Secretary of the Navy was testifying for it. Secretly, however, Navy officials were telling Mr. McNamara that the plane would not work. We found that out, and we realized then with what we were confronted.

Mr. STENNIS. I commend the Senator very highly for the report.

With regard to the commonality question, regardless of who was honest and who was right and sincere in the beginning, this proves that a common plane is not possible now, on the same general design and plan, and that knowledge is worth a great deal, too.

I thank the Senator. Mr. McCLELLAN. I thank the distinguished Senator.

ORDER OF BUSINESS Mr. MUSKIE addressed the Chair. The PRESIDING OFFICER. The Chair wishes to announce that, under the previous order, the Senator from Indiana was to have been recognized. In his absence, that order is vitiated, and the Chair recognizes the Senator from Maine. CLEAN AIR AMENDMENTS OF 1970- CONFERENCE REPORT Mr. MUSKIE. Mr. President, I submit
a report of the committee of conference
on the disagreeing votes of the two Houses on the amendment of the Senate to the bill (H.R. 17255) to amend the Clean Air Act to provide for a more effective program to improve the quality of the Nation's air.

I ask unanimous consent for the present consideration of the report.

The PRESIDING OFFICER (Mr. EAGLETON). IS there objection to the present consideration of the report?

There being no objection, the Senate proceeded to consider the report.

(For conference report, see House proceedings of Dec. 17, 1970, pp. 42283-42294, CONGRESSIONAL RECORD.)

Mr. MUSKIE. Mr. President, it is with considerable satisfaction that I report to the Senate that the Senate conferees on the Clean Air Amendments of 1970 have returned, just in time for Christmas, with the package ordered unanimously by the Senate on September 22.

This was a long conference with the House conferees. There were many points at issue, many provisions in the Senate bill which were not considered at all by the House committee or by the House, nor reflected in the House version of this bill. The conferees worked long and hard on resolving these differences and dealing with the House problem of including in the bill provisions which the House had not considered. I think that what we have is a tough bill.

I commend to all of my Senate colleagues the result of the conferees' painstaking efforts over the past 3 months. It is a strong, tough, air pollution con- trol agreement. It will enable the coun- try to clean up the air and protect the public health.

The conferees' agreement, no less than the Senate bill, intends that all Ameri-
cans in all parts of the country shall have clean air to breathe within the 1970's.

The conferees' agreement, no less than the Senate bill, carries the promise that ambient air in all parts of the country shall have no adverse effects upon any American's health.

The conferees' agreement, no less than the Senate bill, faces the air pollution crisis with urgency and in candor. It makes hard choices, provides just reme- dies, requires stiff penalties.

The conferees' agreement, no less than the Senate bill, calls for the money and the manpower required to clean up the air. A threefold increase in manpower and a total of $1.1 billion in funding
over 3 years are authorized.

Mr. President, I am convinced that nothing short of this kind of commitment to the fight against dirty air, against environmentally induced disease, will be enough.

That is why I am greatly encouraged by the support given to this legislation by the Senate and House conferees, and I am particularly grateful to each of them for his contributions to our work during these 3 months. Let me now review briefly where we were in September, what we had learned from our experience with the existing law, what we felt was needed for a successful effort to obtain clean air and to protect public health, and what the conferees accomplished.

There was little doubt in the Senate, in September, that the country was facing an air pollution crisis. Cities up and down the east coast were living under clouds of smog and daily air pollution alerts. More than 200 million tons of contaminants were being spilled into the air annually.

The costs of air pollution were being counted in death, disease, and disability. The National Institute of Environmental Health scientists estimated the cost of environmentally induced disease at $38 billion a year. A 50-percent reduction in urban air pollution, it was estimated, would result in a saving of $2 billion a year in health care costs.

It was clear that the country was falling behind in its struggle for clean air. Automobiles were putting out 64 percent of the carbon monoxide and 50 percent of the hydrocarbons. Two steel companies in the Chicago area spilled 3,500

more tons of pollutants into the air in 1968 than they had spilled in 1963.

It was clear, too, that the new legislation then being considered would have to go beyond the limited objectives of the Air Quality Act of 1967. Senators will recall that the 1967 act was drawn to enhance air quality, to reduce harmful emissions, and to "give the Secretary authority to implement that objective in the absence of effective State and local control."

The 1967 act established procedures for the achievement and maintenance of federally approved regional standards of ambient air quality. These standards, based on Federal criteria documents describing the effects of pollutants on health and welfare, are adopted and enforced on the State and local level. In the event that adequate standards are not developed or enforced, the Federal Government assumes the responsibility.

The underlying wisdom of the original legislation was confirmed. We learned from the criteria documents issued for five pollutants that more decisive action must be taken. We learned from the standards-setting process that public participation is important. We learned from experience with implementation of the law that States and localities need greater incentives and assistance to protect the health and welfare cf all people.

The effectiveness of existing law depends in great part on the willingness of people to make tough decisions concerning the quality of air they want to breathe. It depends on their wllingness to make their wishes known in public hearings on the local level.

This experiment in public participation worked. People became involved in the standards-setting process. They learned of the threats to their health and they sought to make the program responsive to their needs. 42381CONGRESSIONAL RECORD

- SENATE December 18, 1970

From citizen concern and corporate resistance, we learned that air pollution is more severe, more pervasive and growing faster than we had thought. Unless

we recognized the crisis and generated a
sense of urgency, national lead times to find and apply controls measures could melt away without any chance for a rational solution to the air pollution problem.

It is also clear that ambient air quality standards which will protect the public health must be set as minimum standards for all parts of the Nation, and that they must be met in all areas within national deadlines.

Congress adopted emissions standards

as the basic control technique for moving

sources in 1965, because they are not controllable at the local level. Here we learned that tests of economic and technological feasibility applied to those standards compromise the health of our people and lead to inadequate standards.

In 1963, the Congress recognized that the Federal Government could not handle the enforcement task alone, and that the primary burden would rest on States and local governments. However, State and local governments did not respond adequately to this challenge. Enforcement had to be toughened. More tools

were needed. The Federal presence and backup authority had to be increased.

Finally, no level of government has implemented the existing law to its full potential. On all levels, the air pollution control program was underfunded and undermanned. Greater financial commitments had to be made and met at all levels.

With these lessons in mind last September, the Senate laid down in its bill five sets of requirements for tougher standards and tighter enforcement against air pollutants and air polluters.

First, the bill provided for national ambient air quality standards for at least 10 major contaminants that must be met by national deadlines. This meant that in every region of the country, air quality had to be better than that level of quality which protects health.

Second, national air quality goalsprotective against any known or anticipated adverse environmental effects were to be set for the major pollutants and had to be achieved within specific time frames on a regional basis. These goals

were especially important because some pollutants could have serious effects on the environment at levels below those where health effects occur.

Third, the bill provided that newly constructed sources of pollution had to meet rigorous national standards of performance. While we cleaned up existing pollution, we were determined to guard against new problems. Those areas which have lvels of air quality better than the national standards should not find their air quality degrade by the construction of new sources.

Fourth, the bill provided the Administrator authority to prohibit emissions of hazardous substances. The committee had received strong evidence that any level of emissions of certain pollutants might produce adverse health effects that could not be tolerated. Fifth, the bill provided the Administrator with the authority to set emission standards for selected pollutants which cannot be controlled through the am- bient air quality standards and which are not hazardous substances. These pollutants could later be covered by either ambient air quality standards or by prohibitions as hazardous substance.

The Senate also recommended significant changes in title II of the act dealing with moving sources, and especially with automobiles.

In 1968, moving sources were responsible for more than 42 percent of the total emissions of the five major pollutants.

In health effects, these pollutants
mean cancer, headaches, dizziness, nau- sea, metabolic and respiratory diseases, and impairment of mental processes. Clearly, solving the air pollution problem depended on the achievement of significant reductions in the emissions from automobiles. Clearly, protection of the public health required quick and drastic reductions.

Since legislation to deal with the problem of automotive emissions was first introduced in 1964, the industry had known that they would have to develop the solutions to the problem. In 1965 they announced that national standards could be met in the fall of 1967.

It was clear that continued reliance on gradual reductions in automotive emissions would make achievement of the ambient air quality standards impossible within the national deadlines established in title I of the Senate bill. More important, it would continue hazards to health long after they should have been eliminated.

In order to maintain those standards set under title I-standards which are necessary to protect the public health and which must be met in the next 5 years-the emissions standards for carbon monoxide, hydrocarbons, and nitrogen oxides which have been projected for 1980 had to be met eariler. The bill re- quired that this be done by 1975.

To insure that production line ve- hicles perform adequately, the Senate bill required that each vehicle manufactured comply with the standards for a 50,000 mile lifetime. The manufacturer
was required to warranty the perform-
ance of each individual vehicle as to compliance with emission standards.

The Senate in setting the 1975 deadline made every effort to make that re- quirement consistent with what the industry had testified on many occasions
over the years: It provided 2 years for re- search and development of the necessary technology, and 2 years to apply that technology in the mass production of vehicles.

In response to claims that these re- quirements could be met, the Senate included in the legislation an opportunity for an administrative review of the 1975 deadline. A 1-year extension would be necessary and justified. The bill also provided for a review of that decision by an appellate court.

The Senate was aware of the problems these requirements might create for individual companies. Therefore, the bill provided a procedure for mandatory licensing which would make available patents necessary to achieve compliance to any manufacturer who could show a need and to whom the information was not otherwise available. This provision was also applied to stationary sources.

Predictions of technological impossi- bility of infeasibility were not considered sufficient reasons to avoid tough standards and deadlines, and thus to compro- mise the public health. The urgency of the problems required that the industry consider, not only the improvement of existing technology, but also alternatives to the internal combustion engine and new forms of transportation. Only a clear cut and tough public policy could generate this kind of effort.

The third major area in which the Senate recommended significant changes is the area of enforcement. Standards alone would not insure breatheable air. All levels of government had to be given adequate tools to enforce those standards.

The Senate remains convinced that most effective enforcement of standards would take place on the State and local levels. It was here that the public could participate most actively and bring the most effective pressure to bear for clean air.

Public participation is still important in the development of each State's implementation plan. These plans do not involve technical decisions; they do involve public policy choices that citizens should make on the State and local level. They should be consistent with a ra- tional nationwide policy and should be subject to the approval of the Administrator.

However, the powers to enforce these standards had to be increased for the State and local governments as well as the Federal Government. The bill thus required adequate State enforcement authority as a part of implementation plans and provided that abatement or- ders could be issued by the Administrator or his representative. Violations of these orders were to be punishable by statutory penalties of as much as $25,000 for each day of a first violation.

The bill also provided the Federal Government with the authority to use the influence of the Federal contract as an incentive to compliance with standards.

Federal contracts could be awarded only to facilities which were in com- pliance with the standards and requirements of this act.

The bill extended the concept of public participation to the enforcement proc- ess. The citizen suits authorized in this legislation would apply important pres- sure. Although the Senate did not advocate these suits as the best way to achieve enforcement, it was clear that they should be an effective tool.

Mr. President, those were the basic and principal portions of the package taken by the Senate conferees to the first meeting with the House conferees on October 8. On several of those points, the House bill was silent. I ask unanimous consent to include in the RECORD at the end of my remarks a summary of provisions of the conference agreement. 42382December 18, 1970

I ask unanimous consent that a discussion of the key provisions of this agreement and the implications of those provisions be included immediately following the summary.

The PRESIDING OFFICER. Without objection, it is so ordered.

(See exhibit 1.) Mr. MUSKIE. I have no doubt that this legislation, like its predecessor, will be subject to criticism. Already the auto industry has indicated it is unacceptable. Others will focus on its limitations and still others will find fault for political purposes.

That is the democratic process. It is not in the public interest that all critics be satisfied. But false implications are not needed. This is not a political measure-it had unanimous support from the Senate conferees-some of whom had differing views on specific language but all of whom knew that a public demand needed a stern response.

One issue on which there will be repeated interpretation and misinterpretation involves the deadline for achievement of emissions standards for passenger cars. The Senate did not get all that it wanted here. The Senate conferees had to accept two major changes in order to preserve the deadlines in the Senate bill and to obtain conference agreement.

First, the House insisted that an application for suspension from the effect of the deadline must be made earlier than 24 months before the effective date of the standard in question.

Second, the administration is required to make this decision within 60 days after receipt of such an application for suspension.

Conversely, two improvements were made. First, the Administrator no long-
er can be forced to rely upon the auto manufacturer to determine whether technology is available. He must test engine systems developed by private par- ties to ascertain whether they meet standards; thus, all available technology will be known. When a breakthrough occurs, the administration will know, and standards can be toughened even beyond the degree of control required by this statute.

Let me say, with respect to the con- ference agreement as it relates to the Senate agreement, that the Senate did not get all it wanted. It was necessary to compromise. Yet, in many instances, the compromise resulted in a stronger bill than either the Senate or the House bills. The key decision, the one on which the committee focused most over the past few months, was the deadline for the cleanup of the internal combustion en- gine in the passenger automobile.

The deadline has been retained. That deadline is January 1, 1975, for carbon monoxide and hydrocarbons, and January 1, 1976, for oxides of nitrogen. I repeat, that deadline has been retained.

The Senate bill provided, in addition, the possibility of an extension of 1 year beyond each of the deadlines. The limitation of a 1-year extension has been retained without change, except for the CONGRESSIONAL RECORD

- SENATE

fact that the judicial review provisions of the Senate bill have been eliminated.

There has been one change made, upon House insistence. The date for applying for that 1-year extension of the deadline has been advanced by 1 year.

Mr. President, the Administrator would make the decision on whether an additional year should be granted on the basis of a review of the National Academy of Sciences on technological developments in the field as well as other information available to him. If the Administrator decides the deadline cannot be met, he must impose interim standards, achieving as high a level of emission control as technological developments permit. This advances the date for applying for the 1-year extension by 1 year, but no further extension is possible.

May I say that, in my judgment, the pressure is on the automobile industry. The deadline of 1975 and 1976 is still in the law, and only Congress can change it. If the review procedure is followed and results in an extension, the maximum extension permitted for the 1 year as was the case in the Senate bill. Any extension beyond that can be provided only by action of Congress. That has not been changed by the conference agreement.

I think the action we have taken on the automobile deadline is a reasonable compromise, in light of the fact that the House bill contained nothing of the sort in its legislation. The House moved, I think, close to 100 percent toward the Senate provision. In other respects, the Senate bill is, I think, as tough now, following the agreement with the House, as it was when it left the Senate Chamber.

Other important features of the Senate bill were retained. Each individual manufacturer must, if suspension of the deadline is considered essential, apply to the Administrator and make the necessary showing. This means that the lack of technology or the leadtime to the smaller companies cannot be used as a justification for suspension by the major manufacturers.

Further, the companies must provide the Administrator with the information needed to judge their technical capability. The Administrator should require periodic reports on the progress of technology from each company-such reports and comments thereon should be a part of the report the Congress required by this section.

As in the Senate bill, the Administrator retains certain discretionary authority. He must, for example, prescribe the actual standard which the automobile must achieve to meet a 90-percent reduction from 1970-71 vehicle emission levels.

This technical judgment could be viewed as a way to vitiate the effect of the deadline by adjusting the measurement technique. This has been done once this year. Before the Senate completed action on this bill and before the decision to write a statutory standard for motor vehicles, the National Air Pollution Control Administration proposed a new measurement technique for vehicles. 42383

The new technique had the effect of increasing the allowable emissions for 1970-74 passenger cars. By the seemingly simple method of revising the base on which standards were calculated-new technology made pollutant quality and quantity easier to measure-the amount of allowable pollutants was increased.

The conference committee was aware of the potential for adjustment. The con- ference agreement mandates that meas- urement techniques be determined within 6 months after enactment. Should the base be adjusted again; that is, should a new measurement technique be adopted for carbon monoxide and hydrocarbons
so as to increase the amount of emissions and thus alter the circumstances on which our judgment has been made, oversight hearings, and if necessary, cor- rective legislation will be the result.

Mr. President, this legislation is the product of an effort which involved many people over an extended period of time. The members of the Senate Committee
on Public Works and their staffs deserve particular praise. Our hearings were numerous and there were more executive sessions. The members were patient, attentive, cooperative, and not partisan.

Chairman RANDOLPH and Senator COOPER, both of whom sit with the subcommittee, helped guide the bill through the full committee. Senators BOGGS, BAYH, MONTOYA, SPONG, EAGLETON, BAKER, and DOLE worked long hours on this bill and the final version represents their individual commitments to the goal of a clean environment.

Mr. President, there were many con- ferences with the House Committee on Interstate and Foreign Commerce. The chairman, HARLEY O. STAGGERS of West Virginia, who served as chairman of the conference, guided the legislation well. His constant reminder of the need to get a good, strong, reasonable bill helped maintain our determination. Representative PAUL ROGERS of Florida provided key proposals to break deadlocks and Representatives JOHN JARMAN, BILL SPRINGER, and ANCHER NELSEN worked diligently and patiently to formulate the compromise. The House conferees
were ably and faithfully assisted by Kurt Borchardt and Bob Nordhaus, and without their cooperation with the Senate conferees' staff, this bill could never had been produced.

In conclusion, Mr. President, I want to emphasize again that committing the Congress with this legislation cannot be, and will not be. enough. In this Chamber,
we can make promises to provide the funds and the manpower necessary to set and enforce the standards. That is not enough. We must carry our commitment through to the appropriations of those funds.

This program requires a commitment not only from the Congress and the Executive. It also requires a commitment from the people. And from all of us, it requires a new perspective. We all must recognize that the quality of our air is most valuable, most essential, to the quality of our environment and to the quality of our lives upon this planet.CONGRESSIONAL RECORD

- SENATE December 18, 1970

EXHIBIT 1 SUMMARY OF THE PROVISIONS OF CONFERENCE

AGREEMENT ON THE CLEAN AIR AMENDMENTS

or 1970 STATIONARY SOURCES Air quality control regions: The agreement provides that areas of states not designated will be considered as air qualty control regions and provides authority for Administrator to designate interstate region.

Air quality criteria and control techniques: The agreement requires issuance of remaining air quality criteria for major pollutants within 13 months of date of enactment.

National ambient air quality standards: The agreement establishes procedures for setting primary national ambient air quality standards to protect public health and secondary national quality standards necessary to protect public welfare. Following promulgation of the standards (four months after issuance of criteria), the States will have nine months to develop and to adopt, after public hearings, a plan to implement the primary standards. Additional time will be provided to set implementation plans for secondary standards.

Implementation plans: The Administrator has six months to approve a submitted implementation plan or if no plan is submitted

or the plan is inadequate, to substitute a plan of his own. The plan must be designed
to achieve the level of air quality established by the primary standard within three years, and must include a description of steps which will be taken, including transportation and land use controls, emission requirements, and other enforcement procedure.

State standards: The agreement enables the State or local subdivision to adopt air quality emission standards that are stricter than the national standard.

New source performance standards: The agreement authorizes regulations to require that new major industry plants such as power plants, steel mills, and cement plants achieve

a standard of emission performance based

on the latest available control technology, processes, operating methods, and other alternatives.

Hazardous substance emissions: The agreement requires the administrator to regulate emissions of pollutants found to be hazardous to health.

Federal enforcement: The agreement prohibits violation of any air quality implementation plan, emission standard, etc. It provides criminal penalties and the authority to issue abatement orders. The agreement requires record keeping, authorizes subpoenas, requires emission monitoring, and authorizes right of entry.

Federal facilities: The agreement requires Federal facilities to control air pollution.

Moving sources: Standards-The agreement requires emission standards based on protection of public health and welfare without regard to the propulsion system and provides that the 1975 model cars must achieve at least a 90% reduction from emissions of the 1970 models. This would approximate the 1980 standards projected currently for automobiles. The agreement prohibits violation of standards.

Aircraft emissions: The agreement provides for regulation of aircraft emissions and Federal preemption of authority to regulate such emissions. Aviation fuels regulation is authorized also.

Penalties: The agreement sets penalties of up to $10,000 per vehicle and provides authority to seek injunctions against violators.

Certification: The agreement authorizes the Administrator to test any new vehicle submitted for certification for compliance with standards and authorizes certification for a year. It also provides for production line testing of vehicles.

On the road testing and compliance: The agreement requires warranty of 50,000 miles
on emission system performance. The Administrator can test cars on the road, and can require recall if a representative sample fails the test.

State grants for vehicle inspection: The agreement authorizes 2-1 grants to the States for developing emission inspection systems.

Pre-emption: The agreement preempts State emission standard-setting authority, except for California.

Low emission vehicle: The agreement authorizes certification and purchase of LowEmission Vehicles.

GENERAL

Research: The agreement authorizes $75 million for fiscal 1971, $125 million for fiscal 1972, and $150 million for fiscal 1973 research relating to fuels and vehicles. It authorizes research concerning the health effects of air pollution and authorizes an additional $15 million for long-term contracts to carry out these investigations.

State planning grants: The agreement pro- vides 3 to 1 funding to states with a bonus
now available only to interstate and intermunicipal programs; it also provides for the option of assignment of Federal personnel In lieu of cash grants.

Emergency powers: The agreement gives the Administrator authority to abate any pollution that presents an imminent and substantial endangerment to health.

Citizens suits: The agreement permits citizens suits to enforce violation of standards. Suits against the Administrator are limited to mandatory Yunctions.

Federal contract compliance: The agreement prohibits the Federal Government from signing contracts with any company convicted of violation of air quality laws. The agreement authorizes the President to issue

an executive order to provide uniform contract compliance language.

Judicial review: The agreement permits review of the standards, implementation plans,
or other action taken pursuant to the Act.

Mandatory licensing: The agreement authorizes mandatory licensing of patents, on technology not otherwise reasonably available to facilitate compliance with provision of this Act.

Authorization: The agreement authorizes $650 million for three years for purposes other than Section 104.

Environmental policy: The agreement requires the Administrator to review any National Environmental Policy Act statements and major Federal actions and make his com- ments public.

Noise pollution: The bill establishes an Office of Noise Abatement and Control in the Environmental Protection Agency and authorizes $30 million to carry out functions.

DIscussION OF KEY PROVISIONS Section 107-108. The conference agreement requires the designation of air quality control regions and the issuance of air quality criteria and control technique information within a statutory deadline. These are necessary administrative preconditions on which much of the rest of the agreement depends, and the conference committee felt it desirable to speed up their availability. Criteria have already been issued for five pervasive pollutants: sulfur oxides, particulates, carbon monoxide, hydrocarbons, and photochemical oxidants. Within the 13-month deadline, the Congress expects criteria to be issued for nitrogen oxides, fluorides, lead, polynuclear organic matter, and odors, though others may be necessary.

Section 109. Under section 109 of the agreement, national ambient air quality standards must be established, either within
one month of enactment or simultaneously with any criteria issued. For each pollutant subject to a criteria document, there will be

a primary ambient air quality standard, set at the level of air quality adequate to protect the public health, and a secondary ambient air quality standard to eliminate adverse effects on welfare.

Section 110. Section 110 requires each State to develop an implementation plan which assures the attainment of the primary ambient air quality region within three years from the date the plan is approved. The plan also must provide for reaching the gen. erally more restrictive levels of air pollution of the secondary standards within a reason. able set time period and should be related to the difficulties with which a particular re. gion Is confronted.

With up to four months for the final pro- mulgation of national standards, up to nine months for the States to develop their plans and up to four months for the Administra. tion to either approve a State plan or decide to substitute his own authority in promul. gating a plan, approval of plans for major pollutants is no more than 17 months away, Within four and one-half years, the level of air quality in American cities, as to these major pollutants, should be adequate to avoid adverse effects on public health.

In order to implement the national am- bient air quality standards, these plans must provide for emission limitations on all serv- ices in the region covered by the plan, to- gether with schedules and timetables of compliance, systems for monitoring both ambient air and emissions from individual sources, and adequate enforcement author- ity (including special provisions for air pol- lution emergencies). Implementation plans must provide that when adequate on-the- road motor vehicle emissions tests are de- veloped, the State will have a system for periodic inspection. Federal grants are available to develop such inspection programs.

Implementation of standards will require changes in public policy: land use policies must be developed to prevent location of facilities which are not compatible with im- plementation of national standards. States must review the location of every new sta- tionary source before construction to assure no interference with attainment of the standards.

Transportation policies must be developed or improved to assure that the impact of pollution from existing moving sources is reduced to the minimum compatible with the needs of each region. Construction of urban highways and freeways may be required to take second place to rapid and mass transit and other public transporta- tion systems. Central city use of motor vehicles may have to be restricted. In some congested areas the number of operations of aircraft into an airport may need to be limited, or steps taken to reduce emissions while aircraft are on the ground. If such controls

are required, the plan for implementation should so provide. If the plan is approved, the Congress expects the Federal regulatory agencies to take the steps necessary to assure compliance with the plan.

The conference committee was convinced that the Administrator of the Federal Aviation Agency would work closely with the States and the Environmental Protection Agency to attain these controls when necessary.

If, at the time of plan approval, it appears impossible to bring specific sources into compliance within three years, the Governor of the State may request an extension of the deadline up to two years. The Administrator must be satisfied that alternate

means of achieving the standard have been considered (including closing down the

source in question), that all reasonable interim measures will be applied, and that the State is justified in seeking the extension.

A Governor may also apply for a postponement of the deadline if, when the deadline approaches, it is impossible for a source to meet a requirement under an implementation plan, interim control measures have reduced (or will reduce) the adverse health 42384December 18, 1970 CONGRESSIONAL RECORD

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effects of the source, and the continued operation of the source is essential to national security or the public health or welfare of that State. Such a postponement is subject

to judicial review.

Section 111. The conference agreement, as did the Senate bill, provides for national standards of performance on emission from

new stationary sources. Included under this section would be emissions from new or modified installations of major industries. These
sources, important in themselves and involved in industries of national scope must be controlled to the maximum practicable degree regardless of their location. Standards of performance must be set at the greatest degree of control attainable through the application of the best system of emission reduction which has been adequately demonstrated.

Sources for which the Congress would expect standards of performance to be established include:

Cement manufacturing; Coal cleaning operations; Coke byproduct manufacturing; Cotton ginning; Ferroalloy plants; Grain milling and handling operations; Gray iron foundries; Iron and steel operations; Nitric acid manufacturing; Nonferrous metallurgical operations (e.g. aluminum reduction, copper, lead, and zinc smelting) ;

Petroleum refining; Phosphate manufacturing; Phosphoric acid manufacturing; Pulp and paper mill operations; Rendering plants (animal matter); Sulfuric acid manufacturing; Soap and detergent manufacturing; Municipal incinerators; and Steam electric powerplants. Section. 112. Under section 112, the Administrator must set emission standards for hazardous air pollutants, after public hearings on proposed standards. The standards
must be set to provide an ample margin of safety to protect the public health. This could mean, effectively, that a plant would be required to close because of the absence of control techniques. It could include emission standards which allowed for no measurable emissions.

New sources of such pollutants may be constructed only if they meet the standards. Within two years, if installment of control equipment takes that long, existing sources must meet the standards, and during any relay in meeting the standards, alternate

means must be used to protect the health of persons from imminent endangerment. Examples of substances which the Administration informed the Senate were likely to be controlled under this provision are beryllium, asbestos, mercury, and cadmium.

Section 113. Federal enforcement under section 113 leaves the primary responsibility with the States for enforcing requirements under implementation plans. The Administrator can issue an abatement order to a polluter or go to court seeking an injunction only after 30 days' notice to an individual polluter, or 30 days after notifying the State that the Federal Government is generally assuming enforcement powers in that State because of a widespread failure of States' en- forcement. This gives States 30 days in which to take appropriate action themselves.

For Federal standards of performance for
new sources and emission standards for hazardous air pollutants, the Administrator may enforce without delay by either Issuing an order to abate or seeking an injunction in court. This authority may be delegated to States but the Administrator retains authority to act directly without notice to the State.

The conference agreement retains the existing abatement conference procedure for international pollution and for pollutants not subject to ambient air quality standards or emission standards for hazardous air pollutants. The effect of past enforcement actions is preserved.

Knowing violations of an order issued by the Administrator or of State implementation plan requirements (where the violator has received notice) or of Federal standards of performance for new sources or of Federal emission standards for hazardous emissions shall be punishable by a fine of not more than $25,000 per day of violation or by Imprisonment for not more than 1 year. For second or subsequent violations, the fine is not more than $50,000 and imprisonment for not more than 2 years.

Section 114. The conference agreement grants authority to the Administrator or his authorized representatives to enter the premises of any emission sources, to require the

owner or operator of any source to install and maintain emissions monitoring equipment (and to protect it against tampering), to require sampling of emissions, and to require records and reports. Violations of this provision are subject to restraining orders and knowing falsification of records, reports and other information required by this Act is subject to criminal penalties of $10,000,

or imprisonment of six months, or both.

Section 202. The Administrator is directed to establish emission standards for pollutants from new motor vehicles or engines which are likely to endanger the public health or welfare. Such standards are to be applicable for the useful life of the vehicles

or engines. The statute specifies that "useful life" shall be a period of use of at least five years or 50,000 miles, whichever occurs first. The effective date of the standards is to depend.on the period necessary to develop the requisite technology, giving appropriate consideration to the cost of complying by such date.

Carbon monoxide and hydrocarbon emissions from light duty vehicles for 1975 model year and thereafter are to be reduced at least 90 per centum over 1970 standards for these pollutants. Oxides of nitrogen emissions from light duty vehicles for the 1976 model year and thereafter are to be reduced by at least 90 per centum over the actual emission of these pollutants from 1971 model vehicles, which were not subject to Federal or State standards for such emissions.

Any manufacturer may apply to the Administrator within specified time limits for

a one-year suspension of the statutory time limits, and the Administrator is to issue interim standards if he approves such application. Such interim standards are to reflect the greatest degree of emission control which is achievable by application of technology determined by the Administrator to be available. The Administrator is to take into consideration whether the manufacturer has
met statutory requirements relating to public interest and public health and welfare, availability of technology, and good faith efforts to meet standards.

The Administrator is to enter into appropriate arrangements with the National Academy of Sciences to conduct a study of the feasibility of meeting statutory deadlines for the 1975 and 1976 model years. In entering into such arrangements, the Administrator is to request the Academy to submit its first report not later than July 1, 1971. The Administrator is directed to use all information-gathering authority granted to him to furnish to the Academy any information requested by it.

Section 207. The provisions for warranty of vehicle emission control systems or devices, contained in section 207 of the conference substitute, are among the most important in the Act. Standards for new cars will have little impact if we cannot assure compliance with those standards over the useful life of those vehicles. Testimony required by the Committee indicated significant deterioration from expected performance levels

as between prototype models and production vehicles. According to information provided by the National Air Pollution Control Administration from the record of the Senate hearings:

"The production fleet data indicate that air quality in 1985 will be 25 percent higher in hydrocarbons and 13 percent higher in carbon monoxide than it would have been if there were no discrepancy in emissions rates. Oxidant concentrations are approximately a direct function of hydrocarbon concentrations, as indicated in the "Air Quality Criteria for Hydrocarbons." Thus the oxidant levels in 1985 will also be approximately 25 percent higher. This analysis is based on data gathered from 1968 and 1969 model year cars. To the extent that production fleet performance can be made to approximate prototype emissions more closely, in 1970 and later model years, the discrepancies in the pro- jected curves can be reduced." (Volume 1, p. 372.)

This information, in addition tc data which shows significant deterioration from the standard after a vehicle accumulates mileage, suggests that the investment in emission systems by the American public will be of no purpose and that the air quality objectives of existing and proposed legis- lation will have failed unless better perform-
ance is required.

The responsibility of the industry cannot stop at the factory gate. Without some degree of quality control which can only be assured through individual vehicle compliance, the motorists cannot be required to maintain emission performance-vehicle emission in- spection programs will be meaningless-and air quality will not be maintained.

Conversely, by requiring the manufacturer to warranty performance, margins of safety will be built into each vehicle to insure bet- ter than required performance, systems will be designed to minimize deterioration, State vehicle emission inspection programs can cause proper maintenance to be observed by the motorists and the air quality objectives of this legislation will be implemented.

To achieve this, the conference agreement provides that motor vehicles be warranted by the manufacturer to comply with emis- sion standards for 5 years or 50,000 miles. This performance warranty is in addition to
a statutory warranty of freedom from de- fects in materials and workmanship.

The performance warranty cannot be enforced until the Administrator establishes methods for on-the-road testing of vehicles and states have individual vehicle compliance inspection systems and programs. A warranty will not become effective until the vehicle's deviation from the standards subjects the owner to some sanction, such as a fine or ban from the road. Proper operation and maintenance according to the manufac- turer's reasonable instructions is a precon- dition to the warranty, but all repair work under the warranty, as in the case of vehicles recalled because of non-conformity with the standards, must be at the cost of the manufacturer.

Section 211. Section 211 of the conference substitute authorizes the Administrator to control or prohibit the manufacture or sale of motor vehicle fuels or fuel additives. This is combined with added information-gathering powers in the registration of all fuels and fuel additives. The Administrator may impose such controls or prohibitions if emission products of a fuel will endanger public health or welfare, or if the fuel or additive impairs to a significant degree a vehicle emission control system in general use, as long as the control of a fuel does not result in a greater danger to public health or welfare from a substitute fuel. 42385CONGRESSIONAL RECORD

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The concept of a control or prohibition should be taken to include requiring design changes in motor vehicles, as well as fuel handling equipment, to ensure maximum compliance with regulations specifying acceptable fuel use for various classes of vehicles. In developing any controls, the Administrator should consider the fuel needs of existing motor vehicles, as well as future production.

While the conference substitute specifies procedures under section 211 which the Administrator will use in determining whether to prohibit or control fuels or fuel additives, the conference committee wishes to call the Administrator's attention to the relationship between his functions under this section and the emission deadlines stipulated in Section 202. It is not the intent of Lhe Congress to create a cumbersome, time consuming administrative procedure which will delay necessary controls on fuels and fuel additives required to meet these deadlines.

Neither is it the intention of the Congress to lock the Administrator into a rigid economic interpretation of the cost benefit analysis specified in this section in making his determination to prohibit or control fuels

or fuel additives.

Rather, the conference committee wishes to call the attention of the Administrator to the broad environmental, esthetic and health considerations underlying the enactment of this legislation which should be kept in mind making these determinations.

States and localities are preempted from presenting or enforcing controls or prohibitions not identical to those of the Federal government, unless an approved State implementation plan under section 110 provides for fuel or additive control in order to attain the national ambient air quality standards. California, however, is free to have any regulation of fuels or additives it finds necessary.

Sec. 231-234. A new Part B of Title II, added by the conference agreement, provides authority for the Administrator to prescribe emission standards for civil aircraft and aircraft engines. This he must do after no more than 180 days of study and after public hearings in critically affected regions. The Secretary of Transportation, through the Federal Aviation Agency, will enforce the standards. States and localities are preempted from adopting or enforcing any but identical standards. The Administrator is also authorized to recommend standards for aviation fuels, which must be prescribed by the Administrator of the Federal Aviation Agency.

The conferees expect that critical standards for aircraft will go considerably beyond the present smoke reduction program which is being carried out for three-engine jets. To limit the standards to certain aircraft is un- acceptable. To rely on smoke reduction alone ignores other, perhaps more important pollutants, which will have to be controlled as a part of the national ambient air quality standards program.

Section 304. The conference agreement au- thorizes citizen suits against polluters to abate violations of any emission limitation under the Act (including State implementa- tion plans), and against the Administrator to require him to do any of the functions this Act assigns to him. Any polluter, including a government agency, is subject to such a suit after 60 days notice from the citizen-plaintiff. If a government abatement action is being diligently pursued in a United States or State court, a citizen action cannot be filed, but an interested party may intervene as a matter of right. There is no delay or notice requirement for violations of the Administrator's order or a violation of a hazardous pollutant emission standard. Cost of litigation, including attorney's fees and expert witness fees, could be awarded to either party, as the court thinks appro- priate. The Courts should recognize that in bringing legitimate actions under this section citizens would be performing a public service and in such instances the courts should award costs of litigation to such party. This should extend to plaintiffs in actions which result in successful abatement but do not reach a verdict. For instance, if as a result of a citizen proceeding and before a verdict is issued, a defendant abated a violation, the court may award litigation expenses borne by the plaintiffs in prosecuting such actions. However, there is no question that

some persons may use section 304 to bring frivolous and harassing actions. In such case, the court could award costs of litigation to defendants as it is in the public interest to avoid such actions. This should have the effect of discouraging abuse of this provision, while at the same time encouraging the quality of the actions that will be brought.

Section 305. An important provision of the conference agreement is section 305, granting the Administrator the authority to represent himself in court if the Attorney General does not notify him that he will enter the case within a reasonable time. This is necessary if the Administrator is to have effective control of enforcement actions under this Act. The Administrator is required to initiate enforcement actions; this allows him to satisfactorily carry them out.

Section 308. In order to prevent the stringent standards of the Act from contributing to monopolist concentrations in any industries, the conference agreement provides for a limited mandatory licensing of the technology necessary to meet automobile emission standards, emission standards for hazardous air pollutants, or new source standards of performance, if covered by a U.S. patent. If rights under such a patent
are not reasonably available, or the technology not commercially available through purchase of control equipment, the Attorney General may certify to a district court that
some lessening of competition will result and seek a license on reasonable terms and conditions.

Section 310. The conference agreement instructs the Administrator to review and comment on Federal actions which affect environment and make such comments public upon completion of his review.

This policy conforms with Sec. 102 of the National Environmental Policy Act and was discussed with the Administrator of the Environmental Protection Agency, William D. Ruckelshaus, at his confirmation hearing on December 1, 1970.

The conference agreement thus removes the ambiguity concerning the public release of such reviews and comments which has emerged during the debate on appropriations for the supersonic transport. Those comments must be made public when the Environmental Protection Agency completes its review-not when the environmental impact agency decides the public should be informed.

Authorizations. The conference substitute adopts the House amount for Fiscal Year 1971 for Sec. 104 and Sec. 309-a total of $200 million. For Fiscal Year 1972 the conference agreement provides for a total of $350 million, of which $125 million is for research

on fuels and vehicles. For Fiscal Year 1973 the authorization is $150 million for research under Section 104, out of a total of $450 million. In addition the conference substitute retains $15 million or long term contracts for air pollution effects research under Section 103, $30 million for funding the Office of Noise Abatement in the Environmental Protection Agency, and $55 million for low emission vehicle procurement, $5 million of which is authorized for Fiscal Year 1971 and $25 million each for Fiscal Years 1972 and 1973. Mr. EAGLETON. Mr. President, will the Senator from Maine yield?

Mr. MUSKIE. I am happy to yield to the Senator from Missouri and commend him for his invaluable assistance in the committee, on the floor, and in the con- ference.

Mr. EAGLETON. I thank the Senator from Maine. I should like to propound to him a few brief questions just to illustrate further the significance and the parameters of this very noteworthy piece of legislation.

Before doing so, I wish to praise his enormous efforts in this valuable piece of legislation. But for the Senator from Maine, but for his diligence, his persistence, his persuasiveness, we would not have as good a bill as we today have before us.

We all recognize that this bill has great significance for our national effort to clean up the air pollution that afflicts virtually every citizen in the United States. I think we should also pause to record that this bill also marks a very significant step forward in the continuing development of more responsive and responsible relationships among the Federal Government and the State and local governments of our country. I want to thank the distinguished Senator from Maine for his vigorous and enlightened leadership on this less conspicuous but singularly important aspect of this bill. Would the Senator from Maine agree that this bill has very broad significance in the area of Federal-State relations?

Mr. MUSKIE. Yes. May I say to the Senator that during the deliberations on the bill I have been very much interested in preserving "local option" features, so that State and local authorities would be able to pursue options among a broad array, seeking a possible way of controlling or preventing air pollution that is most responsive to the nature of their air pollution problem and most responsive to their needs. In my judgment, the bill will give State and local authorities sufficient latitude in selecting ways to prevent and control air pollution.

Mr. EAGLETON. It seems to me that
even with the strong provisions in this bill concerning automobiles, it will be necessary for us to devote more of our national resources to alternative ways of transporting people, particularly transporting them to and from our cities and within those cities, at less than supersonic speeds. Would the Senator from Maine care to comment on this proposi- tion?

Mr. MUSKIE. Yes, I would. There is a tendency to focus upon the new car provisions in the bill, and understandably

so. Nevertheless, what really moved the committee, the Senate, and the conferees to go in the direction of a tough deadline for new cars is the fact that there are used cars, and the used car population creates a problem. There are 100 million to 110 million automobiles that are moving about, heavily concentrated in the large urban centers and beyond the reach, really, of any effective technological control development.

Further, if we are to deal with the used car problem, we need a new car deadline in order to begin the process of December 18, 1970December 18, 1970 CONGRESSIONAL RECORD

- SENATE

cleaning up new used cars. We still have existing a mass of used automobiles to deal with. The bill before us deals with that problem by the requirement of national ambient air quality standards geared to help.

Those standards, realistically applied, will require that urban areas do something about their transportation systems, the movement of used cars, the development of public transit systems, and the modification and change of housing patterns, employment patterns, and transportation patterns generally. All of that is implicit in the concept of implementation plans for national ambient air quality standards and what they mean for the used cars in our country.

Mr. EAGLETON. Would the Senator from Maine agree with me that this bill is intended to afford to the citizens of the United States very broad opportunities to participate in the effort to prevent and abate air pollution? Are not the citizen suit provision and the requirement for public hearings on State implementation plans likely to result in higher quality and better air pollution control programs across the Nation than would likely be the case if there were less opportunity for citizen participation?

Mr. MUSKIE. That was the thrust of the Senate bill in many respects, and although we did modify the citizen suit provision I feel that thrust is retained. The Senate committee felt it would be impossible to do the total job of air pollution cleanup relying wholly upon the Federal bureaucracy.

This is why we emphasized the necessity for developing State and local programs. But in addition, this bill provides for other participation by citizens in various ways. We regard that as a key element in the successful prosecution of the air pollution goals which this bill undertakes.

Mr. EAGLETON. Mr. President, as the Senator knows, long after the Senate had completed action on the air pollution bill, well after administration representatives had been invited to react to the Senate's air pollution bill, and even after an an- nounced agreement had been reached
on the vital auto deadline, to which the Senator from Maine has already re- ferred, the Nixon administration wrote an 11th-hour letter to the distinguished Chairman of the Senate Public Works Committee. In my view, that letter can only be interpreted as an attempt on the part of some in the administration to weaken the strong Senate bill and the tentative conference compromise.

Does the Senator from Maine think that the Richardson letter is an indication that we should carefully review implementation of this program in mid1971 to be sure that the regulations are not weakened in application?

Mr. MUSKIE. Mr. President, I agree. The Richardson letter was badly timed. It did complicate the work of the confer- ence and make it more difficult to reach agreement and to achieve what we ultimately achieved in the conference agreement.

On this point I concur with the Senator. We should carefully review the implementation of this program next year to insure that it is moving along in accordance with our interpretation of what
we think the Senate is doing in this piece of legislation.

Regulations are not to be used to dilute and water down the strong policy which the Senate is adopting.

Mr. MAGNUSON. Mr. President, will the Senator yield?

Mr. MUSKIE. I yield. Mr. MAGNUSON. Mr. President, I am not familiar with everything the confer-
ees did. But I think that there is some confusion as to what department would be the enforcement agency.

Mr. MUSKIE. The Environmental Protection Agency.

Mr. MAGNUSON. What about the Department of Transportation? Would it have something to do with it, or the Motor Safety Division?

Mr. MUSKIE. The Senator refers to the low-emission vehicle program which the Senator from Washington introduced and of which I was a cosponsor. We had joint hearings on it with the Committee
on Commerce. And it was reported out of the Committee on Commerce. It was passed as separate legislation. Then it
was included in this bill. It is retained in the conference report.

Mr. MAGNUSON. Mr. President, I thoroughly agree with the Senator from Maine. We can set a deadline and then
no one has any oversight over what is going on. So we come to the deadline and someone will say, "We have not done it."

They give us all the rigmarole and the
reasons why they have not done it.

I am concerned about having some kind of surveillance over this as we move along toward the date decided by the conference. We could do that later. But
we should have the legislative over- sight committee or someone do it. Perhaps it should be the new Environmental Control Committee on which we will meet this afternoon. They might do that. I do not know.

Mr. MUSKIE. This could be within their area of jurisdiction. I think it might be useful to read this provision from the House RECORD of yesterday:

There is established a Low-Emission Vehicle Certification Board to be composed of the Administrator or his designee, the Secretary of Transportation or his designee, the Chairman of the Council on Environmental Quality or his designee, the Director of the National Highway Safety Bureau in the Department of Transportation, the Administrator of General Services, and two members appointed by the President. The President shall designate one member of the Board as Chairman.

Mr. MAGNUSON. This is the sort of thing we have to keep on top of.

Mr. MUSKIE. The Senator is correct. Mr. MAGNUSON. Otherwise we will wake up on a given date and they will say, "Well, we have not been able to do it." They will give all kinds of reasons why they have not been able to do it. There will then be an outcry to extend it. I think we have to be sure that someone is on top of this thing all the time.

Mr. MUSKIE. Mr. President, I thank the Senator from Washington.

Mr. President, I now yield to the Senator from West Virginia. Mr. RANDOLPH. Mr. President, I shall ask the able chairman of the subcommittee several questions. The Senator from Maine who served so effectively as chairman of the Senate conferees, has, not only during this conference, but also during several years past, given much of himeslf to the development of this legislation. It is as he said in commenting on the conference report, good strong legislation.

I respectfully disagree with the words of the Senator from Maine and the words of the Senator from Missouri in reference to the appropriateness of the communication from Secretary Richard-
son.

Each person places his own interpretation on the content of the letter. I do not say this today for the first time. I said it when we discussed the matter within the Public Works Committee and when we discussed it within the confer-
ence. I am only repeating what I have said before.

I am very frank to say that I think the letter should have come to us sooner. This is something that I want the RECORD to reflect. I also want the RECORD to indicate that there had been no final decisions made here on Capitol Hill in reference to this important legislation at the time the communication was re- ceived. The democratic process is at work. The legislative process is at work. The advice from the executive branch is at work in reference to the finalization of this important legislation.

Mr. MUSKIE. Mr. President, will the Senator yield?

Mr. RANDOLPH. I yield. Mr. MUSKIE. Mr. President, to clarify my position with reference to the administrator's prerogative to comment on this legislation or any legislation, it is not my intent in the remarks I made earlier that the administration does not have that prerogative. From the time we re- ported this bill out of the Subcommmittee
on Air and Water Pollution, we publicly and in other ways solicited the administration's position on the provisions of the bill.

It would have been useful to have had the administration position in the course of the floor debate. We speculated about it, but we did not know what it was.

We went to conference, I think, about October 8 or 9. We reached a tentative agreement on the auto emission deadline
on that day. The letter from the Secretary of HEW is dated November 17, some 6 weeks later. It is that to which I direct my criticism. Six weeks after we started the conference we got this letter on the administration's position. Certainly it is the administration's prerogative to send it up at any time it wishes. They could have sent it today. I am talking now about the very disruptive effect the timing had.

Mr. RANDOLPH. I have agreed with my distinguished colleague, the Senator from Maine, that I felt the letter was late in arriving. I made that statement at the very outset. But I do not look on a letter from the administration setting forth its views as disruptive.

I look on it as a further indication of the interest of the parties who are in the Federal Government either officially or 42387CONGRESSIONAL RECORD -SENATE December 18, 1970 indirectly, and that, I think, is the democratic process.

Mr. EAGLETON. Mr. President, will the Senator yield?

Mr. BAKER. Mr. President, a parliamentary inquiry.

The PRESIDING OFFICER. The Senator will state it.

Mr. BAKER. Mr. President, who has the floor?

The PRESIDING OFFICER. The floor is held by the Senator from Maine, who had yielded to the Senator from West Virginia.

Mr. RANDOLPH. Mr. President, I have
some further remarks I am going to make in reference to the conference report, but I have just called attention to the colloquy here.

The PRESIDING OFFICER. The Senator from Maine has the floor.

Mr. MUSKIE. Mr. President, I yield the floor so the Senator from West Virginia can have the floor in his own right for the purpose of yielding to other Senators.

Mr. BAKER. I wanted to make sure who had the floor so that I know to whom I should address my inquiry so that I might comment on the colloquy between the Senator from Maine and the Senator from Missouri.

The PRESIDING OFFICER. The Chair recognizes the Senator from West Virginia.

Mr. RANDOLPH. Mr. President, be-
cause of the colloquy which has ensued, I yield next to the Senator from Missouri.

Mr. EAGLETON. I thank the Senator. As the Senator from West Virginia knows, the air pollution bill was pending before the Committee on Public Works for many months.

Mr. RANDOLPH. The Senator is correct.

Mr. EAGLETON. And on numerous occasions representatives of the administration, Dr. Middleton, and others in the Department of Health, Education, and Welfare, either testified before the Committee on Public Works, and I refer to the Subcommittee on Air and Water Pollution of that committee, or had con- ferences and communications with that committee.

Mr. RANDOLPH. The Senator is correct.

Mr. EAGLETON. It is well known that
as the bill evolved through the committee process, in subcommittee, in full committee, in markup, and so forth, and it was widely disseminated in the public press that the Senate committee was considering a 1975 model year cutoff with respect to new cars.

Mr. RANDOLPH. At this point the able Senator knows that much of what is printed in the press on so-called exec- utive sessions, and conversations of Members, is a constant problem, not that the press should not inform its readers. I commend the media for attempting to be accurate. But I think there is a con- stant question mark in stories of this kind. I would not say that what we were doing was precisely set forth.

Mr. EAGLETON. Passing for a mo- ment from what had or had not been published in the press, it was abundantly well known in the Department of Health, Education, and Welfare that the Senate committee was considering and leaning strongly toward a 1975 cutoff with respect to new cars. Is that correct?

Mr. RANDOLPH. The Senator is cor- rect.

Mr. EAGLETON. Then, I would like to ask this question, without for a mo- ment wishing to detract from the ex- cellent bipartisan cooperation in the committee and in the Senate which has made this bill possible: No one questions the prerogative of any Cabinet official to write a letter to any Senator or Representative at any time he is predisposed to do so; but what is raised by the timing of this letter is more significant than the content of the letter. Bear in mind that we worked on this bill for many months and that we had gone through laborious executive sessions in the Committee on Public Works, and we had Mr. Middleton for a part of those sessions, and the bill was reported to the floor. On the floor it was vigorously debated, and, in particular, the provision on automobiles was debated between the Senator from Maine and the Senator from Michigan. Then the bill went back to conference. There was a tentative agreement, and it was printed in the press before the election recess that the tentative agreement had been reached
on this portion of the bill. After all of that, we hear in writing from Secretary Richardson for the first time after the election recess that he has some objection to the 1975 cutoff deadline.

The point I am trying to make is that I do not question Mr. Richardson's ability or authority to write the letter. But with that history behind this bill I do question why it took him until November 1970 to make his position clear with re- spect to this single most contentious portion of the bill.

Mr. RANDOLPH. I wish to reply. I have said that it would have been much better if the letter from Secretary Richardson had come sooner.

Frankly, in the matter of a conference report I am not interested in attempting to charge the administration with being weak. I am not attempting to charge them with being weak or strong
on this subject matter. The Senate acted, the House acted, and now Congress is acting.

It is my feeling that that which has gone before-the expression of various viewpoints and possibly the late timing of the expression by the Secretary-are matters that perhaps are not as important as what we have done. That is why I have said it is a matter of interpretation. I respect my colleagues in their discussion of the matter and I understand they have their reasoned judgment on the matter. I am sure other members of the committee and of the Senate have their feelings with respect to the situation.

Mr. EAGLETON. I thank the Senator. Mr. BAKER. Mr. President, will the Senator yield?

Mr. RANDOLPH. Mr. President, I yield to the Senator from Tennessee.

(At this point Mr. EAGLETON assumed the Chair.)

Mr. BAKER. Mr. President, I was a conferee in connection with this bill. I
am a member of the Subcommittee on Air and Water Pollution and have been since I came here in 1967. I have served with great pleasure under the chairmanship of the chairman of the subcommittee and the distinguished chairman of the full committee.

As far as I can recall, this is the first time the purposes of an air quality bill, or for that matter a water bill, have been subordinated in debate on the floor, or in committee, for political purposes. I feel that was the case in the colloquy that just took place between the Senator from Maine and the Senator from Missouri.

I feel the Senate passed a meaning- ful, worthwhile and strong bill. I think it will contribute materially to the busi- ness of cleaning up air in this country and taking care of the problem of automobile emissions. That has been accom- plished because Republicans and Democrats on that committee for many years have cooperated not only between each other but at the staff level. Under the leadership of our chairman on the full committee and the chairman of the subcommittee staff members have cooper- ated, and there has also been coopera- tion with the agencies of government in the executive department which, for weeks, months, and years on end have conferred almost constantly with staff members on the minority side and the majority side as to how best to arrive at sound conclusions. This cooperation has been so close that some of these discussions are discernible in the platforms of both major parties and in the state of the Union message of the President of the United States. That is no small ac- complishment for a committee or a subcommittee.

The Senator from Maine is to be com- mended without restraint for his leadership and motivation to the rest of us in this field. That makes it all the more tedious for me to sit in this Chamber on the eve of the adoption of a conference report underscoring a good bill and hear
a political purpose being served by a bill that was worthwhile, notable, and non- political, even under circumstances which might understandably have been suspect of producing a different atmosphere and a different set of circumstances.

If the Senator from West Virginia will yield for a moment more I wish to clarify my statement. I am referring specifically to the remarks, as I understood them, by the junior Senator from Missouri to the effect that the Richardson letter, re- ferring to the Secretary of Health, Education, and Welfare, Elliot Richardson, dated November 17, 1970, and I quote: "must be interpreted as an attempt on the part of the administration to undercut the strong Senate bill."

Now I had not proposed to say anything about the automobile section at this time as the Senate considered this proposal because I believe my colleagues who were conferees on this bill will recall that I was the only conferee in the House or the Senate who did not agree and specifically voted against the first weakening of this bill.

I think my conferee colleagues might also agree that I have contended from the very beginning that Congress ought 42388December 18, 1970 CONGRESSIONAL RECORD

- SENATE

to do what we apparently have not chosen to do in this case, and that is to remove the serious business of deciding whether or not the automobile industry has made a good faith effort to comply with the bill's requirements beyond the tender mercies and the political motivations of a future Congress, and, rather, vest it in the independent judiciary to gather those facts and resolve those conflicts and decide, in 1976, a Presidential year, an election year for a third of this body and all of the House of Representatives.

The legislative department will be called upon to sit as a factfinding body to decide whether or not the automobile industry will be permitted to continue manufacturing automobiles, assuming it has not fully met this statutory deadline. I think it is a horrible prospect. I think it would be difficult enough for the independent judiciary to undertake it.

All of that, I say again, I have subordinated to the desires of the majority of the conferees, and I felt, and I still feel, we have a good bill, but I also feel that it is unfair to overlook the weeks and months of coordination between the members and staff of this committee and this administration and the previous administration, and the weeks and months and even years of nonpartisan cooperation between the members and the staff of this committee, and the inspired leadership of our committee chairman and
our subcommittee chairman in trying to unravel probably the most delicate and complex domestic problem that has con- fronted the country in 100 years, and do it in a spirit of give and take; and then
as we get to final passage of the bill, with a few Senators on the floor, we hear the charge that the position of the administration is to undercut a strong Senate position.

I submit that is not worthy of the effort that has gone into this legislation thus far and into previous legislation in previous sessions of the Congress.

Mr. RANDOLPH and Mr. COOPER addressed the Chair.

The PRESIDING OFFICER. The Senator from West Virginia.

Mr. RANDOLPH. Mr. President, I wonder if I might complete a very brief comment on the conference report.

Mr. COOPER. I wanted to comment on the point just made.

Mr. RANDOLPH. I yield to my able colleague from Kentucky.

Mr. COOPER. Mr. President, I know the Senator from West Virginia will point out the constructive work the Senate and House conference have done on this most important bill. But before he speaks, I want to respond to the statements that have been made that the letter from the Honorable Elliot Richardson indicates that the administration will try to undercut this bill. I must say I have found nothing in the letter which supports the statement. In fact, while the letter disagreed with the Senate and House versions of the bill on some points, the letter states that the administration wants a strong bill. Secretary Richardson, said this in the closing paragraph of his letter: In conclusion we would like to reiterate the Administration's strong support for the effective control of air pollution by legislation embodying the major features of the House and Senate bills. Accordingly, we recommend the enactment of such legislation, incorporating the recommendations made above, during this session of the Congress.

Mr. President, I ask unanimous consent that the entire text of Secretary Richardson's letter be inserted at this point in the RECORD.

There being no objection, the letter

was ordered to be printed in the RECORD, as follows:
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE, Washington, D.C., November 17,1970. Hon. JENNINGS RANDOLPH, Chairman, Committee on Public Works, U.S. Senate, Washington, D.C.

DEAR ME. CHAIRMAN: I am writing to present the views of the Administration to the conference committee considering the House and Senate versions of H.R. 17255, amendments to the Clean Air Act.

To begin with, it is extremely gratifying to note that all of the major Clean Air Act amendments proposed by President Nixon in his February 10, 1970 environmental message to the Congress are reflected in both versions of the bill. I refer specifically to the President's proposals regarding national air quality standards, State adoption of implementation plans covering the whole area of every State, emission standards applicable to major new stationary sources of air pollution and to hazardous emissions from all stationary sources, expanded and streamlined enforcement powers, assembly-line testing of motor vehicles, and regulation of fuels and fuel additives.

We are, therefore, fully in accord with the objectives and the essential features of both the House and Senate bills. In our judg- ment, however, both bills have certain provisions that should be modified in the manner recommended below. While this letter makes reference to the Secretary of HEW throughout, as do both bills, we note that the Senate bill has the effect of vesting these authorities in the Administrator of the Environmental Protection Agency, as contemplated by Reorganization Plan Number 3 of 1970.

Automobile Emissions. The Senate bill would require, under provisions that have
no counterpart in the House bill, that certain automobile emissions be reduced by 90 percent from the 1970 levels by 1975, un- less the Secretary of HEW extends this peri- od for one year, which extension would be subject to judicial review.

The objective of these provisions is to accelerate substantially the current timetable for controlling automobile emissions. The Senate bill does this by making effective in 1975 the standards administratively projected to take effect no later than 1980. We fully support the objective of accelerated control of automotive air pollution and support the proposed establishment of 1975 as a target date for achieving the proposed 90 percent reduction.

Based on the information available to us at this time, we are uncertain whether the requisite control technology will be developed and reduced to commercial practice on a mass-production basis by 1975-76. This presents the Federal government with a dilemma. On the one hand, if, despite a maximum effort, the necessary control technology cannot be developed and put into production, then emissions cannot in fact be reduced to the levels sought. On the other hand, the prospect of repeated deadline extensions based simply on the absence of control technology gives rise to an understandable concern that automobile manufacturers may not press the development of such technology and its application as rapidly as they should to meet air quality requirements.

The Senate bill would resolve this dilemma by providing an absolute statutory deadline of 1976, despite the fact that the very basis the bill provides for the single extension from 1975 to 1976--that all good faith efforts have been made to meet the standards, but
no effective control technology has been developed-would logically justify additional extensions for a manufacturer on the basis of similar findings.

We believe that provision for additional extensions of the deadline can be made while at the same time assuring maximum effort by the manufacturers, as sought by the Senate bill. To accomplish this, we suggest that, using the 1975 standards as a yardstick, the manufacturers' efforts be examined pe- riodically by a highly competent, impartial body outside of Government-the National Academy of Sciences and/or the National Academy of Engineers would be eminently qualified to play such a role. (We understand the conferees are interested in using the Academies in a manner that may be related to this proposal.) Such examination should involve periodic determinations of the manufacturers' level of effort and judgment
as to the progress in developing adequate control technology, and its application to
mass production. The results of such examinations would keep the Congress and the Secretary informed of the manufacturers' efforts and progress toward meeting the standards and provide the Secretary with a basis for determining whether to grant or deny any extension which a manufacturer might seek. It seems to us that such a procedure would provide a more orderly and equally beneficial process for achieving the results sought by the Senate bill.

We would also favor two other changes in the provisions of the Senate bill with respect to automobile emission standards. First, there is a serious question whether the bill, in fixing January 1, 1973 as the earliest time

a manufacturer could seek a deadline extension, gives proper recognition to automotive production lead times. Establishing any specific date in the bill seems unnecessary to us, however, and we recommend that this matter be left up to the judgment of the Secretary. There is clearly a natural reg- ulator at work here, since the earlier a manufacturer might seek an extension, the less credible would be its claim that it had made

a good faith effort to meet the standards. Second, we also recommend that, instead of providing for essentially de novo judicial review of the Secretary's decision with regard to an extension request, the bill should provide for the customary more restrictive scope of judicial review.

Warranty of Automotive Pollution Control Systems. In provisions that again have no counterpart of the House bill, the Senate bill requires, effective 90 days after appropriate test procedures have been established, that the automobile manufacturers warrant that their pollution devices will meet pre- scribed emission standards for 50,000 miles.

In testimony before the Senate committee the Administration supported the principle of requiring a manufacturer's warranty of control devices, and we continue to support this principle. However, we regard the 50,000 mile warranty as inappropriate and unrealistic in the light of known technology and experience.

At the present time neither the Federal government nor the manufacturers have sufficient or reliable knowledge as to why, in

some cases, a particular automobile in actual use fails to meet emission tests. This being the case, substantial and no doubt 42389CONGRESSIONAL RECORD

- SENATE December 18, 1970

lengthly research and studies would have to be undertaken before the Secretary could, with any confidence, promulgate defensible test procedures, which under the bill would make the manufacturers liable for the satisfactory performance of emission devices for 50,000 miles. Thus, the provisions of the Senate bill could have the unintended result of actually delaying the imposition of any warranty requirements for a long period of time. If on the other hand the Secretary were to promulgate test procedures before the Government or the manufacturers better understand why some automobiles fail to meet emission requirements, manufacturers would almost certainly price the warranty at a level which would fully protect them from this lack of knowledge. Also, the manufacturers could understandably specify extremely stringent maintenance requirements as a condition of the warranty. Since most car owners would have little incentive to comply fully with all of these requirements, the warranty would be unenforceable in many cases and would make virtually no contribution to control of air pollution.

We favor including a provision in the bill which would authorize the Secretary to impose warranty requirements on the manufacturers as he determines that such requirements can be justified on the basis of adequate operating knowledge that has become available. Such warranty requirements could be made more stringent as more knowledge and experience in these matters are gained, with a view toward progressing to the goal of a 50,000 mile warranty requirement on all

new automobiles. We also favor requiring from the outset a manufacturer's warranty against defects in material and workmanship.

State Vehicle Emission Standards. The Senate bill, in provisions not contained in the House bill, would empower States to fix special emission standards for new vehicles

more stringent than the standards fixed by this legislation if the States could prove to the satisfaction of the Secretary that such action were necessary to meet air quality standards in regions within their jurisdiction.

We believe that existing law properly provides for Federal preemption of emission control standards for new vehicles, in recognition of the need for uniformity and the inability of manufacturers to produce different types of vehicles for a number of States. In addition, as a practical matter there would appear to be very little further reduction in automobile emissions available to the States, in view of the stringent Federal emission standards contemplated by the Senate bill for 1975. We recommend that the present Federal preemption concept be retained without change, and that the States attain air quality standards by the ample variety of other

means contemplated by the bill-including control of emissions from other than new cars, and, if necessary, traffic controls.

Export Veticles. The Senate bill would eliminate a provision in the existing Clean Air Act which exempts new motor vehicles and engines manufactured solely for export and sale abroad from applicable emission standards. The House bill would make no change in existing law in this regard.

We are unaware of any rationale to support this proposed change, and we believe that the considerations which supported the present export exemption provision are still valid. The emission standards adopted by a number of foreign countries on the basis of their air pollution control needs probably will continue to be significantly less stringent than the emission standards contemplated by the Clean Air Act. American motor vehicles are required, of course, to comply with applicable foreign emission standards, and requiring them to comply with the differing American standards could seriously prejudice their competitive position abroad.

Mandatory Licensing. The Senate bill compels holders of patents, trade secrets, or know-how on pollution control devices to grant licenses to all applicants for the use (upon payment of reasonable royalties) of these devices, if the Secretary of HEW determines that this is necessary to facilitate compliance with air pollution standards for automobiles, aircraft, and vessels, for hazardous facilities, or for new stationary

sources. There are no comparable provisions in the House bill.

The constitutionally-recognized protection which patents afford has been a key element in encouraging innovation, and we
are seriously concerned as to what the ultimate effects of this major change in policy might be. In particular, we are uncertain as to its possible deterrent effects on the incentive to invent in the pollution control field, where the need for innovation is so great. Moreover, we are not aware of the basis for assuming that developers of essential air pollution control technology would refuse to make it available either by license

or direct sale to the users.

We recognize that this authority is permissive, and that the report of the Senate Public Works Committee emphasizes that very restrictive use should be made of it. Despite this, we are not convinced of the need for such a basic change in policy in light of its potential adverse effects and in the absence of known abuses. If in the future a situation arises in which a refusal to make technology available threatens to jeopardize the national air pollution control effort, Congress can then legislate to meet the particular problem.

Citizen Suits. The Senate bill authorizes citizens to bring civil actions against alleged polluters (including governmental entities)

or against the Secretary of HEW to enforce compliance with the requirements of the Act. There are no comparable provisions in the House bill.

In authorizing citizen suits directly against alleged polluters, this provision builds on the trend of existing law, and we do not object to its enactment. Such suits

can contribute to the effective enforcement of air pollution control measures.

However, the authorization of citizen suits against the Secretary to force him to take enforcement action in a particular case would have the unintended result of reducing the overall effectiveness of our air pollution control efforts by distorting enforcement priorities that are essential to an effective national control strategy. Therefore, we recommend the deletion of that portion of the provision authorizing suits against the Secretary. This deletion will not affect the right of citizens to move directly against alleged polluters, including Federal agencies.

We note that the Senate bill contains no express provisions either requiring bonds to be posted as a condition for granting pre- liminary injunctions (i.e., injunctions granted before full hearings) or explicitly stating the authority of the courts to fit final relief to the equities of the case. Adequate bonds and flexibility of relief can be very important in cases of this type. However, we trust that the courts will exercise their existing authority to fix preliminary injunction bonds at levels sufficient to protect any defendants later found upon full hearing to have complied with the Act and to frame final orders that fully take into account all of the circumstances of the case.

State Implementation Plan Deadlines. The Senate bill provides that within nine months after promulgation of any national ambient air quality standard each State is to submit to the Secretary for approval an implementation plan for each air quality control region, providing for the attainment of the stand- ard within three years after approval of the plan. In addition to limited Secretarial au- thority for extensions based on new infor- mation, provision is made in the bill for ju- dicially-granted one-year extensions of the three-year deadline, upon petition of the Governor of the State concerned (subsequent to the approval of the implementation plan) if the Court determines that such relief is in the paramount interest of the U.S. and that
means to control the emissions have not been available for a sufficient period of time. The House bill contains no such provisions.

In providing for extensions of this dead- line subsequent to approval of the imple- mentation plan, the Senate bill plainly con- cedes that cases may very well arise where mariginal or inadequate emission control technology would render it impossible to meet the standard within the three-year period. Although both the State and the Secretary might agree that this is so at the time an implementation plan is submitted for approval, the Senate bill forbids the Sec- retary from approving anything but a three- year implementation plan, which in due
course probably would be appealed by the Governor. The net effect of the bill's provisions in such cases would be to place both the Secretary and the State concerned in the untenable position of approving an implementation plan they know is unrealistic and probably unworkable.

To avoid this type of situation we favor
an amendment which would, in the few

cases where it might be necessary, permit the Secretary to extend the deadline at the time the State's implementation plan is being reviewed and approved. Such extensions should only be made if the Secretary determined that adequate control technology is not available and is not likely to be available, and he should be required to make public his determination and the specific grounds

on which it rests. Moreover, once beyond the three-year period the Secretary should determine periodically whether adequate control technology is available and make known his findings and any requisite compliance determinations resulting therefrom.

Certification of New Sources. The Senate bill establishes a Federal requirement (which could be delegated to the States) to certify that all new stationary sources of emissions meet Federal performance standards reflecing the latest available control technology and processes. Such certification would involve (a) preconstruction review of locations and design of any new source, (b) performance tests within a reasonable time after operation commences, (c) methods to identify violations and enforce compliance, and (d) methods to assure that any new source will not prevent implementation of national air quality standards or goals. The House bill contains no comparable provisions.

We feel that this certification procedure is overly elaborate and would impose a heavy and unnecessary burden on both the Government and industry. Moreover, industry would appear to have ample incentive for preconstruction consultation with responsible officials even without this special mechanism. We see no reason why performance requirements could not be established and enforced in the same manner as other emission requirements. If compliance with performance standards were made part of a State's implementation plan, these adverse consequences would be avoided and there would also be the additional benefit of placing the basic enforcement responsibility in the State,

as is generally the case under the Act, rather than in the Federal Government, as the Senate bill provides.

While we recommend that basic enforcement of performance standards should be in the States, we favor retaining the provision of the Senate bill which allows the Secretary 42390December 18, 1970 CONGRESSIONAL RECORD

- SENATE

to enforce these standards without being required to make a finding that a State has failed to perform adequately. We also would favor a similar pattern for the enforcement of emission standards established under section 114 of the Senate bill.

We can see merit to a statutory requirement that the emissions from all new sources would have to be measured at the time (or within a reasonable time thereafter) they begin operations, and we would support the retention in the bill of provisions to accomplish this purpose.

National Security Exemptions. The Senate bill authorizes the President to exempt Federal property, facilities, vehicles, or vessels from applicable emission standards, whenever he determines that this is necessary in the paramount interest of the United States. The bill also authorizes the Secretary of Defense to defer for one year, if necessary for the purpose of national security, the applicability of emission standards to military aircraft and vessels. The comparable provision in the House bill, which covers only emissions from new stationary sources, carries out the Administration's recommendations for exemptions by the Secretary of HEW when he determines they are necessary for the purpose of research, investigations, studies, demonstrations, or training, or for

reasons of national security.

We would support the approach of the Senate bill, if aircraft are included under the Presidential exemption provision, since the reasons for authorizing exemptions for all other Federal facilities, vehicles, and vessels are equally applicable to aircraft, particularly combat aircraft. We also believe that the Presidential exemption should be made applicable to non-Federal facilities, since there could conceivably be instances where their exemption would be as much in the paramount interest of the U.S., as would be the exemption of Federal facilities.

Hazardous Emissions. The Senate bill requires zero emissions from facilities determined by the Secretary of HEW to be emitting pollutants hazardous to health even in trace amounts, with a specified timetable for compliance and enforcement, unless the

owner of such facility can demonstrate that continued operation (under applicable emission standards) will not endanger the public health. The House bill contains no comparable provisions.

Of course, hazardous emissions should be effectively and quickly controlled, as was recognized in the Administration's bill. Because the Senate bill in Section 114 gives the Secretary general authority to set emission standards, down to zero levels, for all facilities, we think the Secretary should have the flexibility to deal with hazardous emis- sions on a priority basis within this general authority. In fact, the Secretary could move more swiftly and equally effectively under such general authority, in Sections 114 and 116 of the Senate bill, than he would be able to under the special hazardous emission con- trol procedures contained in Section 115. Ac- cordingly, we recommend deletion of Section 115 of the Senate bill, and any necessary modifications of Section 114 to fully cover hazardous emissions.

Low Emission Vehicle Procurement. The Senate bill requires the Federal Government, in provisions not contained in the House bill, to procure vehicles determined to be "low emission", and authorizes premium prices to be paid for such vehicles.

These provisions were contained in a separate bill added by amendment on the Senate floor. We had recommended a number of modifications in these provisions in com- ments on both that separate bill and a com- parable bill in the House. We continue to support these changes, and particularly feel that there should be discretion in the President with respect to procurement of these vehicles in order to assure realistic CXVI- 2670--Part 32 accommodation to budgetary priorities and the special vehicular needs of the Government, and to permit orderly procurement should there be a number of "low emission" vehicles to select from.

Fuels and Fuel Additives. The House bill contains a number of restrictive provisions on the authority to fix standards respecting the composition of fuels or fuel additives. For example, standards on fuels and fuel additives could be fixed under this authority only if the Secretary could show that it is not otherwise technologically or economically feasible to achieve automobile emission standards. The Senate does not contain similiar restrictions.

The Administration recommended broad authority to regulate fuel and fuel additives, because it believed that such authority, in conjunction with controls over sources using such fuels, is necessary in order to mount the most effective overall attack on air pollution. We recommend, therefore, that these provisions be modified to conform with the Administration's air pollution bill, the essential provisions of which on this matter

are incorporated in the Senate bill.

Also in connection with fuels, we would recommend that authority over aviation fuels and additives be lodged in the Secretary of HEW, who will have jurisdiction over all other fuels and additives, rather than being placed in the Administrator of the Federal Aviation Administration, as the House bill provides.

Personnel. Two troublesome provisions of the Senate bill, relating to personnel who would be authorized to participate in carrying out the Act's requirements, raise serious precedential and administrative problems and we urge their deletion. There are no comparable provisions in the House bill.

Section 10 of the Senate bill would authorize a sweeping exemption from the customary Civil Service appointment and classification laws, as they relate to the procurement of personal services to carry out the Act's requirements. We believe that the personnel needs of the air pollution control program, like similar needs in other urgent Federal programs, can be met within the Civil Service framework. In addition to creating a most undesirable precedent, this provision would constitute a marked departure from a longstanding Federal policy against the performance of clearly governmental functions by non-governmental personnel, which is of particular concern in this instance due to the important regulatory and enforcement actions to which such work could give rise.

The Senate bill provides in various sections, but most notably in proposed Section 305 of the Act, that attorneys appointed by the Secretary would be authorized to represent him in suits brought by or against the Government under the Act's provisions. Such authority is at odds with long-standing Federal policy of this and prior Administrations of placing litigating authority in the Attorney General, to be exercised as he deems appropriate. This policy derives from the sound administrative practice of relying on the Justice Department's established legal expertise and resources, rather than promoting the duplication of such expertise and resources in each of the Federal departments and agencies. We favor deleting Section 305 (as well as making comparable conforming changes in other provisions of the bill), the result of which would be that in actions instituted under this Act, officers of the Department of Justice under the direction of the Attorney General would appear for and represent the United States or any officer or agency thereof, including the Secretary.

Procedural and Technical Changes. We believe that there are a number of places in both the Senate and House bills where changes in procedural and technical provisions would avoid unintended results and materially improve the legislation. We would like to furnish such changes to the conferees informally along with the revisions needed to carry out the amendments recommended in this letter. In view of the sweeping and widespread implications of this bill, and in order to avoid, to the greatest extent possible, litigation that could slow down its im- plementation, we believe you will agree that its complex provisions need to be drafted with the greatest possible care and precision.

In conclusion, we would like to reiterate the Administration's strong support for the effective control of air pollution by legislation embodying the major features of the House and Senate bills. Accordingly, we recommend the enactment of such legislation, incorporating the recommendations made above, during this session of the Congress.

The Office of Management and Budget advises that enactment of H.R. 17255, if amended as recommended in this letter, would be in accord with the program of the President, Sincerely, ELLIOT RICHARDSON, Secretary.
Mr. COOPER. Mr. President, Elliot Richardson is a man of quality and integrity. He would not make statements to the Senate and to the Senate Public Works Committee which were in con- tradiction to his deeply held views.

The administration has made, from time to time, recommendations relating to the whole field of the environment and particularly on pollution control. It has responded more to these problems than any administration we have known.

I have always, and do now, pay tribute to the chairman of the subcommittee, whose leadership in this field is known not only to Congress but to the country. I pay tribute to the chairman of the Public Works Committee. I have served

on this committee, I suppose, longer than anyone else on the committee. I served 2 years in the Senate in 1947 and 1948, and I was on that committee. We passed in 1948 the first pollution control bill. It was small in scope, but a good one, and was sponsored by the late Senator Robert Taft of Ohio and the late Senator Alben Barkley of my State of Kentucky.

We have been fortunate that Democrats and Republicans have served together under fine leadership. We have laid aside political matters. We have worked openly and honestly with each other. For that I am thankful, and I am

sure that the Senate is thankful. But, in my opinion, I must say I think it is unfortunate to interject political views

as we come to the point of approving what has been termed as the most complex, and one that will perhaps have greater significance and impact than any bill in this century. So I regret that those speculations have been made. I hope we will continue to go forward and work as we have in the past.

Mr. MUSKIE. Mr. President, will the Senator yield?

Mr. RANDOLPH. I yield. Mr. MUSKIE. Mr. President, I made the statement earlier that I was disturbed by the Elliot Richardson letter, and I was. But I concede that to discuss it, in connection with this conference report is unfortunate. Whatever opinions we had about it we could discuss elsewhere, and

we could discuss them as we wished. I wish the issue. had not arisen most of 42391CONGRESSIONAL RECORD

- SENATE December 18, 1970

all because the Republican side of this subcommittee and this committee has cooperated so wholeheartedly over so many years in the development of this legislation. I refer to the Senator from Kentucky, the Senator from Tennessee, the Senator from Delaware, the Senator from Florida, and the Senator from Kansas. There has never been the slightest bit of partisanship in any of our committee deliberations or in our conference work with each other over a period of
some 7 or 8 years now. I want to underscore what my good friends from the Republican side of the aisle have said on that point this afternoon.

I want to say to them that I do regret that this argument has arisen this afternoon. I hope we will proceed now to dispose of the conference report.

I know the Senator from West Virginia desires to put some questions to me.

Mr. RANDOLPH. Yes; I do wish to do that.

Before doing so, I repeat that this legislation represents a significant achievement in the evolution of our national environmental policy-an evolution which has been carried forward, in great degrees, by the leadership of the Senator from Maine (Mr. MUSKIE). I think that

we have to insure the protection of the health of the citizens of this Nation, and

we have to protect against environmental insults-for when the health of the Nation is endangered, so is our welfare, and

so is our economic prosperity.

I think that the emphasis here on the health benefits that will follow when implementation of the bill becomes law is very important.

I now ask the distinguished chairman of our subcommittee whether it is not a fact that, when we have dealt with previ-

ous legislation, we have concentrated primarily on the immediate problems of air pollution control and the environment, and it seems to me now that we
are providing additional enforcement for those existing sources of air pollution, but, more significantly, we are providing effective means of prevention of future air pollution problems.

Is that the feeling and the understanding? I believe the record should reflect it.

Mr. MUSKIE. Yes; I think that to a greater extent than we might have in past legislation, we are undertaking to deal with the long-term aspects as well

as the short term. I would agree with that.

Mr. RANDOLPH. And provision is made for performance standards for new stationary sources, to make sure that no industrial development will degrade the quality of the air so as to endanger public health and welfare, or interfere with and restrain further economic growth. I know at times on the subcommittee and

on the committee we have talked about the economics of this legislation as well

as the health standards of the legislation, and I know that the Senator from Maine has been one of those who have recognized that this legislation is both

an economic measure and an air pollution measure.

I believe that is correct; may I inquire whether the Senator shares that view? Mr. MUSKIE. The Senator is correct. It undoubtedly will have an economic impact all across this country.

Mr. RANDOLPH. Yes, it will, and it will be costly. And yet the ugly face of pollution must be erased.

The implementation of the policies that are contained in this measure will test the determination in this country to achieve a livable environment, not only for ourselves but for future generations. In turn, the legislation will test the willingness of the citizens-not just the various levels of government, but the citizens of this country-to control, abate, and prevent environmental pol- lution. And I wish to compliment the Senator from Maine that, in his addresses throughout the country, in his presentation of these problems before audiences on college campuses and elsewhere, he has emphasized the personal obligation which must be recognized-a rebirth, I should say, of responsibility on the part of the individual citizen of this country.

Is that the feeling of the Senator from Maine?

Mr. MUSKIE. Completely, may I say to the Senator. We cannot clean up the pollution problem with a piece of legislation. There has to be commitment to it by every citizen, not only with respect to the activities of others, but with respect to each citizen himself, to deal with this problem.

Mr. RANDOLPH. Yes. I appreciate the Senator's attitude.

I conclude by saying that ultimately each and every person will be called on to pay the increased costs-and we must not forget it-associated with the achievement of an environment that, at a minimum, does not endanger public health, for, frankly, if we do endanger public health, we shall have degraded the environment. Effective implementation will require a major commitment,
as the Senator from Maine has said, of Government and of industry, of course, but also-and I appreciate his stressing its importance, as I have-of each individual citizen.

I am pleased that the House conferees have made an authorization of $1.1 billion for fiscal years 1971 and 1972. These figures represent the magnitude of the commitment that will be necessary to meet the challenge that is ahead. The next step must be to provide Federal staffing-and I think this is most important-commensurate with the effective implementation of what we are doing today. We must not allow understaffing -the Senator from Maine has discussed this matter in our subcommittee and our committee, and in conference-of this Federal program, because if that happens, it will be a major interference with the implementation of the National Air Quality Standards Act of 1970, as was the case, very frankly, in connection with the Air Quality Act of 1967.

I commend all those who have worked within the conference and all those who have worked within the House of Representatives and the Senate, and especially I commend the chairman of the confer- ence, Representative HARLEY O. STAGGERS, who was a strong advocate, a fair negotiator, and a patient chairman. I commend also the very able chairman of the Senate conferees, my friend, Senator MUSKIE, and all the members of the Committee on Public Works and their staff, both majority and minority, who have put so many long hours into a bipartisan effort to bring forth what will be the most effective pollution control legislation yet enacted by the Congress.

Mr. SPONG. Mr. President, the con- ference report before the Senate, when fully implemented, will assure an accelerated rate of progress in our national effort to improve the quality of our air environment.

The Senate conferees acceded to sev- eral modifications in the bill approved unanimously by the Senate on Septem- ber 22, 1970, but the final product is an effective and far-reaching environmental protection measure.

The conference report would establish
as 1975 standards the automobile emission goals previously proposed for 1980 for carbon monoxide and hydrocarbons. We have accelerated by 1 year the date
on which automobile manufacturers may seek an extension of that deadline. By allowing such applications to be filed on January 1, 1972, we have taken into fuller account the leadtime problems of the automobile industry.

The report also would enable the Administrator of the Environmental Protection Agency to set interim standards in the event he finds technology is not available to meet the standard provided by law. The Administrator, in making a decision on interim standards, would have the benefit of reports from the National Academy of Sciences on the progress that has been made in the development of technology and knowledge of the goodfaith effort of the industry to meet the 1975 deadline.

The report sets a deadline of 1976 for meeting the standard for oxides of nitrogen, with provision for a 1-year extension. Automakers could apply for that extension on January 1, 1973.

The thrust of the section of the Sen- ate bill requiring the establishment of national emission standards for hazardous substances has been changed. The Senate measure required the publication of a proposed prohibition of emissions of hazardous substances. The conference report requires the Administrator of the Environmental Protection Agency to publish a list of pollutants which in his judgment is extremely hazardous to public health. He would subsequently publish proposed regulations establishing emission standards. The modified provision requires the Administrator to "establish any such standard at the level which in his judgment provides an ample margin of safety to protect the public health from such extreme hazard."

The conference report retains concurrent Federal-State jurisdiction over enforcement activities, although the final product is a combination of the Senate and House approaches to the matter. We agreed that in situations where a State has primary enforcement responsibility, the Administrator of EPA would be re- quired to give the State 30 days notice before issuing an order or seeking court action. The Administrator may act without notice to the State in cases where 42392December 18, 1970

the Federal Government has primary enforcement responsibility.

Both bills provided for the establishment at the Federal level of national ambient air quality standards, and that concept is of course in the conference report. Implementation plans to be prepared by the States to meet the standards must provide for achieving the standards within 3 years. Again, there

are provisions for an extension in the event technology is not available.

I wish to emphasize, Mr. President, that the implementation plans to be prepared by the States to meet the primary national air quality standards must include provision for land use and transportation controls. In my judgment, the term transportation controls is not restricted to motor vehicles. For some areas, the implementation plans may well specify a limitation upon the number of civil aircraft which may land at any airport within such areas. Such restrictions may be necessary in certain metropolitan areas in order to meet the ambient air quality standards.

The conference substitute retains the Senate provision for citizen suits against violators, although suits against the Administrator of the Environmental Protection Agency are limited to actions in which there is an alleged failure by the Administrator to perform mandatory duties imposed by the statute. Before a suit can be brought, 60-day notice must be given to the alleged violator, the Administrator and the State. The courts are given discretionary authority to award costs, including reasonable attorney and witness fees, to any party.

Mr. President, I understand the purpose of that section of the report which establishes a mechanism for the licensing of patents to those subject to emission standards to be set under the legislation. It is our intent to provide an assured supply of technology to all needing it to comply with the standards.

After reflecting upon the implications of the section, I would have preferred that the issues involved be reviewed by the Judiciary Subcommittee on Patents, Trademarks, and Copyrights. However, the conference report language on the matter is an improvement over the pro- visions in the Senate-passed bill. The section will not become generally opera- tive for at least 2 years, and in the interim I would hope that the issues involved will be the subject of hearings and review.

Mr. President, the conference committee has devoted many hours of arduous work on its report. It has been a rewarding personal experience because of the dedication of those involved to see the objective of protecting the public health. I wish to thank and commend the Sen- ator from West Virginia (Mr. RANDOLPH) and the Senator from Maine (Mr. MusKIE), the distinguished chairmen of our committee and subcommittee, for their leadership during the development of this legislation. I also wish to pay tribute to the invaluable contributions of the Senator from Missouri (Mr. EAGLETON), the Senator from Delaware (Mr. BOGos), the Senator from Kentucky (Mr. COOPER), and the Senator from Tennessee (Mr. BAKER). CONGRESSIONAL RECORD

- SENATE

Mr. President, I wish to echo what has been said about the bipartisan approach to this legislation. As a member of the subcommittee and as a conferee, I can attest that Senators on both sides of the aisle have participated on a nonpartisan basis.

I should like to ask the Senator from Maine to answer one question. Section 110 of the conference report requires the development of implementation plans by the various States, and the approval of such plans by the Administrator. Paragraphs 2 and 2(B) of the section, governing those plans, read as follows:

(2) The Administrator shall, within four months after the date required for submission of a plan under paragraph (1), approve or disapprove such plan or each portion thereof. The Admimstrator shall approve such plan, or any portion thereof, if he determines that it was adopted after reason- able notice and hearing and that-

(B) it includes emission limitations, schedules, and timetables for compliance with such limitations, and such other meas- ures as may be necessary to insure attainment and maintenance of such primary or secondary standard, including, but not limited to, land-use and transportation controls;

I should like to know if, in the opinion of the Senator from Maine, the term "transportation controls" is limited to motor vehicles.

Mr. MUSKIE. No; I think that that phrase ought to be considered in a much broader context, if we are to fully understand what the intent of the legislation is.

It seemed to the committee that transportation policies must be developed or improved to insure that the impact of pollution from all existing moving sources-automobiles, aircraft, trains, vessels, and so on-is reduced to the minimum compatible with the needs of each region.

For example, construction of urban highways and freeways may be required to take second place to rapid transit and other public transportation systems. The

use of motor vehicles may have to be restricted and, in some congested areas, the number of operations of aircraft into an airport may need to be limited, or steps taken to reduce emissions while aircraft are on the ground.

If such controls are required, the committee believes the plan for implementation should so provide. If the plan is approved, Congress expects the Federal regulatory agencies to take the steps necessary to assure compliance with the plan; because what is involved in these greater urban areas, from the standpoint of air pollution, is the whole complex of residential patterns, employment patterns, and transportation patterns-the way in which people move about, go to their work, and live-and all of this ought to be subject to modification, and must be modified if the objective of clean air is to be achieved.

Mr. SPONG. I thank the Senator from Maine.

Mr. MUSKIE. Mr. President, I yield to the Senator from Delaware.

Mr. BOGGS. Mr. President, I thank the distinguished chairman.

I wish to express strong support for the conference report on these amendments to the Clean Air Act. This bill, I think, is the most far-reaching and important legislation for the control of air pollution ever to be considered by the Congress.

In time, it will bring our Nation clean air and a healthier environment.

It should be pointed out that this bill follows closely the concepts created in the legislation passed in September by the Senate. Further, it adheres in many details to the concepts and recommendations offered by the administration as long ago as last February.

Mr. President, I share the thoughts of the distinguished chairman of the subcommittee-I know how sincere and dedicated he is--when he stated that he regrets the partisan nature of the discussion of Secretary Richardson's letter. I share his feelings. I, too, am sorry that occurred. The chairman has pointed out, as have others, that we have maintained
an absolutely bipartisan approach on environmental questions, certainly a major problem confronting our country. I have every confidence that it will con- tinue to operate in a bipartisan manner. Therefore, I stand with the chairman of my subcommittee in regretting that the incident occurred.

In conclusion, Mr. President, I com- mend the leadership and cooperation offered by the distinguished chairman of the Committee on Public Works, Mr. RANDOLPH, the distinguished Senator from Maine (Mr. MUSKIE), the distinguished ranking Republican member of the committee, Mr. COOPER, the distinguished Senator from Tennessee (Mr. BAKER), and the distinguished Senator from Kansas (Mr. DOLE). Each has been most cooperative and helpful in studying
a very difficult and complex subject. This legislation is going to involve not only the Federal Government but every other level of government-the States, the cities, the counties-as well as public and private organizations. In actuality, it will affect and benefit every individual in our country.

In addition, I wish to commend Representative STAGGERS of West Virginia, the chairman of the House committee, and the other conferees on the part of the House. And I thank the staffs of both the committees and the Members for their excellent assistance.

The conference was long and painstaking. It nas produced a conference report that I believe will bring to the Nation effective control of air pollution. This bill is a credit to the country. I strongly com- mend it to my colleagues.

Mr. MUSKIE. I thank the Senator. I yield to the distinguished Senator from Rhode Island.

Mr. PASTORE. Mr. President, I commend my distinguished colleagues, the Senate conferees, for the compromise legislative product which is now before

us.

I would have liked to have had more opportunity to review the House-Senate conference report and all the details of these very important amendments to the Clean Air Act, but I recognize that ex- pedition is mandatory if we are to deal with the major items of legislation still before the Senate at this session. 4239342394 CO;

I did take the time to study the bill carefully to ascertain that the new amendments to the Clean Air Act will not interfere with or change the present statutory framework and implementing regulations for controlling radiological effluents from nuclear facilities. The new Environmental Protection Agency and the Atomic Energy Commission now have certain authorities and responsibilities with respect to such matters as radiation protection standards or the regulation and control of radiological effects from nuclear facilities. Under our present statutes we have very excellently safeguarded health and safety in regard to the use and regulatory control of nuclear facilities, and in my judgment it would have been unwise and potentially dangerous for a generally comprehensive legislative measure such as the one before us to dilute or interfere with our presently governing requirements.

I again want to congratulate my distinguished colleagues for bringing about this compromise, for doing a splendid job, and for rendering such an excellent public service.

Mr. MUSKIE. I thank the Senator from Rhode Island. He has accurately stated the effect of the bill on the point he has raised. I am happy to endorse his view of it.

I yield to the Senator from Kentucky. Mr. COOPER. Mr. President, today the Senate members of the Conference Committee on the Clean Air Amendments of 1970 bring back for final action a bill which has been described as perhaps the most significant domestic legislation of the decade. The action today represents the culmination of a thorough exercise of the legislative process, beginning with 20 days of hearings in the subcommittee, followed by more than a dozen executive sessions of the subcommittee, more than 10 executive sessions of the full committee, 2 days of debate on the Senate floor in September and, finally 12 conference meetings with the House in order to bring to the Congress this conference report.

I would like to note for the RECORD that the number of conference meetings with the House was in no way related to any attempt or desire to obstruct or delay on the part of any Member of the Senate or the House conferees. Rather, it simply reflects the degree of the differences between the House and Senate bill and the great scope of the legislation. Every Member had the same objective, and the conference report before the Senate is truly a historically significant bill.

Great credit is due to the cochairmen of the conference committee of both Houses, Representative STAGGERS of West Virginia and Senator MUSKIE. Of course, special credit is due to Senator RANDOLPH, chairman of the Senate Committee on Public Works, and to Senator BOGGS, the ranking minority member of the subcommittee on Air and Water Pollution. But I would like to add that this conference was very well attended by all Members and I am especially proud that Senator BAKER and Senator DOLE on the minority side contributed so much in the development of this conference report. NGRESSIONAL RECORD

- SENATE

The staffs of both committees also deserve special credit, for not only has the work been difficult and heavy with re- sponsibility, but also, the parliamentary situation has compressed the time available and they have performed magnificently. Their work was most helpful, and I think their names should be placed in the RECORD.

It would be difficult to single out any provision in this bill for special attention. I think it represents a firm application of pollution control procedures, while at the same time being just and incorporating throughout, due process and fairness. The bill provides many procedural protections and involves the judicial branch of Government to a degree never before attempted in programs to achieve environmental quality.

The bill will place great responsibilities

on nearly every aspect in our society. It certainly will place great burdens on industry, it will place great burdens on Government, both at the State and Federal level, and it will place great burdens

on the people generally for they will ultimately have to bear the expense and, for the first time, possibly experience inconvenience so that we might achieve clean and healthful air. The provisions ask for the highest quality of Government activity, and I am pleased that the bill will become law nearly coincident with the establishment by the President of the Environmental Protection Agency. The administration of that agency is entrusted to Mr. Ruckelshaus, who I believe is an excellent choice to control the exercise of the many duties and responsibilities of the Federal Government under this law.

With the passage of this bill the time for resolute action has come, action that must not be based on recrimination or punishment, but based on the fair application of the law. The burdens are great and I trust that the Federal Government, State government, industry, and the people will all work together to achieve this goal.

Mr. MUSKIE. I thank the Senator. As he has said, the staff work has been superlative throughout the consideration of this measure.

In addition to the work of committee, Chief Clerk Richard Royce, Minority Clerk Bailey Guard, and Counsel Barry Meyer, the staff of the subcommittee including Leon Billings, Dick Wilson, Dick Grundy, Phil Cummings, Becky Beauregard, Frankie Williams, Sally White, Eleanor Putz, and the minority staff including Tom Jorling, Harold Brayman, Adrien Waller, Hester Dungan, and Ann Brown are to be congratulated.

Several staff members of Senators were also essential in the development of this legislation including Eliot Cutler of my staff, Allen Jones of Senator SPONG's staff, Bob Maynard of Senator EAGLETON'S staff, Jim Jordan of Senator BAKER'S staff, and Ward White of Senator DOLE'S staff.

Mr. BOGGS. I share your views of the staff and their performance. It has been terrific.

Mr. MUSKIE. Mr. President, I yield to the distinguished Senator from Wisconsin. December 18, 1970

Mr. NELSON. Mr. President, I concur in the remarks made by the distinguished Senator from Kentucky.

My staff and I have had occasion from time to time to consult and work with members of the staff of the Air and Wa- ter Pollution Subcommittee. They are all superbly able and cooperative and are making a great contribution to the en- vironmental problems presented to that subcommittee.

I did not know that the conference report was going to be brought up today, so I did not have an opportunity to prepare any remarks. However, I do wish to say that the committee members on both sides of the aisle are to be commended for coming up with such a landmark piece of legislation.

I particularly want to say that this bill is a great credit to Senator MUSKIE, whose record in terms of his concern, his activities, and his constructive efforts in the environmental field are unexcelled by anyone else in public life. Today we see before us another solid environmental achievement from Senator MUSKIE and a landmark piece of legislation. I join all those who are concerned about the environment in commending him for his tremendous contribution.

Mr. MUSKIE. I thank the distinguished Senator from Wisconsin. My greatest regret in the work of this com- mittee was that the Senator from Wisconsin left the committee several years ago. Yet, he has not abandoned his interest in this field. Indeed, he has con- tinued to be a leader nationally in all environmental questions. It is always helpful to have his close interest and attention-and even prodding from time to time-to help us in our work.

Mr. DOLE. Mr. President, I join my colleagues in urging approval of the conference report on the Clean Air Amendments of 1970.

We are all familiar with the need to prevent the further deterioration of our air. Early this year, President Nixon devoted a major portion of his environmental message to the problem of air pollution.

The need was clear, and in response, the Subcommittee on Air and Water Pollution and the full Public Works Committee carefully considered and reported out a bill we felt would contribute to preserving and protecting our environment. Amendments were accepted on the Senate floor which improved that bill. But the legislation we have before us today combines the best elements of the House and Senate bills.

Everyone will not be completely satisfied with the final version of H.R. 17255, but it represents our uest efforts to act with the knowledge available to us at this time in an affirmative but constructive manner. It is possible that we will face unanticipated problems in the future, but the Congress will have the opportunity to review the Clean Air Act upon its expiration.

I would point out that the passage of this act does not mean we will eliminate air pollution overnight. It would be impossible to physically accomplish that fact. But it does mean we have taken aDecember 18, 1970 CONGRESSIONAL RECORD

- SENATE

substantial first step. It is now up to government at all levels, private industry, and every individual American to make this act work.

I commend my colleagues on the subcommittee and the full committee for their long but fruitful work on this important legislation, and urge approval of the conference report.

The PRESIDING OFFICER. The question is on agreeing to the conference report.

The report was agreed to.

MESSAGE FROM THE HOUSE
A message from the House of Representatives, by Mr. Berry, one of its reading clerks, announced that the House had agreed to the following concurrent resolutions, in which it requested the

concurrence of the Senate:

H. Con. Res. 771. Concurrent resolution for the printing of environmental report;

H. Con. Res. 785. Concurrent resolution authorizing the printing as a House document the book entitled "Our American Government and How It Works: 1,001 Questions and Answers"; and

H. Con. Res. 790. Concurrent resolution to provide for the printing of 5,000 additional copies of parts I and II of the hearings before the Special Subcommittee on Education of the Committee on Education and Labor entitled "Discrimination Against Women."

ENROLLED BILLS AND JOINT RESOLUTIONS SIGNED The message also announced that the Speaker had affixed his signature to the following enrolled bills and joint resolutions:

H.R. 6114. An act for the relief of Elmer M. Grade and for other purposes;

H.R. 6400. An act for the relief of Reddick B. Still, Jr., and Richard Carpenter;

H.R. 15549. An act to amend title 10, United States Code, to further the effectiveness of shipment of goods and supplies in foreign commerce by promoting the welfare of U.S. merchant seamen through cooperation with the United Seamen's Service, and for other purposes;

H.R. 17809. An act to provide an equitable system for fixing and adjusting the rates of pay for prevailing rate employees of the Government and for other purposes;

H.J. Res. 1416. Joint resolution fixing the time of assembly of the 92d Congress; and

H.J. Res. 1417. Joint resolution extending the dates for transmission to the Congress of the President's Economic Report and of the report of the Joint Economic Committee.

HOUSE CONCURRENT RESOLUTIONS REFERRED The following concurrent resolutions
were severally referred to the Committee
on Rules and Administration:

H. Con. Res. 771. Concurrent resolution for the printing of environmental report;

H. Con. Res. 785. Concurrent resolution authorizing the printing as a House document the book entitled "Our American Government and How It works: 1,001 Questions and Answers"; and

H. Con. Res. 790. Concurrent resolution to provide for the printing of 5,000 additional copies of parts I and II of the hearings before the Special Subcommittee on Education of the Committee on Education and Labor en- titled "Discrimination Against Women." DEPARTMENT OF TRANSPORTATION AND RELATED AGENCIES APPROPRIATIONS, 1971 The Senate resumed the consideration of the report of the committee of conference on the disagreeing votes of the two Houses on the amendments of the Senate to the bill (H.R. 17755) making appropriations for the Department of Transportation and related agencies for the fiscal year ending June 30, 1971, and for other purposes.

The PRESIDING OFFICER. The question now recurs on the conference report
on the appropriations bill for the Department of Transportation.

Mr. NELSON. Mr. President, what is the question?

The PRESIDING OFFICER. The question is on agreeing to the conference report on the appropriations bill for the Department of Transportation.

Mr. NELSON. Mr. President, I am not prepared to vote yet.

ESTABLISHMENT OF A NATIONAL MINING AND MINERALS POLICY

Mr. ALLOTT. Mr. President, I ask the Chair to lay before the Senate a message from the House of Representatives on S. 719.

The PRESIDING OFFICER (Mr. SPONG) laid before the Senate the amendments of the House of Representatives to the bill (S. 719) to establish a national mining and minerals policy, which were, on page 1, line 4, strike out "1969." and insert "1970".

On page 1, strike out all after line 4

over through and including "Act." in line 11, page 2, and insert:

SEC. 2. The Congress declares that it is the continuing policy of the Federal Government in the national interest to foster and encourage private enterprise in (1) the development of economically sound and stable domestic mining, minerals, metal and mineral reclamation industries, (2) the orderly and economic development of domestic mineral resources, reserves, and reclamation of metals and minerals to help assure satisfaction of industrial, security and environmental needs, (3) mining, mineral, and metallurgical research, including the

use and recycling of scrap to promote the wise and efficient use of our natural and reclaimable mineral resources, and (4) the study and development of methods for the disposal, control, and reclamation of mineral waste products, and the reclamation of mined land, so as to lessen any adverse impact of mineral extraction and processing upon the physical environment that may result from mining or mineral activities.

For the purpose of this Act "minerals" shall include all minerals and mineral fuels including oil, gas, coal, oil shale and uranium.

It shall be the responsibility of the Secretary of the Interior to carry out this policy when exercising his authority under such programs as may be authorized by law other than this Act. For this purpose the Secretary of the Interior shall include in his annual report to the Congress a report on the
state of the domestic mining, minerals, and niAneral reclamation industries, including a statement of the trend in utilization and u depletion of these resources, together with such recommendations for legislative programs as may be necessary to implement the policy of this Act. Mr. ALLOTT. Mr. President, I will shortly ask that the Senate adopt the amendments of the other body to my bill S. 719, but first, I believe a few comments
are in order.

There has been some misunderstanding with regard to my concerns over the inclusion of the energy minerals within the scope of the National Mining and Minerals Policy. The House Report on this measure contained this comment:

One of the chief concerns appeared to be that the inclusion of these minerals in S. 719 would detract from the urgency of establishing a national energy policy. The Committee is fully aware of the need and urgency for
an energy policy and it is also aware of the numerous studies now underway on the en- ergy situation as well as the legislation now pending in both the House and the Senate to set up a commission to study this problem.

While this may be the concern of some, it is not my concern. Quite the contrary, the inclusion of the energy minerals would be a very positive step toward the establishment of an energy policy.

Without commenting upon the merits of a national energy policy, the matter of including the energy minerals concerned
me because as the House Report points out: S.

. The fuel minerals make about 65 percent of the total value of all domestically produced minerals.

To put it another way, two-thirds of

our minerals industry is involved in the production of energy.

My concern is that the energy minerals, and especially in light of the present energy crisis, will dominate considerations in effecting the policy. It is not that I am unaware of the energy crisis-the whole Government is aware of it. There

are a number of committees, commissions, and other groups, both governmental and non-governmental studying the problem, and it appears that there will be more. There seems to be little doubt that the energy problem will receive the attention it deserves. My concern is that the other minerals, so essen- tial to our standard of living and national security, will not receive the attention and consideration they require and deserve.

I expressed this concern during the confirmation hearings on Dr. Osborn, the
new Director of the Bureau of Mines. Dr. Osborn was asked if he would administer the programs of the Bureau of Mines and propose new programs under the authority of S. 719 which would place equal emphasis upon the general mineral industry as on the energy mineral industry. Dr. Osborn indicated that he thought it could be done, and affirmed his belief that it should be done. He concurred in my concern that the energy mineral extraction industry might tend to overshadow the "hard-rock" or general mineral industry, and confirmed his belief that the emphasis on each should be equal or comparable.

The question then is, how best to achieve this equality or comparability of emphasis?

There is little doubt in my mind that the problems of oil and gas are quite different, in general, from the problems 42395

# Exhibit 3

### Calendar No. 427

101ST CONGRESS SENATE REPORT

1st Session 1 A 101-228



### CLEAN AIR ACT AMENDMENTS OF 1989

REPORT

OF THE 

### COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED STATES SENATE
together with

ADDITIONAL AND MINORITY VIEWS

TO ACCOMPANY



### S. 1630

DECEMBER 20, 1989.-Ordered to be printed

U.S. GOVERNMENT PRINTING OFFICE

24-525 WASHINGTON: 1989

For sale by the Superintendent of Documents, U.S. Government Printing Office Washington, DC 20402COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS QUENTIN N. BURDICK, North Dakota, Chairman DANIEL PATRICK MOYNIHAN, New York JOHN H. CHAFEE, Rhode Island GEORGE J. MITCHELL, Maine ALAN K. SIMPSON, Wyoming MAX BAUCUS, Montana STEVE SYMMS, Idaho FRANK R. LAUTENBERG, New Jersey DAVE DURENBERGER, Minnesota JOHN B. BREAUX, Louisiana JOHN W. WARNER, Virginia HARRY REID, Nevada JAMES M. JEFFORDS, Vermont BOB GRAHAM, Florida GORDON J. HUMPHREY, New Hampshire JOSEPH I. LIEBERMAN, Connecticut
DAVID M. STRAUSS, Staff Director ROBERT F. HURLzY, Minority Staff Director
(I)

### CONTENTS

Page G eneral statem ent
........................................................................................................... 1 Discussion of provisions: Title I-Attainment and maintenance of ambient air quality standards: In trodu ction

...................................................................................................... . 5 Designation of areas (section 101)

.................................................................. 13 Enhanced monitoring and inventories (section 102)

................. 16 Transportation guidance (section 103)

.......................................................... 18 General planning requirements (section 104)

............................................. 19 Federal facilities (section 105)

........................................................................ 23 General provisions for nonattainment (section 106)

................. 23 Additional requirements for ozone nonattainment areas (section 107).. 30 Additional requirements for carbon monoxide nonattainment areas

(section 108)

.................................................................................................... 52 Additional requirements for PM-10 nonattainment areas (section

10 9)

................................................................................................................... 68 Interstate pollution (section 110)

................................................................... 75 Outer continental shelf activities (section 111)

........................................... 76 Indian tribes (section 112)

............................................................................... 78 Miscellaneous and conforming amendments (section 113)

....................... 80 Secondary standards (section 114)

................................................................. 81 Title II-Mobile source controls: Introduction

...................................................................................................... . 82 Emission standards for certain motor vehicles (section 201)

.................... 88 Carbon monoxide emissions at cold temperatures (section 202)

.............. 92 Control of vehicle refueling emissions (section 203)

................. 93 Evaporative emissions (section 204)

.............................................................. 94 Onboard emission diagnostic systems (section 205)

.................. 96 Emissions of carbon dioxide from passenger cars (section 206)

............... 98 Low-polluting vehicles (section 207)

.............................................................. 101 Light duty vehicle useful life (section 208)

.................................................. 102 Warranties (section 209)

.................................... 102 Non-road engines (section 210)

...................................................................... 103 Prohibition on production of engines requiring leaded gasoline (section 2 11)

.......................................................................................................... 105 Motor vehicle testing and certification (section 212)

................................. 106 In-use compliance-recalls (section 213)

...................................................... 107 Fuel volatility (section 214)

............................................................................. 109 D esulfurization (section 215)

........................................................................... 110 Lead phasedow n (section 216)

......................................................................... 112 Fuel quality (section 217)

................................................................................. 116 Oxygenated fuels (section 218)

....................................................................... 118 M isfueling (section 219)

................................................................................... 120 U rban buses (section 220)

................................................................................ 121 Enforcem ent (section 221)

............................................................................... 122 Consideration of Federal transportation and environmental policies

(section 222)

.................................................................................................... 127 Title III-Air toxics: B ackground discussion

..................................................................................... 127 Hazardous air pollutants (section 301)

......................................................... 147 Marine manufacturing (section 302)

............................................................. 202 Dual regulation of radionuclides (section 303)

........................................... 203 Prevention of sudden, accidental releases (section 304)

............................ 205 Municipal waste combustion: Air emissions (section 306)

............ 251 Municipal waste combustion: Ash disposal (section 307)

.......................... 257

(III)IV Page Discussion of provisions-Continued Title III-Air toxics-Continued Consultation (section 308)

............................................................................... 260 Title IV-Acid deposition control: Background

........................................................................................................ 261 Acid deposition control (section 401)

............................................................. 302 Repeal of percent reduction (section 402)

.................................................... 337 Federal facilities (section 403)

........................................................................ 338 Acid deposition standard (section 404)

.......................................................... 341 N

ational acid lakes registry (section 405)

.................................................... 344 Industrial sulfur dioxide em issions (section 406)

........................................ 344 Sense of the Congress on emission reduction costs (section 407)

............. 345 Continuation of the Acid Deposition Assessment Program (section

408)

.................................................................................................................. 345 Title V-Permits: Introduction

....................................................................................................... 346 Title VI-Enforcement and reauthorization: Introduction

....................................................................................................... 357 Section 113 enforcem ent (section 601)

......................................................... 358 Reviewability of administrative orders (section 602)

................................. 366 Com pliance certification (section 603)

.......................................................... 368 Contractor inspections (section 604)

.............................................................. 369 Administrative enforcement subpoenas (section 605)

................................ 369 Em ergency orders (section 606)

...................................................................... 370 Contractor listings (section 607)

....................................................................... 371 Judicial review pending reconsideration of regulation (section 608)

...... 372 Citizen suits and petitions (section 609)

....................................................... 372 Enhanced implementation and enforcement of new source review

requirem ents (section 610)

.......................................................................... 376 M ovable stationary sources (section 611)

..................................................... 376 Authorizations (section 612)

............................................................................ 376 Title VII-The Stratospheric Ozone and Climate Protection Act: Introduction

....................................................................................................... 377 H

earings

............................................................................................................................ 402 M arkups

............................................................................................................................. 402 Rollcall votes

.................................................................................................................... 402 Evaluation of regulatory im pact
................................................................................... 403 Cost of legislation

............................................................................................................. 403 Additional views of: Senator M itchell

....................................................................................................... 404 Senator Lautenberg

................................................................................................. 406 Senator Sim pson ....................................................................................................... 410 Senator W arner ........................................................................................................ 412 M inority views of Senator Sym m s ................................................................................ 415 Changes in existing law

.................................................................................................. 489

## Calendar No. 427

101ST CONGRESS REPORT 1st Session SENATE 101-228

CLEAN AIR ACT AMENDMENTS OF 1989

DECEMBER 20, 1989.-Ordered to be printed

Mr. BURDICK, from the Committee on Environment and Public Works, submitted the following



### REPORT
together with

ADDITIONAL AND MINORITY VIEWS

[To accompany S. 1630] The Committee on Environment and Public Works, to which was referred the bill (S. 1630) to amend the Clean Air Act to provide for attainment and maintenance of health protective national ambient air quality standards, and for other purposes having considered the same, reports favorably thereon with an amendment and recommends that the bill as amended do pass.
GENERAL STATEMENT
The Clean Air Act is the first modern environmental law to be enacted. It was first signed into law by President Johnson in 1963, replacing previous Federal air pollution legislation. In 1965 hearings before the Special Subcommittee on Air and Water Pollution, the Assistant Secretary of the Department of Health, Education, and Welfare testified: [S]erious air pollution problems aris[e] from the ever-increasing use of motor vehicles, [and] our rising demands for the energy derived from burning of sulfur-bearing fuels *..

The national importance of resolving these problems is beyond dispute. They are among the most significant factors in the growing and worsening air pollution problems currently faced by thousands of American communities

. ..None of these problems is technologically insurmountable. Our current technical capacity for dealing with them admittedly varies from one problem to another, but even where our knowledge and skills are less refined than we would wish, there exist at least partial solutions which we would have a responsibility to evaluate as rapidly as possible and to apply where feasible. (Hearing of April 6, 1965, page 22.) This statement is still true today. Although some areas of the country have improved their air quality since 1965, a majority of Americans are still breathing air that does not meet the Federal healthbased air quality standards. Our knowledge about the adverse effects of exposure to air pollution has increased since 1965. Researchers have demonstrated adverse effects at levels of exposure previously presumed to be safe. Illnesses of no traumatic origin are now linked to air pollution. In

some areas, for example, residents who do not smoke may have lungs as damaged as the lungs of heavy smokers, due to exposure to air pollution. Air pollution can silently damage our lungs and heart or act swiftly in the case of exposure to toxic air pollutants. Rigorous regulation of toxic air pollutants is needed to avoid risk of serious, irreversible damage to human health.

We are routinely exposed to thousands of different air pollutants emitted every day. Exposure to this mix of pollutants can produce

more adverse health effects than exposure to each of the individual pollutants. These synergistic effects must be considered if we are to adequately protect public health. In addition, there are many pathways of exposure to hazardous pollutants and contaminants. Exposure to polluted outdoor and indoor air, contaminated water and soil can combine to produce greater risks than exposure through only one source. In testimony before the Subcommittee on Environmental Protection, public health leaders acknowledged the continuing health threat posed by air pollution. The American Lung Association, the American Public Health Association and the American Academy of Pediatrics all testified that we are facing a public health crisis due to air pollution. Reductions in emissions of sulfur dioxide and oxides of nitrogen are warranted based on health considerations alone. This conclusion does not address the myriad of other pollutants of concern. With regard to a graph of ozone pollution in the Northeast States for 1987 and 1988, one researcher from the American Lung Association stated:

... Most States went up significantly between 1987 and 1988 and Massachusetts tripled its ozone violation days up to 28 for that particular summer of 1988. Maine and New Hampshire tripled their violation dates in one year. Vermont appears on the graph for the first time in 1988. I consider this graph frightening, hair-raising, and truly a crisis. A Harvard researcher testified before the Subcommittee that "In every epidemiologic investigation that we have performed over thepast 6 years, we have repeatedly found a 2 to 5 percent air pollu- tion effect on human mortality and morbidity. We find it very difficult to reject these consistent findings . . ." (June 17, 1987).

In a separate study, the past President of the American Public Health Association found that ".

. . air pollution is one of the greatest risks to public health in the United States. Its causes, contributes to, or aggravates a long list of disease and dysfunction- chronic bronchitis, lung cancer, nervous disorders and heart disease. As many as 50,000 premature deaths may be caused by single air pollutants or a combination of pollutants.' He further clarified his points by saying that "If further Congressional action, or voluntary action by polluters, is not taken to reduce human exposure to a broad range of toxic air pollutants, then we can expect substantial increases in the incidence of air-pollution provoked disease, dysfunction, and premature deaths. A two- to three-fold (at least) incease, or 100,000 to 150,000 premature deaths per year would not be an unrealistic estimate. It is in fact a most conservative estimate." The health problem is serious and it is pervasive. There is no choice but to breathe the air, whether it is clean or polluted. Air is inhaled regardless of its quality. This is a national resource that should be protected as our parks and national monuments are protected. To protect this resource a strong national control strategy is needed. Air pollution recognizes no State or international borders. Aggressive controls in downwind areas will do little to improve air quality if the quality of air entering the region is poor. Because States have limited resources and many additional responsibilities, both the State and Federal Government should work together to assure implementation of programs that improve air quality.

Recent History.-Since the enactment of the original Clean Air Act and the Clean Air Act Amendments of 1977, issues relating to air quality continue to require Congressional action and concern.

Attainment of the health-based air quality standards has proven more difficult than anticipated in the 1977 Amendments. Although most areas of the country were to have attained the standards for ozone and carbon monoxide by 1983, in 1989, over half of the popu- lation of the United States is still exposed to levels of air pollution considered unhealthful by the Envronmental Protection Agency and medical researchers. New and disturbing evidence on the health effects of ozone and carbon monoxide indicates that the current standards may not be adequate to protect the public health. Very little has been done since the passage of the 1970 Act to identify and control hazardous air pollutants. In the nineteen year history of the Clean Air Act, just eight substances have been listed
as hazardous air pollutants: asbestos, beryllium, mercury, vinyl chloride, radionuclides, inorganic arsenic, benzene, and coke oven emissions. NESHAPS (National Emission Standards for Hazardous Air Pollutants) have been promulgated for sources of only seven of these pollutants. Meanwhile the States collectively have regulated
over 700 hazardous air pollutants.

There is no credible dispute that acid rain is a major contributor to the burden of ill health and environmental damage in the United States. Reputable authorities, publishing their results inpeer-review scientific journals, have concluded that acid rain and its precursors are responsible for between 50,000 and 70,000 premature deaths per year. In addition acid deposition is responsible for massive damage to buildings and other man-made structures, poisoning lakes and stream to the extent that they no longer can support fish and other life, altering the chemical composition of soils and upsetting the natural balance which enables their productive use, and reducing visibility throughout the United States. During the last decade, the Committee on Environment and Public Works has reported legislation addressing all of these issues. During the 1980's, the Committee continued its efforts to devise legislation that would reduce acid precipitation levels, bring about attainment of the air quality standards, and control toxic air pollutants. Bills were introduced and reported by the Committee to the Senate three times, but none has been enacted. In 1982, the Committee reported acid rain legislation by a vote of 15-1. The reported bill required an 8 million ton reduction in sulfur dioxide by 1995. These reductions were required in a 31- State region east of the Mississippi River.

In 1984, the Committee again reported acid rain legislation which required a 10 million ton reduction in sulfur dixoide emissions by 1994. As in 1982, the reduction requirement affected only the 31 States east of the Mississippi. The last bill to be reported by the Committee was S. 1894 in November, 1987. The five title proposal contained provisions on ozone and carbon monoxide nonattainment, acid rain and clean coal technology, mobile sorces, ambient air quality standards, hazardous air pollutants and incinerator standards. The bill's acid title required a national 12 million ton reduction in sulfur dioxide emissions by 1998. Despite efforts to develop an acceptable compromise, the Senate did not act on comprehensive clean air legislation before the 100th Congress adjourned in October of that year. As with acid, rain, the Committee reported comprehensive legislation on nonattainment and air toxics in 1982, 1984 and 1987. In November of 1982, after 27 hearings and 33 markups, the Committee reported S. 3041, the Clean Air Amendments of 1982. In May of 1984 the Committee reported S. 768, the Clean Air Act Amendments of 1984. A total of nine days of hearings was held on S. 768.

In November of 1987, the Committee reported S. 1894, the Clean Air Standards Attainment Act of 1987, after 13 days of hearings and 9 days of mark-up.

S. 1630, the Clean Air Amendments of 1989, reflects the advances in our knowledge of the health effects, sources, and controls of air pollution. It builds on over a decade of careful study and consideration of the air pollution problems facing the country. It incorporates new areas of concern, such as chlorofluorocarbons, whose impact was virtually unknown a decade ago and which we now know depletes the Earth's protective ozone layer. Its goal is to protect, as a national resources, the very air that all of us rely on for
our daily existence.DISCUSSION OF PROVISIONS

TITLE I-ATTAINMENT AND MAINTENANCE OF AMBIENT AIR QUALITY STANDARDS

INTRODUCTION Background.-The goal of the Clean Air Act is to "protect and enhance the quality of the Nation's air resources." The Act distinguishes between two types of air pollutants (causing death or serious illness at low levels) which are addressed in title III of the bill and "criteria" pollutants (so-called because under section 108 of the Act EPA must issue criteria documents identifying the effects of each pollutant). Criteria pollutants are defined as those pollutants that come from numerous or diverse sources and whose presence "may reasonably be anticipated to endanger public health or welfare". Section 109 of the Act requires EPA to establish for each criteria pollutant a national ambient air quality standard that is a uniform, nationwide standard.

As defined in the Act, "primary" ambient air quality standards limit the maximum allowable concentration of each criteria pollutant to the level that "protects the public health" with an "adequate margin of safety", without regard to the economic or technical feasibility of attainment. This means identifying through research the lowest level at which health effects are observed and ap- plying a margin of safety to arrive at the ambient standard. Secondary standards are established to protest against adverse impacts on welfare, including impacts on visibility, vegetation, animals, wildlife, materials and property. The States, together with EPA, are responsible for ensuring that the primary air quality standards are met "as expeditiously as practicable", within the deadlines specified in the Act. The secondary standards are to be attained in a "reasonable" period of time.

The six criteria pollutants for which EPA has established ambient standards are ozone, lead, sulfur dioxide, particulates, nitrogen dioxide, and carbon monoxide. Each ambient standard is based on a detailed review of scientific information contained in the criteria document that is prepared by EPA and expect advisers.

The lack of a program for regular reevaluation and revision of the original ambient standards led Congress, in the Clean Air Act Amendments of 1977, to mandate that the standards be, and revised if appropriate, by December 31, 1980, and at five-year intervals thereafter.

Two standards were promulgated before the end of 1980. A new standard was promulgated for airborne lead in 1978, and a revisedozone standard was published in 1979. However, both of these actions were stimulated, at least in part, by court litigation. The hydrocarbon (HC) standard was dropped in 1983. In 1985 the 1972 standards for nitrogen dioxide and carbon monoxide were reaffirmed. A revised particulate matter standard was promulgated in 1987. Final actions on revisions of the 1971 standard for sulfur dioxide are still pending, as are revisions of the 1978 standard for lead, and the 1979 standard for ozone. The Congressional mandate to reissue or revise ambient standards by December 31, 1980, and at five-year intervals thereafter is clearly not being met.

EPA has the authority to set ambient standards for additional pollutants and is considering establishing a new standard for acid aerosols. The Agency is currently in the process of preparing a criteria document on acid aerosols and estimates the process will take five years to complete.

Health effects of ozone.-The adverse health effects of exposure to ozone are well documented. Ozone is a strong oxidant :formed by the interaction of hydrocarbons (also called volatile organic compounds, or VOCs), nitrogen oxides (NO.), and sunlight. Ozone enters the body by way of the respiratory tract. Ninety percent of the ozone inhaled into the lung is never exhaled. Instead the ozone molecules react rapidly with the cells, fluids, and tissues that line the respiratory tract, irritating and inflaming the lungs. Ozone is fatal at high concentrations. At lower concentrations found in many urban areas in the United States, extensive research has shown that healthy adults and children begin to exhibit adverse health effects. These include chest pains, shortness of breath, coughing, nausea, throat irritation, and increased susceptibility to respiratory infections. Potentially more troubling and less well understood are the effects of long-term chronic exposure to summertime ozone concentrations found in many cities. Regular out-of-doors work or. play during the hot, sunny summer months in the more polluted cities may cause biochemical and structural changes in the lung, paving the way for chronic respiratory diseases. A growing body of scientific evidence indicates that over the long term, chronic exposure to
ozone may produce any accelerated aging of the lung analogous to that produced by cigarette smoke exposure. Ultimately, emphysema may result. New evidence is also accumulating that the current ozone standard may not be sufficiently protective of public health. In one important test recently performed at EPA's research laboratory, 22 healthy individuals were exposed to 0.08 parts per million ozone for 6.6 hours, including five hours of moderate exercise. Respiratory function decreased with each succeeding hour of exposure. At the end of the exposure, it decreased by an average of seven percent, with one individual having a 26 percent reduction.. The Environmental Protection Agency has proposed and its Clean Air Scientific Advisory Committee has agreed, that the decreases in respiratory functions become adverse when the magnitude of the change exceeds ten percent. In EPA's study, seven of the 22 individuals crossed this threshold. EPA's results may indicate that the current air quality standard for ozone does not pro-tect public health with the adequate margin of safety required by the Act.

EPA is currently in the process of revising the criteria documents for ozone based on this and other existing data. The adequacy of the one-hour standard and the need for a longer-term standard (six-to eight-hour time average) has been called into question. EPA anticipates it will take approximately two more years to resolve this issue.

The people most likely to be injured from exposure to ozone include the elderly, people with preexisting respiratory problems, children (who have a faster respiration rate and are thus more exposed), and approximately 20 percent of the population, called "responders," that has a markedly strong and unpredictable adverse reaction to ozone. The American Lung Association estimated that
over 28 million pre-adolescent children, 17 million elderly, 6 million asthmatics, and 7 million persons with chronic obstructive pulmonary disease live in ozone nonattainment areas.

Health effects of carbon monoxide.-Exposure to carbon monoxide produces adverse health effects because carbon monoxide is
more readily absorbed into the blood than is oxygen. As carbon monoxide displaces oxygen, bodily functions which depend on oxygen are threatened. This means that brain and fetal functions
are particularly at risk.

At high CO levels death by asphyxiation results. At lower levels carbon monoxide pollution is especially harmful to fetuses and persons with heart disease. The fetal brain has high oxygen requirements. Health studies conducted on animals suggest that even modest levels of carbon monoxide pollution pose risks to fetal brain development and possible irreversible neural damages. The American Lung Association estimates that over 1.4 million pregnant
women live in areas which have failed to attain the carbon monoxide standards. Persons with heart disease are also susceptible to carbon monoxide pollution. A heart already weakened by pulmonary disease is particularly sensitive to the displacement of oxygen from the bloodstream by carbon monoxide because the circulatory system has limited capacity to transport oxygen throughout the body. Healthy people may also suffer adverse effects from modest carbon monoxide exposure. As oxygen levels in the bloodstream decline and carbon monoxide levels rise, persons may suffer reduced aerobic capacity. As oxygen levels in the brain are reduced, individuals may experience loss of visual perception, manual dexterity, and cognitive functions.

Those particularly at risk with respect to carbon monoxide exposure are the elderly, fetuses, children, and those with existing heart disease.

Health effects of particulate matter.-High levels of small particulate matter (particulate matter less than 10 microns in diameter, called PM-10) can produce a range of effects from temporary reductions of lung function- and increased respiratory symptoms to aggravation of existing respiratory and cardiovascular disease, cancer, and even premature death. Certain types of PM-10 pose special health risks. One especially dangerous component of PM-10 is the carbon-based particles thatresult from incomplete combustion of fuel in diesel engines. EPA has concluded that these particulates, which are emitted in the exhaust of diesel trucks, buses, and other vehicles, may cause as many as 860 cancer cases annually. Particulates from wood stoves have similar hazardous characteristics. Sulfates and nitrates, also called acid aerosols, are another dangerous type of particulates. These particulates are formed from emissions of sulfur dioxide and nitrogen oxides. Acid aerosols can sear sensitive lung tissues when inhaled. According to the Office of Technology Assessment, they could cause thousands of excess deaths each year. Even small dust particles can be hazardous, because they build up in the lungs over time and impair breathing capacity. Children are especially vulnerable to PM-10 due to their higher respiratory rates and small lungs. A recent study in Utah found that hospital admissions for children with respiratory disease (pneumonia, pleurisy, and bronchitis) were three times higher than normal during months in which the Federal PM-10 standards were exceeded. Other vulnerable populations include the elderly, asthmatics, and victims of respiratory disease.

Health care costs.-The American Lung Association estimates that people in the United States spend $40 billion per year in additional health care costs due to exposure to air pollution. A study by the University of California released in July 1989 showed that in Southern California alone, decreased air pollution would save nearly $10 billion in annual health care costs. The study estimated that the health-care costs savings from Southern California's plan to meet the Federal air quality standards by the year 2003 would
more than offset the plan's estimated $2.79 billion in pollution controls. Welfare costs.-In addition, there are environmental and welfare effects of air pollution. Ozone pollution has been shown to cause extensive damage to many types of vegetation. EPA estimates that
ozone pollution levels common in many areas can reduce tomato yields by 33 percent, beans by 26 percent, and soybeans by 20 percent. Other studies have shown that ozone levels below the Federal standard can cause wheat yields to drop by 30 percent.

According to the World Resources Institute, if ozone levels in agricultural regions were halved, the annual cost savings in crop loss would be on the order of $5.3 billion. U.S. wheat production would be boosted by $650 million (in 1987 dollars), soybean production by $3.4 billion, corn production by $880 million, and peanut production by $370 million. EPA has concluded that ozone causes annual crop losses of $2 to $3 billion per year.

Forests can also be damaged by this pollutant, but the damage to forests has not been quantified. Qualitatively, extensive damage and mortality from ozone have been demonstrated among pines in California and in the eastern United States. On high-elevation mountains in New England, most red spruce that showed significant needle loss in 1982 have since died. Fully 20 percent of the spruce alive in 1982 are now dead-a mortality rate eight times that at lower elevations. The stunted growth and 77 percent increase in mortality now showing up in commercial yellow pines in the Southeast may also reflect ozone air pollution at work.Although quantification of these damages is more difficult than ascertaining the costs of pollution control equipment, billions of dollars each year would be saved from better protection of valued
resources from ozone-induced damage, alone. PM-10 pollution, especially PM-10 pollution less than 2.5 microns in diameter, impairs visibility. The National Park Service, for example, has reported that particulate pollution, especially fine sulfate particles, impairs scenic vistas within the national park system 90 percent of the time. PM-10 also soils materials and building surfaces. According to an EPA estimate, the damage is approximately $1 to $2 billion annually. Clean Air Act history.-The 1970 and 1977 Clean Air Act Amendments established a partnership between the States and Federal government. EPA sets nationally uniform air quality standards and States, with the Agency's assistance, are responsible for meeting them. The requirement that the States develop State implementation plans (SIPs) and submit them to EPA for review allows for Federal oversight of the States' efforts to achieve and maintain the required level of air quality. In addition to the SIP process, the 1970 Clean Air Act established two mandatory control programs, one applying to new motor vehicles and the other to new stationary sources. EPA was responsible for setting standards for new motor vehicles. EPA also issues regulations for new stationary sources, called new source performance standards. The 1977 Amendments added three additional control programs, mandating
ozone and carbon monoxide nonattainment areas to require retrofit controls on existing stationary sources, more stringent emissions limits on new stationary sources, and motor vehicle inspection and maintenance programs. Primary and secondary standards for oxidants were first set by EPA in 1971. (Photochemical oxidants are a group of chemically related pollutants. From the standpoint of health and welfare effects,
ozone is the most important of these pollutants.) In 1979 EPA revised the standard from total oxidants to the current definition of
ozone only. Both the primary and secondary standards for ozone are currently defined as a daily maximum, one-hour average concentration of 0.12 parts per million (ppm), not to be exceeded more than once per year, on average. Areas exceeding this threshold are classified as nonattainment areas. EPA updates the nonattainment list annually, as data become available.

Identical primary and secondary standards for carbon monoxide (CO) were set in 1971 at levels of 9 ppm, 8-hour average, and 35 ppm, 1-hour average, neither to be exceeded more than once per year. These standards have been reviewed periodically by EPA and remain in place today. In July 1987, EPA promulgated a modified ambient standard for particulate matter shifting the base for measurement from total suspended particulates (TSP) to particulates that are smaller than
or equal to ten micrometers in size. This new standard is called PM-10 and replaces the old TSP standard. The modification was made as recent health effects documented that it is the smaller particulates, inhaled deeply into the lungs, that cause the primary threat to public health. Measurements of TSP could not reliably capture the extent of this threat, since larger particles have beenthe overwhelming portion of measured TSP (not the smaller particles capable of penetrating so deeply into lung tissue).

The smaller particles that are 10 micrometers or smaller are
more likely to cause most of the adverse health effects because of their ability to reach the thoracic or lower regions of the respiratory tract. (One micrometer is one-millionth of a meter, or 1/25,000 of an inch. For comparison, the thickness of a human air is 100-200 micrometers.) The revised PM-10 measurement establishes a 24 hour primary (health based) and secondary standard limit of 150 micrograms of PM-10 per cubic meter of air. In addition, an annual standard was set at 50 micrograms per public meter. The Agency concluded that these standards will protect the public health with an adequate margin of safety.

At the time the new PM-10 standard was established, 97 counties (or parts of counties) in the nation were not meeting the primary TSP standards and had been designated as nonattainment. Construction bans on new or modified major sources of TSP had been in place in some of these areas since 1979. EPA lifted those bans with the promulgation of the new PM-10 standard. While accurate monitoring data is limited (due primarily to limited Agency and State resources), PM-10 pollution is pervasive. EPA has developed an analysis that classifies all counties into three groups based on their probability of not attaining the revised PM-10 standard. The first group includes, those with a very high probability of not immediately attaining the new standard (roughly seventy counties). A second group contains 110 areas where existing air quality data are not sufficient to determine if they are attaining but there is some possibility that they will not reach attainment without additional control measures. The third groups contains the remaining 3,000 counties which the Agency estimates should be in attainment and will not require additional control efforts. In the Clean Air Act of 1970, Congress set 1975 as the deadline for meeting the primary air quality standards. The States were required to develop State implementation plans that would estimate the emissions reductions required to attain the ambient standards and establish the control programs to achieve the required reductions. In addition, section 111 of the Act required EPA to promulgate new source performance standards (NSPS) for new or modified stationary sources. To enforce the NSPS, the States were required to include construction permit programs in their SIPs. By 1977, two years after the original deadline, 78 areas were still violating the ozone standard then in place (no more than one exceedance per year of a one-hour average oxidant concentration of 0.08 ppm). In 1977, the deadline for meeting the ozone and CO standard was moved back to 1982. Areas could show they could not meet the 1982 deadline were able to obtain an extension until 1987. Responding to the failure to meet the goals of the 1970 Clean Air Act, the 1977 Amendments included a new and more aggressive control program. New SIPs were to be developed and submitted to EPA in 1979, and again in 1982, for areas seeking extensions of the attainment deadlines to 1987. A new schedule was established for limiting emissions from new motor vehicles. Existing stationarysources in nonattainment areas would have to retrofit with reasonably available emission controls. A new source could be constructed in a nonattainment area only if it would operate at the "lowest achievable emissions rate" and if emissions reductions could be obtained from other sources to offset the emissions from the proposed
source. Transportation control measures would have to be considered. Severe nonattainment areas would have to implement automobile emissions inspection and maintenance programs. In 1989, two years past the final deadline in the 1977 Amendments for all areas of the country to attain the CO and ozone health standards, 150 million people still live in areas which exceed
one or both of those standards. The reasons for the failure to achieve healthy air are many. Among them are the understatement of emissions in inventories submitted by the States and approved by EPA; inadequacies in models used to predict ambient air quality; failure of States to implement some of the controls they had committed to in their SIPs; failure of some of the controls to achieve the projected emission reductions; and failure of EPA or the States to require additional controls when it became evident that the attainment deadlines would not be met. The responsibility for the widespread failure to meet the ambient standards rests with both States (and local governments) and EPA. Predicting future air quality based on assumed control programs is

a complicated undertaking that is susceptible to "paper" demonstrations of attainment that bear little relation to the likelihood of actual attainment. States had the responsibility to use the best data and analytical methods available in preparing emissions inventories and conducting modeling, and EPA had the responsibility for providing guidance of what constituted the best methods and carefully scrutinizing State submissions to assure that assumptions and analyses were consistent with the guidance.

In a January 1988 report the General Accounting Office (GAO) found in the three areas it studied-Houston, Los Angeles, and Charlotte, North Carolina-that assumptions used in models and inaccuracies in data exacerbated the uncertainties normally associated with models. This led to understating inventories of emissions and therefore the amount of emissions reductions needed to bring the areas into attainment. Both the States involved and EPA bear responsibility for these miscalculations.

In several areas controls that were included in a SIP were not implemented. For example, in New York and New Jersey Stage II programs that were called for in the SIPs were not implemented until courts (not EPA) ordered the States to fulfill the SIP commitments. An American Lung Association analysis conducted in 1986 found that in Los Angeles only three of 31 transportation and energy measures had been completed on schedule.

In some cases where control measures were implemented, they proved less effective than predicted, often because of lax enforcement. For example, the GAO study reported that EPA identified 13 plants in the Charlotte area in 1985 that were emitting more VOCs than regulations allowed. EPA also found that the county had granted variances to some operations without EPA approval.

Even when EPA identified problems in areas it often did little to require remedial action. For example, EPA discovered in 1985 thatHouston's demonstration of hydrocarbon emissions reductions needed for attainment was based on a faulty ratio of NOx to hydrocarbon emissions in the area. Rather than a 41 percent reduction, the new data showed that Houston needed a 71 percent reduction in hydrocarbons. EPA took no action to require Houston to revise its SIP, however, and instead waited to deal with the deficiencies in its generic nonattainment policy that was proposed in November of 1987.

Lack of resources at the Federal, State and local level has severely hampered implementation of the Act's requirements. During the decade of the 1980's, while the demands on EPA grew, appropriated funds for the air pollution program, as for other EPA programs, decreased both in nominal and real terms. States, which are required by the Act to impose permit fees to cover the costs of administering and enforcing permit programs, in many instances have not complied. Lack of resources led to preparation of inadequate and incomplete inventories, use of less costly-and less accurate-models, less frequent review and updating of inventories and other data on which control strategies are based, inadequate enforcement programs, and, at the Federal level, woefully inadequate oversight of, and technical assistance to, the States. Lack of political will at all levels of government to implement difficult measures has also meant slower progress toward the attainment of healthy air. This is most clearly seen with respect to
measures to reduce vehicle use in heavily polluted and heavily congested areas. The largest number of SIP provisions that were submitted and approved but that have not been implemented are provisions that call for transportation control measures. EPA's Office of Transportation and Land Use Policy was eliminated in 1982, and with its demise came the elimination of the requirement for States to report on the effectiveness of control measures and the ability of EPA to evaluate these measures. Federal transportation dollars have continued to finance programs and projects that have not been sufficiently reviewed for their potential adverse effects on air quality.

The nonattainment policy proposed by EPA in 1987 attempted to address many of the problems illustrated above, primarily by requiring better data and analyses to be used in SIP revisions, inclusion of milestones or interim measures of progress during the period before attainment, and better tracking and reporting of progress. EPA has not published a final policy, but many of the proposals were incorporated in legislation submitted to Congress by the President.

Nonattainment provisions of the bilL-The nonattainment provisions of the bill are based on more than 17 years of experience in trying to attain healthy air in all areas of the nation. The deadlines in the bill for attainment are realistic, with the ozone deadlines being the longest in recognition of the complexity of the ozone pollution problem. The emphasis in the bill, however, is not on the deadlines but on what happens in the period before deadlines. The concept of reasonable further progress, which is in the current Act, is amplified by requiring specific incremental progress over defined periods for each of the pollutants addressed: ozone, carbon monoxide, and particulate matter (PM-10). Remedial steps are mandatedif an area fails to meet these periodic milestones. The bill also requires periodic updates of inventories and establishes regular reporting requirements for the States and explicit data that must be prepared by the States and reviewed by EPA. The bill imposes emissions fees on stationary sources and registration fees for vehicles in order to provide State and local agencies the resources, from polluters, to conduct effective air pollution control programs, including complying with the more explicit requirements of the bill. Stationary source fees will also provide EPA with additional resources.

Motor vehicles are the single largest source of ozone and carbon monoxide pollution. Title II of the bill addresses emissions that result from the operation of vehicles, but that, alone, is not enough. Pollution can also be reduced if fewer vehicle trips take place in polluted and congested urban and suburban areas. Title I contains several provisions to encourage State and local governments, employers and drivers to plan ahead to reduce vehicle use while maintaining-and in some cases where congestion is a serious problem actually enhancing-mobility.

The bill reflects an increasing understanding of how ozone pollution is formed and transported. Because ozone is not a local phenomenon but is formed and transported over hundreds of miles and several days, localized control strategies will not be effective in reducing ozone levels. The bill, thus, expands the size of areas that
are defined as ozone nonattainment areas to assure that controls

are implemented in an area wide enough to address the problem. For the northeastern United States, the bill establishes an ozone transport region and requires that sources of ozone-forming pollutants throughout the region-whether the sources are in attainment

or nonattainment areas-install certain controls.

The bill also requires control of oxides of nitrogen (NOx) as a means of reducing ozone levels. While there remain uncertainties about the localized effect of NOx reductions on ozone levels, it is generally accepted that overall levels of ozone are more effectively reduced by reducing both NOx and volatile organic compound (VOC) emissions than by reducing VOCs, alone. Oxides of nitrogen also contribute to PM-10 levels and are a precursor of acid rain.

In summary, the nonattainment provisions of the bill are designed to bring about emissions reductions from all the major
sources that contribute to ozone CO, and PM-10 pollution, to require regular and monitored progress toward attainment, and to
assure that where progress is not what was predicted or needed to attain the standards, additional steps are taken to keep an area on the path to attainment by the required deadline.

DESIGNATION OF AREAS (SECTION 101)

SUMMARY The bill amends section 107 of the Clean Air Act as follows: A revised section 107(f)(1) of the Act requires that within six months of issuing a new or revised ambient air quality standard, the Administrator must designate all areas of the country as either attainment, nonattainment or unclassifiable. An area that either does not meet the standard or contributes pollution to another areathat does not meet the standard is to be designated nonattainment. An area that meets the standard and does not contribute to another area that exceeds the standard is to be designated attainment. An area that cannot be classified on the basis of available information as meeting the standard is to be designated unclassifiable. Revised section 107(f)(3) of the Act designated any area that did not meet the primary ambient air quality standard for ozone or carbon monoxide as of the last calendar year before the date of enactment of the bill as nonattainment. Revised section 107(f)(4) designates each area that was identified by EPA as a Group I area in the August 7, 1987, promulgation of the revised particulate standard (PM-10) or which contains a site for which monitoring data shows a violation of the air quality standard for PM-10 before the date of enactment as nonattainment.

Revised section 107(d)(5) of the Act provides that areas may be redesignated by the Administrator upon the request of the Governor of a State or on the Administrator's own motion. The Adminis trator must act to redesignate an area not currently designated as nonattainment as a nonattainment area within one hundred eighty days of receiving evidence that the area exceeds the national ambient air quality standard for any pollutant. In order to redesignate
an area from nonattainment to attainment, the Administrator must promulgate the redesignation by rule, must determine that the area has attained the air quality standard and that attainment is due to permanent reductions in emissions, must have approved a maintenance plan, and determine that the State containing the
area has met requirements of the Act applicable to the area. The Administrator may not redesignate an area from nonattainment to unclassified. New paragraphs (2) and (3) of section 107(d) of the Act provide that the boundaries of an area that is designated nonattainment for ozone and that is located within a metropolitan statistical area (MSA) or a consolidated metropolitan statistical area (CMSA) are the boundaries of the MSA or CMSA, unless the State demonstrates that some portion of the MSA or CMSA does not contribute to violations of the air quality standard and that there is a geographical basis for excluding the portion. With respect to a serious carbon monoxide area, the Administrator may, by rule, include the entire MSA or CMSA in the nonattainment area.

DISCUSSION This section of the bill restructures and clarifies the process for designating and redesignating areas of the country depending on their emissions and ambient air quality. The bill gives significant authority to the Administrator in order to overcome the deficiencies in current law that have failed to allow the Administrator to respond to new information about pollution levels and control needs.

Existing law, as interpreted by EPA, precludes the Administrator from issuing new designations or revising existing ones when an ambient standard is revised, as occurred with the promulgation in 1987 of the ambient standard for PM-10. Current law is alsoread to prohibit new or revised designations unless requests have been received by EPA from a State, see, e.g., Bethlehem Steel v. EPA, 728 F. 2d 1303 (7th Cir. 1983). Questions have also arisen about EPA's authority to define broad nonattainment boundaries, Illinois State Chamber of Commerce v. EPA, 775 F. 2d 1141 (7th Cir. 1985).

The bill requires the Administrator to designate the status of all
areas within six months of the date a new ambient standard is promulgated or an existing standard is revised. An additional six months is available if sufficient information is not available to make the designations by the first deadline. EPA may rely for these designations on sound data that is available, preferably air quality monitoring data, but in some cases where appropriate and necessary, the Agency may rely on modeling or on statistical extrapolation from monitored concentrations of another pollutant. The Administrator is given broad discretion to determine the boundaries of the designated areas based on air quality, planning and control considerations, and other appropriate considerations. The bill explicitly provides that EPA may include within the boundary an area that may cause or contribute to nonattainment in another area, regardless of whether pollutant concentrations in the first area exceed the standard. The bill by operation of law designates areas as ozone or carbon monoxide (CO) nonattainment areas if they did not meet the primary standard for these pollutants (or other) as of the last calendar year before the date of enactment. The Environmental Protection Agency's current methods for determining attainment status with respect to these pollutants are to be the basis for determining whether an area met the standard as of the applicable date. For example, for ozone areas this would involve the most recent three years of data. And for CO, this means use of the most recent two years of data. The bill specifies by operation of law, that minimum boundaries for any zone nonattainment area that is located in a metropolitan statistical area (MSA) or consolidated metropolitan statistical area (CMSA) are the boundaries of the MSA or CMSA. If, for clear geographic reasons such as a mountain range that runs through a CMSA or MSA, emissions from an attaining portion of the area do not cause or contribute to air pollution in a nonattaining portion, the Administrator may approve a State's request to exclude the attaining portion from the nonattainment area. The bill authorizes the Administrator to redesignate an area at any time, on the Administrator's own motion or on petition from a State, based on air quality, planning and control, and other appropriate considerations. This provision makes clear that the Administrator does not have to wait for a request from a State before making a redesignation. As under current law, the submission of a redesignation petition by a State has no effect on the SIP requirements for the area for which the redesignation is requested, notwithstanding allegations which have been presented in counterclaims to Agency enforcement actions that the pendency of a State request for a redesignation to attainment is sufficient to render the current SIP unenforceable unless and until EPA denies the request.The Administrator may redesignate an area from nonattainment to attainment only by rule after determining that the area has met all the requirements applicable to it under part D and section 110 of the Act, including implementation of all stationary and mobile
source controls specified in the Act. As a condition for redesignation, the Administrator must determine that improvement in air quality is due to permanent reductions in emissions, which means that control requirements that are in place at the time the redesignation is sought must remain in effect after redesignation. The bill also requires the Administrator to determine that the maintenance plan required as a condition of redesignation assures that emissions levels will not rise so as to cuse exceedances of the applicable standard.

ENHANCED MONITORING AND INVENTORIES (SECTION 102)

SUMMARY Within six months of enactment of the Clean Air Act Amendments of 1989, the Administrator must publish guidance on improved air quality monitoring an preparation of emissions inventories for use by the States.

DISCUSSION

Monitoring. -Ozone and carbon monoxide (CO) monitoring networks have been relatively stable since the last major round of State implementation plan revisions in 1982. Nationally, ozone monitoring has grown from 610 monitors nationwide in 1982 to 630 at present, while CO monitors increased from 440 to 460. The current network leaves unanswered several important questions about these pollutants and the most effective ways to reduce ambient levels. In addition, the PM-10 network, being a relatively new program, will need careful scrutiny as it matures. The guidance required to be issued by the Administrator should address some specific issues with respect to each of these pollutants.

For ozone, there is a need for enhanced ozone monitoring in rural areas since rural areas are not adequately covered or characterized by existing ozone monitoring networks. The downwind area affected by ozone transport often extends far past the coverage of current monitoring systems. Since neither the concentrations nor the extent of the ozone problem in non-urban areas are fully understood, the rural population may be exposed to high ozone levels caused by this pervasive urban problem. Additionally, detrimental effects on agriculture and forestry have been documented in recent research and point to the need for expanding the area coverage of the ozone networks. Also, the complex mechanisms for ozone formation and the
sources of ozone precursors and their interactions remain somewhat unclear. These uncertainties suggest that if realistic, economic, and effective control strategies are to be developed, the establishment of comprehensive ozone precursor (volatile organic compounds (VOCs) and nitrogen oxides) monitoring in nonattainment
areas is needed. This precursor monitoring should include systems for both biogenic and anthropogenic VOCs. Nonmethane organiccompound (NMOC) monitoring should be instituted to track and corroborate VOC emission reductions that are assumed or projected in SIPs, to identify VOC species that may be having a significant effect on the ozone problem, and to verify and corroborate emission inventories.

For carbon monoxide, an effort to review the adequacy of existing CO networks for charaterizing the spatial distribution of the CO problem and whether an area is attainment or nonattainment must be initiated. To properly site and evaluate networks, define critical areas of impact, and to corroborate attainment/nonattainment decision, the use of inexpensive, portable, saturation monitoring techniques is needed. With constantly increasing vehicle miles traveled in the United States, there is a need for increased deployment of CO monitors and increased oversight of CO monitoring networks to ensure their adequacy. In addition to the evaluation of the adequacy of the PM-10 network and its sites, such monitoring should be enhanced for areas experiencing ambient concentrations from nontraditional sources such as residential wood combustion, agricultural tilling and diesel particulates.

Inventories. -Emissions inventories for ozone and CO are generally acknowledged to have major deficiencies which have contributed significantly to undercontrol of emissions and the lack of progress in many urban areas in attaining the ambient standards for these pollutants.

The overriding major deficiency is the generally inadequate resources and staffing devoted to emission inventory development programs at the State and local levels, as well as by EPA of the Federal level. More specifically, major deficiencies include the following: -Inadequate quality assurance programs and national oversight by EPA to assure acceptable quality and consistency of these inventories, including lack of comprehensive and prescriptive guidance on how to develop these inventories and absence of consistent review procedures that would assure that requirements are being adhered to. -Lack of completeness in inventories. Area source inventories

for small, but ubiquitious sources, for example, consumer solvents, were not compiled in many areas. Also, newly identified significant sources were not included. -Lack of periodic inventory updating that would allow credible tracking of reasonable further progress. To assure that future ozone and CO SIPs are based on inventories that are complete, current and accurate, the bill provides for substantial increases in funding (sections 106, 107, 108 and 109) to carry out improvements through emission fees that will provide resources at all levels of government.

The greatest deficiency in current efforts to develop good PM-10 inventories is the incomplete set of emission factors needed to estimate emissions from point sources and, more importantly, from

area sources-mostly fugitive dust sources-that are dominant in arid areas of the western United States. To develop these emission factors, field testing needs to be conducted. Some field testing and engineering efforts also need to be devoted to developing reliablecontrol efficiency information relative to control of PM-10 for many of the control devices and practices that have been used to control total particulate matter. Presently, rough default approximations of PM-10 control efficiencies are being used in estimating PM-10 emissions from controlled sources.

Area source emissions estimating procedures for PM-10 also provide only rough approximations of PM-10 emissions and need improvement that will take several years to achieve. Area source procedures apply, for example, to paved and unpaved road dust reentrainment, storage piles, construction activities, residential wood burning, road salting and sanding. The bill, in this section and section 109 (pertaining to PM-10), requires the Administrator to publish guidance to address the deficiencies enumerated.

TRANSPORTATION GUIDANCE (SECTION 103)

SUMMARY The bill amends section 108(e) of the Act and requires the Administrator, in consultation with the Secretary of Transportation and State and local officials, to revise the Transportation-Air Quality Planning Guidelines issued in 1987. The Administrator is also required, by an amendment to section 108(f) of the Act, to publish updated information on a specified list of transportation control measures, including information on the emissions reductions potentials of each measure.

DISCUSSION The purpose of the amendment to section 108(e) is to provide updated guidance to State and local officials on how best to coordinate air quality and transportation planning in an area.

The purpose of the amendment to section 108(f) is to require the Administrator to take a strong role in providing assistance to State and local agencies regarding transportation control measures. States containing areas classified as severe or extreme for ozone and serious for carbon monoxide will be required to consider these

measures as part of their State implementation plan. The intent of revisions of section 108(f) is to give States the information they will need to implement measures that have the potential of decreasing emissions by reducing vehicle miles traveled (VMT) or improving traffic flow. Transportation control measures are needed because the VMT nationwide is projected to increase by 2 to 3 percent per year from

now through 2005, resulting in a cumulative increase of about 40 to 60 percent, according to the Congressional Office of Technology Assessment. Average nationwide motor vehicle exhaust emissions are projected to decline through the late 1990s as an increasing percentage of vehicles on the road meet new standards, but to rise after that due to the increase in VMT.

Because of these projected emission trends, in many nonattainment areas it will be necessary to implement transportation control measures which can bring about reductions in future VMT growth, but at the same time provide enhanced mobility to serveincreasing travel demands. The intention of the requirements in the bill related to transportation planning and control measures is to direct air quality and transportation planning toward optimum
use of all potential alternatives to the single occupancy vehicle, ranging from highway facilities dedicated to moving high occupancy vehicles, to providing carpool, vanpool services and improved public transit. The 1977 Amendments to the Act required areas that would not be able to meet the ozone or carbon monoxide standards by 1982 to implement transportation control measures (TCNs) as necessary to attain the standards, and some areas included these measures in their State implementation plans. However, OTA reports that the effect of these measures has not been evaluated at the Federal level because EPA's Office of Transportation and Land Use Policy
was eliminated in 1982 and EPA has not required any reporting from the states.

In contrast, the South Coast Air Quality Management District and the Southern California Association of Governments completed in 1987-8 an assessment of the effectiveness of TCMs for the Los Angeles area. The study concluded that implementation of a wide range of TCMs would reduce highway vehicle VOC emissions by a total of 30 percent by 2010, compared to levels projected without TCMs. Total reductions in highway vehicle emissions of NO, carbon monoxide and particulate matter based on the TCM measures are also expected to be about 30 percent, compared to emissions levels projected for 2010 without the measures.

These studies indicate that in order to reduce or even avoid increases in vehicle pollution, it is not enought to control the pollution each car emits; the use of the car must be examined as well because growth in VMT threatens to overwhelm what can be achieved through tailpipe standards. These provisions, coupled with others in the bill, give EPA and the States the power to pursue a wide range of transportation demand management efforts.

GENERAL PLANNING REQUIREMENTS (SECTION 104)

SUMMARY This section of the bill makes numerous revisions to section 110 of the Clean Air Act, many of which are technical, to eliminate outdated material. Substantive changes include the following: States must submit State Department implementation plans (SIPS) within no more than 24 months after the promulgation of a national ambient air quality standard, rather than within nine months as in existing law.

Areas designated attainment or unclassifiable for a pollutant may be required by the Administrator to submit a SIP that shows how the area will maintain compliance with the ambient air quality standard for a 20-year period. States required to submit maintenance plans must update them every ten years. Any attainment or unclassified area that contains all or part of on MSA or CMSA must submit maintenance plans to the Administrator.

Provisions in existing law requiring SIPs to take into account the effect of emissions on other States are strengthened.The bill requires the Administrator to issue minimum criteria that any SIP submission must meet and sets up timetables and procedures for EPA to determine whether or not to approve a SIP.

If a State fails to submit an appropriate SIP within two years after being sanctioned for failure to submit such a plan, as required by subpart D of the Act, the Administrator must promulgate a Federal implementation plan. The initial Federal plan must require reductions in emissions but does not have to provide for attainment. Within three years after proposal of the initial plan, the Federal plan must be revised to so provide. The bill makes clear that provisions of an approved SIP stay in effect and are enforceable until a revision is approved by the Administrator.

DISCUSSION Submission and review of plans. -Experience since passage of the Clean Air Amendments of 1970 has shown that nine months is not adequate time for States to prepare and submit implementation plans for new or revised ambient air quality standards. The bill extends the period to twenty-four months. This period applies to submission of maintenance plans, which are required for every MSA
or CMSA that is contained in or contains an area designated attainment or unclassified with respect to a criteria pollutant, and to plans for every area designated nonattainment for any such pollutant, as well as to any other area the Administrator determines must submit a SIP.

Revisions to section 110(a)(2).-The bill replaces provisions currently in section 110(a)(2) of the Act with provisions that appear in paragraphs (1)-(12) of rewritten section 110(c) of the Act. The changes are as follows: Paragraph (1) of rewritten section 110(c) combines and streamlines existing section 110(a)(2)(B) and the enforceability requirement of section 172(c) of current law. Paragraph (2) rewrites existing section 110(a)(2)(C). Paragraph (3) rewrites and streamlines current section 110(a)(2)(D), deleting the reference in that section to the preconstruction review program in section 110(a)(4) of existing law.

Paragraph (4) is described below in the interstate pollution discussion.

Paragraph (5) rewrites and expands current sections 110(a)(2)(F)(i) and (vi). The new provision requires that where a local authority, to which a State has granted authority to implement a SIP, fails to do so, the State will have the means and authority to implement the plan. EPA can hold the State responsible for any implementation failure caused by local action or inaction,
or choose to exercise its existing authority to implement the SIP itself or act directly against the local authority. In addition, the State is required to manage and keep up-to-date information on implementation by local authorities so that EPA only has to rely on the State agency when it wishes to track implementation of measures throughout the State. Paragraph (6) incorporates and expands current section 110(a)(2)(F)(ii)-(iv).Paragraph (7) rewrites current section 110(a)(2)(F)(v). Paragraph (8) rewrites current section 1 l0(a)(2)(H). Paragraph (9) replaces current section 110(a)(2)(I) with a simple cross-reference to part D, deleting the construction ban in the existing section. Revised construction ban provisions appear elsewhere in the bill in revisions to part D.

Paragraph (10) rewrites current section 110(a)(2)(J). Paragraph (11) adds a new provision to the Act requiring air quality modeling as prescribed by the Adminstrator to ensure that States perform the technical work necessary to provide the basis for pollution control strategies.

Paragraph (12) rewrites current section 110(a)(2)(K) with minor revisions to be consistent with new permit fee requirements in titles I and V.

SIP provisions addressing interstate pollution. -Section 1l0(a)(2)(E) of the Act is replaced by new section 110(c)(4), which, together with changes made to section 126 of the Act by section 110 of the bill, improve the effectiveness of the Act as a means of dealing with interstate air pollution. Where prohibitions in existing section 110(a)(2)(E) apply only to emissions from a single source, the amendment includes "any other type of emissions activity," which makes the provision effective in prohibiting emissions from, for example, multiple sources, mobile sources, and area sources.

For interstate pollution to violate current law, it must "prevent attainment." Since it may be impossible to say that any single
source or group of sources is the one which actually prevents attainment, the bill changes "prevent attainment or maintenance" to "contribute significantly to nonattainment or interfere with maintenance by," thus clarifying when a violation occurs.

Under existing section 110(a)(2)(E), interstate pollution that is to be prohibited under a SIP is that which leads to a violation of the Act's specifically protected interests-attainment of the ambient standards, prevention of significant deterioration, or visibility. There are many legitimate State interests that are not spelled out and explicitly protected by the Act, for example, the effect of toxic pollutants on health or the environment. The amendment in new section 110(c)(4) makes an injury to interests that may be identified by States but that are not explicitly listed in the statute-described
as "an adverse effect on public health or welfare or the environment"-a violation of the Act.

EPA action on plan submissions.-The Environmental Protection Agency reports that in recent years a substantial number of SIP submissions have been incomplete or so deficient that they have not warranted further review. Newly rewritten section 110(d)(1) of the Act requires EPA to issue minimum completeness criteria that any SIP submission must meet and provides that the Agency need not review submissions that fail to meet the criteria. Where the Administrator finds that a SIP submission does not meet the minimum criteria, the State shall be treated as having failed to make the required submission for purposes of the sanctions provisions of the Act.

New section 110(d)(2) requires EPA to act on each SIP submission within twelve months of the date EPA determines (or is deemed to have determined) that the submission is complete. The four-monthperiod provided in current section 110(a)(2) has proved insufficient to allow EPA to conduct the necessary analyses and rulemaking proceedings. New section 110(d)(3) authorizes EPA to approve a plan in full, disapprove it in full, or approve it in part and disapprove it in part, depending on the extent to which it meets the requirements of the Act. This provision overrules the portion of the decision Abramowitz v. EPA, 832 F. 2d 1071 (9th Cir. 1987), which held that EPA could not approve individual measures in a plan submission without either approving or disapproving the plan as a whole.

New section 110(d)(4) provides that a finding by the administrator of the inadequacy of a SIP could renew previously applicable requirements, even if those requirements contained fixed, elapsed deadlines. The Administrator is given the authority to adjust the statutory deadlines consistent with the time originally allowed in the law for compliance with the requirements.

Federal implementation plans.-The bill in a rewritten section 110(f) of the Act, changes existing law (section 110(c) of the Act) with respect to the preparation of Federal implementation plans (FIPs). Current law requires the Administrator to prepare a FIP whenever a State fails to submit an approvable implementation plan, the plan is determined not to be in accordance with requirements of the act, or the State fails to revise its plan as required by the Act. In several instances EPA has been compelled by court orders to prepare FIPs.

The success of air pollution control under the Clean Air Act is premised on strong State and local control programs. Preparation by EPA of control plans applicable to specific areas within a State should be a last resort, but it is an important one to have available in cases where a State fails to take the required steps to achieve a health-based ambient standard. The bill authorizes, but does not require, the Administrator to promulgate a FIP whenever a State fails to submit a plan or submits a plan that is not adequate. The Administrator is required to propose a FIP only after a State has been sanctioned for failure to submit a plan or portion of a plan that meets the requirements of the Act and has not submitted an approvable plan or portion within two years after the sanctions were imposed. The Administrator must promulgate a FIP within one year after the end of the two-year sanction period, unless the State has submitted a plan that meets the requirements of the Act. If the State's plan or portion of a plan was required to demonstrate attainment of an ambient standard, the FIP must demonstrate attainment, but not in the original promulgation. The original promulgation must require effective emissions reductions, but an additional two years are provided the Administrator to revise the original FIP to provide such

a demonstration.

Applicable implementation plan provisions.-The bill adds a new subsection 110(k) to the Act to clarify that a provision of a SIP that has been approved by the Administrator remains in effect and is enforceable until a subsequent revision is approved by the Administrator. Current law on this issue is not clear, as courts have differed in their interpretation of the Act's requirements.FEDERAL FACILITIES (SECTION 105)

SUMMARY The bill amends section 118 of the Clean Air Act to make clear that Federal facilities are subject to fees and charges levied by State or local agencies to the same extent as nongovernmental entities.

DISCUSSION

Military installations in California's South Air Quality Management District have filed suit challenging the District's authority to require payment of fees, including permit fees. Similar suits have been filed in Federal District Court in New York, and there have been other challenges to the authority of State or local agencies to impose fees on Federal facilities. The bill clarifies existing law to make explicit what section 118 already requires: Federal facilities
are subject to the same fee requirements that are applicable to nongovernmental entities.

GENERAL PROVISIONS FOR NONATTAINMENT AREAS (SECTION 106)

SUMMARY This section of the bill designates sections 171-178 of the Act as subpart 1 of part D, adds new sections 170 and 179, and makes changes in sections 171-176 as follows:

A new definition is added to section 171. "Major stationary source" or "major emitting facility" is, for the purposes of part D of the Act, defined as including "each discrete operation, unit, or other activity and each combination thereof". The definition of "nonattainment area" is also clarified.

The plan for an area that has been designated nonattainment with respect to an ambient air quality standard must provide for attaining that standard five years from the date the nonattainment designation was made. The Administrator may extend the deadline for up to an additional five years.

All major stationary sources in nonattainment areas are required to have operating permits, beginning three years after the date of enactment of the Clean Air Act Amendments of 1989. Operating permits must be issued for no more than five years, and applications for a permit must be accompanied by a fee sufficient to cover the source's share of the direct and indirect costs of developing and administering the permit program. A permit application must be submitted to the Administrator who has sixty days to object to its issuance. Sources of volatile organic compounds, oxides of nitrogen, PM10, and carbon monoxide are required to pay an emissions fee of no less than $15 per ton, which will be available to be appropriated to EPA to carry out its responsibilities under the Act.

States with ozone or carbon monoxide nonattainment areas and local elected officials of those areas are required to review and update, as necessary, planning and implementation procedures that specify the State, local, or regional agency or agencies that will develop, adopt and implement each element of the SIP.

# P ages omi tted due to document size. Available upon request.

# Exhibit 14Source: NEI 2011 for SO2 State AK AL SO2 Emissions from Fuel Comb ‐ Electric Generation ‐ Coal (tons) 1,785 179,209 SO2 Emissions from all sources (tons) 27,651 254,121 Percent SO2 Emissions from coal EGUs by State (%) 6.5% 70.5%AR AZ CA CO CT DC DE 58,439 26,239 665 44,646 585 9,194 93,231 76,938 37,674 57,033 14,793 1,833 14,396

62.7% 34.1% 1.8% 78.3% 4.0% 0.0% 63.9%FL GA HI IA ID IL IN 84,252 187,739 1,723 99,844 217,840 354,405 173,619 233,738 27,138 133,992 13,799 288,166 427,733 48.5% 80.3% 6.4% 74.5% 0.0% 75.6% 82.9%KS KY LA MA MD ME MI 39,375 247,341 86,286 22,211 31,465 229,015 60,381 272,684 227,743 49,516 71,279 15,025 285,658

65.2% 90.7% 37.9% 44.9% 44.1% 0.0% 80.2%MN MO MS MT NC ND NE s 205,098 43,001 15,711 82,604 92,613 71,427 74,000 263,546 63,411 29,358 128,885 106,843 77,955 #VALUE! 77.8% 67.8% 53.5% 64.1% 86.7% 91.6%NH NJ NM NV NY OH OK 24,098 3,471 4,720 5,225 39,399 589,755 95,553 31,241 16,724 29,691 13,253 150,780 680,642 131,187

77.1% 20.8% 15.9% 39.4% 26.1% 86.6% 72.8%OR PA PR RI SC SD TN 13,100 320,504 196 71,697 11,101 120,108 31,031 402,958 37,407 4,397 102,941 17,893 208,407

42.2% 79.5% 0.5% 0.0% 69.6% 62.0% 57.6%TR TX UT VA VI VT WA 17,643 425,879 20,407 68,887 1,136 17,884 559,231 27,875 106,460 115 3,440 29,833

98.6% 76.2% 73.2% 64.7% 0.0% 0.0% 3.8%WI WV WY All States 90,976 93,064 35,424 4,525,848 147,471 124,107 79,926 6,557,033 61.7% 75.0% 44.3% 69.0%Ranking State Sox Emissions 1 OH 680,642 2 TX 559,231 3 IN 427,733 4 PA 402,958 5 IL 288,166 6 MI 285,658 7 KY 272,684 8 MO 263,546 9 AL 254,121 10 GA 233,738 11 LA 227,743 12 TN 208,407 13 FL 173,619 14 NY 150,780 15 WI 147,471 16 IA 133,992 17 OK 131,187 18 NC 128,885 19 WV 124,107 20 ND 106,843 21 VA 106,460 22 SC 102,941 23 AR 93,231 24 WY 79,926 25 NE 77,955 26 AZ 76,938 27 MN 74,000 28 MD 71,279 29 MS 63,411 30 KS 60,381 31 CO 57,033 33 MA 49,516 34 CA 37,674 35 NH 31,241 36 OR 31,031 36 WA 29,833 37 NM 29,691 38 MT 29,358 39 UT 27,875 40 AK 27,651 41 HI 27,138 42 SD 17,893 43 NJ 16,72444 ME 15,025 45 CT 14,793 46 DE 14,396 47 ID 13,799 48 NV 13,253 49 RI 4,397 50 VT 3,440 DC 1,833Sum of EMISSIONS Column Labels Row Labels AK AL AR Agriculture ‐ Livestock Waste Bulk Gasoline Terminals 0 Commercial Cooking Dust ‐ Construction Dust Dust ‐ Paved Road Dust Dust ‐ Unpaved Road Dust Fires ‐ Agricultural Field Burnin g 66 1,721 Fires ‐ Prescribed Fires 203 5,482 4,962 Fires ‐ Wildfires 13,095 1,195 888 Fuel Comb ‐ Comm/Institutional ‐ Biomass 2 10 7 Fuel Comb ‐ Comm/Institutional ‐ Coal 195 227 Fuel Comb ‐ Comm/Institutional ‐ Natural Gas 8 20 14 Fuel Comb ‐ Comm/Institutional ‐ Oil 62 2 0 Fuel Comb ‐ Comm/Institutional ‐ Other 2 0 0 Fuel Comb ‐ Electric Generation ‐ Biomass 8 4 Fuel Comb ‐ Electric Generation ‐ Coal 1,785 179,209 58,439 Fuel Comb ‐ Electric Generation ‐ Natural Gas 359 83 31 Fuel Comb ‐ Electric Generation ‐ Oil 916 27 66 Fuel Comb ‐ Electric Generation ‐ Other 87 Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass 0 3,071 1,855 Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal 714 8,779 18,501 Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas 988 735 36 Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil 199 457 5 Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other 0 2,815 162 Fuel Comb ‐ Residential ‐ Natural Gas 6 11 10 Fuel Comb ‐ Residential ‐ Oil 1,388 99 8 Fuel Comb ‐ Residential ‐ Other 293 2 2 Fuel Comb ‐ Residential ‐ Wood 16 23 20 Gas Stations 1 Industrial Processes ‐ Cement Manuf 498 440 Industrial Processes ‐ Chemical Manuf 4 6,571 274 Industrial Processes ‐ Ferrous Metals 3,074 827 Industrial Processes ‐ Mining 4 1 Industrial Processes ‐ NEC 23 6,449 1,677 Industrial Processes ‐ Non

‐ ferrous Metals 1 8,145 1 Industrial Processes ‐ Oil & Gas Production 506 20,151 273 Industrial Processes ‐ Petroleum Refineries 29 471 42 Industrial Processes ‐ Pulp & Paper 4,937 2,101 Industrial Processes ‐ Storage and Transfer 0 1 7 Miscellaneous Non

‐ Industrial NEC 0 2 2 Mobile ‐ Aircraft 429 75 50 Mobile ‐ Commercial Marine Vessels 6,287 320 23 Mobile ‐ Locomotives 4 168 188Mobile ‐ Non

‐ Road Equipment ‐ Diesel 47 40 41 Mobile ‐ Non

‐ Road Equipment ‐ Gasoline 7 19 12 Mobile ‐ Non

‐ Road Equipment ‐ Other 7 9 6 Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles 6 116 82 Mobile ‐ On

‐ Road Diesel Light Duty Vehicles 0 3 1 Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles 3 30 14 Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles 40 541 260 Solvent ‐ Consumer & Commercial Solvent Use Solvent ‐ Degreasing Solvent ‐ Dry Cleaning Solvent ‐ Graphic Arts 0 Solvent ‐ Industrial Surface Coating & Solvent Use 1 1 Solvent ‐ Non

‐ Industrial Surface Coating Waste Disposal 24 175 88 Grand Total 27,651 254,121 93,231AZ CA CO CT DC DE FL 8 0

143 204 615 1 747 612 2,162 1,976 2 8 7,631 10,847 5,785 726 4 30 2,084 19 53 15 5 0 1 8 18 92 ‐ 43 0 ‐ 6 496 93 16 5 3 18 1 244 77 830 375 15 931 0 394 123 1 ‐ 0 93 66 156 100 26,239 665 44,646 585 9,194 84,252 64 229 38 32 91 584 13 106 63 238 730 5 5,964

0 675 0 67 62 4,186 0 147 0 39 0 2,500 2,895 164 2,164 ‐ ‐ 1,274 15,619 15 557 328 19 1 27 942

7 1,057 282 293 7 588 7,325 0 1,446 12 1 ‐ 187 972 11 172 39 13 4 3 5

3 787 17 11,437 604 541 50 2 69 277 2 ‐ 1 3 51 350 144 125 10 18 54

10 1,063 265 58

1 1,383 100 77 21,955 28 12 76 42 31 74 55 37 2,588 5,221 1,662 7 1 4 932 31,874 31 1 0 500 0 1,132 1,761 10 6,706 136 106 0 0 0 8 3,913 0 345 4 7 29 13 4 0 2 0 0 10 350 1,484 374 52 0 3 1,117 1,663 454 0 1,980 7,277 375 70 163 11 2 4 8962 87 57 22 5 7 190 14 60 19 11 1 4 87 16 48 19 7 0 1 44 115 333 54 19 3 9 210 3 2 2 1 0 0 9 18 122 20 11 2 4 86 304 1,520 402 251 40 73 1,758

0 0 0 56 4 0 0

98 333 139 236 26 1,245 76,938 37,674 57,033 14,793 1,833 14,396 173,619GA HI IA ID IL IN KS

0 0 0 0

736 178 3,190 58 374 7 2,287 3,745 36 626 1,542 457 203 9,770 6,918 9 43 3,233 62 15 298

287 0 8 22 ‐ 27 8 4,094 ‐ 5,115 64 4,187 9,127 ‐ 15 1 15 5 68 25 10 115 402 45 26 1,073 39 3 1 0 10 1 30 5 1 82 ‐ ‐ 9 3 187,739 1,723 99,844 217,840 354,405 39,375 50 9 0 18 462 11 136 18,258 14 0 15 33 9 1 57 0 2 604 27 15 1,214 0 11 278 1 40 6 9,855 ‐ 17,771 4,287 28,775 16,492 ‐ 2,216 0 32 12 114 166 42 4,555 3,171 175 201 863 285 47 2,965 4 62 0 378 9,232 155 36 0 21 7 128 42 22 55 0 101 150 133 390 2 18 0 2,018 18 1,057 1,397 3 32 6 117 78 329 372 90 0 0 404 1,706 ‐ 825 3,342 1,650 1,580 278 377 2,758 1,480 914 3,064 92 249 893 4,181 44

‐ 3 2,459 0 1,596 561 17,658 16,667 502 0 1 610 6,760 2

‐ 359 84 196 0 1,164 0 3,324 1,010 1,920 1,405 ‐ 12 0 6 55 180 426 1 4 1 2 2 ‐ 3 2 545 296 43 39 735 133 35 648 1,433 8 0 689 31 0 222 258 100 472 217 37290 5 94 24 174 91 74 34 4 19 9 44 24 9 34 8 6 3 44 17 5 200 53 42 176 115 51 5 1 1 6 4 1 52 4 13 10 52 34 13 876 94 239 119 862 651 247

‐ ‐

‐ 0 0 0 0 0 24 0 0

223 4 95 73 3,052 239 36 233,738 27,138 133,992 13,799 288,166 427,733 60,381KY LA MA MD ME MI MN

0 ‐ 0 0

214 639 1 31 0 26 3,777 772 6,514 34 80 27 154 1,427 754 1,402 114 2 86 4,259

17 3 8 3 23 78 22 1,162 ‐ ‐ 331 2,230 47 6 55 25 44 3 51 26 12 4 6,457 2,293 2,676 764 975

2 13 38 2 10 24 2 1 6 25 108 336 247,341 86,286 22,211 31,465 229,015 40,792 9 190 56 28 18 42 129 69 241 516 439 455 286 10 137 6,347 79 3 54 726 61

53 2,260 53 111 991 502 732 3,988 340 796 22,003 132 17,461 6,428

106 356 18 3 1 71 309 164 20,887 1,797 2,425 2,717 643 632 315 11,660 31 32 555 3,495 309

15 11 38 23 0 95 40 393 25 13,502 3,105 5,246 331 949 146 1 2 44 2 307 79 126 13 211 56 188 1,091 785 0

‐ 0 188 555 16 12,847 1,665 53,382 2 1 92 42

897 48 0 674 2,727 4,808 63 0 6,606 6,685 240 138 243 3,225 2,498 5,381 1 0 ‐ 3,288 1,753

133 1,223 0 67 ‐ 208 16,236 24 ‐ 0 474 812 586 2,265 ‐ 656 697 40 28 4 3,472 0 0 0 0 2 2 2 21 3 2 5 1 236 109 244 98 28 330 271

83 6,292 1,325 5,347 359 3,178 135 158 111 230 2 9 64 19046 42 38 39 11 100 98 15 20 22 20 11 60 33 13 7 15 6 2 28 16 88 79 39 63 23 115 87

2 2 3 3 0 5 3 22 23 20 22 6 55 25 389 395 464 465 104 808 485 8 0 0

0 0 ‐ 0 0 1 0 5 0 0 1 2

161 98 937 488 388 561 589 272,684 227,743 49,516 71,279 15,025 285,658 74,000MO MS MT NC ND NE NH

0 0 0

1,531 1,083 298 399 1,902 1,747 3 3,675 2,936 1,763 2,053 1,229 1,054 5

718 228 4,633 8,944 37 110 0

36 10 12 36 1 2 5 6,796 2,698 17 6 7 18 3 10 3 61 1 248 364 9 0 1,626

4 ‐ 11 22 9 0 35 1 988 0 10 205,098 43,001 15,711 82,604 92,613 71,427 24,098 18 256 1 33 22 5 14 16 1 7 256 0 11 307

3 ‐ 2,106 23 59 11 65 435 27 1,512 1 0 8 13,759 5,055 149 7,118 2,092 356 20 126 17 265 22 91 2 313 6 4 6,244 208 15 1,095 189 26 13 890 1,087 1 5

32 7 7 20 3 12 2 57 11 106 1,497 295 35 3,082

6 2 10 532 145 3 3 236 13 30 75 13 33 149

‐ 953 398 1,067 200 1,383 1,988 5,507 353 18 0 121 22 193 0 23 70 4,601 114 94 2,265 331 585 13 23,405 3 10 257 4 0 2 5,451 170 2,073 0 143 1,501 971 305 14 1 591 21 1,485 0 0 16 45 0 8 3,728 2 0

7 2 0 5 0 1 1 205 33 35 409 29 52 25

23 348 732 0 380 348 78 245 108 158 746 378 31 30 88 62 64 10 23 12 5 34 4 7 8 14 5 2 28 1 4 3 235 64 20 119 19 37 13 2 2 1 6 0 1 0 28 17 5 52 4 8 7 451 316 94 919 70 154 105

‐ 0

‐ 1 0 0 0 6 3 0

134 91 41 246 12 25 213 263,546 63,411 29,358 128,885 106,843 77,955 31,241NJ NM NV NY OH OK OR

‐ 0 0 0 0 0 0

‐ ‐ 1

‐

‐ 115 39 65 37 230 750 87 322 58 42 79 7,131 6,325 14 7,386 822 19 4 2,470 2,908

3 18 4 9 43 6 29 0 ‐ 2,029 3,977 ‐ ‐ 54 7 21 85 46 11 11 1,543 2 581 30,409 75 4 245 13 0 7 166 16 0 0 6 9 17 3,471 4,720 5,225 39,399 589,755 95,553 13,100 57 1,279 85 386 20 128 40 162 1 4 3,261 53 10 0 193 7 1 166 2,619 0 11

45 5 5 25 197 145 1,044

1 723 1,030 26,728 45,246 2,584 667 1,070 79 23 46 88 144 53 1,090 75 3,582 8,406 950 2,760 1,767 39 3 3 273 2,750 384 207 66 10 10 117 88 20 13 3,855 2 234 18,474 1,829 6 552 7 2 1 536 1,214 3 1 119 40 32 551 624 17 309

‐ 667 0 9,650 1,604 3,443 24 12 0 168 2,929 703 38 38 0 621 4,430 21 48 0 9 0 1 489 38 300 1,130 13,725 965 320 0 0 94 2,724 3,175 0 8 19 12,833 0 95 335 914 0 199 734 20 1,144 12,576 0 2 365 229 45 986 2 1 1 3 95 0 16 4 1 2 13 72 2 2 309 56 320 781 213 65 136 2,389 1,388 660 1 720 17 253 76 146 358 189 10655 15 35 108 113 46 38 28 6 10 64 43 14 16 18 3 13 41 24 6 8 48 58 37 120 230 87 47

4 1 1 6 5 2 2 32 13 12 56 56 23 16 639 195 221 1,141 1,070 392 278

‐

‐ 0

‐ 0 0 ‐ 0 0 1 0 0 0 0 1 0 1

‐ 534 20 337 961 411 85 171 16,724 29,691 13,253 150,780 680,642 131,187 31,031PA PR RI SC SD TN TR

0 0 ‐ 1

54 0 76 2,220 185 0 151 1 6 1,572 1,177 881

11 0 1 325 1,280 278 32 1 11 59 14 0 2,658 38 177 4,814 8 46 1 7 3 33 0 2,551 171 410 21 ‐ 21 18 24 6 0 5 1 0 0 22 29 0 1 320,504 196 71,697 11,101 120,108 17,643 152 176 18 75 1 8 7,811 33,952 1 63 13 13 0

145 0 201 36 40 0 405 1,697 15 1,925 26 25,244 9,018 1,034 73,671 26 200 ‐ 2 81 58 55 5 4,303 1,594 174 1,946

‐ 163 5 2,254 0 0 2,072 0 5 0 68 5 8 4 21 0 12,797 2,814 213 116 263 15 435 0 6 15 235 3 483 32 24 14 45 1

4,003 279 520 215 86

164 9 494 734 412 309 451 ‐ ‐ 6,832 56 37 2,262 162 1,673 0 1,052 2 3,765 0 293 1,952 2 2 131 3,453 0 ‐ 154 0

127 4,350 3 942 4 ‐ 1 0 4 8 2 1 2 0 3 0 360 708 30 79 27 399 0 1,269 0 210 1,708 31

202 1 84 38 190 087 17 6 42 44 59 0 41 11 3 18 4 22 0 28 4 2 9 1 21 0 162 5 95 16 137 4 0 2 0 3 45 8 2 25 4 31 755 172 70 399 73 584

0 ‐

0 0 11 4 ‐ 0 ‐ 6

869 51 364 140 17 174 0 402,958 37,407 4,397 102,941 17,893 208,407 17,884TX UT VA VI VT WA WI

1 ‐

726 61 48 4 213 87 495 352 755 4 1,470 290 18,643 220 680 0 348 4 23 4 17 12 23 3 181 1,053 ‐ 1,123 104 16 20 1 26 26

96 364 646 816 ‐ 103

1 3 3 0 2 150 11 2 56 303 425,879 20,407 68,887 1,136 90,976 462 15 53 ‐ 9 18 44 4 1,072 1 1 8 1,167 17 6 0 0 345

210 3 296 26 1,159 188 149 1,803 11,487 ‐ 40,338 7,015 12 38 1 36 61 8,767 880 3,407 1,158 762 495 3,170 166 116 0 301 3,716 65 20 16 1 23 40

4 22 2,732 1,074 887 1,164 26 9 192 2 3 197 96 53 205 239 280 908

0 ‐ 9,011 344 1,918 51 20,342 12 214 154 34 685 45 108 79 530 3 23 1 10,674 182 7,341 ‐ 160 3,205

1,517 694 0 7,445 74 16,233 343 10 0 21,434 988 ‐ 908 145

2,610 ‐ 927 ‐ 1,383 1,278

273 3 0 0 3

10 2 4 0 0 3 3 958 151 575 110 11 351 132 4,801 1,105 11,529 307

690 94 179 4 107 122115 24 68 1 5 63 71 51 10 28 0 4 25 37 39 9 22 0 1 14 14 211 52 102 8 102 98

10 2 2 0 3 3 81 15 16 0 2 45 36 1,719 254 608 3 56 484 463

0 ‐

0 313 ‐ 0

‐ 0 0

309 39 1,469 0 6 192 375 559,231 27,875 106,460 115 3,440 29,833 147,471WV WY Grand Total 8 0 4

‐ ‐ 1

‐

‐ 6 70 26,965 413 2,338 85,087 263 3,036 105,227

19 21 1,080

‐ 7,357 59,840 4 3 1,614 97 159 58,064

‐ 1,227 2,359 93,064 35,424 4,525,848 2 0 5,868 14 166 75,865

‐ 20,344 15 3 23,345 15,305 21,182 483,203 10 196 16,909 462 213 99,624 450 17 52,923 8 4 1,441 521 21 91,994

40 39 9,410 71 15 9,010 2 1,276 283 59,659

177 1,701 132,599 1,182 28,281

606 648 2,071 448 958 136,606 547 103,420 2,639 3,875 72,975 6,032 1,624 85,010 10 32,003

0 42 8,785 1 0 234 14 16 13,665 40 65,172 111 387 8,52111 13 2,883 6 4 1,096 2 1 700 30 26 4,259

1 0 123 6 4 1,308 140 70 23,278 8 0

‐ 14 1 431

‐ 63 13 16,668 124,107 79,926 6,557,033STFIPS STATE_ABBR EI_SECTOR POLLUTANT_CODE 1 AL Fires ‐ Agricultural Field Burnin g SO2 1 AL Fires ‐ Prescribed Fires SO2 1 AL Fires ‐ Wildfires SO2 1 AL Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 1 AL Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 1 AL Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 1 AL Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 1 AL Fuel Comb ‐ Comm/Institutional ‐ Other SO2 1 AL Fuel Comb ‐ Electric Generation ‐ Biomass SO2 1 AL Fuel Comb ‐ Electric Generation ‐ Coal SO2 1 AL Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 1 AL Fuel Comb ‐ Electric Generation ‐ Oil SO2 1 AL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 1 AL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 1 AL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 1 AL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 1 AL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 1 AL Fuel Comb ‐ Residential ‐ Natural Gas SO2 1 AL Fuel Comb ‐ Residential ‐ Oil SO2 1 AL Fuel Comb ‐ Residential ‐ Other SO2 1 AL Fuel Comb ‐ Residential ‐ Wood SO2 1 AL Gas Stations SO2 1 AL Industrial Processes ‐ Cement Manuf SO2 1 AL Industrial Processes ‐ Chemical Manuf SO2 1 AL Industrial Processes ‐ Ferrous Metals SO2 1 AL Industrial Processes ‐ Mining SO2 1 AL Industrial Processes ‐ NEC SO2 1 AL Industrial Processes ‐ Non

‐ ferrous Metals SO2 1 AL Industrial Processes ‐ Oil & Gas Production SO2 1 AL Industrial Processes ‐ Petroleum Refineries SO2 1 AL Industrial Processes ‐ Pulp & Paper SO2 1 AL Industrial Processes ‐ Storage and Transfer SO2 1 AL Miscellaneous Non

‐ Industrial NEC SO2 1 AL Mobile ‐ Aircraft SO2 1 AL Mobile ‐ Commercial Marine Vessels SO2 1 AL Mobile ‐ Locomotives SO2 1 AL Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 1 AL Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 1 AL Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 1 AL Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 1 AL Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 1 AL Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 1 AL Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 1 AL Solvent ‐ Industrial Surface Coating & Solvent Use SO2 1 AL Waste Disposal SO2 2 AK Bulk Gasoline Terminals SO22 AK Fires ‐ Prescribed Fires SO2 2 AK Fires ‐ Wildfires SO2 2 AK Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 2 AK Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 2 AK Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 2 AK Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 2 AK Fuel Comb ‐ Comm/Institutional ‐ Other SO2 2 AK Fuel Comb ‐ Electric Generation ‐ Coal SO2 2 AK Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 2 AK Fuel Comb ‐ Electric Generation ‐ Oil SO2 2 AK Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 2 AK Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 2 AK Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 2 AK Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 2 AK Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 2 AK Fuel Comb ‐ Residential ‐ Natural Gas SO2 2 AK Fuel Comb ‐ Residential ‐ Oil SO2 2 AK Fuel Comb ‐ Residential ‐ Other SO2 2 AK Fuel Comb ‐ Residential ‐ Wood SO2 2 AK Industrial Processes ‐ Chemical Manuf SO2 2 AK Industrial Processes ‐ NEC SO2 2 AK Industrial Processes ‐ Non

‐ ferrous Metals SO2 2 AK Industrial Processes ‐ Oil & Gas Production SO2 2 AK Industrial Processes ‐ Petroleum Refineries SO2 2 AK Industrial Processes ‐ Storage and Transfer SO2 2 AK Miscellaneous Non

‐ Industrial NEC SO2 2 AK Mobile ‐ Aircraft SO2 2 AK Mobile ‐ Commercial Marine Vessels SO2 2 AK Mobile ‐ Locomotives SO2 2 AK Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 2 AK Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 2 AK Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 2 AK Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 2 AK Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 2 AK Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 2 AK Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 2 AK Waste Disposal SO2 4 AZ Fires ‐ Agricultural Field Burnin g SO2 4 AZ Fires ‐ Prescribed Fires SO2 4 AZ Fires ‐ Wildfires SO2 4 AZ Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 4 AZ Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 4 AZ Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 4 AZ Fuel Comb ‐ Comm/Institutional ‐ Other SO2 4 AZ Fuel Comb ‐ Electric Generation ‐ Biomass SO2 4 AZ Fuel Comb ‐ Electric Generation ‐ Coal SO2 4 AZ Fuel Comb ‐ Electric Generation ‐ Natural Gas SO24 AZ Fuel Comb ‐ Electric Generation ‐ Oil SO2 4 AZ Fuel Comb ‐ Electric Generation ‐ Other SO2 4 AZ Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 4 AZ Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 4 AZ Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 4 AZ Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 4 AZ Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 4 AZ Fuel Comb ‐ Residential ‐ Natural Gas SO2 4 AZ Fuel Comb ‐ Residential ‐ Oil SO2 4 AZ Fuel Comb ‐ Residential ‐ Other SO2 4 AZ Fuel Comb ‐ Residential ‐ Wood SO2 4 AZ Industrial Processes ‐ Cement Manuf SO2 4 AZ Industrial Processes ‐ Chemical Manuf SO2 4 AZ Industrial Processes ‐ Ferrous Metals SO2 4 AZ Industrial Processes ‐ Mining SO2 4 AZ Industrial Processes ‐ NEC SO2 4 AZ Industrial Processes ‐ Non

‐ ferrous Metals SO2 4 AZ Industrial Processes ‐ Oil & Gas Production SO2 4 AZ Industrial Processes ‐ Pulp & Paper SO2 4 AZ Industrial Processes ‐ Storage and Transfer SO2 4 AZ Miscellaneous Non

‐ Industrial NEC SO2 4 AZ Mobile ‐ Aircraft SO2 4 AZ Mobile ‐ Locomotives SO2 4 AZ Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 4 AZ Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 4 AZ Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 4 AZ Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 4 AZ Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 4 AZ Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 4 AZ Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 4 AZ Solvent ‐ Industrial Surface Coating & Solvent Use SO2 4 AZ Waste Disposal SO2 5 AR Fires ‐ Agricultural Field Burnin g SO2 5 AR Fires ‐ Prescribed Fires SO2 5 AR Fires ‐ Wildfires SO2 5 AR Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 5 AR Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 5 AR Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 5 AR Fuel Comb ‐ Comm/Institutional ‐ Other SO2 5 AR Fuel Comb ‐ Electric Generation ‐ Biomass SO2 5 AR Fuel Comb ‐ Electric Generation ‐ Coal SO2 5 AR Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 5 AR Fuel Comb ‐ Electric Generation ‐ Oil SO2 5 AR Fuel Comb ‐ Electric Generation ‐ Other SO2 5 AR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 5 AR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 5 AR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO25 AR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 5 AR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 5 AR Fuel Comb ‐ Residential ‐ Natural Gas SO2 5 AR Fuel Comb ‐ Residential ‐ Oil SO2 5 AR Fuel Comb ‐ Residential ‐ Other SO2 5 AR Fuel Comb ‐ Residential ‐ Wood SO2 5 AR Industrial Processes ‐ Cement Manuf SO2 5 AR Industrial Processes ‐ Chemical Manuf SO2 5 AR Industrial Processes ‐ Ferrous Metals SO2 5 AR Industrial Processes ‐ Mining SO2 5 AR Industrial Processes ‐ NEC SO2 5 AR Industrial Processes ‐ Non

‐ ferrous Metals SO2 5 AR Industrial Processes ‐ Oil & Gas Production SO2 5 AR Industrial Processes ‐ Petroleum Refineries SO2 5 AR Industrial Processes ‐ Pulp & Paper SO2 5 AR Industrial Processes ‐ Storage and Transfer SO2 5 AR Miscellaneous Non

‐ Industrial NEC SO2 5 AR Mobile ‐ Aircraft SO2 5 AR Mobile ‐ Commercial Marine Vessels SO2 5 AR Mobile ‐ Locomotives SO2 5 AR Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 5 AR Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 5 AR Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 5 AR Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 5 AR Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 5 AR Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 5 AR Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 5 AR Solvent ‐ Graphic Arts SO2 5 AR Solvent ‐ Industrial Surface Coating & Solvent Use SO2 5 AR Waste Disposal SO2 6 CA Agriculture ‐ Livestock Waste SO2 6 CA Bulk Gasoline Terminals SO2 6 CA Fires ‐ Agricultural Field Burnin g SO2 6 CA Fires ‐ Prescribed Fires SO2 6 CA Fires ‐ Wildfires SO2 6 CA Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 6 CA Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 6 CA Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 6 CA Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 6 CA Fuel Comb ‐ Comm/Institutional ‐ Other SO2 6 CA Fuel Comb ‐ Electric Generation ‐ Biomass SO2 6 CA Fuel Comb ‐ Electric Generation ‐ Coal SO2 6 CA Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 6 CA Fuel Comb ‐ Electric Generation ‐ Oil SO2 6 CA Fuel Comb ‐ Electric Generation ‐ Other SO2 6 CA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 6 CA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO26 CA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 6 CA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 6 CA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 6 CA Fuel Comb ‐ Residential ‐ Natural Gas SO2 6 CA Fuel Comb ‐ Residential ‐ Oil SO2 6 CA Fuel Comb ‐ Residential ‐ Other SO2 6 CA Fuel Comb ‐ Residential ‐ Wood SO2 6 CA Industrial Processes ‐ Cement Manuf SO2 6 CA Industrial Processes ‐ Chemical Manuf SO2 6 CA Industrial Processes ‐ Ferrous Metals SO2 6 CA Industrial Processes ‐ Mining SO2 6 CA Industrial Processes ‐ NEC SO2 6 CA Industrial Processes ‐ Non

‐ ferrous Metals SO2 6 CA Industrial Processes ‐ Oil & Gas Production SO2 6 CA Industrial Processes ‐ Petroleum Refineries SO2 6 CA Industrial Processes ‐ Pulp & Paper SO2 6 CA Industrial Processes ‐ Storage and Transfer SO2 6 CA Miscellaneous Non

‐ Industrial NEC SO2 6 CA Mobile ‐ Aircraft SO2 6 CA Mobile ‐ Commercial Marine Vessels SO2 6 CA Mobile ‐ Locomotives SO2 6 CA Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 6 CA Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 6 CA Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 6 CA Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 6 CA Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 6 CA Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 6 CA Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 6 CA Solvent ‐ Graphic Arts SO2 6 CA Solvent ‐ Industrial Surface Coating & Solvent Use SO2 6 CA Waste Disposal SO2 8 CO Fires ‐ Agricultural Field Burnin g SO2 8 CO Fires ‐ Prescribed Fires SO2 8 CO Fires ‐ Wildfires SO2 8 CO Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 8 CO Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 8 CO Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 8 CO Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 8 CO Fuel Comb ‐ Comm/Institutional ‐ Other SO2 8 CO Fuel Comb ‐ Electric Generation ‐ Coal SO2 8 CO Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 8 CO Fuel Comb ‐ Electric Generation ‐ Oil SO2 8 CO Fuel Comb ‐ Electric Generation ‐ Other SO2 8 CO Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 8 CO Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 8 CO Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 8 CO Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO28 CO Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 8 CO Fuel Comb ‐ Residential ‐ Natural Gas SO2 8 CO Fuel Comb ‐ Residential ‐ Oil SO2 8 CO Fuel Comb ‐ Residential ‐ Other SO2 8 CO Fuel Comb ‐ Residential ‐ Wood SO2 8 CO Industrial Processes ‐ Cement Manuf SO2 8 CO Industrial Processes ‐ Chemical Manuf SO2 8 CO Industrial Processes ‐ Ferrous Metals SO2 8 CO Industrial Processes ‐ Mining SO2 8 CO Industrial Processes ‐ NEC SO2 8 CO Industrial Processes ‐ Non

‐ ferrous Metals SO2 8 CO Industrial Processes ‐ Oil & Gas Production SO2 8 CO Industrial Processes ‐ Petroleum Refineries SO2 8 CO Industrial Processes ‐ Pulp & Paper SO2 8 CO Industrial Processes ‐ Storage and Transfer SO2 8 CO Miscellaneous Non

‐ Industrial NEC SO2 8 CO Mobile ‐ Aircraft SO2 8 CO Mobile ‐ Locomotives SO2 8 CO Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 8 CO Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 8 CO Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 8 CO Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 8 CO Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 8 CO Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 8 CO Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 8 CO Solvent ‐ Graphic Arts SO2 8 CO Solvent ‐ Industrial Surface Coating & Solvent Use SO2 8 CO Waste Disposal SO2 9 CT Fires ‐ Agricultural Field Burnin g SO2 9 CT Fires ‐ Prescribed Fires SO2 9 CT Fires ‐ Wildfires SO2 9 CT Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 9 CT Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 9 CT Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 9 CT Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 9 CT Fuel Comb ‐ Comm/Institutional ‐ Other SO2 9 CT Fuel Comb ‐ Electric Generation ‐ Coal SO2 9 CT Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 9 CT Fuel Comb ‐ Electric Generation ‐ Oil SO2 9 CT Fuel Comb ‐ Electric Generation ‐ Other SO2 9 CT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 9 CT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 9 CT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 9 CT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 9 CT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 9 CT Fuel Comb ‐ Residential ‐ Natural Gas SO2 9 CT Fuel Comb ‐ Residential ‐ Oil SO29 CT Fuel Comb ‐ Residential ‐ Other SO2 9 CT Fuel Comb ‐ Residential ‐ Wood SO2 9 CT Industrial Processes ‐ NEC SO2 9 CT Miscellaneous Non

‐ Industrial NEC SO2 9 CT Mobile ‐ Aircraft SO2 9 CT Mobile ‐ Commercial Marine Vessels SO2 9 CT Mobile ‐ Locomotives SO2 9 CT Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 9 CT Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 9 CT Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 9 CT Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 9 CT Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 9 CT Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 9 CT Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 9 CT Waste Disposal SO2 10 DE Fires ‐ Prescribed Fires SO2 10 DE Fires ‐ Wildfires SO2 10 DE Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 10 DE Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 10 DE Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 10 DE Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 10 DE Fuel Comb ‐ Comm/Institutional ‐ Other SO2 10 DE Fuel Comb ‐ Electric Generation ‐ Coal SO2 10 DE Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 10 DE Fuel Comb ‐ Electric Generation ‐ Oil SO2 10 DE Fuel Comb ‐ Electric Generation ‐ Other SO2 10 DE Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 10 DE Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 10 DE Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 10 DE Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 10 DE Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 10 DE Fuel Comb ‐ Residential ‐ Natural Gas SO2 10 DE Fuel Comb ‐ Residential ‐ Oil SO2 10 DE Fuel Comb ‐ Residential ‐ Other SO2 10 DE Fuel Comb ‐ Residential ‐ Wood SO2 10 DE Industrial Processes ‐ Chemical Manuf SO2 10 DE Industrial Processes ‐ Ferrous Metals SO2 10 DE Industrial Processes ‐ NEC SO2 10 DE Industrial Processes ‐ Non

‐ ferrous Metals SO2 10 DE Industrial Processes ‐ Petroleum Refineries SO2 10 DE Industrial Processes ‐ Storage and Transfer SO2 10 DE Miscellaneous Non

‐ Industrial NEC SO2 10 DE Mobile ‐ Aircraft SO2 10 DE Mobile ‐ Commercial Marine Vessels SO2 10 DE Mobile ‐ Locomotives SO2 10 DE Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 10 DE Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO210 DE Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 10 DE Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 10 DE Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 10 DE Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 10 DE Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 10 DE Solvent ‐ Industrial Surface Coating & Solvent Use SO2 10 DE Waste Disposal SO2 11 DC Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 11 DC Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 11 DC Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 11 DC Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 11 DC Fuel Comb ‐ Comm/Institutional ‐ Other SO2 11 DC Fuel Comb ‐ Electric Generation ‐ Oil SO2 11 DC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 11 DC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 11 DC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 11 DC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 11 DC Fuel Comb ‐ Residential ‐ Natural Gas SO2 11 DC Fuel Comb ‐ Residential ‐ Oil SO2 11 DC Fuel Comb ‐ Residential ‐ Other SO2 11 DC Fuel Comb ‐ Residential ‐ Wood SO2 11 DC Industrial Processes ‐ NEC SO2 11 DC Miscellaneous Non

‐ Industrial NEC SO2 11 DC Mobile ‐ Aircraft SO2 11 DC Mobile ‐ Commercial Marine Vessels SO2 11 DC Mobile ‐ Locomotives SO2 11 DC Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 11 DC Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 11 DC Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 11 DC Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 11 DC Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 11 DC Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 11 DC Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 12 FL Fires ‐ Agricultural Field Burnin g SO2 12 FL Fires ‐ Prescribed Fires SO2 12 FL Fires ‐ Wildfires SO2 12 FL Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 12 FL Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 12 FL Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 12 FL Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 12 FL Fuel Comb ‐ Comm/Institutional ‐ Other SO2 12 FL Fuel Comb ‐ Electric Generation ‐ Biomass SO2 12 FL Fuel Comb ‐ Electric Generation ‐ Coal SO2 12 FL Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 12 FL Fuel Comb ‐ Electric Generation ‐ Oil SO2 12 FL Fuel Comb ‐ Electric Generation ‐ Other SO2 12 FL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO212 FL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 12 FL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 12 FL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 12 FL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 12 FL Fuel Comb ‐ Residential ‐ Natural Gas SO2 12 FL Fuel Comb ‐ Residential ‐ Oil SO2 12 FL Fuel Comb ‐ Residential ‐ Other SO2 12 FL Fuel Comb ‐ Residential ‐ Wood SO2 12 FL Industrial Processes ‐ Cement Manuf SO2 12 FL Industrial Processes ‐ Chemical Manuf SO2 12 FL Industrial Processes ‐ Ferrous Metals SO2 12 FL Industrial Processes ‐ NEC SO2 12 FL Industrial Processes ‐ Non

‐ ferrous Metals SO2 12 FL Industrial Processes ‐ Oil & Gas Production SO2 12 FL Industrial Processes ‐ Petroleum Refineries SO2 12 FL Industrial Processes ‐ Pulp & Paper SO2 12 FL Industrial Processes ‐ Storage and Transfer SO2 12 FL Miscellaneous Non

‐ Industrial NEC SO2 12 FL Mobile ‐ Aircraft SO2 12 FL Mobile ‐ Commercial Marine Vessels SO2 12 FL Mobile ‐ Locomotives SO2 12 FL Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 12 FL Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 12 FL Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 12 FL Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 12 FL Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 12 FL Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 12 FL Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 12 FL Solvent ‐ Industrial Surface Coating & Solvent Use SO2 12 FL Waste Disposal SO2 13 GA Fires ‐ Agricultural Field Burnin g SO2 13 GA Fires ‐ Prescribed Fires SO2 13 GA Fires ‐ Wildfires SO2 13 GA Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 13 GA Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 13 GA Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 13 GA Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 13 GA Fuel Comb ‐ Comm/Institutional ‐ Other SO2 13 GA Fuel Comb ‐ Electric Generation ‐ Biomass SO2 13 GA Fuel Comb ‐ Electric Generation ‐ Coal SO2 13 GA Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 13 GA Fuel Comb ‐ Electric Generation ‐ Oil SO2 13 GA Fuel Comb ‐ Electric Generation ‐ Other SO2 13 GA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 13 GA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 13 GA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 13 GA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO213 GA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 13 GA Fuel Comb ‐ Residential ‐ Natural Gas SO2 13 GA Fuel Comb ‐ Residential ‐ Oil SO2 13 GA Fuel Comb ‐ Residential ‐ Other SO2 13 GA Fuel Comb ‐ Residential ‐ Wood SO2 13 GA Industrial Processes ‐ Cement Manuf SO2 13 GA Industrial Processes ‐ Chemical Manuf SO2 13 GA Industrial Processes ‐ Ferrous Metals SO2 13 GA Industrial Processes ‐ NEC SO2 13 GA Industrial Processes ‐ Non

‐ ferrous Metals SO2 13 GA Industrial Processes ‐ Petroleum Refineries SO2 13 GA Industrial Processes ‐ Pulp & Paper SO2 13 GA Miscellaneous Non

‐ Industrial NEC SO2 13 GA Mobile ‐ Aircraft SO2 13 GA Mobile ‐ Commercial Marine Vessels SO2 13 GA Mobile ‐ Locomotives SO2 13 GA Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 13 GA Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 13 GA Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 13 GA Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 13 GA Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 13 GA Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 13 GA Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 13 GA Solvent ‐ Industrial Surface Coating & Solvent Use SO2 13 GA Waste Disposal SO2 15 HI Fires ‐ Agricultural Field Burnin g SO2 15 HI Fires ‐ Prescribed Fires SO2 15 HI Fires ‐ Wildfires SO2 15 HI Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 15 HI Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 15 HI Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 15 HI Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 15 HI Fuel Comb ‐ Comm/Institutional ‐ Other SO2 15 HI Fuel Comb ‐ Electric Generation ‐ Biomass SO2 15 HI Fuel Comb ‐ Electric Generation ‐ Coal SO2 15 HI Fuel Comb ‐ Electric Generation ‐ Oil SO2 15 HI Fuel Comb ‐ Electric Generation ‐ Other SO2 15 HI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 15 HI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 15 HI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 15 HI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 15 HI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 15 HI Fuel Comb ‐ Residential ‐ Natural Gas SO2 15 HI Fuel Comb ‐ Residential ‐ Oil SO2 15 HI Fuel Comb ‐ Residential ‐ Other SO2 15 HI Fuel Comb ‐ Residential ‐ Wood SO2 15 HI Industrial Processes ‐ Chemical Manuf SO215 HI Industrial Processes ‐ NEC SO2 15 HI Industrial Processes ‐ Petroleum Refineries SO2 15 HI Miscellaneous Non

‐ Industrial NEC SO2 15 HI Mobile ‐ Aircraft SO2 15 HI Mobile ‐ Commercial Marine Vessels SO2 15 HI Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 15 HI Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 15 HI Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 15 HI Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 15 HI Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 15 HI Waste Disposal SO2 16 ID Fires ‐ Agricultural Field Burnin g SO2 16 ID Fires ‐ Prescribed Fires SO2 16 ID Fires ‐ Wildfires SO2 16 ID Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 16 ID Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 16 ID Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 16 ID Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 16 ID Fuel Comb ‐ Comm/Institutional ‐ Other SO2 16 ID Fuel Comb ‐ Electric Generation ‐ Biomass SO2 16 ID Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 16 ID Fuel Comb ‐ Electric Generation ‐ Oil SO2 16 ID Fuel Comb ‐ Electric Generation ‐ Other SO2 16 ID Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 16 ID Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 16 ID Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 16 ID Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 16 ID Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 16 ID Fuel Comb ‐ Residential ‐ Natural Gas SO2 16 ID Fuel Comb ‐ Residential ‐ Oil SO2 16 ID Fuel Comb ‐ Residential ‐ Other SO2 16 ID Fuel Comb ‐ Residential ‐ Wood SO2 16 ID Industrial Processes ‐ Cement Manuf SO2 16 ID Industrial Processes ‐ Chemical Manuf SO2 16 ID Industrial Processes ‐ NEC SO2 16 ID Industrial Processes ‐ Pulp & Paper SO2 16 ID Industrial Processes ‐ Storage and Transfer SO2 16 ID Miscellaneous Non

‐ Industrial NEC SO2 16 ID Mobile ‐ Aircraft SO2 16 ID Mobile ‐ Commercial Marine Vessels SO2 16 ID Mobile ‐ Locomotives SO2 16 ID Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 16 ID Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 16 ID Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 16 ID Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 16 ID Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 16 ID Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO216 ID Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 16 ID Waste Disposal SO2 17 IL Bulk Gasoline Terminals SO2 17 IL Fires ‐ Agricultural Field Burnin g SO2 17 IL Fires ‐ Prescribed Fires SO2 17 IL Fires ‐ Wildfires SO2 17 IL Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 17 IL Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 17 IL Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 17 IL Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 17 IL Fuel Comb ‐ Comm/Institutional ‐ Other SO2 17 IL Fuel Comb ‐ Electric Generation ‐ Biomass SO2 17 IL Fuel Comb ‐ Electric Generation ‐ Coal SO2 17 IL Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 17 IL Fuel Comb ‐ Electric Generation ‐ Oil SO2 17 IL Fuel Comb ‐ Electric Generation ‐ Other SO2 17 IL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 17 IL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 17 IL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 17 IL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 17 IL Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 17 IL Fuel Comb ‐ Residential ‐ Natural Gas SO2 17 IL Fuel Comb ‐ Residential ‐ Oil SO2 17 IL Fuel Comb ‐ Residential ‐ Other SO2 17 IL Fuel Comb ‐ Residential ‐ Wood SO2 17 IL Gas Stations SO2 17 IL Industrial Processes ‐ Cement Manuf SO2 17 IL Industrial Processes ‐ Chemical Manuf SO2 17 IL Industrial Processes ‐ Ferrous Metals SO2 17 IL Industrial Processes ‐ NEC SO2 17 IL Industrial Processes ‐ Non

‐ ferrous Metals SO2 17 IL Industrial Processes ‐ Oil & Gas Production SO2 17 IL Industrial Processes ‐ Petroleum Refineries SO2 17 IL Industrial Processes ‐ Pulp & Paper SO2 17 IL Industrial Processes ‐ Storage and Transfer SO2 17 IL Miscellaneous Non

‐ Industrial NEC SO2 17 IL Mobile ‐ Aircraft SO2 17 IL Mobile ‐ Commercial Marine Vessels SO2 17 IL Mobile ‐ Locomotives SO2 17 IL Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 17 IL Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 17 IL Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 17 IL Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 17 IL Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 17 IL Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 17 IL Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 17 IL Solvent ‐ Graphic Arts SO217 IL Solvent ‐ Industrial Surface Coating & Solvent Use SO2 17 IL Waste Disposal SO2 18 IN Bulk Gasoline Terminals SO2 18 IN Fires ‐ Agricultural Field Burnin g SO2 18 IN Fires ‐ Prescribed Fires SO2 18 IN Fires ‐ Wildfires SO2 18 IN Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 18 IN Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 18 IN Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 18 IN Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 18 IN Fuel Comb ‐ Comm/Institutional ‐ Other SO2 18 IN Fuel Comb ‐ Electric Generation ‐ Coal SO2 18 IN Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 18 IN Fuel Comb ‐ Electric Generation ‐ Oil SO2 18 IN Fuel Comb ‐ Electric Generation ‐ Other SO2 18 IN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 18 IN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 18 IN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 18 IN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 18 IN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 18 IN Fuel Comb ‐ Residential ‐ Natural Gas SO2 18 IN Fuel Comb ‐ Residential ‐ Oil SO2 18 IN Fuel Comb ‐ Residential ‐ Other SO2 18 IN Fuel Comb ‐ Residential ‐ Wood SO2 18 IN Industrial Processes ‐ Cement Manuf SO2 18 IN Industrial Processes ‐ Chemical Manuf SO2 18 IN Industrial Processes ‐ Ferrous Metals SO2 18 IN Industrial Processes ‐ NEC SO2 18 IN Industrial Processes ‐ Non

‐ ferrous Metals SO2 18 IN Industrial Processes ‐ Oil & Gas Production SO2 18 IN Industrial Processes ‐ Petroleum Refineries SO2 18 IN Industrial Processes ‐ Storage and Transfer SO2 18 IN Miscellaneous Non

‐ Industrial NEC SO2 18 IN Mobile ‐ Aircraft SO2 18 IN Mobile ‐ Commercial Marine Vessels SO2 18 IN Mobile ‐ Locomotives SO2 18 IN Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 18 IN Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 18 IN Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 18 IN Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 18 IN Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 18 IN Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 18 IN Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 18 IN Solvent ‐ Degreasing SO2 18 IN Solvent ‐ Industrial Surface Coating & Solvent Use SO2 18 IN Waste Disposal SO2 19 IA Bulk Gasoline Terminals SO219 IA Fires ‐ Agricultural Field Burnin g SO2 19 IA Fires ‐ Prescribed Fires SO2 19 IA Fires ‐ Wildfires SO2 19 IA Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 19 IA Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 19 IA Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 19 IA Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 19 IA Fuel Comb ‐ Comm/Institutional ‐ Other SO2 19 IA Fuel Comb ‐ Electric Generation ‐ Biomass SO2 19 IA Fuel Comb ‐ Electric Generation ‐ Coal SO2 19 IA Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 19 IA Fuel Comb ‐ Electric Generation ‐ Oil SO2 19 IA Fuel Comb ‐ Electric Generation ‐ Other SO2 19 IA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 19 IA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 19 IA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 19 IA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 19 IA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 19 IA Fuel Comb ‐ Residential ‐ Natural Gas SO2 19 IA Fuel Comb ‐ Residential ‐ Oil SO2 19 IA Fuel Comb ‐ Residential ‐ Other SO2 19 IA Fuel Comb ‐ Residential ‐ Wood SO2 19 IA Gas Stations SO2 19 IA Industrial Processes ‐ Cement Manuf SO2 19 IA Industrial Processes ‐ Chemical Manuf SO2 19 IA Industrial Processes ‐ Ferrous Metals SO2 19 IA Industrial Processes ‐ Mining SO2 19 IA Industrial Processes ‐ NEC SO2 19 IA Industrial Processes ‐ Non

‐ ferrous Metals SO2 19 IA Industrial Processes ‐ Oil & Gas Production SO2 19 IA Industrial Processes ‐ Petroleum Refineries SO2 19 IA Industrial Processes ‐ Pulp & Paper SO2 19 IA Industrial Processes ‐ Storage and Transfer SO2 19 IA Miscellaneous Non

‐ Industrial NEC SO2 19 IA Mobile ‐ Aircraft SO2 19 IA Mobile ‐ Commercial Marine Vessels SO2 19 IA Mobile ‐ Locomotives SO2 19 IA Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 19 IA Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 19 IA Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 19 IA Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 19 IA Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 19 IA Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 19 IA Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 19 IA Solvent ‐ Degreasing SO2 19 IA Solvent ‐ Dry Cleaning SO2 19 IA Solvent ‐ Graphic Arts SO219 IA Solvent ‐ Industrial Surface Coating & Solvent Use SO2 19 IA Waste Disposal SO2 20 KS Bulk Gasoline Terminals SO2 20 KS Fires ‐ Agricultural Field Burnin g SO2 20 KS Fires ‐ Prescribed Fires SO2 20 KS Fires ‐ Wildfires SO2 20 KS Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 20 KS Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 20 KS Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 20 KS Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 20 KS Fuel Comb ‐ Comm/Institutional ‐ Other SO2 20 KS Fuel Comb ‐ Electric Generation ‐ Coal SO2 20 KS Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 20 KS Fuel Comb ‐ Electric Generation ‐ Oil SO2 20 KS Fuel Comb ‐ Electric Generation ‐ Other SO2 20 KS Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 20 KS Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 20 KS Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 20 KS Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 20 KS Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 20 KS Fuel Comb ‐ Residential ‐ Natural Gas SO2 20 KS Fuel Comb ‐ Residential ‐ Oil SO2 20 KS Fuel Comb ‐ Residential ‐ Other SO2 20 KS Fuel Comb ‐ Residential ‐ Wood SO2 20 KS Industrial Processes ‐ Cement Manuf SO2 20 KS Industrial Processes ‐ Chemical Manuf SO2 20 KS Industrial Processes ‐ Ferrous Metals SO2 20 KS Industrial Processes ‐ Mining SO2 20 KS Industrial Processes ‐ NEC SO2 20 KS Industrial Processes ‐ Non

‐ ferrous Metals SO2 20 KS Industrial Processes ‐ Oil & Gas Production SO2 20 KS Industrial Processes ‐ Petroleum Refineries SO2 20 KS Industrial Processes ‐ Storage and Transfer SO2 20 KS Miscellaneous Non

‐ Industrial NEC SO2 20 KS Mobile ‐ Aircraft SO2 20 KS Mobile ‐ Commercial Marine Vessels SO2 20 KS Mobile ‐ Locomotives SO2 20 KS Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 20 KS Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 20 KS Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 20 KS Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 20 KS Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 20 KS Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 20 KS Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 20 KS Solvent ‐ Graphic Arts SO2 20 KS Solvent ‐ Industrial Surface Coating & Solvent Use SO2 20 KS Waste Disposal SO221 KY Fires ‐ Agricultural Field Burnin g SO2 21 KY Fires ‐ Prescribed Fires SO2 21 KY Fires ‐ Wildfires SO2 21 KY Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 21 KY Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 21 KY Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 21 KY Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 21 KY Fuel Comb ‐ Comm/Institutional ‐ Other SO2 21 KY Fuel Comb ‐ Electric Generation ‐ Biomass SO2 21 KY Fuel Comb ‐ Electric Generation ‐ Coal SO2 21 KY Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 21 KY Fuel Comb ‐ Electric Generation ‐ Oil SO2 21 KY Fuel Comb ‐ Electric Generation ‐ Other SO2 21 KY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 21 KY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 21 KY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 21 KY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 21 KY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 21 KY Fuel Comb ‐ Residential ‐ Natural Gas SO2 21 KY Fuel Comb ‐ Residential ‐ Oil SO2 21 KY Fuel Comb ‐ Residential ‐ Other SO2 21 KY Fuel Comb ‐ Residential ‐ Wood SO2 21 KY Industrial Processes ‐ Cement Manuf SO2 21 KY Industrial Processes ‐ Chemical Manuf SO2 21 KY Industrial Processes ‐ Ferrous Metals SO2 21 KY Industrial Processes ‐ NEC SO2 21 KY Industrial Processes ‐ Non

‐ ferrous Metals SO2 21 KY Industrial Processes ‐ Oil & Gas Production SO2 21 KY Industrial Processes ‐ Petroleum Refineries SO2 21 KY Industrial Processes ‐ Pulp & Paper SO2 21 KY Industrial Processes ‐ Storage and Transfer SO2 21 KY Miscellaneous Non

‐ Industrial NEC SO2 21 KY Mobile ‐ Aircraft SO2 21 KY Mobile ‐ Commercial Marine Vessels SO2 21 KY Mobile ‐ Locomotives SO2 21 KY Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 21 KY Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 21 KY Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 21 KY Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 21 KY Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 21 KY Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 21 KY Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 21 KY Solvent ‐ Graphic Arts SO2 21 KY Solvent ‐ Industrial Surface Coating & Solvent Use SO2 21 KY Waste Disposal SO2 22 LA Bulk Gasoline Terminals SO2 22 LA Fires ‐ Agricultural Field Burnin g SO222 LA Fires ‐ Prescribed Fires SO2 22 LA Fires ‐ Wildfires SO2 22 LA Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 22 LA Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 22 LA Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 22 LA Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 22 LA Fuel Comb ‐ Comm/Institutional ‐ Other SO2 22 LA Fuel Comb ‐ Electric Generation ‐ Coal SO2 22 LA Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 22 LA Fuel Comb ‐ Electric Generation ‐ Oil SO2 22 LA Fuel Comb ‐ Electric Generation ‐ Other SO2 22 LA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 22 LA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 22 LA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 22 LA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 22 LA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 22 LA Fuel Comb ‐ Residential ‐ Natural Gas SO2 22 LA Fuel Comb ‐ Residential ‐ Oil SO2 22 LA Fuel Comb ‐ Residential ‐ Other SO2 22 LA Fuel Comb ‐ Residential ‐ Wood SO2 22 LA Gas Stations SO2 22 LA Industrial Processes ‐ Chemical Manuf SO2 22 LA Industrial Processes ‐ Ferrous Metals SO2 22 LA Industrial Processes ‐ NEC SO2 22 LA Industrial Processes ‐ Non

‐ ferrous Metals SO2 22 LA Industrial Processes ‐ Oil & Gas Production SO2 22 LA Industrial Processes ‐ Petroleum Refineries SO2 22 LA Industrial Processes ‐ Pulp & Paper SO2 22 LA Industrial Processes ‐ Storage and Transfer SO2 22 LA Miscellaneous Non

‐ Industrial NEC SO2 22 LA Mobile ‐ Aircraft SO2 22 LA Mobile ‐ Commercial Marine Vessels SO2 22 LA Mobile ‐ Locomotives SO2 22 LA Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 22 LA Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 22 LA Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 22 LA Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 22 LA Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 22 LA Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 22 LA Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 22 LA Solvent ‐ Graphic Arts SO2 22 LA Solvent ‐ Industrial Surface Coating & Solvent Use SO2 22 LA Waste Disposal SO2 23 ME Fires ‐ Agricultural Field Burnin g SO2 23 ME Fires ‐ Prescribed Fires SO2 23 ME Fires ‐ Wildfires SO2 23 ME Fuel Comb ‐ Comm/Institutional ‐ Biomass SO223 ME Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 23 ME Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 23 ME Fuel Comb ‐ Comm/Institutional ‐ Other SO2 23 ME Fuel Comb ‐ Electric Generation ‐ Biomass SO2 23 ME Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 23 ME Fuel Comb ‐ Electric Generation ‐ Oil SO2 23 ME Fuel Comb ‐ Electric Generation ‐ Other SO2 23 ME Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 23 ME Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 23 ME Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 23 ME Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 23 ME Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 23 ME Fuel Comb ‐ Residential ‐ Natural Gas SO2 23 ME Fuel Comb ‐ Residential ‐ Oil SO2 23 ME Fuel Comb ‐ Residential ‐ Other SO2 23 ME Fuel Comb ‐ Residential ‐ Wood SO2 23 ME Industrial Processes ‐ Cement Manuf SO2 23 ME Industrial Processes ‐ NEC SO2 23 ME Industrial Processes ‐ Petroleum Refineries SO2 23 ME Industrial Processes ‐ Pulp & Paper SO2 23 ME Industrial Processes ‐ Storage and Transfer SO2 23 ME Miscellaneous Non

‐ Industrial NEC SO2 23 ME Mobile ‐ Aircraft SO2 23 ME Mobile ‐ Commercial Marine Vessels SO2 23 ME Mobile ‐ Locomotives SO2 23 ME Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 23 ME Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 23 ME Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 23 ME Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 23 ME Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 23 ME Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 23 ME Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 23 ME Solvent ‐ Industrial Surface Coating & Solvent Use SO2 23 ME Waste Disposal SO2 24 MD Bulk Gasoline Terminals SO2 24 MD Fires ‐ Agricultural Field Burnin g SO2 24 MD Fires ‐ Prescribed Fires SO2 24 MD Fires ‐ Wildfires SO2 24 MD Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 24 MD Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 24 MD Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 24 MD Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 24 MD Fuel Comb ‐ Comm/Institutional ‐ Other SO2 24 MD Fuel Comb ‐ Electric Generation ‐ Coal SO2 24 MD Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 24 MD Fuel Comb ‐ Electric Generation ‐ Oil SO2 24 MD Fuel Comb ‐ Electric Generation ‐ Other SO224 MD Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 24 MD Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 24 MD Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 24 MD Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 24 MD Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 24 MD Fuel Comb ‐ Residential ‐ Natural Gas SO2 24 MD Fuel Comb ‐ Residential ‐ Oil SO2 24 MD Fuel Comb ‐ Residential ‐ Other SO2 24 MD Fuel Comb ‐ Residential ‐ Wood SO2 24 MD Gas Stations SO2 24 MD Industrial Processes ‐ Cement Manuf SO2 24 MD Industrial Processes ‐ Chemical Manuf SO2 24 MD Industrial Processes ‐ Ferrous Metals SO2 24 MD Industrial Processes ‐ Mining SO2 24 MD Industrial Processes ‐ NEC SO2 24 MD Industrial Processes ‐ Non

‐ ferrous Metals SO2 24 MD Industrial Processes ‐ Oil & Gas Production SO2 24 MD Industrial Processes ‐ Petroleum Refineries SO2 24 MD Industrial Processes ‐ Pulp & Paper SO2 24 MD Industrial Processes ‐ Storage and Transfer SO2 24 MD Miscellaneous Non

‐ Industrial NEC SO2 24 MD Mobile ‐ Aircraft SO2 24 MD Mobile ‐ Commercial Marine Vessels SO2 24 MD Mobile ‐ Locomotives SO2 24 MD Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 24 MD Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 24 MD Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 24 MD Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 24 MD Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 24 MD Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 24 MD Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 24 MD Solvent ‐ Degreasing SO2 24 MD Solvent ‐ Graphic Arts SO2 24 MD Solvent ‐ Industrial Surface Coating & Solvent Use SO2 24 MD Waste Disposal SO2 25 MA Bulk Gasoline Terminals SO2 25 MA Fires ‐ Agricultural Field Burnin g SO2 25 MA Fires ‐ Prescribed Fires SO2 25 MA Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 25 MA Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 25 MA Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 25 MA Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 25 MA Fuel Comb ‐ Comm/Institutional ‐ Other SO2 25 MA Fuel Comb ‐ Electric Generation ‐ Biomass SO2 25 MA Fuel Comb ‐ Electric Generation ‐ Coal SO2 25 MA Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 25 MA Fuel Comb ‐ Electric Generation ‐ Oil SO225 MA Fuel Comb ‐ Electric Generation ‐ Other SO2 25 MA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 25 MA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 25 MA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 25 MA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 25 MA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 25 MA Fuel Comb ‐ Residential ‐ Natural Gas SO2 25 MA Fuel Comb ‐ Residential ‐ Oil SO2 25 MA Fuel Comb ‐ Residential ‐ Other SO2 25 MA Fuel Comb ‐ Residential ‐ Wood SO2 25 MA Industrial Processes ‐ Chemical Manuf SO2 25 MA Industrial Processes ‐ Ferrous Metals SO2 25 MA Industrial Processes ‐ NEC SO2 25 MA Industrial Processes ‐ Non

‐ ferrous Metals SO2 25 MA Industrial Processes ‐ Petroleum Refineries SO2 25 MA Industrial Processes ‐ Pulp & Paper SO2 25 MA Industrial Processes ‐ Storage and Transfer SO2 25 MA Miscellaneous Non

‐ Industrial NEC SO2 25 MA Mobile ‐ Aircraft SO2 25 MA Mobile ‐ Commercial Marine Vessels SO2 25 MA Mobile ‐ Locomotives SO2 25 MA Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 25 MA Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 25 MA Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 25 MA Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 25 MA Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 25 MA Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 25 MA Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 25 MA Solvent ‐ Consumer & Commercial Solvent Use SO2 25 MA Solvent ‐ Degreasing SO2 25 MA Solvent ‐ Graphic Arts SO2 25 MA Solvent ‐ Industrial Surface Coating & Solvent Use SO2 25 MA Waste Disposal SO2 26 MI Fires ‐ Agricultural Field Burnin g SO2 26 MI Fires ‐ Prescribed Fires SO2 26 MI Fires ‐ Wildfires SO2 26 MI Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 26 MI Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 26 MI Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 26 MI Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 26 MI Fuel Comb ‐ Comm/Institutional ‐ Other SO2 26 MI Fuel Comb ‐ Electric Generation ‐ Biomass SO2 26 MI Fuel Comb ‐ Electric Generation ‐ Coal SO2 26 MI Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 26 MI Fuel Comb ‐ Electric Generation ‐ Oil SO2 26 MI Fuel Comb ‐ Electric Generation ‐ Other SO2 26 MI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO226 MI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 26 MI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 26 MI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 26 MI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 26 MI Fuel Comb ‐ Residential ‐ Natural Gas SO2 26 MI Fuel Comb ‐ Residential ‐ Oil SO2 26 MI Fuel Comb ‐ Residential ‐ Other SO2 26 MI Fuel Comb ‐ Residential ‐ Wood SO2 26 MI Industrial Processes ‐ Cement Manuf SO2 26 MI Industrial Processes ‐ Chemical Manuf SO2 26 MI Industrial Processes ‐ Ferrous Metals SO2 26 MI Industrial Processes ‐ NEC SO2 26 MI Industrial Processes ‐ Non

‐ ferrous Metals SO2 26 MI Industrial Processes ‐ Oil & Gas Production SO2 26 MI Industrial Processes ‐ Petroleum Refineries SO2 26 MI Industrial Processes ‐ Pulp & Paper SO2 26 MI Industrial Processes ‐ Storage and Transfer SO2 26 MI Miscellaneous Non

‐ Industrial NEC SO2 26 MI Mobile ‐ Aircraft SO2 26 MI Mobile ‐ Commercial Marine Vessels SO2 26 MI Mobile ‐ Locomotives SO2 26 MI Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 26 MI Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 26 MI Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 26 MI Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 26 MI Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 26 MI Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 26 MI Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 26 MI Solvent ‐ Industrial Surface Coating & Solvent Use SO2 26 MI Waste Disposal SO2 27 MN Bulk Gasoline Terminals SO2 27 MN Fires ‐ Agricultural Field Burnin g SO2 27 MN Fires ‐ Prescribed Fires SO2 27 MN Fires ‐ Wildfires SO2 27 MN Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 27 MN Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 27 MN Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 27 MN Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 27 MN Fuel Comb ‐ Comm/Institutional ‐ Other SO2 27 MN Fuel Comb ‐ Electric Generation ‐ Biomass SO2 27 MN Fuel Comb ‐ Electric Generation ‐ Coal SO2 27 MN Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 27 MN Fuel Comb ‐ Electric Generation ‐ Oil SO2 27 MN Fuel Comb ‐ Electric Generation ‐ Other SO2 27 MN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 27 MN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 27 MN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO227 MN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 27 MN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 27 MN Fuel Comb ‐ Residential ‐ Natural Gas SO2 27 MN Fuel Comb ‐ Residential ‐ Oil SO2 27 MN Fuel Comb ‐ Residential ‐ Other SO2 27 MN Fuel Comb ‐ Residential ‐ Wood SO2 27 MN Gas Stations SO2 27 MN Industrial Processes ‐ Chemical Manuf SO2 27 MN Industrial Processes ‐ Ferrous Metals SO2 27 MN Industrial Processes ‐ Mining SO2 27 MN Industrial Processes ‐ NEC SO2 27 MN Industrial Processes ‐ Non

‐ ferrous Metals SO2 27 MN Industrial Processes ‐ Oil & Gas Production SO2 27 MN Industrial Processes ‐ Petroleum Refineries SO2 27 MN Industrial Processes ‐ Pulp & Paper SO2 27 MN Industrial Processes ‐ Storage and Transfer SO2 27 MN Miscellaneous Non

‐ Industrial NEC SO2 27 MN Mobile ‐ Aircraft SO2 27 MN Mobile ‐ Commercial Marine Vessels SO2 27 MN Mobile ‐ Locomotives SO2 27 MN Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 27 MN Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 27 MN Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 27 MN Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 27 MN Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 27 MN Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 27 MN Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 27 MN Solvent ‐ Graphic Arts SO2 27 MN Solvent ‐ Industrial Surface Coating & Solvent Use SO2 27 MN Waste Disposal SO2 28 MS Bulk Gasoline Terminals SO2 28 MS Fires ‐ Agricultural Field Burnin g SO2 28 MS Fires ‐ Prescribed Fires SO2 28 MS Fires ‐ Wildfires SO2 28 MS Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 28 MS Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 28 MS Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 28 MS Fuel Comb ‐ Comm/Institutional ‐ Other SO2 28 MS Fuel Comb ‐ Electric Generation ‐ Coal SO2 28 MS Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 28 MS Fuel Comb ‐ Electric Generation ‐ Oil SO2 28 MS Fuel Comb ‐ Electric Generation ‐ Other SO2 28 MS Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 28 MS Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 28 MS Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 28 MS Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 28 MS Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO228 MS Fuel Comb ‐ Residential ‐ Natural Gas SO2 28 MS Fuel Comb ‐ Residential ‐ Oil SO2 28 MS Fuel Comb ‐ Residential ‐ Other SO2 28 MS Fuel Comb ‐ Residential ‐ Wood SO2 28 MS Gas Stations SO2 28 MS Industrial Processes ‐ Chemical Manuf SO2 28 MS Industrial Processes ‐ Ferrous Metals SO2 28 MS Industrial Processes ‐ NEC SO2 28 MS Industrial Processes ‐ Non

‐ ferrous Metals SO2 28 MS Industrial Processes ‐ Oil & Gas Production SO2 28 MS Industrial Processes ‐ Petroleum Refineries SO2 28 MS Industrial Processes ‐ Pulp & Paper SO2 28 MS Industrial Processes ‐ Storage and Transfer SO2 28 MS Miscellaneous Non

‐ Industrial NEC SO2 28 MS Mobile ‐ Aircraft SO2 28 MS Mobile ‐ Commercial Marine Vessels SO2 28 MS Mobile ‐ Locomotives SO2 28 MS Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 28 MS Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 28 MS Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 28 MS Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 28 MS Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 28 MS Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 28 MS Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 28 MS Solvent ‐ Degreasing SO2 28 MS Solvent ‐ Graphic Arts SO2 28 MS Solvent ‐ Industrial Surface Coating & Solvent Use SO2 28 MS Waste Disposal SO2 29 MO Fires ‐ Agricultural Field Burnin g SO2 29 MO Fires ‐ Prescribed Fires SO2 29 MO Fires ‐ Wildfires SO2 29 MO Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 29 MO Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 29 MO Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 29 MO Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 29 MO Fuel Comb ‐ Comm/Institutional ‐ Other SO2 29 MO Fuel Comb ‐ Electric Generation ‐ Biomass SO2 29 MO Fuel Comb ‐ Electric Generation ‐ Coal SO2 29 MO Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 29 MO Fuel Comb ‐ Electric Generation ‐ Oil SO2 29 MO Fuel Comb ‐ Electric Generation ‐ Other SO2 29 MO Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 29 MO Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 29 MO Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 29 MO Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 29 MO Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 29 MO Fuel Comb ‐ Residential ‐ Natural Gas SO229 MO Fuel Comb ‐ Residential ‐ Oil SO2 29 MO Fuel Comb ‐ Residential ‐ Other SO2 29 MO Fuel Comb ‐ Residential ‐ Wood SO2 29 MO Industrial Processes ‐ Cement Manuf SO2 29 MO Industrial Processes ‐ Chemical Manuf SO2 29 MO Industrial Processes ‐ Ferrous Metals SO2 29 MO Industrial Processes ‐ Mining SO2 29 MO Industrial Processes ‐ NEC SO2 29 MO Industrial Processes ‐ Non

‐ ferrous Metals SO2 29 MO Industrial Processes ‐ Oil & Gas Production SO2 29 MO Industrial Processes ‐ Petroleum Refineries SO2 29 MO Industrial Processes ‐ Pulp & Paper SO2 29 MO Industrial Processes ‐ Storage and Transfer SO2 29 MO Miscellaneous Non

‐ Industrial NEC SO2 29 MO Mobile ‐ Aircraft SO2 29 MO Mobile ‐ Commercial Marine Vessels SO2 29 MO Mobile ‐ Locomotives SO2 29 MO Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 29 MO Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 29 MO Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 29 MO Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 29 MO Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 29 MO Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 29 MO Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 29 MO Solvent ‐ Industrial Surface Coating & Solvent Use SO2 29 MO Waste Disposal SO2 30 MT Fires ‐ Agricultural Field Burnin g SO2 30 MT Fires ‐ Prescribed Fires SO2 30 MT Fires ‐ Wildfires SO2 30 MT Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 30 MT Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 30 MT Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 30 MT Fuel Comb ‐ Comm/Institutional ‐ Other SO2 30 MT Fuel Comb ‐ Electric Generation ‐ Coal SO2 30 MT Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 30 MT Fuel Comb ‐ Electric Generation ‐ Oil SO2 30 MT Fuel Comb ‐ Electric Generation ‐ Other SO2 30 MT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 30 MT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 30 MT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 30 MT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 30 MT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 30 MT Fuel Comb ‐ Residential ‐ Natural Gas SO2 30 MT Fuel Comb ‐ Residential ‐ Oil SO2 30 MT Fuel Comb ‐ Residential ‐ Other SO2 30 MT Fuel Comb ‐ Residential ‐ Wood SO2 30 MT Industrial Processes ‐ Cement Manuf SO230 MT Industrial Processes ‐ Chemical Manuf SO2 30 MT Industrial Processes ‐ Mining SO2 30 MT Industrial Processes ‐ NEC SO2 30 MT Industrial Processes ‐ Non

‐ ferrous Metals SO2 30 MT Industrial Processes ‐ Oil & Gas Production SO2 30 MT Industrial Processes ‐ Petroleum Refineries SO2 30 MT Industrial Processes ‐ Pulp & Paper SO2 30 MT Industrial Processes ‐ Storage and Transfer SO2 30 MT Miscellaneous Non

‐ Industrial NEC SO2 30 MT Mobile ‐ Aircraft SO2 30 MT Mobile ‐ Locomotives SO2 30 MT Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 30 MT Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 30 MT Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 30 MT Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 30 MT Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 30 MT Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 30 MT Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 30 MT Solvent ‐ Industrial Surface Coating & Solvent Use SO2 30 MT Waste Disposal SO2 31 NE Bulk Gasoline Terminals SO2 31 NE Fires ‐ Agricultural Field Burnin g SO2 31 NE Fires ‐ Prescribed Fires SO2 31 NE Fires ‐ Wildfires SO2 31 NE Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 31 NE Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 31 NE Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 31 NE Fuel Comb ‐ Comm/Institutional ‐ Other SO2 31 NE Fuel Comb ‐ Electric Generation ‐ Biomass SO2 31 NE Fuel Comb ‐ Electric Generation ‐ Coal SO2 31 NE Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 31 NE Fuel Comb ‐ Electric Generation ‐ Oil SO2 31 NE Fuel Comb ‐ Electric Generation ‐ Other SO2 31 NE Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 31 NE Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 31 NE Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 31 NE Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 31 NE Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 31 NE Fuel Comb ‐ Residential ‐ Natural Gas SO2 31 NE Fuel Comb ‐ Residential ‐ Oil SO2 31 NE Fuel Comb ‐ Residential ‐ Other SO2 31 NE Fuel Comb ‐ Residential ‐ Wood SO2 31 NE Industrial Processes ‐ Cement Manuf SO2 31 NE Industrial Processes ‐ Chemical Manuf SO2 31 NE Industrial Processes ‐ Ferrous Metals SO2 31 NE Industrial Processes ‐ NEC SO2 31 NE Industrial Processes ‐ Non

‐ ferrous Metals SO231 NE Industrial Processes ‐ Oil & Gas Production SO2 31 NE Industrial Processes ‐ Petroleum Refineries SO2 31 NE Industrial Processes ‐ Storage and Transfer SO2 31 NE Miscellaneous Non

‐ Industrial NEC SO2 31 NE Mobile ‐ Aircraft SO2 31 NE Mobile ‐ Commercial Marine Vessels SO2 31 NE Mobile ‐ Locomotives SO2 31 NE Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 31 NE Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 31 NE Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 31 NE Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 31 NE Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 31 NE Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 31 NE Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 31 NE Solvent ‐ Degreasing SO2 31 NE Solvent ‐ Industrial Surface Coating & Solvent Use SO2 31 NE Waste Disposal SO2 32 NV Agriculture ‐ Livestock Waste SO2 32 NV Bulk Gasoline Terminals SO2 32 NV Commercial Cooking SO2 32 NV Dust ‐ Construction Dust SO2 32 NV Dust ‐ Paved Road Dust SO2 32 NV Dust ‐ Unpaved Road Dust SO2 32 NV Fires ‐ Agricultural Field Burnin g SO2 32 NV Fires ‐ Prescribed Fires SO2 32 NV Fires ‐ Wildfires SO2 32 NV Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 32 NV Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 32 NV Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 32 NV Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 32 NV Fuel Comb ‐ Comm/Institutional ‐ Other SO2 32 NV Fuel Comb ‐ Electric Generation ‐ Coal SO2 32 NV Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 32 NV Fuel Comb ‐ Electric Generation ‐ Oil SO2 32 NV Fuel Comb ‐ Electric Generation ‐ Other SO2 32 NV Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 32 NV Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 32 NV Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 32 NV Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 32 NV Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 32 NV Fuel Comb ‐ Residential ‐ Natural Gas SO2 32 NV Fuel Comb ‐ Residential ‐ Oil SO2 32 NV Fuel Comb ‐ Residential ‐ Other SO2 32 NV Fuel Comb ‐ Residential ‐ Wood SO2 32 NV Gas Stations SO2 32 NV Industrial Processes ‐ Cement Manuf SO2 32 NV Industrial Processes ‐ Chemical Manuf SO232 NV Industrial Processes ‐ Ferrous Metals SO2 32 NV Industrial Processes ‐ Mining SO2 32 NV Industrial Processes ‐ NEC SO2 32 NV Industrial Processes ‐ Non

‐ ferrous Metals SO2 32 NV Industrial Processes ‐ Oil & Gas Production SO2 32 NV Industrial Processes ‐ Petroleum Refineries SO2 32 NV Industrial Processes ‐ Storage and Transfer SO2 32 NV Miscellaneous Non

‐ Industrial NEC SO2 32 NV Mobile ‐ Aircraft SO2 32 NV Mobile ‐ Locomotives SO2 32 NV Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 32 NV Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 32 NV Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 32 NV Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 32 NV Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 32 NV Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 32 NV Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 32 NV Solvent ‐ Consumer & Commercial Solvent Use SO2 32 NV Solvent ‐ Degreasing SO2 32 NV Solvent ‐ Dry Cleaning SO2 32 NV Solvent ‐ Graphic Arts SO2 32 NV Solvent ‐ Industrial Surface Coating & Solvent Use SO2 32 NV Solvent ‐ Non

‐ Industrial Surface Coating SO2 32 NV Waste Disposal SO2 33 NH Fires ‐ Agricultural Field Burnin g SO2 33 NH Fires ‐ Prescribed Fires SO2 33 NH Fires ‐ Wildfires SO2 33 NH Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 33 NH Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 33 NH Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 33 NH Fuel Comb ‐ Comm/Institutional ‐ Other SO2 33 NH Fuel Comb ‐ Electric Generation ‐ Biomass SO2 33 NH Fuel Comb ‐ Electric Generation ‐ Coal SO2 33 NH Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 33 NH Fuel Comb ‐ Electric Generation ‐ Oil SO2 33 NH Fuel Comb ‐ Electric Generation ‐ Other SO2 33 NH Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 33 NH Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 33 NH Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 33 NH Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 33 NH Fuel Comb ‐ Residential ‐ Natural Gas SO2 33 NH Fuel Comb ‐ Residential ‐ Oil SO2 33 NH Fuel Comb ‐ Residential ‐ Other SO2 33 NH Fuel Comb ‐ Residential ‐ Wood SO2 33 NH Industrial Processes ‐ Ferrous Metals SO2 33 NH Industrial Processes ‐ NEC SO2 33 NH Industrial Processes ‐ Non

‐ ferrous Metals SO233 NH Industrial Processes ‐ Pulp & Paper SO2 33 NH Industrial Processes ‐ Storage and Transfer SO2 33 NH Miscellaneous Non

‐ Industrial NEC SO2 33 NH Mobile ‐ Aircraft SO2 33 NH Mobile ‐ Commercial Marine Vessels SO2 33 NH Mobile ‐ Locomotives SO2 33 NH Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 33 NH Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 33 NH Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 33 NH Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 33 NH Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 33 NH Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 33 NH Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 33 NH Solvent ‐ Industrial Surface Coating & Solvent Use SO2 33 NH Waste Disposal SO2 34 NJ Bulk Gasoline Terminals SO2 34 NJ Commercial Cooking SO2 34 NJ Fires ‐ Prescribed Fires SO2 34 NJ Fires ‐ Wildfires SO2 34 NJ Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 34 NJ Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 34 NJ Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 34 NJ Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 34 NJ Fuel Comb ‐ Comm/Institutional ‐ Other SO2 34 NJ Fuel Comb ‐ Electric Generation ‐ Coal SO2 34 NJ Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 34 NJ Fuel Comb ‐ Electric Generation ‐ Oil SO2 34 NJ Fuel Comb ‐ Electric Generation ‐ Other SO2 34 NJ Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 34 NJ Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 34 NJ Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 34 NJ Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 34 NJ Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 34 NJ Fuel Comb ‐ Residential ‐ Natural Gas SO2 34 NJ Fuel Comb ‐ Residential ‐ Oil SO2 34 NJ Fuel Comb ‐ Residential ‐ Other SO2 34 NJ Fuel Comb ‐ Residential ‐ Wood SO2 34 NJ Industrial Processes ‐ Chemical Manuf SO2 34 NJ Industrial Processes ‐ Ferrous Metals SO2 34 NJ Industrial Processes ‐ NEC SO2 34 NJ Industrial Processes ‐ Non

‐ ferrous Metals SO2 34 NJ Industrial Processes ‐ Oil & Gas Production SO2 34 NJ Industrial Processes ‐ Petroleum Refineries SO2 34 NJ Industrial Processes ‐ Pulp & Paper SO2 34 NJ Industrial Processes ‐ Storage and Transfer SO2 34 NJ Miscellaneous Non

‐ Industrial NEC SO2 34 NJ Mobile ‐ Aircraft SO234 NJ Mobile ‐ Commercial Marine Vessels SO2 34 NJ Mobile ‐ Locomotives SO2 34 NJ Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 34 NJ Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 34 NJ Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 34 NJ Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 34 NJ Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 34 NJ Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 34 NJ Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 34 NJ Solvent ‐ Graphic Arts SO2 34 NJ Solvent ‐ Industrial Surface Coating & Solvent Use SO2 34 NJ Waste Disposal SO2 35 NM Fires ‐ Agricultural Field Burnin g SO2 35 NM Fires ‐ Prescribed Fires SO2 35 NM Fires ‐ Wildfires SO2 35 NM Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 35 NM Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 35 NM Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 35 NM Fuel Comb ‐ Comm/Institutional ‐ Other SO2 35 NM Fuel Comb ‐ Electric Generation ‐ Coal SO2 35 NM Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 35 NM Fuel Comb ‐ Electric Generation ‐ Oil SO2 35 NM Fuel Comb ‐ Electric Generation ‐ Other SO2 35 NM Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 35 NM Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 35 NM Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 35 NM Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 35 NM Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 35 NM Fuel Comb ‐ Residential ‐ Natural Gas SO2 35 NM Fuel Comb ‐ Residential ‐ Oil SO2 35 NM Fuel Comb ‐ Residential ‐ Other SO2 35 NM Fuel Comb ‐ Residential ‐ Wood SO2 35 NM Industrial Processes ‐ Cement Manuf SO2 35 NM Industrial Processes ‐ Mining SO2 35 NM Industrial Processes ‐ NEC SO2 35 NM Industrial Processes ‐ Non

‐ ferrous Metals SO2 35 NM Industrial Processes ‐ Oil & Gas Production SO2 35 NM Industrial Processes ‐ Petroleum Refineries SO2 35 NM Industrial Processes ‐ Storage and Transfer SO2 35 NM Miscellaneous Non

‐ Industrial NEC SO2 35 NM Mobile ‐ Aircraft SO2 35 NM Mobile ‐ Locomotives SO2 35 NM Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 35 NM Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 35 NM Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 35 NM Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 35 NM Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO235 NM Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 35 NM Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 35 NM Solvent ‐ Graphic Arts SO2 35 NM Solvent ‐ Industrial Surface Coating & Solvent Use SO2 35 NM Waste Disposal SO2 36 NY Bulk Gasoline Terminals SO2 36 NY Fires ‐ Agricultural Field Burnin g SO2 36 NY Fires ‐ Prescribed Fires SO2 36 NY Fires ‐ Wildfires SO2 36 NY Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 36 NY Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 36 NY Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 36 NY Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 36 NY Fuel Comb ‐ Comm/Institutional ‐ Other SO2 36 NY Fuel Comb ‐ Electric Generation ‐ Biomass SO2 36 NY Fuel Comb ‐ Electric Generation ‐ Coal SO2 36 NY Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 36 NY Fuel Comb ‐ Electric Generation ‐ Oil SO2 36 NY Fuel Comb ‐ Electric Generation ‐ Other SO2 36 NY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 36 NY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 36 NY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 36 NY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 36 NY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 36 NY Fuel Comb ‐ Residential ‐ Natural Gas SO2 36 NY Fuel Comb ‐ Residential ‐ Oil SO2 36 NY Fuel Comb ‐ Residential ‐ Other SO2 36 NY Fuel Comb ‐ Residential ‐ Wood SO2 36 NY Industrial Processes ‐ Cement Manuf SO2 36 NY Industrial Processes ‐ Chemical Manuf SO2 36 NY Industrial Processes ‐ Ferrous Metals SO2 36 NY Industrial Processes ‐ NEC SO2 36 NY Industrial Processes ‐ Non

‐ ferrous Metals SO2 36 NY Industrial Processes ‐ Oil & Gas Production SO2 36 NY Industrial Processes ‐ Pulp & Paper SO2 36 NY Industrial Processes ‐ Storage and Transfer SO2 36 NY Miscellaneous Non

‐ Industrial NEC SO2 36 NY Mobile ‐ Aircraft SO2 36 NY Mobile ‐ Commercial Marine Vessels SO2 36 NY Mobile ‐ Locomotives SO2 36 NY Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 36 NY Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 36 NY Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 36 NY Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 36 NY Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 36 NY Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 36 NY Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO236 NY Solvent ‐ Graphic Arts SO2 36 NY Solvent ‐ Industrial Surface Coating & Solvent Use SO2 36 NY Waste Disposal SO2 37 NC Bulk Gasoline Terminals SO2 37 NC Fires ‐ Agricultural Field Burnin g SO2 37 NC Fires ‐ Prescribed Fires SO2 37 NC Fires ‐ Wildfires SO2 37 NC Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 37 NC Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 37 NC Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 37 NC Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 37 NC Fuel Comb ‐ Comm/Institutional ‐ Other SO2 37 NC Fuel Comb ‐ Electric Generation ‐ Biomass SO2 37 NC Fuel Comb ‐ Electric Generation ‐ Coal SO2 37 NC Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 37 NC Fuel Comb ‐ Electric Generation ‐ Oil SO2 37 NC Fuel Comb ‐ Electric Generation ‐ Other SO2 37 NC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 37 NC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 37 NC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 37 NC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 37 NC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 37 NC Fuel Comb ‐ Residential ‐ Natural Gas SO2 37 NC Fuel Comb ‐ Residential ‐ Oil SO2 37 NC Fuel Comb ‐ Residential ‐ Other SO2 37 NC Fuel Comb ‐ Residential ‐ Wood SO2 37 NC Industrial Processes ‐ Chemical Manuf SO2 37 NC Industrial Processes ‐ Ferrous Metals SO2 37 NC Industrial Processes ‐ NEC SO2 37 NC Industrial Processes ‐ Non

‐ ferrous Metals SO2 37 NC Industrial Processes ‐ Pulp & Paper SO2 37 NC Industrial Processes ‐ Storage and Transfer SO2 37 NC Miscellaneous Non

‐ Industrial NEC SO2 37 NC Mobile ‐ Aircraft SO2 37 NC Mobile ‐ Commercial Marine Vessels SO2 37 NC Mobile ‐ Locomotives SO2 37 NC Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 37 NC Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 37 NC Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 37 NC Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 37 NC Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 37 NC Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 37 NC Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 37 NC Solvent ‐ Graphic Arts SO2 37 NC Solvent ‐ Industrial Surface Coating & Solvent Use SO2 37 NC Waste Disposal SO2 38 ND Fires ‐ Agricultural Field Burnin g SO238 ND Fires ‐ Prescribed Fires SO2 38 ND Fires ‐ Wildfires SO2 38 ND Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 38 ND Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 38 ND Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 38 ND Fuel Comb ‐ Comm/Institutional ‐ Other SO2 38 ND Fuel Comb ‐ Electric Generation ‐ Coal SO2 38 ND Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 38 ND Fuel Comb ‐ Electric Generation ‐ Oil SO2 38 ND Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 38 ND Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 38 ND Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 38 ND Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 38 ND Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 38 ND Fuel Comb ‐ Residential ‐ Natural Gas SO2 38 ND Fuel Comb ‐ Residential ‐ Oil SO2 38 ND Fuel Comb ‐ Residential ‐ Other SO2 38 ND Fuel Comb ‐ Residential ‐ Wood SO2 38 ND Industrial Processes ‐ Chemical Manuf SO2 38 ND Industrial Processes ‐ NEC SO2 38 ND Industrial Processes ‐ Oil & Gas Production SO2 38 ND Industrial Processes ‐ Petroleum Refineries SO2 38 ND Industrial Processes ‐ Pulp & Paper SO2 38 ND Industrial Processes ‐ Storage and Transfer SO2 38 ND Miscellaneous Non

‐ Industrial NEC SO2 38 ND Mobile ‐ Aircraft SO2 38 ND Mobile ‐ Locomotives SO2 38 ND Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 38 ND Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 38 ND Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 38 ND Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 38 ND Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 38 ND Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 38 ND Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 38 ND Waste Disposal SO2 39 OH Bulk Gasoline Terminals SO2 39 OH Fires ‐ Agricultural Field Burnin g SO2 39 OH Fires ‐ Prescribed Fires SO2 39 OH Fires ‐ Wildfires SO2 39 OH Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 39 OH Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 39 OH Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 39 OH Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 39 OH Fuel Comb ‐ Comm/Institutional ‐ Other SO2 39 OH Fuel Comb ‐ Electric Generation ‐ Biomass SO2 39 OH Fuel Comb ‐ Electric Generation ‐ Coal SO2 39 OH Fuel Comb ‐ Electric Generation ‐ Natural Gas SO239 OH Fuel Comb ‐ Electric Generation ‐ Oil SO2 39 OH Fuel Comb ‐ Electric Generation ‐ Other SO2 39 OH Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 39 OH Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 39 OH Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 39 OH Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 39 OH Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 39 OH Fuel Comb ‐ Residential ‐ Natural Gas SO2 39 OH Fuel Comb ‐ Residential ‐ Oil SO2 39 OH Fuel Comb ‐ Residential ‐ Other SO2 39 OH Fuel Comb ‐ Residential ‐ Wood SO2 39 OH Industrial Processes ‐ Cement Manuf SO2 39 OH Industrial Processes ‐ Chemical Manuf SO2 39 OH Industrial Processes ‐ Ferrous Metals SO2 39 OH Industrial Processes ‐ Mining SO2 39 OH Industrial Processes ‐ NEC SO2 39 OH Industrial Processes ‐ Non

‐ ferrous Metals SO2 39 OH Industrial Processes ‐ Oil & Gas Production SO2 39 OH Industrial Processes ‐ Petroleum Refineries SO2 39 OH Industrial Processes ‐ Pulp & Paper SO2 39 OH Industrial Processes ‐ Storage and Transfer SO2 39 OH Miscellaneous Non

‐ Industrial NEC SO2 39 OH Mobile ‐ Aircraft SO2 39 OH Mobile ‐ Commercial Marine Vessels SO2 39 OH Mobile ‐ Locomotives SO2 39 OH Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 39 OH Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 39 OH Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 39 OH Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 39 OH Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 39 OH Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 39 OH Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 39 OH Solvent ‐ Degreasing SO2 39 OH Solvent ‐ Graphic Arts SO2 39 OH Solvent ‐ Industrial Surface Coating & Solvent Use SO2 39 OH Waste Disposal SO2 40 OK Bulk Gasoline Terminals SO2 40 OK Fires ‐ Agricultural Field Burnin g SO2 40 OK Fires ‐ Prescribed Fires SO2 40 OK Fires ‐ Wildfires SO2 40 OK Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 40 OK Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 40 OK Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 40 OK Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 40 OK Fuel Comb ‐ Comm/Institutional ‐ Other SO2 40 OK Fuel Comb ‐ Electric Generation ‐ Coal SO2 40 OK Fuel Comb ‐ Electric Generation ‐ Natural Gas SO240 OK Fuel Comb ‐ Electric Generation ‐ Oil SO2 40 OK Fuel Comb ‐ Electric Generation ‐ Other SO2 40 OK Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 40 OK Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 40 OK Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 40 OK Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 40 OK Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 40 OK Fuel Comb ‐ Residential ‐ Natural Gas SO2 40 OK Fuel Comb ‐ Residential ‐ Oil SO2 40 OK Fuel Comb ‐ Residential ‐ Other SO2 40 OK Fuel Comb ‐ Residential ‐ Wood SO2 40 OK Industrial Processes ‐ Cement Manuf SO2 40 OK Industrial Processes ‐ Chemical Manuf SO2 40 OK Industrial Processes ‐ Ferrous Metals SO2 40 OK Industrial Processes ‐ NEC SO2 40 OK Industrial Processes ‐ Non

‐ ferrous Metals SO2 40 OK Industrial Processes ‐ Oil & Gas Production SO2 40 OK Industrial Processes ‐ Petroleum Refineries SO2 40 OK Industrial Processes ‐ Pulp & Paper SO2 40 OK Industrial Processes ‐ Storage and Transfer SO2 40 OK Miscellaneous Non

‐ Industrial NEC SO2 40 OK Mobile ‐ Aircraft SO2 40 OK Mobile ‐ Commercial Marine Vessels SO2 40 OK Mobile ‐ Locomotives SO2 40 OK Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 40 OK Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 40 OK Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 40 OK Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 40 OK Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 40 OK Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 40 OK Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 40 OK Solvent ‐ Industrial Surface Coating & Solvent Use SO2 40 OK Waste Disposal SO2 41 OR Bulk Gasoline Terminals SO2 41 OR Fires ‐ Agricultural Field Burnin g SO2 41 OR Fires ‐ Prescribed Fires SO2 41 OR Fires ‐ Wildfires SO2 41 OR Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 41 OR Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 41 OR Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 41 OR Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 41 OR Fuel Comb ‐ Comm/Institutional ‐ Other SO2 41 OR Fuel Comb ‐ Electric Generation ‐ Biomass SO2 41 OR Fuel Comb ‐ Electric Generation ‐ Coal SO2 41 OR Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 41 OR Fuel Comb ‐ Electric Generation ‐ Oil SO2 41 OR Fuel Comb ‐ Electric Generation ‐ Other SO241 OR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 41 OR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 41 OR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 41 OR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 41 OR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 41 OR Fuel Comb ‐ Residential ‐ Natural Gas SO2 41 OR Fuel Comb ‐ Residential ‐ Oil SO2 41 OR Fuel Comb ‐ Residential ‐ Other SO2 41 OR Fuel Comb ‐ Residential ‐ Wood SO2 41 OR Industrial Processes ‐ Cement Manuf SO2 41 OR Industrial Processes ‐ Chemical Manuf SO2 41 OR Industrial Processes ‐ Ferrous Metals SO2 41 OR Industrial Processes ‐ Mining SO2 41 OR Industrial Processes ‐ NEC SO2 41 OR Industrial Processes ‐ Non

‐ ferrous Metals SO2 41 OR Industrial Processes ‐ Oil & Gas Production SO2 41 OR Industrial Processes ‐ Petroleum Refineries SO2 41 OR Industrial Processes ‐ Pulp & Paper SO2 41 OR Industrial Processes ‐ Storage and Transfer SO2 41 OR Miscellaneous Non

‐ Industrial NEC SO2 41 OR Mobile ‐ Aircraft SO2 41 OR Mobile ‐ Commercial Marine Vessels SO2 41 OR Mobile ‐ Locomotives SO2 41 OR Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 41 OR Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 41 OR Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 41 OR Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 41 OR Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 41 OR Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 41 OR Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 41 OR Solvent ‐ Graphic Arts SO2 41 OR Solvent ‐ Industrial Surface Coating & Solvent Use SO2 41 OR Waste Disposal SO2 42 PA Bulk Gasoline Terminals SO2 42 PA Fires ‐ Agricultural Field Burnin g SO2 42 PA Fires ‐ Prescribed Fires SO2 42 PA Fires ‐ Wildfires SO2 42 PA Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 42 PA Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 42 PA Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 42 PA Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 42 PA Fuel Comb ‐ Comm/Institutional ‐ Other SO2 42 PA Fuel Comb ‐ Electric Generation ‐ Biomass SO2 42 PA Fuel Comb ‐ Electric Generation ‐ Coal SO2 42 PA Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 42 PA Fuel Comb ‐ Electric Generation ‐ Oil SO2 42 PA Fuel Comb ‐ Electric Generation ‐ Other SO242 PA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 42 PA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 42 PA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 42 PA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 42 PA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 42 PA Fuel Comb ‐ Residential ‐ Natural Gas SO2 42 PA Fuel Comb ‐ Residential ‐ Oil SO2 42 PA Fuel Comb ‐ Residential ‐ Other SO2 42 PA Fuel Comb ‐ Residential ‐ Wood SO2 42 PA Industrial Processes ‐ Cement Manuf SO2 42 PA Industrial Processes ‐ Chemical Manuf SO2 42 PA Industrial Processes ‐ Ferrous Metals SO2 42 PA Industrial Processes ‐ Mining SO2 42 PA Industrial Processes ‐ NEC SO2 42 PA Industrial Processes ‐ Non

‐ ferrous Metals SO2 42 PA Industrial Processes ‐ Oil & Gas Production SO2 42 PA Industrial Processes ‐ Petroleum Refineries SO2 42 PA Industrial Processes ‐ Pulp & Paper SO2 42 PA Industrial Processes ‐ Storage and Transfer SO2 42 PA Miscellaneous Non

‐ Industrial NEC SO2 42 PA Mobile ‐ Aircraft SO2 42 PA Mobile ‐ Commercial Marine Vessels SO2 42 PA Mobile ‐ Locomotives SO2 42 PA Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 42 PA Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 42 PA Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 42 PA Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 42 PA Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 42 PA Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 42 PA Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 42 PA Solvent ‐ Degreasing SO2 42 PA Solvent ‐ Graphic Arts SO2 42 PA Solvent ‐ Industrial Surface Coating & Solvent Use SO2 42 PA Waste Disposal SO2 44 RI Bulk Gasoline Terminals SO2 44 RI Fires ‐ Agricultural Field Burnin g SO2 44 RI Fires ‐ Prescribed Fires SO2 44 RI Fires ‐ Wildfires SO2 44 RI Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 44 RI Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 44 RI Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 44 RI Fuel Comb ‐ Comm/Institutional ‐ Other SO2 44 RI Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 44 RI Fuel Comb ‐ Electric Generation ‐ Oil SO2 44 RI Fuel Comb ‐ Electric Generation ‐ Other SO2 44 RI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 44 RI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO244 RI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 44 RI Fuel Comb ‐ Residential ‐ Natural Gas SO2 44 RI Fuel Comb ‐ Residential ‐ Oil SO2 44 RI Fuel Comb ‐ Residential ‐ Other SO2 44 RI Fuel Comb ‐ Residential ‐ Wood SO2 44 RI Industrial Processes ‐ NEC SO2 44 RI Miscellaneous Non

‐ Industrial NEC SO2 44 RI Mobile ‐ Aircraft SO2 44 RI Mobile ‐ Commercial Marine Vessels SO2 44 RI Mobile ‐ Locomotives SO2 44 RI Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 44 RI Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 44 RI Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 44 RI Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 44 RI Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 44 RI Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 44 RI Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 44 RI Waste Disposal SO2 45 SC Fires ‐ Agricultural Field Burnin g SO2 45 SC Fires ‐ Prescribed Fires SO2 45 SC Fires ‐ Wildfires SO2 45 SC Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 45 SC Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 45 SC Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 45 SC Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 45 SC Fuel Comb ‐ Comm/Institutional ‐ Other SO2 45 SC Fuel Comb ‐ Electric Generation ‐ Biomass SO2 45 SC Fuel Comb ‐ Electric Generation ‐ Coal SO2 45 SC Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 45 SC Fuel Comb ‐ Electric Generation ‐ Oil SO2 45 SC Fuel Comb ‐ Electric Generation ‐ Other SO2 45 SC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 45 SC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 45 SC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 45 SC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 45 SC Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 45 SC Fuel Comb ‐ Residential ‐ Natural Gas SO2 45 SC Fuel Comb ‐ Residential ‐ Oil SO2 45 SC Fuel Comb ‐ Residential ‐ Other SO2 45 SC Fuel Comb ‐ Residential ‐ Wood SO2 45 SC Industrial Processes ‐ Cement Manuf SO2 45 SC Industrial Processes ‐ Chemical Manuf SO2 45 SC Industrial Processes ‐ Ferrous Metals SO2 45 SC Industrial Processes ‐ NEC SO2 45 SC Industrial Processes ‐ Non

‐ ferrous Metals SO2 45 SC Industrial Processes ‐ Petroleum Refineries SO2 45 SC Industrial Processes ‐ Pulp & Paper SO245 SC Industrial Processes ‐ Storage and Transfer SO2 45 SC Miscellaneous Non

‐ Industrial NEC SO2 45 SC Mobile ‐ Aircraft SO2 45 SC Mobile ‐ Commercial Marine Vessels SO2 45 SC Mobile ‐ Locomotives SO2 45 SC Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 45 SC Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 45 SC Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 45 SC Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 45 SC Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 45 SC Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 45 SC Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 45 SC Solvent ‐ Graphic Arts SO2 45 SC Solvent ‐ Industrial Surface Coating & Solvent Use SO2 45 SC Waste Disposal SO2 46 SD Bulk Gasoline Terminals SO2 46 SD Fires ‐ Agricultural Field Burnin g SO2 46 SD Fires ‐ Prescribed Fires SO2 46 SD Fires ‐ Wildfires SO2 46 SD Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 46 SD Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 46 SD Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 46 SD Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 46 SD Fuel Comb ‐ Comm/Institutional ‐ Other SO2 46 SD Fuel Comb ‐ Electric Generation ‐ Biomass SO2 46 SD Fuel Comb ‐ Electric Generation ‐ Coal SO2 46 SD Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 46 SD Fuel Comb ‐ Electric Generation ‐ Oil SO2 46 SD Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 46 SD Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 46 SD Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 46 SD Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 46 SD Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 46 SD Fuel Comb ‐ Residential ‐ Natural Gas SO2 46 SD Fuel Comb ‐ Residential ‐ Oil SO2 46 SD Fuel Comb ‐ Residential ‐ Other SO2 46 SD Fuel Comb ‐ Residential ‐ Wood SO2 46 SD Industrial Processes ‐ Cement Manuf SO2 46 SD Industrial Processes ‐ Mining SO2 46 SD Industrial Processes ‐ NEC SO2 46 SD Industrial Processes ‐ Non

‐ ferrous Metals SO2 46 SD Industrial Processes ‐ Oil & Gas Production SO2 46 SD Industrial Processes ‐ Petroleum Refineries SO2 46 SD Industrial Processes ‐ Pulp & Paper SO2 46 SD Industrial Processes ‐ Storage and Transfer SO2 46 SD Miscellaneous Non

‐ Industrial NEC SO2 46 SD Mobile ‐ Aircraft SO246 SD Mobile ‐ Locomotives SO2 46 SD Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 46 SD Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 46 SD Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 46 SD Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 46 SD Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 46 SD Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 46 SD Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 46 SD Solvent ‐ Industrial Surface Coating & Solvent Use SO2 46 SD Waste Disposal SO2 47 TN Bulk Gasoline Terminals SO2 47 TN Fires ‐ Agricultural Field Burnin g SO2 47 TN Fires ‐ Prescribed Fires SO2 47 TN Fires ‐ Wildfires SO2 47 TN Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 47 TN Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 47 TN Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 47 TN Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 47 TN Fuel Comb ‐ Comm/Institutional ‐ Other SO2 47 TN Fuel Comb ‐ Electric Generation ‐ Biomass SO2 47 TN Fuel Comb ‐ Electric Generation ‐ Coal SO2 47 TN Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 47 TN Fuel Comb ‐ Electric Generation ‐ Oil SO2 47 TN Fuel Comb ‐ Electric Generation ‐ Other SO2 47 TN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 47 TN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 47 TN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 47 TN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 47 TN Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 47 TN Fuel Comb ‐ Residential ‐ Natural Gas SO2 47 TN Fuel Comb ‐ Residential ‐ Oil SO2 47 TN Fuel Comb ‐ Residential ‐ Other SO2 47 TN Fuel Comb ‐ Residential ‐ Wood SO2 47 TN Industrial Processes ‐ Cement Manuf SO2 47 TN Industrial Processes ‐ Chemical Manuf SO2 47 TN Industrial Processes ‐ Ferrous Metals SO2 47 TN Industrial Processes ‐ NEC SO2 47 TN Industrial Processes ‐ Non

‐ ferrous Metals SO2 47 TN Industrial Processes ‐ Oil & Gas Production SO2 47 TN Industrial Processes ‐ Petroleum Refineries SO2 47 TN Industrial Processes ‐ Pulp & Paper SO2 47 TN Industrial Processes ‐ Storage and Transfer SO2 47 TN Miscellaneous Non

‐ Industrial NEC SO2 47 TN Mobile ‐ Aircraft SO2 47 TN Mobile ‐ Commercial Marine Vessels SO2 47 TN Mobile ‐ Locomotives SO2 47 TN Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO247 TN Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 47 TN Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 47 TN Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 47 TN Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 47 TN Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 47 TN Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 47 TN Solvent ‐ Graphic Arts SO2 47 TN Solvent ‐ Industrial Surface Coating & Solvent Use SO2 47 TN Waste Disposal SO2 48 TX Bulk Gasoline Terminals SO2 48 TX Fires ‐ Agricultural Field Burnin g SO2 48 TX Fires ‐ Prescribed Fires SO2 48 TX Fires ‐ Wildfires SO2 48 TX Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 48 TX Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 48 TX Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 48 TX Fuel Comb ‐ Comm/Institutional ‐ Other SO2 48 TX Fuel Comb ‐ Electric Generation ‐ Coal SO2 48 TX Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 48 TX Fuel Comb ‐ Electric Generation ‐ Oil SO2 48 TX Fuel Comb ‐ Electric Generation ‐ Other SO2 48 TX Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 48 TX Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 48 TX Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 48 TX Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 48 TX Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 48 TX Fuel Comb ‐ Residential ‐ Natural Gas SO2 48 TX Fuel Comb ‐ Residential ‐ Oil SO2 48 TX Fuel Comb ‐ Residential ‐ Other SO2 48 TX Fuel Comb ‐ Residential ‐ Wood SO2 48 TX Gas Stations SO2 48 TX Industrial Processes ‐ Cement Manuf SO2 48 TX Industrial Processes ‐ Chemical Manuf SO2 48 TX Industrial Processes ‐ Ferrous Metals SO2 48 TX Industrial Processes ‐ NEC SO2 48 TX Industrial Processes ‐ Non

‐ ferrous Metals SO2 48 TX Industrial Processes ‐ Oil & Gas Production SO2 48 TX Industrial Processes ‐ Petroleum Refineries SO2 48 TX Industrial Processes ‐ Pulp & Paper SO2 48 TX Industrial Processes ‐ Storage and Transfer SO2 48 TX Miscellaneous Non

‐ Industrial NEC SO2 48 TX Mobile ‐ Aircraft SO2 48 TX Mobile ‐ Commercial Marine Vessels SO2 48 TX Mobile ‐ Locomotives SO2 48 TX Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 48 TX Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 48 TX Mobile ‐ Non

‐ Road Equipment ‐ Other SO248 TX Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 48 TX Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 48 TX Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 48 TX Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 48 TX Solvent ‐ Degreasing SO2 48 TX Solvent ‐ Graphic Arts SO2 48 TX Solvent ‐ Industrial Surface Coating & Solvent Use SO2 48 TX Waste Disposal SO2 49 UT Fires ‐ Agricultural Field Burnin g SO2 49 UT Fires ‐ Prescribed Fires SO2 49 UT Fires ‐ Wildfires SO2 49 UT Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 49 UT Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 49 UT Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 49 UT Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 49 UT Fuel Comb ‐ Comm/Institutional ‐ Other SO2 49 UT Fuel Comb ‐ Electric Generation ‐ Coal SO2 49 UT Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 49 UT Fuel Comb ‐ Electric Generation ‐ Oil SO2 49 UT Fuel Comb ‐ Electric Generation ‐ Other SO2 49 UT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 49 UT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 49 UT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 49 UT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 49 UT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 49 UT Fuel Comb ‐ Residential ‐ Natural Gas SO2 49 UT Fuel Comb ‐ Residential ‐ Oil SO2 49 UT Fuel Comb ‐ Residential ‐ Other SO2 49 UT Fuel Comb ‐ Residential ‐ Wood SO2 49 UT Gas Stations SO2 49 UT Industrial Processes ‐ Cement Manuf SO2 49 UT Industrial Processes ‐ Chemical Manuf SO2 49 UT Industrial Processes ‐ Ferrous Metals SO2 49 UT Industrial Processes ‐ Mining SO2 49 UT Industrial Processes ‐ NEC SO2 49 UT Industrial Processes ‐ Non

‐ ferrous Metals SO2 49 UT Industrial Processes ‐ Oil & Gas Production SO2 49 UT Industrial Processes ‐ Petroleum Refineries SO2 49 UT Industrial Processes ‐ Pulp & Paper SO2 49 UT Industrial Processes ‐ Storage and Transfer SO2 49 UT Miscellaneous Non

‐ Industrial NEC SO2 49 UT Mobile ‐ Aircraft SO2 49 UT Mobile ‐ Locomotives SO2 49 UT Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 49 UT Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 49 UT Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 49 UT Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO249 UT Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 49 UT Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 49 UT Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 49 UT Solvent ‐ Degreasing SO2 49 UT Solvent ‐ Industrial Surface Coating & Solvent Use SO2 49 UT Waste Disposal SO2 50 VT Fires ‐ Agricultural Field Burnin g SO2 50 VT Fires ‐ Prescribed Fires SO2 50 VT Fires ‐ Wildfires SO2 50 VT Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 50 VT Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 50 VT Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 50 VT Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 50 VT Fuel Comb ‐ Comm/Institutional ‐ Other SO2 50 VT Fuel Comb ‐ Electric Generation ‐ Biomass SO2 50 VT Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 50 VT Fuel Comb ‐ Electric Generation ‐ Oil SO2 50 VT Fuel Comb ‐ Electric Generation ‐ Other SO2 50 VT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 50 VT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 50 VT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 50 VT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 50 VT Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 50 VT Fuel Comb ‐ Residential ‐ Natural Gas SO2 50 VT Fuel Comb ‐ Residential ‐ Oil SO2 50 VT Fuel Comb ‐ Residential ‐ Other SO2 50 VT Fuel Comb ‐ Residential ‐ Wood SO2 50 VT Industrial Processes ‐ NEC SO2 50 VT Industrial Processes ‐ Pulp & Paper SO2 50 VT Miscellaneous Non

‐ Industrial NEC SO2 50 VT Mobile ‐ Aircraft SO2 50 VT Mobile ‐ Locomotives SO2 50 VT Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 50 VT Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 50 VT Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 50 VT Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 50 VT Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 50 VT Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 50 VT Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 50 VT Solvent ‐ Industrial Surface Coating & Solvent Use SO2 50 VT Waste Disposal SO2 51 VA Fires ‐ Agricultural Field Burnin g SO2 51 VA Fires ‐ Prescribed Fires SO2 51 VA Fires ‐ Wildfires SO2 51 VA Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 51 VA Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 51 VA Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO251 VA Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 51 VA Fuel Comb ‐ Comm/Institutional ‐ Other SO2 51 VA Fuel Comb ‐ Electric Generation ‐ Biomass SO2 51 VA Fuel Comb ‐ Electric Generation ‐ Coal SO2 51 VA Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 51 VA Fuel Comb ‐ Electric Generation ‐ Oil SO2 51 VA Fuel Comb ‐ Electric Generation ‐ Other SO2 51 VA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 51 VA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 51 VA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 51 VA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 51 VA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 51 VA Fuel Comb ‐ Residential ‐ Natural Gas SO2 51 VA Fuel Comb ‐ Residential ‐ Oil SO2 51 VA Fuel Comb ‐ Residential ‐ Other SO2 51 VA Fuel Comb ‐ Residential ‐ Wood SO2 51 VA Industrial Processes ‐ Cement Manuf SO2 51 VA Industrial Processes ‐ Chemical Manuf SO2 51 VA Industrial Processes ‐ Ferrous Metals SO2 51 VA Industrial Processes ‐ Mining SO2 51 VA Industrial Processes ‐ NEC SO2 51 VA Industrial Processes ‐ Non

‐ ferrous Metals SO2 51 VA Industrial Processes ‐ Oil & Gas Production SO2 51 VA Industrial Processes ‐ Petroleum Refineries SO2 51 VA Industrial Processes ‐ Pulp & Paper SO2 51 VA Industrial Processes ‐ Storage and Transfer SO2 51 VA Miscellaneous Non

‐ Industrial NEC SO2 51 VA Mobile ‐ Aircraft SO2 51 VA Mobile ‐ Commercial Marine Vessels SO2 51 VA Mobile ‐ Locomotives SO2 51 VA Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 51 VA Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 51 VA Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 51 VA Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 51 VA Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 51 VA Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 51 VA Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 51 VA Solvent ‐ Industrial Surface Coating & Solvent Use SO2 51 VA Waste Disposal SO2 53 WA Bulk Gasoline Terminals SO2 53 WA Fires ‐ Agricultural Field Burnin g SO2 53 WA Fires ‐ Prescribed Fires SO2 53 WA Fires ‐ Wildfires SO2 53 WA Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 53 WA Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 53 WA Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 53 WA Fuel Comb ‐ Comm/Institutional ‐ Other SO253 WA Fuel Comb ‐ Electric Generation ‐ Biomass SO2 53 WA Fuel Comb ‐ Electric Generation ‐ Coal SO2 53 WA Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 53 WA Fuel Comb ‐ Electric Generation ‐ Oil SO2 53 WA Fuel Comb ‐ Electric Generation ‐ Other SO2 53 WA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 53 WA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 53 WA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 53 WA Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 53 WA Fuel Comb ‐ Residential ‐ Natural Gas SO2 53 WA Fuel Comb ‐ Residential ‐ Oil SO2 53 WA Fuel Comb ‐ Residential ‐ Other SO2 53 WA Fuel Comb ‐ Residential ‐ Wood SO2 53 WA Industrial Processes ‐ Cement Manuf SO2 53 WA Industrial Processes ‐ Chemical Manuf SO2 53 WA Industrial Processes ‐ Ferrous Metals SO2 53 WA Industrial Processes ‐ NEC SO2 53 WA Industrial Processes ‐ Non

‐ ferrous Metals SO2 53 WA Industrial Processes ‐ Petroleum Refineries SO2 53 WA Industrial Processes ‐ Pulp & Paper SO2 53 WA Industrial Processes ‐ Storage and Transfer SO2 53 WA Miscellaneous Non

‐ Industrial NEC SO2 53 WA Mobile ‐ Aircraft SO2 53 WA Mobile ‐ Commercial Marine Vessels SO2 53 WA Mobile ‐ Locomotives SO2 53 WA Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 53 WA Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 53 WA Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 53 WA Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 53 WA Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 53 WA Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 53 WA Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 53 WA Solvent ‐ Industrial Surface Coating & Solvent Use SO2 53 WA Waste Disposal SO2 54 WV Commercial Cooking SO2 54 WV Fires ‐ Agricultural Field Burnin g SO2 54 WV Fires ‐ Prescribed Fires SO2 54 WV Fires ‐ Wildfires SO2 54 WV Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 54 WV Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 54 WV Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 54 WV Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 54 WV Fuel Comb ‐ Comm/Institutional ‐ Other SO2 54 WV Fuel Comb ‐ Electric Generation ‐ Coal SO2 54 WV Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 54 WV Fuel Comb ‐ Electric Generation ‐ Oil SO2 54 WV Fuel Comb ‐ Electric Generation ‐ Other SO254 WV Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 54 WV Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 54 WV Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 54 WV Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 54 WV Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 54 WV Fuel Comb ‐ Residential ‐ Natural Gas SO2 54 WV Fuel Comb ‐ Residential ‐ Oil SO2 54 WV Fuel Comb ‐ Residential ‐ Other SO2 54 WV Fuel Comb ‐ Residential ‐ Wood SO2 54 WV Industrial Processes ‐ Cement Manuf SO2 54 WV Industrial Processes ‐ Chemical Manuf SO2 54 WV Industrial Processes ‐ Ferrous Metals SO2 54 WV Industrial Processes ‐ Mining SO2 54 WV Industrial Processes ‐ NEC SO2 54 WV Industrial Processes ‐ Non

‐ ferrous Metals SO2 54 WV Industrial Processes ‐ Oil & Gas Production SO2 54 WV Industrial Processes ‐ Petroleum Refineries SO2 54 WV Industrial Processes ‐ Pulp & Paper SO2 54 WV Industrial Processes ‐ Storage and Transfer SO2 54 WV Miscellaneous Non

‐ Industrial NEC SO2 54 WV Mobile ‐ Aircraft SO2 54 WV Mobile ‐ Commercial Marine Vessels SO2 54 WV Mobile ‐ Locomotives SO2 54 WV Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 54 WV Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 54 WV Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 54 WV Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 54 WV Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 54 WV Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 54 WV Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 54 WV Solvent ‐ Industrial Surface Coating & Solvent Use SO2 54 WV Waste Disposal SO2 55 WI Fires ‐ Agricultural Field Burnin g SO2 55 WI Fires ‐ Prescribed Fires SO2 55 WI Fires ‐ Wildfires SO2 55 WI Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 55 WI Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 55 WI Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 55 WI Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 55 WI Fuel Comb ‐ Comm/Institutional ‐ Other SO2 55 WI Fuel Comb ‐ Electric Generation ‐ Biomass SO2 55 WI Fuel Comb ‐ Electric Generation ‐ Coal SO2 55 WI Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 55 WI Fuel Comb ‐ Electric Generation ‐ Oil SO2 55 WI Fuel Comb ‐ Electric Generation ‐ Other SO2 55 WI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 55 WI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO255 WI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 55 WI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 55 WI Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 55 WI Fuel Comb ‐ Residential ‐ Natural Gas SO2 55 WI Fuel Comb ‐ Residential ‐ Oil SO2 55 WI Fuel Comb ‐ Residential ‐ Other SO2 55 WI Fuel Comb ‐ Residential ‐ Wood SO2 55 WI Industrial Processes ‐ Chemical Manuf SO2 55 WI Industrial Processes ‐ Ferrous Metals SO2 55 WI Industrial Processes ‐ Mining SO2 55 WI Industrial Processes ‐ NEC SO2 55 WI Industrial Processes ‐ Non

‐ ferrous Metals SO2 55 WI Industrial Processes ‐ Oil & Gas Production SO2 55 WI Industrial Processes ‐ Petroleum Refineries SO2 55 WI Industrial Processes ‐ Pulp & Paper SO2 55 WI Industrial Processes ‐ Storage and Transfer SO2 55 WI Miscellaneous Non

‐ Industrial NEC SO2 55 WI Mobile ‐ Aircraft SO2 55 WI Mobile ‐ Commercial Marine Vessels SO2 55 WI Mobile ‐ Locomotives SO2 55 WI Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 55 WI Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 55 WI Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 55 WI Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 55 WI Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 55 WI Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 55 WI Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 55 WI Solvent ‐ Industrial Surface Coating & Solvent Use SO2 55 WI Waste Disposal SO2 56 WY Bulk Gasoline Terminals SO2 56 WY Fires ‐ Agricultural Field Burnin g SO2 56 WY Fires ‐ Prescribed Fires SO2 56 WY Fires ‐ Wildfires SO2 56 WY Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 56 WY Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 56 WY Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 56 WY Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 56 WY Fuel Comb ‐ Electric Generation ‐ Coal SO2 56 WY Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 56 WY Fuel Comb ‐ Electric Generation ‐ Oil SO2 56 WY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 56 WY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 56 WY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 56 WY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 56 WY Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 56 WY Fuel Comb ‐ Residential ‐ Natural Gas SO2 56 WY Fuel Comb ‐ Residential ‐ Oil SO256 WY Fuel Comb ‐ Residential ‐ Other SO2 56 WY Fuel Comb ‐ Residential ‐ Wood SO2 56 WY Industrial Processes ‐ Cement Manuf SO2 56 WY Industrial Processes ‐ Chemical Manuf SO2 56 WY Industrial Processes ‐ Mining SO2 56 WY Industrial Processes ‐ NEC SO2 56 WY Industrial Processes ‐ Oil & Gas Production SO2 56 WY Industrial Processes ‐ Petroleum Refineries SO2 56 WY Industrial Processes ‐ Storage and Transfer SO2 56 WY Miscellaneous Non

‐ Industrial NEC SO2 56 WY Mobile ‐ Aircraft SO2 56 WY Mobile ‐ Locomotives SO2 56 WY Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 56 WY Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 56 WY Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 56 WY Mobile ‐ On

‐ Road Diesel Heavy Duty Vehicles SO2 56 WY Mobile ‐ On

‐ Road Diesel Light Duty Vehicles SO2 56 WY Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 56 WY Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 56 WY Waste Disposal SO2 72 PR Fires ‐ Prescribed Fires SO2 72 PR Fires ‐ Wildfires SO2 72 PR Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 72 PR Fuel Comb ‐ Comm/Institutional ‐ Other SO2 72 PR Fuel Comb ‐ Electric Generation ‐ Coal SO2 72 PR Fuel Comb ‐ Electric Generation ‐ Natural Gas SO2 72 PR Fuel Comb ‐ Electric Generation ‐ Oil SO2 72 PR Fuel Comb ‐ Electric Generation ‐ Other SO2 72 PR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 72 PR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 72 PR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 72 PR Industrial Processes ‐ Cement Manuf SO2 72 PR Industrial Processes ‐ Mining SO2 72 PR Industrial Processes ‐ NEC SO2 72 PR Industrial Processes ‐ Non

‐ ferrous Metals SO2 72 PR Industrial Processes ‐ Storage and Transfer SO2 72 PR Miscellaneous Non

‐ Industrial NEC SO2 72 PR Mobile ‐ Aircraft SO2 72 PR Mobile ‐ Commercial Marine Vessels SO2 72 PR Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 72 PR Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 72 PR Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 72 PR Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 72 PR Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 72 PR Solvent ‐ Degreasing SO2 72 PR Solvent ‐ Industrial Surface Coating & Solvent Use SO2 72 PR Waste Disposal SO278 VI Miscellaneous Non

‐ Industrial NEC SO2 78 VI Mobile ‐ Aircraft SO2 78 VI Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 78 VI Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 78 VI Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 78 VI Mobile ‐ On

‐ Road Gasoline Heavy Duty Vehicles SO2 78 VI Mobile ‐ On

‐ Road Gasoline Light Duty Vehicles SO2 78 VI Waste Disposal SO2 88 TR Fires ‐ Agricultural Field Burnin g SO2 88 TR Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2 88 TR Fuel Comb ‐ Comm/Institutional ‐ Coal SO2 88 TR Fuel Comb ‐ Comm/Institutional ‐ Natural Gas SO2 88 TR Fuel Comb ‐ Comm/Institutional ‐ Oil SO2 88 TR Fuel Comb ‐ Comm/Institutional ‐ Other SO2 88 TR Fuel Comb ‐ Electric Generation ‐ Coal SO2 88 TR Fuel Comb ‐ Electric Generation ‐ Oil SO2 88 TR Fuel Comb ‐ Electric Generation ‐ Other SO2 88 TR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Biomass SO2 88 TR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Coal SO2 88 TR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Natural Gas SO2 88 TR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Oil SO2 88 TR Fuel Comb ‐ Industrial Boilers, ICEs ‐ Other SO2 88 TR Fuel Comb ‐ Residential ‐ Natural Gas SO2 88 TR Fuel Comb ‐ Residential ‐ Oil SO2 88 TR Fuel Comb ‐ Residential ‐ Other SO2 88 TR Fuel Comb ‐ Residential ‐ Wood SO2 88 TR Industrial Processes ‐ NEC SO2 88 TR Industrial Processes ‐ Oil & Gas Production SO2 88 TR Industrial Processes ‐ Petroleum Refineries SO2 88 TR Miscellaneous Non

‐ Industrial NEC SO2 88 TR Mobile ‐ Aircraft SO2 88 TR Mobile ‐ Locomotives SO2 88 TR Mobile ‐ Non

‐ Road Equipment ‐ Diesel SO2 88 TR Mobile ‐ Non

‐ Road Equipment ‐ Gasoline SO2 88 TR Mobile ‐ Non

‐ Road Equipment ‐ Other SO2 88 TR Waste Disposal SO2POLLUTANT_NAME UOM INVENTORY_YEAR EMISSIONS Sulfur Dioxide TON 2011 66.36189141 Sulfur Dioxide TON 2011 5481.984733 Sulfur Dioxide TON 2011 1194.676111 Sulfur Dioxide TON 2011 9.78 Sulfur Dioxide TON 2011 226.55 Sulfur Dioxide TON 2011 19.894019 Sulfur Dioxide TON 2011 1.9662 Sulfur Dioxide TON 2011 0.01444 Sulfur Dioxide TON 2011 8.33 Sulfur Dioxide TON 2011 179208.632 Sulfur Dioxide TON 2011 83.101 Sulfur Dioxide TON 2011 27.023175 Sulfur Dioxide TON 2011 3070.803 Sulfur Dioxide TON 2011 8778.754 Sulfur Dioxide TON 2011 734.86545 Sulfur Dioxide TON 2011 456.9749 Sulfur Dioxide TON 2011 2815.37572 Sulfur Dioxide TON 2011 10.79969267 Sulfur Dioxide TON 2011 99.233082 Sulfur Dioxide TON 2011 2.426534 Sulfur Dioxide TON 2011 23.16803638 Sulfur Dioxide TON 2011 0.86759 Sulfur Dioxide TON 2011 497.638 Sulfur Dioxide TON 2011 6571.4846 Sulfur Dioxide TON 2011 3074.02508 Sulfur Dioxide TON 2011 4.32749 Sulfur Dioxide TON 2011 6448.532926 Sulfur Dioxide TON 2011 8145.22582 Sulfur Dioxide TON 2011 20150.94952 Sulfur Dioxide TON 2011 471.25448 Sulfur Dioxide TON 2011 4936.842 Sulfur Dioxide TON 2011 0.902999999 Sulfur Dioxide TON 2011 2.48417 Sulfur Dioxide TON 2011 75.38163189 Sulfur Dioxide TON 2011 319.7463068 Sulfur Dioxide TON 2011 167.946697 Sulfur Dioxide TON 2011 39.95972987 Sulfur Dioxide TON 2011 19.2364191 Sulfur Dioxide TON 2011 8.556274265 Sulfur Dioxide TON 2011 115.6113672 Sulfur Dioxide TON 2011 2.979969521 Sulfur Dioxide TON 2011 30.22243041 Sulfur Dioxide TON 2011 540.7413257 Sulfur Dioxide TON 2011 0.59454 Sulfur Dioxide TON 2011 174.7176165 Sulfur Dioxide TON 2011 0.13Sulfur Dioxide TON 2011 202.944822 Sulfur Dioxide TON 2011 13094.78661 Sulfur Dioxide TON 2011 1.88749934 Sulfur Dioxide TON 2011 194.6 Sulfur Dioxide TON 2011 8.04 Sulfur Dioxide TON 2011 62.38959538 Sulfur Dioxide TON 2011 2.25 Sulfur Dioxide TON 2011 1785.29 Sulfur Dioxide TON 2011 358.76 Sulfur Dioxide TON 2011 916.496 Sulfur Dioxide TON 2011 0.349999733 Sulfur Dioxide TON 2011 714 Sulfur Dioxide TON 2011 987.95 Sulfur Dioxide TON 2011 198.9428207 Sulfur Dioxide TON 2011 0.19 Sulfur Dioxide TON 2011 5.993403365 Sulfur Dioxide TON 2011 1387.766723 Sulfur Dioxide TON 2011 293.3686166 Sulfur Dioxide TON 2011 16.40769619 Sulfur Dioxide TON 2011 3.75 Sulfur Dioxide TON 2011 22.87 Sulfur Dioxide TON 2011 1.14 Sulfur Dioxide TON 2011 506.4314522 Sulfur Dioxide TON 2011 29.31 Sulfur Dioxide TON 2011 0.04 Sulfur Dioxide TON 2011 0.21122721 Sulfur Dioxide TON 2011 428.748041 Sulfur Dioxide TON 2011 6286.635057 Sulfur Dioxide TON 2011 3.897001962 Sulfur Dioxide TON 2011 47.18958201 Sulfur Dioxide TON 2011 6.767793237 Sulfur Dioxide TON 2011 7.097440578 Sulfur Dioxide TON 2011 6.01868492 Sulfur Dioxide TON 2011 0.481150399 Sulfur Dioxide TON 2011 3.404126299 Sulfur Dioxide TON 2011 40.35096708 Sulfur Dioxide TON 2011 24.33784926 Sulfur Dioxide TON 2011 142.7601632 Sulfur Dioxide TON 2011 611.92122 Sulfur Dioxide TON 2011 10847.04578 Sulfur Dioxide TON 2011 19.48799845 Sulfur Dioxide TON 2011 5.502617882 Sulfur Dioxide TON 2011 1.038490094 Sulfur Dioxide TON 2011 0.032505459 Sulfur Dioxide TON 2011 66.2339 Sulfur Dioxide TON 2011 26238.97 Sulfur Dioxide TON 2011 63.98497718Sulfur Dioxide TON 2011 12.88594802 Sulfur Dioxide TON 2011 0.052767007 Sulfur Dioxide TON 2011 0.0004 Sulfur Dioxide TON 2011 2895.45 Sulfur Dioxide TON 2011 14.61044444 Sulfur Dioxide TON 2011 7.253595191 Sulfur Dioxide TON 2011 0.376369031 Sulfur Dioxide TON 2011 11.0617048 Sulfur Dioxide TON 2011 3.333563322 Sulfur Dioxide TON 2011 1.51799273 Sulfur Dioxide TON 2011 50.63566195 Sulfur Dioxide TON 2011 9.624046 Sulfur Dioxide TON 2011 0.5218 Sulfur Dioxide TON 2011 27.8145 Sulfur Dioxide TON 2011 74.048463 Sulfur Dioxide TON 2011 2588.315886 Sulfur Dioxide TON 2011 31874.22161 Sulfur Dioxide TON 2011 0.042360572 Sulfur Dioxide TON 2011 0.002626092 Sulfur Dioxide TON 2011 0.251030798 Sulfur Dioxide TON 2011 12.8402634 Sulfur Dioxide TON 2011 350.4092305 Sulfur Dioxide TON 2011 375.4702239 Sulfur Dioxide TON 2011 62.49788272 Sulfur Dioxide TON 2011 13.69873352 Sulfur Dioxide TON 2011 16.11569237 Sulfur Dioxide TON 2011 114.8558623 Sulfur Dioxide TON 2011 2.719009957 Sulfur Dioxide TON 2011 17.91319457 Sulfur Dioxide TON 2011 304.2456877 Sulfur Dioxide TON 2011 0.007515 Sulfur Dioxide TON 2011 97.91917661 Sulfur Dioxide TON 2011 1721.087302 Sulfur Dioxide TON 2011 4961.881102 Sulfur Dioxide TON 2011 887.559348 Sulfur Dioxide TON 2011 7.11717 Sulfur Dioxide TON 2011 13.9024609 Sulfur Dioxide TON 2011 0.148524737 Sulfur Dioxide TON 2011 0.003808086 Sulfur Dioxide TON 2011 3.57424 Sulfur Dioxide TON 2011 58439.4 Sulfur Dioxide TON 2011 31.39673968 Sulfur Dioxide TON 2011 66.02704125 Sulfur Dioxide TON 2011 87.15 Sulfur Dioxide TON 2011 1855.400682 Sulfur Dioxide TON 2011 18501.1 Sulfur Dioxide TON 2011 35.84627569Sulfur Dioxide TON 2011 4.81839198 Sulfur Dioxide TON 2011 162.3157011 Sulfur Dioxide TON 2011 9.975594785 Sulfur Dioxide TON 2011 7.6598448 Sulfur Dioxide TON 2011 2.11492153 Sulfur Dioxide TON 2011 20.11159866 Sulfur Dioxide TON 2011 440 Sulfur Dioxide TON 2011 274.2106429 Sulfur Dioxide TON 2011 827.4443962 Sulfur Dioxide TON 2011 1.28 Sulfur Dioxide TON 2011 1677.382475 Sulfur Dioxide TON 2011 0.9896754 Sulfur Dioxide TON 2011 273.3310324 Sulfur Dioxide TON 2011 42.37450647 Sulfur Dioxide TON 2011 2100.508671 Sulfur Dioxide TON 2011 6.6164 Sulfur Dioxide TON 2011 1.777510745 Sulfur Dioxide TON 2011 50.12989423 Sulfur Dioxide TON 2011 22.81107275 Sulfur Dioxide TON 2011 188.4740978 Sulfur Dioxide TON 2011 40.96715796 Sulfur Dioxide TON 2011 12.08301811 Sulfur Dioxide TON 2011 5.948204094 Sulfur Dioxide TON 2011 81.91662232 Sulfur Dioxide TON 2011 1.444028779 Sulfur Dioxide TON 2011 14.30850501 Sulfur Dioxide TON 2011 259.6324108 Sulfur Dioxide TON 2011 0.0116204 Sulfur Dioxide TON 2011 1.1232456 Sulfur Dioxide TON 2011 87.74540119 Sulfur Dioxide TON 2011 8.453339685 Sulfur Dioxide TON 2011 0.261922592 Sulfur Dioxide TON 2011 204.2870159 Sulfur Dioxide TON 2011 2161.633093 Sulfur Dioxide TON 2011 5784.578207 Sulfur Dioxide TON 2011 52.98847615 Sulfur Dioxide TON 2011 18.0000525 Sulfur Dioxide TON 2011 496.3541642 Sulfur Dioxide TON 2011 243.8672361 Sulfur Dioxide TON 2011 394.065823 Sulfur Dioxide TON 2011 155.9529785 Sulfur Dioxide TON 2011 665.36658 Sulfur Dioxide TON 2011 229.4019173 Sulfur Dioxide TON 2011 105.8261222 Sulfur Dioxide TON 2011 675.181769 Sulfur Dioxide TON 2011 147.049143 Sulfur Dioxide TON 2011 164.1416016Sulfur Dioxide TON 2011 556.6632318 Sulfur Dioxide TON 2011 1056.504468 Sulfur Dioxide TON 2011 1446.225746 Sulfur Dioxide TON 2011 171.9668432 Sulfur Dioxide TON 2011 787.2208026 Sulfur Dioxide TON 2011 68.91808341 Sulfur Dioxide TON 2011 349.663534 Sulfur Dioxide TON 2011 1063.16556 Sulfur Dioxide TON 2011 1382.665981 Sulfur Dioxide TON 2011 12.067 Sulfur Dioxide TON 2011 54.6453204 Sulfur Dioxide TON 2011 5220.89347 Sulfur Dioxide TON 2011 30.70097283 Sulfur Dioxide TON 2011 1131.883596 Sulfur Dioxide TON 2011 6705.524693 Sulfur Dioxide TON 2011 0.378193084 Sulfur Dioxide TON 2011 344.9760965 Sulfur Dioxide TON 2011 4.190052851 Sulfur Dioxide TON 2011 1484.031464 Sulfur Dioxide TON 2011 1663.364876 Sulfur Dioxide TON 2011 70.46175258 Sulfur Dioxide TON 2011 87.03192465 Sulfur Dioxide TON 2011 59.90847097 Sulfur Dioxide TON 2011 48.06996352 Sulfur Dioxide TON 2011 333.2419562 Sulfur Dioxide TON 2011 2.336 Sulfur Dioxide TON 2011 121.618 Sulfur Dioxide TON 2011 1519.714 Sulfur Dioxide TON 2011 0.01 Sulfur Dioxide TON 2011 55.60416649 Sulfur Dioxide TON 2011 333.0934285 Sulfur Dioxide TON 2011 614.9973635 Sulfur Dioxide TON 2011 1975.981795 Sulfur Dioxide TON 2011 725.987542 Sulfur Dioxide TON 2011 14.74780048 Sulfur Dioxide TON 2011 91.71 Sulfur Dioxide TON 2011 93.434736 Sulfur Dioxide TON 2011 77.218756 Sulfur Dioxide TON 2011 122.742333 Sulfur Dioxide TON 2011 44645.63 Sulfur Dioxide TON 2011 37.503375 Sulfur Dioxide TON 2011 63.464249 Sulfur Dioxide TON 2011 0.147939 Sulfur Dioxide TON 2011 0.37 Sulfur Dioxide TON 2011 2164.455266 Sulfur Dioxide TON 2011 327.519638 Sulfur Dioxide TON 2011 282.236361Sulfur Dioxide TON 2011 11.731041 Sulfur Dioxide TON 2011 38.69790136 Sulfur Dioxide TON 2011 16.60419889 Sulfur Dioxide TON 2011 277.4568823 Sulfur Dioxide TON 2011 144.452871 Sulfur Dioxide TON 2011 265.3 Sulfur Dioxide TON 2011 99.7125 Sulfur Dioxide TON 2011 75.924633 Sulfur Dioxide TON 2011 37.3 Sulfur Dioxide TON 2011 1661.78815 Sulfur Dioxide TON 2011 1.413815 Sulfur Dioxide TON 2011 1761.382969 Sulfur Dioxide TON 2011 136.122581 Sulfur Dioxide TON 2011 8.28 Sulfur Dioxide TON 2011 4.2272 Sulfur Dioxide TON 2011 0.107233797 Sulfur Dioxide TON 2011 374.1028882 Sulfur Dioxide TON 2011 162.6219909 Sulfur Dioxide TON 2011 57.10390956 Sulfur Dioxide TON 2011 19.33121615 Sulfur Dioxide TON 2011 19.20416244 Sulfur Dioxide TON 2011 54.13324535 Sulfur Dioxide TON 2011 2.143469764 Sulfur Dioxide TON 2011 20.18505839 Sulfur Dioxide TON 2011 402.3247749 Sulfur Dioxide TON 2011 0.001185 Sulfur Dioxide TON 2011 4.149664 Sulfur Dioxide TON 2011 139.206769 Sulfur Dioxide TON 2011 0.8159275 Sulfur Dioxide TON 2011 1.50757 Sulfur Dioxide TON 2011 3.975971 Sulfur Dioxide TON 2011 5.0750015 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 15.85045188 Sulfur Dioxide TON 2011 830.2565209 Sulfur Dioxide TON 2011 0.557846461 Sulfur Dioxide TON 2011 585.1583 Sulfur Dioxide TON 2011 31.75969155 Sulfur Dioxide TON 2011 237.6173833 Sulfur Dioxide TON 2011 66.873983 Sulfur Dioxide TON 2011 39.16247 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 18.65677322 Sulfur Dioxide TON 2011 293.3103145 Sulfur Dioxide TON 2011 0.800926054 Sulfur Dioxide TON 2011 13.198507 Sulfur Dioxide TON 2011 11436.94937Sulfur Dioxide TON 2011 1.9555044 Sulfur Dioxide TON 2011 124.955816 Sulfur Dioxide TON 2011 6.792371947 Sulfur Dioxide TON 2011 1.7463995 Sulfur Dioxide TON 2011 52.21927104 Sulfur Dioxide TON 2011 454.4127705 Sulfur Dioxide TON 2011 11.12094157 Sulfur Dioxide TON 2011 22.24338414 Sulfur Dioxide TON 2011 11.07919372 Sulfur Dioxide TON 2011 6.759716248 Sulfur Dioxide TON 2011 19.29409257 Sulfur Dioxide TON 2011 1.458620051 Sulfur Dioxide TON 2011 10.70029834 Sulfur Dioxide TON 2011 250.9749411 Sulfur Dioxide TON 2011 236.2094725 Sulfur Dioxide TON 2011 8.145029 Sulfur Dioxide TON 2011 30.246139 Sulfur Dioxide TON 2011 1.2124985 Sulfur Dioxide TON 2011 0.129568 Sulfur Dioxide TON 2011 2.6377731 Sulfur Dioxide TON 2011 15.23785015 Sulfur Dioxide TON 2011 0.3840713 Sulfur Dioxide TON 2011 9194.4 Sulfur Dioxide TON 2011 91.4534 Sulfur Dioxide TON 2011 4.73832451 Sulfur Dioxide TON 2011 61.558 Sulfur Dioxide TON 2011 0.325 Sulfur Dioxide TON 2011 1273.92 Sulfur Dioxide TON 2011 26.5082367 Sulfur Dioxide TON 2011 588.0674597 Sulfur Dioxide TON 2011 186.8499283 Sulfur Dioxide TON 2011 2.962502 Sulfur Dioxide TON 2011 541.21462 Sulfur Dioxide TON 2011 0.836893 Sulfur Dioxide TON 2011 17.83448322 Sulfur Dioxide TON 2011 76.88794572 Sulfur Dioxide TON 2011 41.84 Sulfur Dioxide TON 2011 3.843417503 Sulfur Dioxide TON 2011 0.3651984 Sulfur Dioxide TON 2011 105.5920745 Sulfur Dioxide TON 2011 6.807457 Sulfur Dioxide TON 2011 0.462298 Sulfur Dioxide TON 2011 3.128552799 Sulfur Dioxide TON 2011 1980.061293 Sulfur Dioxide TON 2011 4.23821383 Sulfur Dioxide TON 2011 7.193759243 Sulfur Dioxide TON 2011 3.832134191Sulfur Dioxide TON 2011 0.921603945 Sulfur Dioxide TON 2011 9.465521935 Sulfur Dioxide TON 2011 0.472397863 Sulfur Dioxide TON 2011 3.72987493 Sulfur Dioxide TON 2011 72.57004177 Sulfur Dioxide TON 2011 0.0200921 Sulfur Dioxide TON 2011 25.68369788 Sulfur Dioxide TON 2011 0.075 Sulfur Dioxide TON 2011 42.64106 Sulfur Dioxide TON 2011 4.79523625 Sulfur Dioxide TON 2011 375.0271737 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 729.61822 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.91581632 Sulfur Dioxide TON 2011 7.3116605 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 4.2 Sulfur Dioxide TON 2011 603.57 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 9.93934181 Sulfur Dioxide TON 2011 0.904466 Sulfur Dioxide TON 2011 0.3116555 Sulfur Dioxide TON 2011 0.02339391 Sulfur Dioxide TON 2011 0.38675393 Sulfur Dioxide TON 2011 2.029831162 Sulfur Dioxide TON 2011 5.254014287 Sulfur Dioxide TON 2011 0.757026945 Sulfur Dioxide TON 2011 0.195673103 Sulfur Dioxide TON 2011 2.861262866 Sulfur Dioxide TON 2011 0.21158033 Sulfur Dioxide TON 2011 1.831798 Sulfur Dioxide TON 2011 39.65092115 Sulfur Dioxide TON 2011 746.8296966 Sulfur Dioxide TON 2011 7630.661681 Sulfur Dioxide TON 2011 2084.021218 Sulfur Dioxide TON 2011 8.048895345 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 18.10359575 Sulfur Dioxide TON 2011 931.3756696 Sulfur Dioxide TON 2011 92.61115706 Sulfur Dioxide TON 2011 100.2055 Sulfur Dioxide TON 2011 84252.206 Sulfur Dioxide TON 2011 584.053953 Sulfur Dioxide TON 2011 5964.357713 Sulfur Dioxide TON 2011 4185.955028 Sulfur Dioxide TON 2011 2500.335481Sulfur Dioxide TON 2011 15619.08019 Sulfur Dioxide TON 2011 942.0764985 Sulfur Dioxide TON 2011 7324.573803 Sulfur Dioxide TON 2011 971.7330887 Sulfur Dioxide TON 2011 4.564200616 Sulfur Dioxide TON 2011 50.15997842 Sulfur Dioxide TON 2011 2.86753472 Sulfur Dioxide TON 2011 53.77363134 Sulfur Dioxide TON 2011 57.842553 Sulfur Dioxide TON 2011 21955.17368 Sulfur Dioxide TON 2011 31.024003 Sulfur Dioxide TON 2011 931.838191 Sulfur Dioxide TON 2011 500.226938 Sulfur Dioxide TON 2011 9.693082705 Sulfur Dioxide TON 2011 0.022702 Sulfur Dioxide TON 2011 3913.41171 Sulfur Dioxide TON 2011 29.130705 Sulfur Dioxide TON 2011 10.35019922 Sulfur Dioxide TON 2011 1116.991753 Sulfur Dioxide TON 2011 7276.741576 Sulfur Dioxide TON 2011 88.61706627 Sulfur Dioxide TON 2011 190.2837463 Sulfur Dioxide TON 2011 86.64654598 Sulfur Dioxide TON 2011 44.39896948 Sulfur Dioxide TON 2011 210.2781298 Sulfur Dioxide TON 2011 9.344343452 Sulfur Dioxide TON 2011 86.4254728 Sulfur Dioxide TON 2011 1758.375947 Sulfur Dioxide TON 2011 0.123705 Sulfur Dioxide TON 2011 1244.822105 Sulfur Dioxide TON 2011 735.7014741 Sulfur Dioxide TON 2011 3744.999069 Sulfur Dioxide TON 2011 6917.759337 Sulfur Dioxide TON 2011 286.93 Sulfur Dioxide TON 2011 4094.3 Sulfur Dioxide TON 2011 14.50056862 Sulfur Dioxide TON 2011 115.3294372 Sulfur Dioxide TON 2011 0.514833106 Sulfur Dioxide TON 2011 82.1789 Sulfur Dioxide TON 2011 187739.331 Sulfur Dioxide TON 2011 49.8525 Sulfur Dioxide TON 2011 135.8731 Sulfur Dioxide TON 2011 1.3205 Sulfur Dioxide TON 2011 1213.531 Sulfur Dioxide TON 2011 9855.477 Sulfur Dioxide TON 2011 2216.478 Sulfur Dioxide TON 2011 4554.723975Sulfur Dioxide TON 2011 2964.620565 Sulfur Dioxide TON 2011 35.57668465 Sulfur Dioxide TON 2011 54.52507639 Sulfur Dioxide TON 2011 18.02443628 Sulfur Dioxide TON 2011 32.4181861 Sulfur Dioxide TON 2011 404.1 Sulfur Dioxide TON 2011 1579.9927 Sulfur Dioxide TON 2011 92.124 Sulfur Dioxide TON 2011 2459.2597 Sulfur Dioxide TON 2011 0.2714 Sulfur Dioxide TON 2011 0.065 Sulfur Dioxide TON 2011 1405.2721 Sulfur Dioxide TON 2011 4.24164727 Sulfur Dioxide TON 2011 544.8059532 Sulfur Dioxide TON 2011 647.6759717 Sulfur Dioxide TON 2011 222.3173656 Sulfur Dioxide TON 2011 89.77672674 Sulfur Dioxide TON 2011 33.64712854 Sulfur Dioxide TON 2011 34.15905801 Sulfur Dioxide TON 2011 199.760654 Sulfur Dioxide TON 2011 4.644316443 Sulfur Dioxide TON 2011 52.01052427 Sulfur Dioxide TON 2011 876.3562227 Sulfur Dioxide TON 2011 0.3484 Sulfur Dioxide TON 2011 222.7394048 Sulfur Dioxide TON 2011 178.054295 Sulfur Dioxide TON 2011 36.1562945 Sulfur Dioxide TON 2011 8.7073512 Sulfur Dioxide TON 2011 0.3624999 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.656116565 Sulfur Dioxide TON 2011 402.3445958 Sulfur Dioxide TON 2011 0.023535285 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 1723.455 Sulfur Dioxide TON 2011 18258.2905 Sulfur Dioxide TON 2011 57.22969353 Sulfur Dioxide TON 2011 0.28750025 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.077996301 Sulfur Dioxide TON 2011 3170.685961 Sulfur Dioxide TON 2011 4.319860171 Sulfur Dioxide TON 2011 0.318585694 Sulfur Dioxide TON 2011 0.444590572 Sulfur Dioxide TON 2011 0.154947781 Sulfur Dioxide TON 2011 6.443837387 Sulfur Dioxide TON 2011 278.021Sulfur Dioxide TON 2011 0.12206974 Sulfur Dioxide TON 2011 1163.943723 Sulfur Dioxide TON 2011 0.574612789 Sulfur Dioxide TON 2011 296.4815577 Sulfur Dioxide TON 2011 1432.666128 Sulfur Dioxide TON 2011 4.887826683 Sulfur Dioxide TON 2011 4.242412916 Sulfur Dioxide TON 2011 7.677614777 Sulfur Dioxide TON 2011 4.07746085 Sulfur Dioxide TON 2011 93.67550854 Sulfur Dioxide TON 2011 3.882932762 Sulfur Dioxide TON 2011 57.978481 Sulfur Dioxide TON 2011 1541.751377 Sulfur Dioxide TON 2011 3232.77867 Sulfur Dioxide TON 2011 22.03547373 Sulfur Dioxide TON 2011 63.99786618 Sulfur Dioxide TON 2011 4.54229366 Sulfur Dioxide TON 2011 25.63468072 Sulfur Dioxide TON 2011 0.86822512 Sulfur Dioxide TON 2011 9.093 Sulfur Dioxide TON 2011 0.430880154 Sulfur Dioxide TON 2011 3.92E

‐ 07 Sulfur Dioxide TON 2011 1.671 Sulfur Dioxide TON 2011 277.781849 Sulfur Dioxide TON 2011 4287.400682 Sulfur Dioxide TON 2011 12.09473693 Sulfur Dioxide TON 2011 201.1090889 Sulfur Dioxide TON 2011 0.408455402 Sulfur Dioxide TON 2011 7.192500599 Sulfur Dioxide TON 2011 149.6682825 Sulfur Dioxide TON 2011 17.54867509 Sulfur Dioxide TON 2011 78.4939023 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 2757.713329 Sulfur Dioxide TON 2011 560.9634193 Sulfur Dioxide TON 2011 12.0833 Sulfur Dioxide TON 2011 54.95109 Sulfur Dioxide TON 2011 2.205304 Sulfur Dioxide TON 2011 38.89484835 Sulfur Dioxide TON 2011 0.001236736 Sulfur Dioxide TON 2011 99.72090973 Sulfur Dioxide TON 2011 24.22494957 Sulfur Dioxide TON 2011 8.550854887 Sulfur Dioxide TON 2011 2.521768196 Sulfur Dioxide TON 2011 41.74305817 Sulfur Dioxide TON 2011 0.643286777 Sulfur Dioxide TON 2011 9.932819868Sulfur Dioxide TON 2011 118.5756779 Sulfur Dioxide TON 2011 73.38644762 Sulfur Dioxide TON 2011 0.02268 Sulfur Dioxide TON 2011 373.8866019 Sulfur Dioxide TON 2011 456.956895 Sulfur Dioxide TON 2011 61.519974 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 4187.26871 Sulfur Dioxide TON 2011 68.28559643 Sulfur Dioxide TON 2011 1073.322587 Sulfur Dioxide TON 2011 29.56266413 Sulfur Dioxide TON 2011 2.759775 Sulfur Dioxide TON 2011 217839.93 Sulfur Dioxide TON 2011 18.313743 Sulfur Dioxide TON 2011 14.777535 Sulfur Dioxide TON 2011 603.58634 Sulfur Dioxide TON 2011 0.802 Sulfur Dioxide TON 2011 28775.13 Sulfur Dioxide TON 2011 114.1872238 Sulfur Dioxide TON 2011 863.3011346 Sulfur Dioxide TON 2011 377.6147 Sulfur Dioxide TON 2011 127.8345102 Sulfur Dioxide TON 2011 133.1339055 Sulfur Dioxide TON 2011 1056.529142 Sulfur Dioxide TON 2011 329.0068862 Sulfur Dioxide TON 2011 0.24 Sulfur Dioxide TON 2011 824.933 Sulfur Dioxide TON 2011 1479.936232 Sulfur Dioxide TON 2011 893.228324 Sulfur Dioxide TON 2011 17658.16263 Sulfur Dioxide TON 2011 610.26632 Sulfur Dioxide TON 2011 358.6597115 Sulfur Dioxide TON 2011 3323.79805 Sulfur Dioxide TON 2011 0.0432 Sulfur Dioxide TON 2011 179.601904 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 734.743358 Sulfur Dioxide TON 2011 688.9402769 Sulfur Dioxide TON 2011 471.5032396 Sulfur Dioxide TON 2011 173.9692123 Sulfur Dioxide TON 2011 44.08252817 Sulfur Dioxide TON 2011 43.92873939 Sulfur Dioxide TON 2011 176.1204357 Sulfur Dioxide TON 2011 6.001797035 Sulfur Dioxide TON 2011 51.90982227 Sulfur Dioxide TON 2011 861.7620305 Sulfur Dioxide TON 2011 0.01Sulfur Dioxide TON 2011 24.064374 Sulfur Dioxide TON 2011 3052.005078 Sulfur Dioxide TON 2011 0.07 Sulfur Dioxide TON 2011 7.392218112 Sulfur Dioxide TON 2011 202.85815 Sulfur Dioxide TON 2011 14.60326 Sulfur Dioxide TON 2011 26.77584645 Sulfur Dioxide TON 2011 9127.3288 Sulfur Dioxide TON 2011 24.75885833 Sulfur Dioxide TON 2011 38.8376434 Sulfur Dioxide TON 2011 4.938125697 Sulfur Dioxide TON 2011 354404.8398 Sulfur Dioxide TON 2011 462.2234192 Sulfur Dioxide TON 2011 32.91665094 Sulfur Dioxide TON 2011 27.2827913 Sulfur Dioxide TON 2011 40.13889824 Sulfur Dioxide TON 2011 16492.0662 Sulfur Dioxide TON 2011 165.5032849 Sulfur Dioxide TON 2011 284.949352 Sulfur Dioxide TON 2011 9232.189283 Sulfur Dioxide TON 2011 41.9229205 Sulfur Dioxide TON 2011 390.2411255 Sulfur Dioxide TON 2011 1397.161293 Sulfur Dioxide TON 2011 371.6576683 Sulfur Dioxide TON 2011 3341.8955 Sulfur Dioxide TON 2011 913.7162409 Sulfur Dioxide TON 2011 4181.012948 Sulfur Dioxide TON 2011 16667.13603 Sulfur Dioxide TON 2011 6759.747129 Sulfur Dioxide TON 2011 83.83915196 Sulfur Dioxide TON 2011 1009.738843 Sulfur Dioxide TON 2011 426.300297 Sulfur Dioxide TON 2011 3.441191595 Sulfur Dioxide TON 2011 133.2647039 Sulfur Dioxide TON 2011 31.26307717 Sulfur Dioxide TON 2011 217.4896229 Sulfur Dioxide TON 2011 91.00245227 Sulfur Dioxide TON 2011 23.71278616 Sulfur Dioxide TON 2011 16.81273033 Sulfur Dioxide TON 2011 114.8747195 Sulfur Dioxide TON 2011 3.514201203 Sulfur Dioxide TON 2011 34.44275886 Sulfur Dioxide TON 2011 650.656328 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.1082456 Sulfur Dioxide TON 2011 238.5813069 Sulfur Dioxide TON 2011 0.048Sulfur Dioxide TON 2011 3190.204844 Sulfur Dioxide TON 2011 626.015598 Sulfur Dioxide TON 2011 42.605903 Sulfur Dioxide TON 2011 7.79655339 Sulfur Dioxide TON 2011 5115.123 Sulfur Dioxide TON 2011 14.7242677 Sulfur Dioxide TON 2011 44.73587132 Sulfur Dioxide TON 2011 9.535971083 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 99843.66 Sulfur Dioxide TON 2011 8.889148 Sulfur Dioxide TON 2011 14.067145 Sulfur Dioxide TON 2011 0.07 Sulfur Dioxide TON 2011 10.84574599 Sulfur Dioxide TON 2011 17770.883 Sulfur Dioxide TON 2011 31.85079416 Sulfur Dioxide TON 2011 175.0049536 Sulfur Dioxide TON 2011 62.31507004 Sulfur Dioxide TON 2011 20.5179053 Sulfur Dioxide TON 2011 100.6105282 Sulfur Dioxide TON 2011 2017.734487 Sulfur Dioxide TON 2011 117.2127007 Sulfur Dioxide TON 2011 0.068 Sulfur Dioxide TON 2011 1706.443 Sulfur Dioxide TON 2011 376.988 Sulfur Dioxide TON 2011 249.04603 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 1596.005733 Sulfur Dioxide TON 2011 1.013616 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.0105 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 6.28 Sulfur Dioxide TON 2011 1.730390175 Sulfur Dioxide TON 2011 42.98497838 Sulfur Dioxide TON 2011 7.86146375 Sulfur Dioxide TON 2011 258.4776505 Sulfur Dioxide TON 2011 93.98411217 Sulfur Dioxide TON 2011 18.90235614 Sulfur Dioxide TON 2011 6.313323634 Sulfur Dioxide TON 2011 52.97313246 Sulfur Dioxide TON 2011 1.313763718 Sulfur Dioxide TON 2011 13.14510115 Sulfur Dioxide TON 2011 238.9622235 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.004Sulfur Dioxide TON 2011 0.204 Sulfur Dioxide TON 2011 94.81429524 Sulfur Dioxide TON 2011 0.0593 Sulfur Dioxide TON 2011 2287.4825 Sulfur Dioxide TON 2011 9770.441005 Sulfur Dioxide TON 2011 298.382767 Sulfur Dioxide TON 2011 8.170871 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 9.89977077 Sulfur Dioxide TON 2011 3.09756337 Sulfur Dioxide TON 2011 0.71356011 Sulfur Dioxide TON 2011 39375.355 Sulfur Dioxide TON 2011 10.70831637 Sulfur Dioxide TON 2011 9.0591133 Sulfur Dioxide TON 2011 15.15825 Sulfur Dioxide TON 2011 5.63722082 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 41.58696416 Sulfur Dioxide TON 2011 46.96429887 Sulfur Dioxide TON 2011 155.0139075 Sulfur Dioxide TON 2011 22.32031 Sulfur Dioxide TON 2011 2.015890178 Sulfur Dioxide TON 2011 2.5632305 Sulfur Dioxide TON 2011 89.74438423 Sulfur Dioxide TON 2011 1650.31 Sulfur Dioxide TON 2011 3063.537651 Sulfur Dioxide TON 2011 44.346202 Sulfur Dioxide TON 2011 2.60978 Sulfur Dioxide TON 2011 502.4305822 Sulfur Dioxide TON 2011 2.079369 Sulfur Dioxide TON 2011 196.2588864 Sulfur Dioxide TON 2011 1919.634138 Sulfur Dioxide TON 2011 0.51295 Sulfur Dioxide TON 2011 1.51425046 Sulfur Dioxide TON 2011 34.56643337 Sulfur Dioxide TON 2011 0.07265068 Sulfur Dioxide TON 2011 372.2979225 Sulfur Dioxide TON 2011 73.63221068 Sulfur Dioxide TON 2011 9.456622531 Sulfur Dioxide TON 2011 4.880336998 Sulfur Dioxide TON 2011 51.22259043 Sulfur Dioxide TON 2011 1.353626411 Sulfur Dioxide TON 2011 13.06669641 Sulfur Dioxide TON 2011 247.4460092 Sulfur Dioxide TON 2011 0.000759 Sulfur Dioxide TON 2011 0.1495616 Sulfur Dioxide TON 2011 35.527841Sulfur Dioxide TON 2011 213.8503032 Sulfur Dioxide TON 2011 771.520917 Sulfur Dioxide TON 2011 754.497007 Sulfur Dioxide TON 2011 17.4194245 Sulfur Dioxide TON 2011 1161.894802 Sulfur Dioxide TON 2011 6.03309178 Sulfur Dioxide TON 2011 11.55304336 Sulfur Dioxide TON 2011 2.01832922 Sulfur Dioxide TON 2011 0.51645 Sulfur Dioxide TON 2011 247341.2635 Sulfur Dioxide TON 2011 8.71045911 Sulfur Dioxide TON 2011 69.22686499 Sulfur Dioxide TON 2011 137.3392055 Sulfur Dioxide TON 2011 52.8475798 Sulfur Dioxide TON 2011 3988.29196 Sulfur Dioxide TON 2011 105.6217597 Sulfur Dioxide TON 2011 163.7708126 Sulfur Dioxide TON 2011 315.207087 Sulfur Dioxide TON 2011 15.48450162 Sulfur Dioxide TON 2011 392.6923054 Sulfur Dioxide TON 2011 145.8902131 Sulfur Dioxide TON 2011 125.7272547 Sulfur Dioxide TON 2011 187.506675 Sulfur Dioxide TON 2011 1665.308646 Sulfur Dioxide TON 2011 897.3036925 Sulfur Dioxide TON 2011 6606.169503 Sulfur Dioxide TON 2011 5380.800649 Sulfur Dioxide TON 2011 132.51916 Sulfur Dioxide TON 2011 208.4983814 Sulfur Dioxide TON 2011 586.446007 Sulfur Dioxide TON 2011 3.60773168 Sulfur Dioxide TON 2011 2.467751035 Sulfur Dioxide TON 2011 235.6294792 Sulfur Dioxide TON 2011 82.7624887 Sulfur Dioxide TON 2011 158.0474556 Sulfur Dioxide TON 2011 45.90844817 Sulfur Dioxide TON 2011 14.5645058 Sulfur Dioxide TON 2011 13.26356675 Sulfur Dioxide TON 2011 88.06533586 Sulfur Dioxide TON 2011 2.140630235 Sulfur Dioxide TON 2011 21.78939312 Sulfur Dioxide TON 2011 388.5680073 Sulfur Dioxide TON 2011 0.02 Sulfur Dioxide TON 2011 0.55847495 Sulfur Dioxide TON 2011 160.683154 Sulfur Dioxide TON 2011 0.459997 Sulfur Dioxide TON 2011 639.4938111Sulfur Dioxide TON 2011 6513.646955 Sulfur Dioxide TON 2011 1401.85962 Sulfur Dioxide TON 2011 3.45349949 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 55.44288981 Sulfur Dioxide TON 2011 4.21868004 Sulfur Dioxide TON 2011 12.81820797 Sulfur Dioxide TON 2011 86286 Sulfur Dioxide TON 2011 190.020604 Sulfur Dioxide TON 2011 241.287138 Sulfur Dioxide TON 2011 6347.015 Sulfur Dioxide TON 2011 2260.479844 Sulfur Dioxide TON 2011 340.2520423 Sulfur Dioxide TON 2011 355.655478 Sulfur Dioxide TON 2011 20886.53384 Sulfur Dioxide TON 2011 11660.09 Sulfur Dioxide TON 2011 10.9539068 Sulfur Dioxide TON 2011 25.09583378 Sulfur Dioxide TON 2011 0.976980715 Sulfur Dioxide TON 2011 13.43755074 Sulfur Dioxide TON 2011 0.03981 Sulfur Dioxide TON 2011 53381.75869 Sulfur Dioxide TON 2011 48.209753 Sulfur Dioxide TON 2011 6685.419085 Sulfur Dioxide TON 2011 1.4118 Sulfur Dioxide TON 2011 1222.83416 Sulfur Dioxide TON 2011 16236.21306 Sulfur Dioxide TON 2011 2265.130464 Sulfur Dioxide TON 2011 3471.516501 Sulfur Dioxide TON 2011 2.49961431 Sulfur Dioxide TON 2011 108.7434436 Sulfur Dioxide TON 2011 6291.848694 Sulfur Dioxide TON 2011 111.2188442 Sulfur Dioxide TON 2011 42.06027578 Sulfur Dioxide TON 2011 20.16321826 Sulfur Dioxide TON 2011 7.41482375 Sulfur Dioxide TON 2011 78.96419543 Sulfur Dioxide TON 2011 2.158728878 Sulfur Dioxide TON 2011 23.1588496 Sulfur Dioxide TON 2011 394.5615581 Sulfur Dioxide TON 2011 0.007 Sulfur Dioxide TON 2011 0.372354 Sulfur Dioxide TON 2011 98.32232711 Sulfur Dioxide TON 2011 0.2307969 Sulfur Dioxide TON 2011 26.838038 Sulfur Dioxide TON 2011 1.751972 Sulfur Dioxide TON 2011 22.9608745Sulfur Dioxide TON 2011 3.060405264 Sulfur Dioxide TON 2011 2675.818343 Sulfur Dioxide TON 2011 10.26280151 Sulfur Dioxide TON 2011 25.1842945 Sulfur Dioxide TON 2011 17.9204002 Sulfur Dioxide TON 2011 455.4217317 Sulfur Dioxide TON 2011 53.85184579 Sulfur Dioxide TON 2011 990.7101431 Sulfur Dioxide TON 2011 131.67 Sulfur Dioxide TON 2011 1.24724576 Sulfur Dioxide TON 2011 2716.546555 Sulfur Dioxide TON 2011 555.2810628 Sulfur Dioxide TON 2011 0.422655 Sulfur Dioxide TON 2011 5245.7862 Sulfur Dioxide TON 2011 1.8737595 Sulfur Dioxide TON 2011 187.8042882 Sulfur Dioxide TON 2011 16.29 Sulfur Dioxide TON 2011 243.4864328 Sulfur Dioxide TON 2011 0.1078885 Sulfur Dioxide TON 2011 696.694576 Sulfur Dioxide TON 2011 0.15 Sulfur Dioxide TON 2011 1.6108614 Sulfur Dioxide TON 2011 28.09213093 Sulfur Dioxide TON 2011 359.1470244 Sulfur Dioxide TON 2011 8.922725696 Sulfur Dioxide TON 2011 10.79004928 Sulfur Dioxide TON 2011 11.2978048 Sulfur Dioxide TON 2011 2.131801402 Sulfur Dioxide TON 2011 23.2086012 Sulfur Dioxide TON 2011 0.402417086 Sulfur Dioxide TON 2011 6.018178547 Sulfur Dioxide TON 2011 103.828083 Sulfur Dioxide TON 2011 0.013716593 Sulfur Dioxide TON 2011 387.9019985 Sulfur Dioxide TON 2011 0.0043618 Sulfur Dioxide TON 2011 30.62850808 Sulfur Dioxide TON 2011 80.033725 Sulfur Dioxide TON 2011 114.381914 Sulfur Dioxide TON 2011 2.54175 Sulfur Dioxide TON 2011 331.20031 Sulfur Dioxide TON 2011 43.63150953 Sulfur Dioxide TON 2011 2293.412176 Sulfur Dioxide TON 2011 2.10358603 Sulfur Dioxide TON 2011 31465.177 Sulfur Dioxide TON 2011 27.634291 Sulfur Dioxide TON 2011 438.9805759 Sulfur Dioxide TON 2011 2.69646Sulfur Dioxide TON 2011 111.300025 Sulfur Dioxide TON 2011 22003.1 Sulfur Dioxide TON 2011 2.791784 Sulfur Dioxide TON 2011 2425.181746 Sulfur Dioxide TON 2011 31.672418 Sulfur Dioxide TON 2011 23.22351008 Sulfur Dioxide TON 2011 3105.4123 Sulfur Dioxide TON 2011 44.112391 Sulfur Dioxide TON 2011 55.88965527 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 555.4531516 Sulfur Dioxide TON 2011 0.7167033 Sulfur Dioxide TON 2011 674.3202015 Sulfur Dioxide TON 2011 62.57684 Sulfur Dioxide TON 2011 138.3389988 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.012188956 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 656.374855 Sulfur Dioxide TON 2011 0.422559 Sulfur Dioxide TON 2011 2.9234332 Sulfur Dioxide TON 2011 97.7056356 Sulfur Dioxide TON 2011 5346.876425 Sulfur Dioxide TON 2011 2.27115225 Sulfur Dioxide TON 2011 39.40218371 Sulfur Dioxide TON 2011 19.85546466 Sulfur Dioxide TON 2011 6.142247864 Sulfur Dioxide TON 2011 62.89773325 Sulfur Dioxide TON 2011 2.656657363 Sulfur Dioxide TON 2011 21.56340612 Sulfur Dioxide TON 2011 464.9821778 Sulfur Dioxide TON 2011 0.0275575 Sulfur Dioxide TON 2011 0.0274458 Sulfur Dioxide TON 2011 0.065299 Sulfur Dioxide TON 2011 487.9663654 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.83508224 Sulfur Dioxide TON 2011 34.209036 Sulfur Dioxide TON 2011 7.6365019 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 24.7336 Sulfur Dioxide TON 2011 6456.9395 Sulfur Dioxide TON 2011 38.3804 Sulfur Dioxide TON 2011 5.945 Sulfur Dioxide TON 2011 22210.88 Sulfur Dioxide TON 2011 56.4522 Sulfur Dioxide TON 2011 515.5247Sulfur Dioxide TON 2011 78.9637 Sulfur Dioxide TON 2011 53.038 Sulfur Dioxide TON 2011 795.588 Sulfur Dioxide TON 2011 18.3483 Sulfur Dioxide TON 2011 1797.4345 Sulfur Dioxide TON 2011 30.6801 Sulfur Dioxide TON 2011 37.64 Sulfur Dioxide TON 2011 13501.81 Sulfur Dioxide TON 2011 2.13 Sulfur Dioxide TON 2011 210.9627263 Sulfur Dioxide TON 2011 2.413 Sulfur Dioxide TON 2011 0.0196 Sulfur Dioxide TON 2011 240.24047 Sulfur Dioxide TON 2011 0.0534 Sulfur Dioxide TON 2011 23.88 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.05 Sulfur Dioxide TON 2011 20.8358386 Sulfur Dioxide TON 2011 244.4127028 Sulfur Dioxide TON 2011 1324.599687 Sulfur Dioxide TON 2011 229.8542266 Sulfur Dioxide TON 2011 37.78501121 Sulfur Dioxide TON 2011 22.13496191 Sulfur Dioxide TON 2011 15.02467697 Sulfur Dioxide TON 2011 39.42517874 Sulfur Dioxide TON 2011 2.730414833 Sulfur Dioxide TON 2011 20.23791073 Sulfur Dioxide TON 2011 464.1499092 Sulfur Dioxide TON 2011 7.7 Sulfur Dioxide TON 2011 0.0008 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 5.3005 Sulfur Dioxide TON 2011 937.1420773 Sulfur Dioxide TON 2011 25.96619495 Sulfur Dioxide TON 2011 153.593768 Sulfur Dioxide TON 2011 85.578036 Sulfur Dioxide TON 2011 77.66408586 Sulfur Dioxide TON 2011 2229.77 Sulfur Dioxide TON 2011 51.422101 Sulfur Dioxide TON 2011 763.60293 Sulfur Dioxide TON 2011 23.636925 Sulfur Dioxide TON 2011 108.17635 Sulfur Dioxide TON 2011 229014.8 Sulfur Dioxide TON 2011 42.30842915 Sulfur Dioxide TON 2011 286.4197585 Sulfur Dioxide TON 2011 725.576295 Sulfur Dioxide TON 2011 502.46Sulfur Dioxide TON 2011 17460.927 Sulfur Dioxide TON 2011 70.99021675 Sulfur Dioxide TON 2011 643.4560105 Sulfur Dioxide TON 2011 3495.286177 Sulfur Dioxide TON 2011 94.7 Sulfur Dioxide TON 2011 331.18 Sulfur Dioxide TON 2011 307.38 Sulfur Dioxide TON 2011 1090.928067 Sulfur Dioxide TON 2011 12846.7105 Sulfur Dioxide TON 2011 92.486365 Sulfur Dioxide TON 2011 2726.68795 Sulfur Dioxide TON 2011 3225.170016 Sulfur Dioxide TON 2011 3288.459191 Sulfur Dioxide TON 2011 67.18327665 Sulfur Dioxide TON 2011 474.451245 Sulfur Dioxide TON 2011 40.09849 Sulfur Dioxide TON 2011 0.05025 Sulfur Dioxide TON 2011 5.280141645 Sulfur Dioxide TON 2011 329.7622785 Sulfur Dioxide TON 2011 3177.965303 Sulfur Dioxide TON 2011 64.24380916 Sulfur Dioxide TON 2011 99.5416691 Sulfur Dioxide TON 2011 60.37867046 Sulfur Dioxide TON 2011 28.36871935 Sulfur Dioxide TON 2011 115.1228499 Sulfur Dioxide TON 2011 4.894057477 Sulfur Dioxide TON 2011 54.98069931 Sulfur Dioxide TON 2011 807.5645504 Sulfur Dioxide TON 2011 1.182690429 Sulfur Dioxide TON 2011 561.3325794 Sulfur Dioxide TON 2011 0.02 Sulfur Dioxide TON 2011 3776.597578 Sulfur Dioxide TON 2011 1427.16347 Sulfur Dioxide TON 2011 4259.136927 Sulfur Dioxide TON 2011 21.848524 Sulfur Dioxide TON 2011 47.2549 Sulfur Dioxide TON 2011 25.82600193 Sulfur Dioxide TON 2011 975.049902 Sulfur Dioxide TON 2011 1.676507543 Sulfur Dioxide TON 2011 336.2588895 Sulfur Dioxide TON 2011 40791.7976 Sulfur Dioxide TON 2011 128.8964 Sulfur Dioxide TON 2011 9.614441908 Sulfur Dioxide TON 2011 60.700937 Sulfur Dioxide TON 2011 731.905726 Sulfur Dioxide TON 2011 6427.53418 Sulfur Dioxide TON 2011 309.0456387Sulfur Dioxide TON 2011 631.6334549 Sulfur Dioxide TON 2011 308.7271083 Sulfur Dioxide TON 2011 40.007616 Sulfur Dioxide TON 2011 949.434164 Sulfur Dioxide TON 2011 79.01006765 Sulfur Dioxide TON 2011 784.8456274 Sulfur Dioxide TON 2011 0.2917 Sulfur Dioxide TON 2011 41.8703628 Sulfur Dioxide TON 2011 4807.695882 Sulfur Dioxide TON 2011 0.04214 Sulfur Dioxide TON 2011 2497.882182 Sulfur Dioxide TON 2011 1752.868948 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 811.5847074 Sulfur Dioxide TON 2011 27.853059 Sulfur Dioxide TON 2011 1.90977 Sulfur Dioxide TON 2011 0.703631385 Sulfur Dioxide TON 2011 270.717743 Sulfur Dioxide TON 2011 135.0785554 Sulfur Dioxide TON 2011 190.3547867 Sulfur Dioxide TON 2011 97.86418968 Sulfur Dioxide TON 2011 33.10411752 Sulfur Dioxide TON 2011 15.75523718 Sulfur Dioxide TON 2011 87.43206865 Sulfur Dioxide TON 2011 2.909587361 Sulfur Dioxide TON 2011 25.44263606 Sulfur Dioxide TON 2011 484.5067745 Sulfur Dioxide TON 2011 0.06646 Sulfur Dioxide TON 2011 1.704145141 Sulfur Dioxide TON 2011 588.8461569 Sulfur Dioxide TON 2011 0.01 Sulfur Dioxide TON 2011 1082.994422 Sulfur Dioxide TON 2011 2935.507862 Sulfur Dioxide TON 2011 227.5413 Sulfur Dioxide TON 2011 9.90000108 Sulfur Dioxide TON 2011 6.2090816 Sulfur Dioxide TON 2011 1.225228048 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 43001.4 Sulfur Dioxide TON 2011 256.44 Sulfur Dioxide TON 2011 1.41 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 434.55 Sulfur Dioxide TON 2011 5054.79 Sulfur Dioxide TON 2011 125.76 Sulfur Dioxide TON 2011 5.7 Sulfur Dioxide TON 2011 26.16Sulfur Dioxide TON 2011 7.0175987 Sulfur Dioxide TON 2011 11.46449352 Sulfur Dioxide TON 2011 2.44719519 Sulfur Dioxide TON 2011 13.18541373 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 1382.54 Sulfur Dioxide TON 2011 120.8 Sulfur Dioxide TON 2011 114.1 Sulfur Dioxide TON 2011 3.18 Sulfur Dioxide TON 2011 5450.63539 Sulfur Dioxide TON 2011 1500.99 Sulfur Dioxide TON 2011 590.87 Sulfur Dioxide TON 2011 44.77 Sulfur Dioxide TON 2011 1.7574976 Sulfur Dioxide TON 2011 33.31085333 Sulfur Dioxide TON 2011 348.424351 Sulfur Dioxide TON 2011 78.40669605 Sulfur Dioxide TON 2011 30.75819581 Sulfur Dioxide TON 2011 11.61137169 Sulfur Dioxide TON 2011 4.932022666 Sulfur Dioxide TON 2011 64.43695476 Sulfur Dioxide TON 2011 1.77423978 Sulfur Dioxide TON 2011 16.96880212 Sulfur Dioxide TON 2011 315.6698181 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.3 Sulfur Dioxide TON 2011 91.38256416 Sulfur Dioxide TON 2011 1531.123896 Sulfur Dioxide TON 2011 3675.22865 Sulfur Dioxide TON 2011 717.848397 Sulfur Dioxide TON 2011 35.55702419 Sulfur Dioxide TON 2011 6795.6 Sulfur Dioxide TON 2011 16.82840531 Sulfur Dioxide TON 2011 61.44014107 Sulfur Dioxide TON 2011 3.978225398 Sulfur Dioxide TON 2011 1.4 Sulfur Dioxide TON 2011 205097.61 Sulfur Dioxide TON 2011 17.749 Sulfur Dioxide TON 2011 15.74 Sulfur Dioxide TON 2011 3.43 Sulfur Dioxide TON 2011 65.17107129 Sulfur Dioxide TON 2011 13759.39 Sulfur Dioxide TON 2011 20.3307514 Sulfur Dioxide TON 2011 312.8283723 Sulfur Dioxide TON 2011 188.5567121 Sulfur Dioxide TON 2011 32.21669987Sulfur Dioxide TON 2011 56.679295 Sulfur Dioxide TON 2011 5.82036474 Sulfur Dioxide TON 2011 236.4664478 Sulfur Dioxide TON 2011 953.35 Sulfur Dioxide TON 2011 200.28 Sulfur Dioxide TON 2011 0.23 Sulfur Dioxide TON 2011 23.13 Sulfur Dioxide TON 2011 4601.48 Sulfur Dioxide TON 2011 23405.33 Sulfur Dioxide TON 2011 1.568623931 Sulfur Dioxide TON 2011 143.4626 Sulfur Dioxide TON 2011 0.51 Sulfur Dioxide TON 2011 15.74 Sulfur Dioxide TON 2011 6.5098 Sulfur Dioxide TON 2011 205.1748334 Sulfur Dioxide TON 2011 23.41532907 Sulfur Dioxide TON 2011 348.4429632 Sulfur Dioxide TON 2011 78.46388798 Sulfur Dioxide TON 2011 23.46513882 Sulfur Dioxide TON 2011 14.39864329 Sulfur Dioxide TON 2011 235.3892907 Sulfur Dioxide TON 2011 1.950283579 Sulfur Dioxide TON 2011 27.70779081 Sulfur Dioxide TON 2011 450.5054423 Sulfur Dioxide TON 2011 0.45 Sulfur Dioxide TON 2011 133.9663137 Sulfur Dioxide TON 2011 297.6895045 Sulfur Dioxide TON 2011 1762.88963 Sulfur Dioxide TON 2011 4632.712953 Sulfur Dioxide TON 2011 12.35000053 Sulfur Dioxide TON 2011 7.10212813 Sulfur Dioxide TON 2011 247.8041308 Sulfur Dioxide TON 2011 11.0408 Sulfur Dioxide TON 2011 15710.696 Sulfur Dioxide TON 2011 0.7254 Sulfur Dioxide TON 2011 7.4139 Sulfur Dioxide TON 2011 2105.6524 Sulfur Dioxide TON 2011 26.8339 Sulfur Dioxide TON 2011 148.8807 Sulfur Dioxide TON 2011 16.7458 Sulfur Dioxide TON 2011 3.8322 Sulfur Dioxide TON 2011 12.8461 Sulfur Dioxide TON 2011 6.529501934 Sulfur Dioxide TON 2011 105.8876046 Sulfur Dioxide TON 2011 10.35675102 Sulfur Dioxide TON 2011 29.79183471 Sulfur Dioxide TON 2011 397.9166Sulfur Dioxide TON 2011 1987.8125 Sulfur Dioxide TON 2011 69.79 Sulfur Dioxide TON 2011 93.9192 Sulfur Dioxide TON 2011 10.0854 Sulfur Dioxide TON 2011 170.4186158 Sulfur Dioxide TON 2011 971.1579 Sulfur Dioxide TON 2011 20.8359 Sulfur Dioxide TON 2011 0.002 Sulfur Dioxide TON 2011 0.124549728 Sulfur Dioxide TON 2011 35.47824684 Sulfur Dioxide TON 2011 245.1498367 Sulfur Dioxide TON 2011 30.47515915 Sulfur Dioxide TON 2011 4.768118946 Sulfur Dioxide TON 2011 1.534343297 Sulfur Dioxide TON 2011 20.48661389 Sulfur Dioxide TON 2011 0.525515639 Sulfur Dioxide TON 2011 5.250054481 Sulfur Dioxide TON 2011 93.61479698 Sulfur Dioxide TON 2011 0.0063 Sulfur Dioxide TON 2011 40.50363903 Sulfur Dioxide TON 2011 0.08 Sulfur Dioxide TON 2011 1747.067688 Sulfur Dioxide TON 2011 1053.736793 Sulfur Dioxide TON 2011 109.743797 Sulfur Dioxide TON 2011 2.1 Sulfur Dioxide TON 2011 9.678846177 Sulfur Dioxide TON 2011 0.1602017 Sulfur Dioxide TON 2011 0.0629822 Sulfur Dioxide TON 2011 1.00E

‐ 07 Sulfur Dioxide TON 2011 71426.6 Sulfur Dioxide TON 2011 4.9315183 Sulfur Dioxide TON 2011 11.1758552 Sulfur Dioxide TON 2011 59.0433003 Sulfur Dioxide TON 2011 0.387 Sulfur Dioxide TON 2011 355.975 Sulfur Dioxide TON 2011 91.133545 Sulfur Dioxide TON 2011 14.8221626 Sulfur Dioxide TON 2011 1.0277956 Sulfur Dioxide TON 2011 12.04290023 Sulfur Dioxide TON 2011 34.88905136 Sulfur Dioxide TON 2011 2.5817387 Sulfur Dioxide TON 2011 32.88855077 Sulfur Dioxide TON 2011 1067 Sulfur Dioxide TON 2011 18.2412002 Sulfur Dioxide TON 2011 192.8343801 Sulfur Dioxide TON 2011 585.0549523 Sulfur Dioxide TON 2011 4.359093601Sulfur Dioxide TON 2011 0.475177847 Sulfur Dioxide TON 2011 13.9480459 Sulfur Dioxide TON 2011 2.1358712 Sulfur Dioxide TON 2011 0.556126406 Sulfur Dioxide TON 2011 51.76784074 Sulfur Dioxide TON 2011 0.073588765 Sulfur Dioxide TON 2011 745.7951877 Sulfur Dioxide TON 2011 63.76111042 Sulfur Dioxide TON 2011 6.688549575 Sulfur Dioxide TON 2011 3.741553467 Sulfur Dioxide TON 2011 36.85752873 Sulfur Dioxide TON 2011 0.849739553 Sulfur Dioxide TON 2011 8.279054868 Sulfur Dioxide TON 2011 154.2112625 Sulfur Dioxide TON 2011 5.00E

‐ 11 Sulfur Dioxide TON 2011 2.7174668 Sulfur Dioxide TON 2011 25.11149504 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.004 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.71427 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 39.43135905 Sulfur Dioxide TON 2011 58.11473415 Sulfur Dioxide TON 2011 821.791059 Sulfur Dioxide TON 2011 4.028257775 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 20.92988346 Sulfur Dioxide TON 2011 580.7896261 Sulfur Dioxide TON 2011 6.554104263 Sulfur Dioxide TON 2011 5224.987 Sulfur Dioxide TON 2011 85.10247301 Sulfur Dioxide TON 2011 4.21828721 Sulfur Dioxide TON 2011 0.6903453 Sulfur Dioxide TON 2011 4.587498795 Sulfur Dioxide TON 2011 1029.729 Sulfur Dioxide TON 2011 23.36997239 Sulfur Dioxide TON 2011 3581.896486 Sulfur Dioxide TON 2011 2.955656365 Sulfur Dioxide TON 2011 10.12504465 Sulfur Dioxide TON 2011 233.5706166 Sulfur Dioxide TON 2011 0.76570831 Sulfur Dioxide TON 2011 32.14201041 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.0090627 Sulfur Dioxide TON 2011 0.002200006Sulfur Dioxide TON 2011 0.001509508 Sulfur Dioxide TON 2011 8.735155607 Sulfur Dioxide TON 2011 300.4459857 Sulfur Dioxide TON 2011 93.91464102 Sulfur Dioxide TON 2011 0.050630321 Sulfur Dioxide TON 2011 20.027098 Sulfur Dioxide TON 2011 1.32896065 Sulfur Dioxide TON 2011 1.659408511 Sulfur Dioxide TON 2011 319.8865789 Sulfur Dioxide TON 2011 75.78860002 Sulfur Dioxide TON 2011 34.53149454 Sulfur Dioxide TON 2011 9.933613417 Sulfur Dioxide TON 2011 12.85663687 Sulfur Dioxide TON 2011 36.72836212 Sulfur Dioxide TON 2011 1.224575111 Sulfur Dioxide TON 2011 11.64925063 Sulfur Dioxide TON 2011 220.7013644 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.087346 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 336.9913519 Sulfur Dioxide TON 2011 2.68304395 Sulfur Dioxide TON 2011 4.529555 Sulfur Dioxide TON 2011 0.027844 Sulfur Dioxide TON 2011 4.81 Sulfur Dioxide TON 2011 3.2559273 Sulfur Dioxide TON 2011 1625.983811 Sulfur Dioxide TON 2011 34.80302042 Sulfur Dioxide TON 2011 9.996186 Sulfur Dioxide TON 2011 24097.618 Sulfur Dioxide TON 2011 14.40074 Sulfur Dioxide TON 2011 307.27554 Sulfur Dioxide TON 2011 10.97968 Sulfur Dioxide TON 2011 7.663524 Sulfur Dioxide TON 2011 1.98639702 Sulfur Dioxide TON 2011 1094.608068 Sulfur Dioxide TON 2011 4.966652 Sulfur Dioxide TON 2011 2.03039665 Sulfur Dioxide TON 2011 3082.06385 Sulfur Dioxide TON 2011 2.62 Sulfur Dioxide TON 2011 148.7269276 Sulfur Dioxide TON 2011 0.003304 Sulfur Dioxide TON 2011 13.105184 Sulfur Dioxide TON 2011 0.03939Sulfur Dioxide TON 2011 0.02798 Sulfur Dioxide TON 2011 0.015912 Sulfur Dioxide TON 2011 0.6227049 Sulfur Dioxide TON 2011 25.10703673 Sulfur Dioxide TON 2011 379.8775442 Sulfur Dioxide TON 2011 2.666759927 Sulfur Dioxide TON 2011 10.47587851 Sulfur Dioxide TON 2011 7.800471638 Sulfur Dioxide TON 2011 3.071667608 Sulfur Dioxide TON 2011 12.53639009 Sulfur Dioxide TON 2011 0.426109149 Sulfur Dioxide TON 2011 6.742971713 Sulfur Dioxide TON 2011 105.2521971 Sulfur Dioxide TON 2011 0.059994 Sulfur Dioxide TON 2011 212.5908925 Sulfur Dioxide TON 2011 0.029 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 87.409902 Sulfur Dioxide TON 2011 13.795775 Sulfur Dioxide TON 2011 2.89999955 Sulfur Dioxide TON 2011 0.0003 Sulfur Dioxide TON 2011 53.731416 Sulfur Dioxide TON 2011 1543.37209 Sulfur Dioxide TON 2011 12.8237863 Sulfur Dioxide TON 2011 3470.687 Sulfur Dioxide TON 2011 56.7765 Sulfur Dioxide TON 2011 162.0901 Sulfur Dioxide TON 2011 192.6078 Sulfur Dioxide TON 2011 44.874998 Sulfur Dioxide TON 2011 0.57 Sulfur Dioxide TON 2011 1069.8738 Sulfur Dioxide TON 2011 1089.725783 Sulfur Dioxide TON 2011 38.52361094 Sulfur Dioxide TON 2011 65.700004 Sulfur Dioxide TON 2011 3854.757811 Sulfur Dioxide TON 2011 7.310383 Sulfur Dioxide TON 2011 118.9294719 Sulfur Dioxide TON 2011 12.4085 Sulfur Dioxide TON 2011 38.0158 Sulfur Dioxide TON 2011 489.1875 Sulfur Dioxide TON 2011 0.4853 Sulfur Dioxide TON 2011 18.94 Sulfur Dioxide TON 2011 199.1643 Sulfur Dioxide TON 2011 1.63 Sulfur Dioxide TON 2011 1.6851 Sulfur Dioxide TON 2011 4.24473955 Sulfur Dioxide TON 2011 308.7962097Sulfur Dioxide TON 2011 2389.242287 Sulfur Dioxide TON 2011 17.22106125 Sulfur Dioxide TON 2011 54.52997207 Sulfur Dioxide TON 2011 27.53193081 Sulfur Dioxide TON 2011 18.31291157 Sulfur Dioxide TON 2011 47.82888011 Sulfur Dioxide TON 2011 3.55411514 Sulfur Dioxide TON 2011 31.56905312 Sulfur Dioxide TON 2011 639.4995296 Sulfur Dioxide TON 2011 0.0134 Sulfur Dioxide TON 2011 0.2019 Sulfur Dioxide TON 2011 533.9359731 Sulfur Dioxide TON 2011 115.2100863 Sulfur Dioxide TON 2011 322.16918 Sulfur Dioxide TON 2011 7386.217431 Sulfur Dioxide TON 2011 18.43750523 Sulfur Dioxide TON 2011 6.92551868 Sulfur Dioxide TON 2011 2.374926608 Sulfur Dioxide TON 2011 0.0015274 Sulfur Dioxide TON 2011 4720.3 Sulfur Dioxide TON 2011 1279.127342 Sulfur Dioxide TON 2011 1.28730228 Sulfur Dioxide TON 2011 7.25003 Sulfur Dioxide TON 2011 4.81249819 Sulfur Dioxide TON 2011 722.58188 Sulfur Dioxide TON 2011 79.23160768 Sulfur Dioxide TON 2011 75.48665315 Sulfur Dioxide TON 2011 2.5241725 Sulfur Dioxide TON 2011 9.705904752 Sulfur Dioxide TON 2011 2.003609555 Sulfur Dioxide TON 2011 2.167426495 Sulfur Dioxide TON 2011 40.1447828 Sulfur Dioxide TON 2011 666.70254 Sulfur Dioxide TON 2011 0.08 Sulfur Dioxide TON 2011 38.34453208 Sulfur Dioxide TON 2011 0.00419899 Sulfur Dioxide TON 2011 12833.43341 Sulfur Dioxide TON 2011 734.088 Sulfur Dioxide TON 2011 0.66 Sulfur Dioxide TON 2011 0.970080263 Sulfur Dioxide TON 2011 55.94160184 Sulfur Dioxide TON 2011 252.8973555 Sulfur Dioxide TON 2011 14.91239542 Sulfur Dioxide TON 2011 5.606227465 Sulfur Dioxide TON 2011 3.064931187 Sulfur Dioxide TON 2011 58.07450727 Sulfur Dioxide TON 2011 1.079771593Sulfur Dioxide TON 2011 12.77244358 Sulfur Dioxide TON 2011 194.5137093 Sulfur Dioxide TON 2011 0.00148 Sulfur Dioxide TON 2011 0.000052 Sulfur Dioxide TON 2011 19.87815833 Sulfur Dioxide TON 2011 0.0235 Sulfur Dioxide TON 2011 65.45062722 Sulfur Dioxide TON 2011 42.212217 Sulfur Dioxide TON 2011 19.046474 Sulfur Dioxide TON 2011 9.09546817 Sulfur Dioxide TON 2011 2028.523 Sulfur Dioxide TON 2011 85.46068342 Sulfur Dioxide TON 2011 30408.74922 Sulfur Dioxide TON 2011 165.590873 Sulfur Dioxide TON 2011 5.691575 Sulfur Dioxide TON 2011 39398.9065 Sulfur Dioxide TON 2011 385.9808097 Sulfur Dioxide TON 2011 3261.146263 Sulfur Dioxide TON 2011 166.1400125 Sulfur Dioxide TON 2011 25.2865 Sulfur Dioxide TON 2011 26728.2855 Sulfur Dioxide TON 2011 46.40288242 Sulfur Dioxide TON 2011 8406.391401 Sulfur Dioxide TON 2011 272.776264 Sulfur Dioxide TON 2011 116.9999897 Sulfur Dioxide TON 2011 18473.92324 Sulfur Dioxide TON 2011 535.7732556 Sulfur Dioxide TON 2011 551.449511 Sulfur Dioxide TON 2011 9649.57085 Sulfur Dioxide TON 2011 167.9434503 Sulfur Dioxide TON 2011 621.32392 Sulfur Dioxide TON 2011 1130.444432 Sulfur Dioxide TON 2011 2724.016859 Sulfur Dioxide TON 2011 95.05120803 Sulfur Dioxide TON 2011 364.838 Sulfur Dioxide TON 2011 3.4065 Sulfur Dioxide TON 2011 12.70823139 Sulfur Dioxide TON 2011 780.6876707 Sulfur Dioxide TON 2011 1387.933468 Sulfur Dioxide TON 2011 145.5779376 Sulfur Dioxide TON 2011 107.5646317 Sulfur Dioxide TON 2011 64.09893999 Sulfur Dioxide TON 2011 40.64971563 Sulfur Dioxide TON 2011 119.8404525 Sulfur Dioxide TON 2011 6.04289969 Sulfur Dioxide TON 2011 55.72215131 Sulfur Dioxide TON 2011 1141.270187Sulfur Dioxide TON 2011 0.0135 Sulfur Dioxide TON 2011 0.1967725 Sulfur Dioxide TON 2011 961.455477 Sulfur Dioxide TON 2011 0.01 Sulfur Dioxide TON 2011 399.1757507 Sulfur Dioxide TON 2011 2052.913141 Sulfur Dioxide TON 2011 8943.762729 Sulfur Dioxide TON 2011 36.39629875 Sulfur Dioxide TON 2011 2697.509451 Sulfur Dioxide TON 2011 17.76780619 Sulfur Dioxide TON 2011 363.7491529 Sulfur Dioxide TON 2011 22.11416967 Sulfur Dioxide TON 2011 988.15 Sulfur Dioxide TON 2011 82603.79 Sulfur Dioxide TON 2011 33.18002316 Sulfur Dioxide TON 2011 256.2875463 Sulfur Dioxide TON 2011 22.5128078 Sulfur Dioxide TON 2011 1511.528135 Sulfur Dioxide TON 2011 7118.031624 Sulfur Dioxide TON 2011 264.907576 Sulfur Dioxide TON 2011 6243.838382 Sulfur Dioxide TON 2011 889.7414882 Sulfur Dioxide TON 2011 19.69259687 Sulfur Dioxide TON 2011 1496.741943 Sulfur Dioxide TON 2011 532.4114857 Sulfur Dioxide TON 2011 74.58144957 Sulfur Dioxide TON 2011 5506.64 Sulfur Dioxide TON 2011 21.969 Sulfur Dioxide TON 2011 2264.554317 Sulfur Dioxide TON 2011 256.57511 Sulfur Dioxide TON 2011 1485.48 Sulfur Dioxide TON 2011 7.575 Sulfur Dioxide TON 2011 4.570086635 Sulfur Dioxide TON 2011 409.0517351 Sulfur Dioxide TON 2011 732.0257746 Sulfur Dioxide TON 2011 107.7392856 Sulfur Dioxide TON 2011 88.45234601 Sulfur Dioxide TON 2011 34.4512541 Sulfur Dioxide TON 2011 27.61696032 Sulfur Dioxide TON 2011 119.3325161 Sulfur Dioxide TON 2011 6.372978375 Sulfur Dioxide TON 2011 52.26993793 Sulfur Dioxide TON 2011 918.7508312 Sulfur Dioxide TON 2011 0.504705 Sulfur Dioxide TON 2011 5.653304541 Sulfur Dioxide TON 2011 246.445718 Sulfur Dioxide TON 2011 1902.03391Sulfur Dioxide TON 2011 1228.867599 Sulfur Dioxide TON 2011 36.937857 Sulfur Dioxide TON 2011 0.737500237 Sulfur Dioxide TON 2011 3.173728898 Sulfur Dioxide TON 2011 9.17852916 Sulfur Dioxide TON 2011 8.79 Sulfur Dioxide TON 2011 92612.6 Sulfur Dioxide TON 2011 22 Sulfur Dioxide TON 2011 0.21 Sulfur Dioxide TON 2011 1.112500347 Sulfur Dioxide TON 2011 2091.8 Sulfur Dioxide TON 2011 21.8 Sulfur Dioxide TON 2011 207.8263194 Sulfur Dioxide TON 2011 1086.8 Sulfur Dioxide TON 2011 3.455400157 Sulfur Dioxide TON 2011 295.2731488 Sulfur Dioxide TON 2011 145.1672745 Sulfur Dioxide TON 2011 12.5679394 Sulfur Dioxide TON 2011 353 Sulfur Dioxide TON 2011 331.1 Sulfur Dioxide TON 2011 2073.440067 Sulfur Dioxide TON 2011 305.4 Sulfur Dioxide TON 2011 0.16 Sulfur Dioxide TON 2011 3728 Sulfur Dioxide TON 2011 0.355987375 Sulfur Dioxide TON 2011 28.70792839 Sulfur Dioxide TON 2011 157.7034083 Sulfur Dioxide TON 2011 62.44601847 Sulfur Dioxide TON 2011 4.433441097 Sulfur Dioxide TON 2011 1.383173571 Sulfur Dioxide TON 2011 19.48434598 Sulfur Dioxide TON 2011 0.395172677 Sulfur Dioxide TON 2011 4.147939377 Sulfur Dioxide TON 2011 70.48334991 Sulfur Dioxide TON 2011 11.79629136 Sulfur Dioxide TON 2011 0.06 Sulfur Dioxide TON 2011 36.82691113 Sulfur Dioxide TON 2011 79.25863 Sulfur Dioxide TON 2011 4.240798 Sulfur Dioxide TON 2011 42.8517831 Sulfur Dioxide TON 2011 3976.5118 Sulfur Dioxide TON 2011 45.5121217 Sulfur Dioxide TON 2011 74.54721288 Sulfur Dioxide TON 2011 16.04672931 Sulfur Dioxide TON 2011 9.379 Sulfur Dioxide TON 2011 589755.18 Sulfur Dioxide TON 2011 20.15550147Sulfur Dioxide TON 2011 53.3734385 Sulfur Dioxide TON 2011 2618.665 Sulfur Dioxide TON 2011 196.8419151 Sulfur Dioxide TON 2011 45246.28176 Sulfur Dioxide TON 2011 87.84569476 Sulfur Dioxide TON 2011 949.7272417 Sulfur Dioxide TON 2011 2750.040988 Sulfur Dioxide TON 2011 87.7317447 Sulfur Dioxide TON 2011 1829.450595 Sulfur Dioxide TON 2011 1213.864451 Sulfur Dioxide TON 2011 624.018469 Sulfur Dioxide TON 2011 1604.1 Sulfur Dioxide TON 2011 2928.619258 Sulfur Dioxide TON 2011 4429.525467 Sulfur Dioxide TON 2011 0.0192 Sulfur Dioxide TON 2011 13724.95252 Sulfur Dioxide TON 2011 3175.101531 Sulfur Dioxide TON 2011 335.134498 Sulfur Dioxide TON 2011 1144.24377 Sulfur Dioxide TON 2011 228.762707 Sulfur Dioxide TON 2011 95.498 Sulfur Dioxide TON 2011 72.249815 Sulfur Dioxide TON 2011 212.9615248 Sulfur Dioxide TON 2011 659.580833 Sulfur Dioxide TON 2011 357.8542134 Sulfur Dioxide TON 2011 112.8960257 Sulfur Dioxide TON 2011 43.3051754 Sulfur Dioxide TON 2011 24.0349314 Sulfur Dioxide TON 2011 229.6938199 Sulfur Dioxide TON 2011 5.309490602 Sulfur Dioxide TON 2011 56.08267673 Sulfur Dioxide TON 2011 1070.383806 Sulfur Dioxide TON 2011 0.42 Sulfur Dioxide TON 2011 0.063497 Sulfur Dioxide TON 2011 1.071638574 Sulfur Dioxide TON 2011 411.3748257 Sulfur Dioxide TON 2011 0.008 Sulfur Dioxide TON 2011 229.8158319 Sulfur Dioxide TON 2011 7130.790959 Sulfur Dioxide TON 2011 2470.226313 Sulfur Dioxide TON 2011 6.49999187 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 11.2309093 Sulfur Dioxide TON 2011 3.87580021 Sulfur Dioxide TON 2011 0.027925819 Sulfur Dioxide TON 2011 95553.38 Sulfur Dioxide TON 2011 128.111Sulfur Dioxide TON 2011 9.72 Sulfur Dioxide TON 2011 0.131 Sulfur Dioxide TON 2011 145.1023249 Sulfur Dioxide TON 2011 2584.48799 Sulfur Dioxide TON 2011 144.3629755 Sulfur Dioxide TON 2011 2760.170751 Sulfur Dioxide TON 2011 383.76 Sulfur Dioxide TON 2011 19.6257085 Sulfur Dioxide TON 2011 5.6551499 Sulfur Dioxide TON 2011 2.56000474 Sulfur Dioxide TON 2011 17.41179311 Sulfur Dioxide TON 2011 3442.618 Sulfur Dioxide TON 2011 703.459 Sulfur Dioxide TON 2011 20.755 Sulfur Dioxide TON 2011 965.061 Sulfur Dioxide TON 2011 0.058 Sulfur Dioxide TON 2011 914.3448775 Sulfur Dioxide TON 2011 12575.888 Sulfur Dioxide TON 2011 44.696 Sulfur Dioxide TON 2011 0.134 Sulfur Dioxide TON 2011 2.24757195 Sulfur Dioxide TON 2011 65.32515633 Sulfur Dioxide TON 2011 1.363622443 Sulfur Dioxide TON 2011 189.2138795 Sulfur Dioxide TON 2011 45.74027076 Sulfur Dioxide TON 2011 14.29523542 Sulfur Dioxide TON 2011 6.178742024 Sulfur Dioxide TON 2011 87.1011867 Sulfur Dioxide TON 2011 2.146350315 Sulfur Dioxide TON 2011 22.59878722 Sulfur Dioxide TON 2011 391.7399309 Sulfur Dioxide TON 2011 0.039 Sulfur Dioxide TON 2011 84.93997818 Sulfur Dioxide TON 2011 0.45 Sulfur Dioxide TON 2011 749.6258692 Sulfur Dioxide TON 2011 6324.931476 Sulfur Dioxide TON 2011 2907.532944 Sulfur Dioxide TON 2011 29.2596024 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 10.93961932 Sulfur Dioxide TON 2011 245.1531141 Sulfur Dioxide TON 2011 0.358543748 Sulfur Dioxide TON 2011 17 Sulfur Dioxide TON 2011 13100 Sulfur Dioxide TON 2011 40.331125 Sulfur Dioxide TON 2011 0.0045 Sulfur Dioxide TON 2011 11.322Sulfur Dioxide TON 2011 1043.945904 Sulfur Dioxide TON 2011 666.688985 Sulfur Dioxide TON 2011 53.08614744 Sulfur Dioxide TON 2011 1767.322446 Sulfur Dioxide TON 2011 206.5291572 Sulfur Dioxide TON 2011 13.44569632 Sulfur Dioxide TON 2011 552.3030337 Sulfur Dioxide TON 2011 0.92607156 Sulfur Dioxide TON 2011 308.8582665 Sulfur Dioxide TON 2011 24 Sulfur Dioxide TON 2011 38.14 Sulfur Dioxide TON 2011 47.614 Sulfur Dioxide TON 2011 0.646 Sulfur Dioxide TON 2011 319.523468 Sulfur Dioxide TON 2011 7.50119 Sulfur Dioxide TON 2011 0.041790723 Sulfur Dioxide TON 2011 0.17484 Sulfur Dioxide TON 2011 985.70457 Sulfur Dioxide TON 2011 16.26 Sulfur Dioxide TON 2011 1.93694696 Sulfur Dioxide TON 2011 135.7155119 Sulfur Dioxide TON 2011 720.3275082 Sulfur Dioxide TON 2011 105.7175058 Sulfur Dioxide TON 2011 38.43018958 Sulfur Dioxide TON 2011 15.5498621 Sulfur Dioxide TON 2011 8.004371404 Sulfur Dioxide TON 2011 47.45438057 Sulfur Dioxide TON 2011 1.677216626 Sulfur Dioxide TON 2011 15.55126693 Sulfur Dioxide TON 2011 277.5676768 Sulfur Dioxide TON 2011 1 Sulfur Dioxide TON 2011 1.010434 Sulfur Dioxide TON 2011 171.2020829 Sulfur Dioxide TON 2011 0.03 Sulfur Dioxide TON 2011 53.75053408 Sulfur Dioxide TON 2011 151.473594 Sulfur Dioxide TON 2011 11.106121 Sulfur Dioxide TON 2011 32.1085 Sulfur Dioxide TON 2011 2658.4353 Sulfur Dioxide TON 2011 46.0871 Sulfur Dioxide TON 2011 2551.2286 Sulfur Dioxide TON 2011 23.6699 Sulfur Dioxide TON 2011 21.6595 Sulfur Dioxide TON 2011 320503.8476 Sulfur Dioxide TON 2011 152.403 Sulfur Dioxide TON 2011 7810.9986 Sulfur Dioxide TON 2011 144.6285Sulfur Dioxide TON 2011 405.3068 Sulfur Dioxide TON 2011 25243.8124 Sulfur Dioxide TON 2011 199.8567 Sulfur Dioxide TON 2011 4302.6446 Sulfur Dioxide TON 2011 2253.8486 Sulfur Dioxide TON 2011 68.31274498 Sulfur Dioxide TON 2011 12797.44269 Sulfur Dioxide TON 2011 434.5914749 Sulfur Dioxide TON 2011 482.8073816 Sulfur Dioxide TON 2011 4003.0967 Sulfur Dioxide TON 2011 164.4722 Sulfur Dioxide TON 2011 734.293 Sulfur Dioxide TON 2011 451.1563 Sulfur Dioxide TON 2011 6831.7863 Sulfur Dioxide TON 2011 1052.3048 Sulfur Dioxide TON 2011 1952.200266 Sulfur Dioxide TON 2011 3453.3395 Sulfur Dioxide TON 2011 127.4518 Sulfur Dioxide TON 2011 4.2585 Sulfur Dioxide TON 2011 7.729230485 Sulfur Dioxide TON 2011 360.1355613 Sulfur Dioxide TON 2011 1268.589883 Sulfur Dioxide TON 2011 202.318329 Sulfur Dioxide TON 2011 87.28792925 Sulfur Dioxide TON 2011 41.17072812 Sulfur Dioxide TON 2011 27.74588675 Sulfur Dioxide TON 2011 161.9373027 Sulfur Dioxide TON 2011 4.003857463 Sulfur Dioxide TON 2011 45.42357953 Sulfur Dioxide TON 2011 754.7689603 Sulfur Dioxide TON 2011 0.0002 Sulfur Dioxide TON 2011 0.1475 Sulfur Dioxide TON 2011 3.706 Sulfur Dioxide TON 2011 868.85693 Sulfur Dioxide TON 2011 0.01 Sulfur Dioxide TON 2011 0.03940795 Sulfur Dioxide TON 2011 6.425917 Sulfur Dioxide TON 2011 0.502655 Sulfur Dioxide TON 2011 1.23749945 Sulfur Dioxide TON 2011 1.230075 Sulfur Dioxide TON 2011 410.1065624 Sulfur Dioxide TON 2011 0.0005 Sulfur Dioxide TON 2011 18.378 Sulfur Dioxide TON 2011 0.663 Sulfur Dioxide TON 2011 200.7645 Sulfur Dioxide TON 2011 2.3605 Sulfur Dioxide TON 2011 173.691025Sulfur Dioxide TON 2011 0.0175 Sulfur Dioxide TON 2011 5.374204 Sulfur Dioxide TON 2011 2814.068885 Sulfur Dioxide TON 2011 0.26330946 Sulfur Dioxide TON 2011 31.74716882 Sulfur Dioxide TON 2011 37.168975 Sulfur Dioxide TON 2011 0.5906841 Sulfur Dioxide TON 2011 29.9552267 Sulfur Dioxide TON 2011 209.9054119 Sulfur Dioxide TON 2011 0.511531027 Sulfur Dioxide TON 2011 5.587790929 Sulfur Dioxide TON 2011 3.416234841 Sulfur Dioxide TON 2011 2.445721104 Sulfur Dioxide TON 2011 4.680913278 Sulfur Dioxide TON 2011 0.311663589 Sulfur Dioxide TON 2011 2.137667754 Sulfur Dioxide TON 2011 69.92900434 Sulfur Dioxide TON 2011 363.6585471 Sulfur Dioxide TON 2011 75.84842 Sulfur Dioxide TON 2011 1571.938476 Sulfur Dioxide TON 2011 325.268594 Sulfur Dioxide TON 2011 10.94775635 Sulfur Dioxide TON 2011 37.8138067 Sulfur Dioxide TON 2011 6.648395941 Sulfur Dioxide TON 2011 21.4430521 Sulfur Dioxide TON 2011 4.756747142 Sulfur Dioxide TON 2011 28.5 Sulfur Dioxide TON 2011 71696.59437 Sulfur Dioxide TON 2011 75.00639373 Sulfur Dioxide TON 2011 63.26140753 Sulfur Dioxide TON 2011 36.06841738 Sulfur Dioxide TON 2011 1696.729595 Sulfur Dioxide TON 2011 9017.673795 Sulfur Dioxide TON 2011 81.48733606 Sulfur Dioxide TON 2011 1946.101072 Sulfur Dioxide TON 2011 2071.633306 Sulfur Dioxide TON 2011 8.14800472 Sulfur Dioxide TON 2011 213.0775315 Sulfur Dioxide TON 2011 5.769214444 Sulfur Dioxide TON 2011 24.07162654 Sulfur Dioxide TON 2011 519.98131 Sulfur Dioxide TON 2011 8.6071704 Sulfur Dioxide TON 2011 411.5911 Sulfur Dioxide TON 2011 2262.244743 Sulfur Dioxide TON 2011 3765.076075 Sulfur Dioxide TON 2011 0.004143 Sulfur Dioxide TON 2011 4350.460154Sulfur Dioxide TON 2011 0.52 Sulfur Dioxide TON 2011 2.44430435 Sulfur Dioxide TON 2011 79.34032455 Sulfur Dioxide TON 2011 1707.748407 Sulfur Dioxide TON 2011 84.16500172 Sulfur Dioxide TON 2011 41.86379756 Sulfur Dioxide TON 2011 17.73680599 Sulfur Dioxide TON 2011 8.807052959 Sulfur Dioxide TON 2011 95.13015549 Sulfur Dioxide TON 2011 2.196987966 Sulfur Dioxide TON 2011 25.10730701 Sulfur Dioxide TON 2011 398.9089235 Sulfur Dioxide TON 2011 0.2745 Sulfur Dioxide TON 2011 0.143904982 Sulfur Dioxide TON 2011 139.7148512 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 2219.919213 Sulfur Dioxide TON 2011 1176.531557 Sulfur Dioxide TON 2011 1279.874905 Sulfur Dioxide TON 2011 58.6 Sulfur Dioxide TON 2011 177.3 Sulfur Dioxide TON 2011 3.2 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.8 Sulfur Dioxide TON 2011 0.1 Sulfur Dioxide TON 2011 11101.3 Sulfur Dioxide TON 2011 0.7 Sulfur Dioxide TON 2011 13.4 Sulfur Dioxide TON 2011 14.5 Sulfur Dioxide TON 2011 1033.820255 Sulfur Dioxide TON 2011 58.4 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.118433892 Sulfur Dioxide TON 2011 4.078496864 Sulfur Dioxide TON 2011 116.495758 Sulfur Dioxide TON 2011 14.92332601 Sulfur Dioxide TON 2011 13.62547064 Sulfur Dioxide TON 2011 215 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 161.8 Sulfur Dioxide TON 2011 0.1 Sulfur Dioxide TON 2011 1.755466584 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 2.7 Sulfur Dioxide TON 2011 0.4 Sulfur Dioxide TON 2011 0.429367875 Sulfur Dioxide TON 2011 26.70678859Sulfur Dioxide TON 2011 37.6279072 Sulfur Dioxide TON 2011 44.10205702 Sulfur Dioxide TON 2011 4.134088551 Sulfur Dioxide TON 2011 1.499233301 Sulfur Dioxide TON 2011 15.50022391 Sulfur Dioxide TON 2011 0.404792237 Sulfur Dioxide TON 2011 3.987320686 Sulfur Dioxide TON 2011 72.78760667 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 16.6466035 Sulfur Dioxide TON 2011 1.08671 Sulfur Dioxide TON 2011 185.4927294 Sulfur Dioxide TON 2011 881.2300298 Sulfur Dioxide TON 2011 277.520901 Sulfur Dioxide TON 2011 13.9449382 Sulfur Dioxide TON 2011 4813.96929 Sulfur Dioxide TON 2011 33.03958497 Sulfur Dioxide TON 2011 21.23845106 Sulfur Dioxide TON 2011 0.003770761 Sulfur Dioxide TON 2011 0.73 Sulfur Dioxide TON 2011 120108.401 Sulfur Dioxide TON 2011 8.10665695 Sulfur Dioxide TON 2011 12.58616099 Sulfur Dioxide TON 2011 39.7082015 Sulfur Dioxide TON 2011 1925.484991 Sulfur Dioxide TON 2011 73671.0448 Sulfur Dioxide TON 2011 54.94444347 Sulfur Dioxide TON 2011 163.232132 Sulfur Dioxide TON 2011 4.923575741 Sulfur Dioxide TON 2011 21.20512007 Sulfur Dioxide TON 2011 262.9687231 Sulfur Dioxide TON 2011 235.057215 Sulfur Dioxide TON 2011 44.90568509 Sulfur Dioxide TON 2011 85.67 Sulfur Dioxide TON 2011 493.9050331 Sulfur Dioxide TON 2011 308.7411254 Sulfur Dioxide TON 2011 1673.48464 Sulfur Dioxide TON 2011 292.6924749 Sulfur Dioxide TON 2011 1.555408996 Sulfur Dioxide TON 2011 154.2713664 Sulfur Dioxide TON 2011 941.93075 Sulfur Dioxide TON 2011 3.7006221 Sulfur Dioxide TON 2011 3.019902095 Sulfur Dioxide TON 2011 398.6428461 Sulfur Dioxide TON 2011 30.6706936 Sulfur Dioxide TON 2011 189.8808902 Sulfur Dioxide TON 2011 59.11691494Sulfur Dioxide TON 2011 22.42456646 Sulfur Dioxide TON 2011 21.47214992 Sulfur Dioxide TON 2011 137.2095835 Sulfur Dioxide TON 2011 3.149039252 Sulfur Dioxide TON 2011 30.54993228 Sulfur Dioxide TON 2011 583.5723505 Sulfur Dioxide TON 2011 11.04271211 Sulfur Dioxide TON 2011 6.184048732 Sulfur Dioxide TON 2011 173.6820016 Sulfur Dioxide TON 2011 1.1195 Sulfur Dioxide TON 2011 725.6159309 Sulfur Dioxide TON 2011 494.8271788 Sulfur Dioxide TON 2011 18643.19101 Sulfur Dioxide TON 2011 23.3278 Sulfur Dioxide TON 2011 103.7389846 Sulfur Dioxide TON 2011 95.73227684 Sulfur Dioxide TON 2011 1.247581211 Sulfur Dioxide TON 2011 425879.3731 Sulfur Dioxide TON 2011 461.8635 Sulfur Dioxide TON 2011 44.4463 Sulfur Dioxide TON 2011 1166.8621 Sulfur Dioxide TON 2011 210.0782 Sulfur Dioxide TON 2011 149.1593 Sulfur Dioxide TON 2011 7015.231096 Sulfur Dioxide TON 2011 8766.597982 Sulfur Dioxide TON 2011 3170.1155 Sulfur Dioxide TON 2011 64.80326484 Sulfur Dioxide TON 2011 4.053839367 Sulfur Dioxide TON 2011 26.46474557 Sulfur Dioxide TON 2011 96.29321952 Sulfur Dioxide TON 2011 0.0001 Sulfur Dioxide TON 2011 9011.0736 Sulfur Dioxide TON 2011 20342.3823 Sulfur Dioxide TON 2011 685.1183 Sulfur Dioxide TON 2011 10673.7189 Sulfur Dioxide TON 2011 1516.7927 Sulfur Dioxide TON 2011 16233.16925 Sulfur Dioxide TON 2011 21433.9199 Sulfur Dioxide TON 2011 2610.3968 Sulfur Dioxide TON 2011 273.3164 Sulfur Dioxide TON 2011 10.01840141 Sulfur Dioxide TON 2011 957.6757811 Sulfur Dioxide TON 2011 4800.704225 Sulfur Dioxide TON 2011 690.1945655 Sulfur Dioxide TON 2011 114.758067 Sulfur Dioxide TON 2011 51.24694731 Sulfur Dioxide TON 2011 38.69772822Sulfur Dioxide TON 2011 211.3019884 Sulfur Dioxide TON 2011 10.14014794 Sulfur Dioxide TON 2011 80.77731511 Sulfur Dioxide TON 2011 1719.306204 Sulfur Dioxide TON 2011 0.0066 Sulfur Dioxide TON 2011 0.3527 Sulfur Dioxide TON 2011 312.7976 Sulfur Dioxide TON 2011 308.9968241 Sulfur Dioxide TON 2011 61.1283765 Sulfur Dioxide TON 2011 352.416001 Sulfur Dioxide TON 2011 219.666439 Sulfur Dioxide TON 2011 3.950001705 Sulfur Dioxide TON 2011 181.287891 Sulfur Dioxide TON 2011 15.95887277 Sulfur Dioxide TON 2011 363.635415 Sulfur Dioxide TON 2011 2.80146166 Sulfur Dioxide TON 2011 20406.954 Sulfur Dioxide TON 2011 14.557523 Sulfur Dioxide TON 2011 4.095001 Sulfur Dioxide TON 2011 17.0382 Sulfur Dioxide TON 2011 2.624999145 Sulfur Dioxide TON 2011 1802.8738 Sulfur Dioxide TON 2011 11.684964 Sulfur Dioxide TON 2011 880.2688799 Sulfur Dioxide TON 2011 166.077832 Sulfur Dioxide TON 2011 19.55520297 Sulfur Dioxide TON 2011 21.56346882 Sulfur Dioxide TON 2011 8.5524147 Sulfur Dioxide TON 2011 52.52701883 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 344.3733 Sulfur Dioxide TON 2011 11.943734 Sulfur Dioxide TON 2011 44.81779 Sulfur Dioxide TON 2011 2.692759 Sulfur Dioxide TON 2011 182.191359 Sulfur Dioxide TON 2011 693.75299 Sulfur Dioxide TON 2011 343.067935 Sulfur Dioxide TON 2011 988.495355 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 3.2772 Sulfur Dioxide TON 2011 2.208686928 Sulfur Dioxide TON 2011 150.9889186 Sulfur Dioxide TON 2011 93.7336734 Sulfur Dioxide TON 2011 23.65289493 Sulfur Dioxide TON 2011 9.934374319 Sulfur Dioxide TON 2011 9.003072804 Sulfur Dioxide TON 2011 52.37457059Sulfur Dioxide TON 2011 1.634304888 Sulfur Dioxide TON 2011 14.75925797 Sulfur Dioxide TON 2011 254.2197493 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 38.79234235 Sulfur Dioxide TON 2011 3.7625552 Sulfur Dioxide TON 2011 4.112718 Sulfur Dioxide TON 2011 0.495255 Sulfur Dioxide TON 2011 11.7750087 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.712312 Sulfur Dioxide TON 2011 815.9831761 Sulfur Dioxide TON 2011 0.451821785 Sulfur Dioxide TON 2011 2.33 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 1.303645 Sulfur Dioxide TON 2011 0.00021625 Sulfur Dioxide TON 2011 25.80128025 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 1.04574 Sulfur Dioxide TON 2011 1158.029906 Sulfur Dioxide TON 2011 0.084434627 Sulfur Dioxide TON 2011 0.925 Sulfur Dioxide TON 2011 1074.088 Sulfur Dioxide TON 2011 1.8662062 Sulfur Dioxide TON 2011 238.721017 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0.31614331 Sulfur Dioxide TON 2011 11.46978658 Sulfur Dioxide TON 2011 4.410443392 Sulfur Dioxide TON 2011 5.389500428 Sulfur Dioxide TON 2011 4.033065452 Sulfur Dioxide TON 2011 1.361763127 Sulfur Dioxide TON 2011 7.634843237 Sulfur Dioxide TON 2011 0.235751008 Sulfur Dioxide TON 2011 1.758034266 Sulfur Dioxide TON 2011 56.44605339 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 5.71291702 Sulfur Dioxide TON 2011 48.24530891 Sulfur Dioxide TON 2011 755.125316 Sulfur Dioxide TON 2011 679.713095 Sulfur Dioxide TON 2011 17.1440955 Sulfur Dioxide TON 2011 1053.4368 Sulfur Dioxide TON 2011 20.3512234Sulfur Dioxide TON 2011 646.0359731 Sulfur Dioxide TON 2011 3.0794425 Sulfur Dioxide TON 2011 11.34 Sulfur Dioxide TON 2011 68887.47247 Sulfur Dioxide TON 2011 53.033006 Sulfur Dioxide TON 2011 1071.893 Sulfur Dioxide TON 2011 6.305403 Sulfur Dioxide TON 2011 296.1235065 Sulfur Dioxide TON 2011 11486.9383 Sulfur Dioxide TON 2011 38.28595745 Sulfur Dioxide TON 2011 3407.485292 Sulfur Dioxide TON 2011 115.7201412 Sulfur Dioxide TON 2011 16.1478 Sulfur Dioxide TON 2011 2731.513 Sulfur Dioxide TON 2011 192.1769 Sulfur Dioxide TON 2011 204.6849346 Sulfur Dioxide TON 2011 1917.74 Sulfur Dioxide TON 2011 214.151659 Sulfur Dioxide TON 2011 107.53634 Sulfur Dioxide TON 2011 22.9064 Sulfur Dioxide TON 2011 7341.040895 Sulfur Dioxide TON 2011 0.055434 Sulfur Dioxide TON 2011 9.809019763 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 926.5437025 Sulfur Dioxide TON 2011 0.025 Sulfur Dioxide TON 2011 3.5939 Sulfur Dioxide TON 2011 575.4427324 Sulfur Dioxide TON 2011 1104.954169 Sulfur Dioxide TON 2011 178.9881479 Sulfur Dioxide TON 2011 67.54461704 Sulfur Dioxide TON 2011 27.62430975 Sulfur Dioxide TON 2011 21.9098999 Sulfur Dioxide TON 2011 101.9969806 Sulfur Dioxide TON 2011 1.991341092 Sulfur Dioxide TON 2011 15.82171997 Sulfur Dioxide TON 2011 608.0511098 Sulfur Dioxide TON 2011 0.305655 Sulfur Dioxide TON 2011 1469.390375 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 212.6065355 Sulfur Dioxide TON 2011 1470.393781 Sulfur Dioxide TON 2011 348.317921 Sulfur Dioxide TON 2011 23.22501234 Sulfur Dioxide TON 2011 26.00145 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 2.4335Sulfur Dioxide TON 2011 55.739 Sulfur Dioxide TON 2011 1136 Sulfur Dioxide TON 2011 8.9831 Sulfur Dioxide TON 2011 1.0608 Sulfur Dioxide TON 2011 0.005 Sulfur Dioxide TON 2011 1158.6 Sulfur Dioxide TON 2011 35.8229 Sulfur Dioxide TON 2011 762.035732 Sulfur Dioxide TON 2011 301.006 Sulfur Dioxide TON 2011 22.66619077 Sulfur Dioxide TON 2011 886.8964261 Sulfur Dioxide TON 2011 2.81696191 Sulfur Dioxide TON 2011 279.8031195 Sulfur Dioxide TON 2011 51.202 Sulfur Dioxide TON 2011 153.91 Sulfur Dioxide TON 2011 78.93 Sulfur Dioxide TON 2011 159.7955 Sulfur Dioxide TON 2011 7444.505 Sulfur Dioxide TON 2011 907.66 Sulfur Dioxide TON 2011 1383.0735 Sulfur Dioxide TON 2011 0.01 Sulfur Dioxide TON 2011 2.94753814 Sulfur Dioxide TON 2011 351.1428447 Sulfur Dioxide TON 2011 11528.93085 Sulfur Dioxide TON 2011 107.3397936 Sulfur Dioxide TON 2011 63.17108365 Sulfur Dioxide TON 2011 25.45759986 Sulfur Dioxide TON 2011 14.24872074 Sulfur Dioxide TON 2011 102.4347837 Sulfur Dioxide TON 2011 3.073100572 Sulfur Dioxide TON 2011 44.76793778 Sulfur Dioxide TON 2011 484.012372 Sulfur Dioxide TON 2011 0.028 Sulfur Dioxide TON 2011 191.7910528 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 6.28074843 Sulfur Dioxide TON 2011 412.904637 Sulfur Dioxide TON 2011 262.789919 Sulfur Dioxide TON 2011 19.04998905 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 3.569811248 Sulfur Dioxide TON 2011 96.51829049 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 93063.8 Sulfur Dioxide TON 2011 2.15470967 Sulfur Dioxide TON 2011 14.452646 Sulfur Dioxide TON 2011 0Sulfur Dioxide TON 2011 14.924 Sulfur Dioxide TON 2011 15305.0531 Sulfur Dioxide TON 2011 9.78227635 Sulfur Dioxide TON 2011 462.2103666 Sulfur Dioxide TON 2011 450.3900341 Sulfur Dioxide TON 2011 8.1188625 Sulfur Dioxide TON 2011 521.28677 Sulfur Dioxide TON 2011 40.477778 Sulfur Dioxide TON 2011 70.60991211 Sulfur Dioxide TON 2011 1276 Sulfur Dioxide TON 2011 176.7814677 Sulfur Dioxide TON 2011 1182.2323 Sulfur Dioxide TON 2011 606.06 Sulfur Dioxide TON 2011 447.6771338 Sulfur Dioxide TON 2011 547.2492 Sulfur Dioxide TON 2011 2638.578157 Sulfur Dioxide TON 2011 6031.955 Sulfur Dioxide TON 2011 9.80958 Sulfur Dioxide TON 2011 0.00011 Sulfur Dioxide TON 2011 1.195286 Sulfur Dioxide TON 2011 13.58855331 Sulfur Dioxide TON 2011 39.58891312 Sulfur Dioxide TON 2011 111.1127422 Sulfur Dioxide TON 2011 11.14513193 Sulfur Dioxide TON 2011 6.445891338 Sulfur Dioxide TON 2011 2.06398731 Sulfur Dioxide TON 2011 30.25294643 Sulfur Dioxide TON 2011 0.674767328 Sulfur Dioxide TON 2011 6.453943415 Sulfur Dioxide TON 2011 139.9205615 Sulfur Dioxide TON 2011 0.716 Sulfur Dioxide TON 2011 62.64614 Sulfur Dioxide TON 2011 87.40683357 Sulfur Dioxide TON 2011 289.6853543 Sulfur Dioxide TON 2011 4.47714 Sulfur Dioxide TON 2011 2.859077341 Sulfur Dioxide TON 2011 1122.732282 Sulfur Dioxide TON 2011 25.90682099 Sulfur Dioxide TON 2011 102.8834699 Sulfur Dioxide TON 2011 149.9963176 Sulfur Dioxide TON 2011 302.8111084 Sulfur Dioxide TON 2011 90976.23825 Sulfur Dioxide TON 2011 17.57116819 Sulfur Dioxide TON 2011 7.649042315 Sulfur Dioxide TON 2011 344.9224589 Sulfur Dioxide TON 2011 187.7666186 Sulfur Dioxide TON 2011 40337.8803Sulfur Dioxide TON 2011 61.26632006 Sulfur Dioxide TON 2011 494.8859483 Sulfur Dioxide TON 2011 3716.093377 Sulfur Dioxide TON 2011 39.9527852 Sulfur Dioxide TON 2011 1163.863538 Sulfur Dioxide TON 2011 197.1979525 Sulfur Dioxide TON 2011 908.1966378 Sulfur Dioxide TON 2011 34.17029293 Sulfur Dioxide TON 2011 530.3808506 Sulfur Dioxide TON 2011 0.80107 Sulfur Dioxide TON 2011 3205.054621 Sulfur Dioxide TON 2011 73.94011567 Sulfur Dioxide TON 2011 0.01136308 Sulfur Dioxide TON 2011 145.4700439 Sulfur Dioxide TON 2011 1277.682477 Sulfur Dioxide TON 2011 2.79947523 Sulfur Dioxide TON 2011 2.838135195 Sulfur Dioxide TON 2011 131.7702431 Sulfur Dioxide TON 2011 307.012034 Sulfur Dioxide TON 2011 121.8208257 Sulfur Dioxide TON 2011 70.7127352 Sulfur Dioxide TON 2011 36.75950631 Sulfur Dioxide TON 2011 14.42094686 Sulfur Dioxide TON 2011 97.58218085 Sulfur Dioxide TON 2011 2.775987223 Sulfur Dioxide TON 2011 35.58114916 Sulfur Dioxide TON 2011 462.6231035 Sulfur Dioxide TON 2011 0.08968565 Sulfur Dioxide TON 2011 374.6671103 Sulfur Dioxide TON 2011 0.04 Sulfur Dioxide TON 2011 70.04638394 Sulfur Dioxide TON 2011 2337.58656 Sulfur Dioxide TON 2011 3036.370093 Sulfur Dioxide TON 2011 20.5378 Sulfur Dioxide TON 2011 7356.7273 Sulfur Dioxide TON 2011 3.17939758 Sulfur Dioxide TON 2011 159.133 Sulfur Dioxide TON 2011 35423.88 Sulfur Dioxide TON 2011 0.051 Sulfur Dioxide TON 2011 165.89802 Sulfur Dioxide TON 2011 2.5 Sulfur Dioxide TON 2011 21182.47 Sulfur Dioxide TON 2011 195.838925 Sulfur Dioxide TON 2011 212.5205 Sulfur Dioxide TON 2011 16.87995 Sulfur Dioxide TON 2011 3.7967999 Sulfur Dioxide TON 2011 21.38106632Sulfur Dioxide TON 2011 39.051134 Sulfur Dioxide TON 2011 14.60076461 Sulfur Dioxide TON 2011 282.56 Sulfur Dioxide TON 2011 1700.91 Sulfur Dioxide TON 2011 647.815 Sulfur Dioxide TON 2011 957.63 Sulfur Dioxide TON 2011 3874.8776 Sulfur Dioxide TON 2011 1623.975 Sulfur Dioxide TON 2011 41.6 Sulfur Dioxide TON 2011 0.256044165 Sulfur Dioxide TON 2011 15.82417272 Sulfur Dioxide TON 2011 386.5904431 Sulfur Dioxide TON 2011 13.13997809 Sulfur Dioxide TON 2011 3.561419549 Sulfur Dioxide TON 2011 0.964004207 Sulfur Dioxide TON 2011 26.41315115 Sulfur Dioxide TON 2011 0.392253702 Sulfur Dioxide TON 2011 3.832600282 Sulfur Dioxide TON 2011 70.16541352 Sulfur Dioxide TON 2011 13.28804059 Sulfur Dioxide TON 2011 1.2151204 Sulfur Dioxide TON 2011 0.336763885 Sulfur Dioxide TON 2011 171.1651414 Sulfur Dioxide TON 2011 6.0195632 Sulfur Dioxide TON 2011 196.4 Sulfur Dioxide TON 2011 176.126558 Sulfur Dioxide TON 2011 33951.95162 Sulfur Dioxide TON 2011 0.033 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 1593.943291 Sulfur Dioxide TON 2011 0.00585841 Sulfur Dioxide TON 2011 279.36 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 56.4510004 Sulfur Dioxide TON 2011 1.58 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 1.745429355 Sulfur Dioxide TON 2011 707.8669045 Sulfur Dioxide TON 2011 0.31512721 Sulfur Dioxide TON 2011 16.89703768 Sulfur Dioxide TON 2011 10.52556036 Sulfur Dioxide TON 2011 3.901636448 Sulfur Dioxide TON 2011 7.83351014 Sulfur Dioxide TON 2011 171.7055366 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 0 Sulfur Dioxide TON 2011 51.35384723Sulfur Dioxide TON 2011 0.042391025 Sulfur Dioxide TON 2011 110.0558394 Sulfur Dioxide TON 2011 1.096508619 Sulfur Dioxide TON 2011 0.436000652 Sulfur Dioxide TON 2011 0.249214056 Sulfur Dioxide TON 2011 0.052847945 Sulfur Dioxide TON 2011 3.210390312 Sulfur Dioxide TON 2011 0.07991666 Sulfur Dioxide TON 2011 0.010353292 Sulfur Dioxide TON 2011 0.268669706 Sulfur Dioxide TON 2011 8.49652934 Sulfur Dioxide TON 2011 0.084765272 Sulfur Dioxide TON 2011 17.97671396 Sulfur Dioxide TON 2011 0.027684286 Sulfur Dioxide TON 2011 17642.501 Sulfur Dioxide TON 2011 0.3 Sulfur Dioxide TON 2011 0.01 Sulfur Dioxide TON 2011 26.4325296 Sulfur Dioxide TON 2011 25.8190179 Sulfur Dioxide TON 2011 5.309589552 Sulfur Dioxide TON 2011 5.010437182 Sulfur Dioxide TON 2011 0.025934951 Sulfur Dioxide TON 2011 0.080626445 Sulfur Dioxide TON 2011 14.6964505 Sulfur Dioxide TON 2011 3.443401729 Sulfur Dioxide TON 2011 1.207046052 Sulfur Dioxide TON 2011 0.482763 Sulfur Dioxide TON 2011 130.945 Sulfur Dioxide TON 2011 0.3 Sulfur Dioxide TON 2011 0.074616493 Sulfur Dioxide TON 2011 0.33445185 Sulfur Dioxide TON 2011 0.201044 Sulfur Dioxide TON 2011 0.0111136 Sulfur Dioxide TON 2011 0.00233744 Sulfur Dioxide TON 2011 0.00041119 Sulfur Dioxide TON 2011 0.28298

# Exhibit 5

## AERMOD Modeling of SO2 Impacts of the Minnesota Power Boswell Coal Plant

Final Report

October 6, 2011

Prepared for

SIERRA CLUB San Francisco, California

Prepared by Mr. Khanh T. Tran Principal



## AMI Environmental 206 Black Eagle Ave Henderson, NV 89002

Tel. (714)679-7363

### 2 Table of Contents

Page I. Introduction 3
II. Modeling Methodologies 3
III. Modeling Results 5

IV. Conclusions 9

V. References 9
Appendix A - Summary of 1-hr Modeling Results of Allowable Emissions 10 Appendix B - Summary of 1-hr Modeling Results of Actual Emissions 12

### 3 I. INTRODUCTION
This document presents the methodologies and results of an application of the AERMOD model to predict the air quality impacts of sulfur dioxide (SO2) emitted by the Boswell Energy Center. Boswell is a coal-fired power plant owned and operated by Minnesota Power near Cohasset, Minnesota (Figure 1). It consists of four coal-fired boilers with a total electric generating capacity of 1,073 MW (gross). SO2 impacts were predicted by the AERMOD model according to the Sierra Club Modeling Protocol and compared against the 1-hour SO2 National Ambient Air Quality Standard (NAAQS) of 75 ppb (or 196 ug/m3) which was promulgated in June 2010 by the U.S. Environmental Protection Agency (EPA).

Figure 1. Minnesota Power Boswell Coal Plant

II. MODELING METHODOLOGIES
This section documents the methodologies and assumptions used in the generation of modeling inputs such as source emissions, stack parameters, receptors and meteorological data.

### 4 A. Model Version
Version 11103 of the AERMOD model has been used in the modeling study. It is currently the latest version of the model that has been approved by the US Environmental Protection Agency ( US EPA, 2011). It predicts the 1-hour SO2 concentrations that can be compared against the 1-hour NAAQS which is attained when the 3- year average of the 99 th 

### percentile of the daily maximum 1-hour concentrations does not exceed 75 ppb (or 196 ug/m3) at each monitor within an area (USEPA, 2010a; 2010b).

B. Source Emissions

Four c oal -fired boilers at the plant emit SO2. Based on the facility's governing Title V permit 06100004-005 (page 80 in Appendix B-1) issued by Minnesota Pollution Control Agency (MPCA) on July 10, 2010, maximum hourly allowable emissions are:

 19,420 lbs/hr for Unit s 1,2 and 3,

 6,130 lbs/hr for Unit 4 and,

 a total of 25,550 lbs/hr for all boilers.

In addition to the above allowable emissions, the US EPA Clean Air Market database had been searched to identify the maximum plant-wide hourly emissions that actually occurred in 2010. This search indicated that the maximum hourly emissions occurred on February 5, 2010, hour 16. The following actual emissions were retrieved from the US EPA Clean Air Market database:

 777.5 lb s/hr for Unit 1, 938.3 lbs/hr for Unit 2,

 178.7 lbs/hr for Unit 3 and 1,982.6 lbs/hr for Unit 4,

 a total of 3,877.1 lbs/hr for all boilers.
Both allowable and actual emissions were modeled as emitted from the plant's stack s (SV03 for Units 1-3 and SV04 for Unit 4). They have been converted to grams per second (g/s) in Table 1 as required by the AERMOD mod el

.

C. Stack Para meters
Stack parameters (stack height, diameter, temperature an d exit velocity) for stacks SV03 and SV04 are shown in Table 1. They were provided in the Facility Permit No. 06100004-005 (page 80 in Appendix B-1) issued by MPCA on July 10, 2010 and used in modeling both the maximum allowable and 2010 actual emissions.

### 5 Table 1. Plant SO2 Allowable and 2010 Actual Emissions & Stack Parameters

Stack Allowable SO2 (g/s ) Actual SO2 (g/s) Height (m) Diameter (m) Temperature (K) Veloci ty (m/s)

S V03 2446.9 364.707 192.44 8.84 361.48 12.64 S V04 772.46 249.8076 170.31 6.10 343.15 35.85

D. Receptors
The current AERMOD modeling uses a Cartesian grid of discrete receptors that are located within a radius of 50 km around the Boswell plant. The receptor grid has varying resolutions: 100 m within the first 10 km and 500 m between 10 km and 50 km. Receptors located on-site within the plant boundaries have been removed from consideration. A total of 80,822 receptors have been used in the AERMOD modeling. A flagpole height of 1.5 m was also assigned to the modeled receptors. The preprocessor AERMAP has been employed to obtain terrain elevations at these receptors using the NED data and the NAD83 datum.

E. Meteorological Data
The AERMOD modeling uses the 2006-2010 surface meteorological data from Hibbing Chisholm Airport and upper-air data from International Falls. This dataset has been processed by MPCA. It has 422 calm hours and 2,080 hours with missing data (4.75% of possible 43,824 hours).

F. Background Concentration
For comparison with the SO2 1-hour NAAQS, background concentrations at a monitoring station are added to the concentrations predicted by the AERMOD model. There is no monitoring near Cohasset. Monitoring data from the EPA AirData indicate that the 2007 maximum 1-hour SO2 of 10 ppb (26.2 ug/m3) was measured in Fargo, Cass County, North Dakota. This value is appropriate as a background since Boswell is an existing facility so that "double counting" should be minimized.

III. MODELING RESULTS
In June 2010, US EPA announced a new 1-hour NAAQS which is attained when the 3- year average of the 99 th 

### percentile of the daily maximum 1-hour SO2 concentrations does not exceed 75 ppb (or 196 ug/m3) at each monitor within an area. Subsequently, US EPA issued in August 2010 a modeling guidance for using the AERMOD model with

### 6 one year or five year s of meteorological data (USEPA, 2010b). According to the US EPA, the 4 th 

### highest maximum daily 1-hour concentrations obtained with one year of onsite data or averaged over the modeled five years of offsite data should be used in the NAA QS comparison.

A. Predicted Impacts by Allowable Emissions

An AERMOD modeling run with the 2006-2010 meteorological data and maximum allowable emissions was performed. SO2 modeling results for the 4 th 

### highest concentrations are summarized in Appendix A and presented in Table 2. The AERMOD model has predicted a 4 th 

### highest (99 th 

### percentile) concentration of 533.0 ug/m3 from the plant emissions alone. This concentration s largely e xceed s, by more than a factor of 2, the NAAQS of 196 ug/m3. With the background of 26.2 ug/m3, the maximum total 4 th 

### highest concentration is 559.2 ug/m3 which is 185% above the 1-hour NAAQS of 196 ug/m3. The maximum 99 th 

### percentile has been predicted to occur at about 3.75 km (about 2.3 mi.) sou th of the plant. A plot of the contour of 196 ug/m3 is shown in Figure 2. This figure shows that the area with concentrations exceeding 196 ug/m3, i.e. violating the 1-hr NAAQS due to the plant emissions alone, has a radius of about 10 miles around the plant.
The emission reduction required to mitigate the NAAQS exceedances can be calculated from the formula R = [C-(196-B)]/C where C is the plant 4 th 

### highest concentration and B is the background. With C= 533.0 ug/m3 and B=26.2 ug/m3, the required emission reduction is R= 0.68 or 68%. This 68% reduction will decrease the allowable emissions from 25,550 lbs/hr to 8,176 lbs/hr.

Table 2. Predicted 1-Hour SO2 Impacts by Allowable Emissions of the Minnesota Power Boswell Plant

Pollutant Project Conc. (ug/m3) Backgroun d Conc. (ug/m3) Total Conc. (ug/m3) NAAQS (ug/m3) NAAQS Exceed Percent Over NAAQS

1

- hour SO2 (4 th 

### highest) 533.0 26.2 559.2 196 YES 185 %

### 7 Figure 2. Area with 4 th 

### Highest SO2 Co ncentrations Exceeding the 1-Hour NAAQS of 196 ug/m3 by Plant Allowable Emissions Alone

### 8 B. Predicted Impacts by 2010 Actual Emissions
An AERMOD modeling run with maximum actual hourly emissions in 2010 was also performed. SO2 modeling results for the 4 th 

### highest concentrations are summarized in Appendix B and presented in Table 3. The AERMOD model predicted a 4 th 

### highest (99 th 

### percentile) concentration of 101.8 ug/m3 from the plant emissions alone. This concentration is below the NAAQS of 196 ug/m3. With the background of 26.2 ug/m3, the maximum total 4 th 

### highest concentration is 128.0 ug/m3 which is below the 1-hour NAAQS of 196 ug/m3. The maximum 99 th 

### percentile has been predicted to occur about 3.3 km (about 2 mi.) sou th east of the plant.

Table 3. Predicted 1-Hour SO2 Impacts by 2010 Actual Emissions of the Minnesota Power Boswell Plant

Pollutant Project Conc. (ug/m3) Background Conc. (ug/m3) Total Conc. (ug/m3) NAAQS (ug/m3) NAAQS Exceed Percent Over NAAQS

1

- hour SO2 (4 th 

### highest) 1 01 .8 26.2 1 28.0 196 NO

---

### 9 IV. CONCLUSIONS

Ai r quality impacts of SO2 emissions from the Minnesota Power Boswell facility have been analyzed with the AERMOD model. Using maximum allowable emissions in the MPCA permit, the 2006-2010 Hibbing meteorological data and the latest US EPA modeling guidance, the AERMOD model predicted large exceedances (up to 185%) of the SO2 1-hour NAAQS of 196 ug/m3. These exceedances occur within an area with a radius of 10 miles around the facility. Concentrations predicted with the 2010 actual emissions are below the 1-hour standard. Thus, SO2 impacts from the Boswell coal plant are significant since its SO2 allowable emissions alone cause exceedances of the 1-hour NAAQS. A 68% reduction in allowable SO2 emissions is required to mitigate these NAAQS violations.

V. REFERENCES

U.S. EPA, 2011. Addendum to User’ s Guide of the AMS/EPA Regulatory Model AERMOD version 11103, March 2011. Available at: http://www.epa.gov/ttn/scram/models/aermod/aermod_userguide.zip

U.S. EPA, 2010a. Guidance Concerning the Implementation of the 1-hour SO2 NAAQS for the Prevention of Significant Deterioration Program . Memorandum issued on August 23, 2010 from Stephen D. Page, Director of OAQPS. Available at http://www.epa.gov/region07/air/nsr/nsrmemos/appwso2.pdf

U.S. EPA, 2010b. Applicability of Appendix W Modeling Guidance for the 1-hour SO2 NAAQS . Memorandum issued on August 23, 2010 from Tyler Fox, Leader of Air Quality Modeling Group, OAQPS. Available at http://www.epa.gov/region07/air/nsr/nsrmemos/appwso2.pdf

-

### 10 Appendix A
Summary of AERMOD 1-hour Modeling Results of Allowable Emissions

### 11 *** AERMOD - VERSION 11103 *** *** Boswell - SO2 Run with Allowable Emissions - 5 Year Run *** 09/30/11 *** *** 02:11:25 PAGE 5 **MODELOPTs: RegDFAULT CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 4TH-HIGHEST MAX DAILY 1- HR R ESULTS AVERAGED OVER 5 YEARS ***

** CONC OF SO2 IN MICROGRAMS/M**3 **

NETWORK GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID- ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ALL 1ST HIGHEST VALUE IS 532.99318 AT ( 451400.00, 5230700.00, 394.27, 394.27, 1.50) DC 2ND HIGHEST VALUE IS 532.71969 AT ( 451600.00, 5231100.00, 388.26, 388.26, 1.50) DC 3RD HIGHEST VALUE IS 532.71969 AT ( 451600.00, 5231100.00, 388.26, 388.26, 1.50) DC 4TH HIGHEST VALUE IS 532.30986 AT ( 451400.00, 5230800.00, 394.30, 394.30, 1.50) DC 5TH HIGHEST VALUE IS 532.00525 AT ( 4514 00.00, 5230600.00, 393.35, 393.35, 1.50) DC 6TH HIGHEST VALUE IS 529.03487 AT ( 451500.00, 5231400.00, 388.26, 388.26, 1.50) DC 7TH HIGHEST VALUE IS 526.99027 AT ( 451400.00, 5230900.00, 391.66, 391.66, 1.50) DC 8TH HIGHEST VALUE IS 526.87668 AT ( 451600.00, 5231200.00, 388.26, 388.26, 1.50) DC 9TH HIGHEST VALUE IS 526.83380 AT ( 451400.00, 5230500.00, 390.59, 390.59, 1.50) DC 10TH HIGHEST VALUE IS 525.44264 AT ( 451500.00, 5231300.00, 388.26, 388.26, 1.50) DC

*** RECEPTOR TYPES: GC = GRIDCART GP = GRIDPOLR DC = DISCCART DP = DISCPOLR

### 12 Appendix B
Summary of AERMOD 1-hour Modeling Results of Actual Emissions

### 13 *** AERMOD - VERSION 11103 *** *** Boswell - SO2 Run with Actual Emissions - 5 Year Run *** 10/04/11 *** *** 04:11:37 PAGE 5 **MODELOPTs: RegDFAULT CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 4 TH -HIGHEST MAX DAILY 1-HR RESULTS AVERAGED OVER 5 YEARS ***

** CONC OF SO2 IN MICROGRAMS/M**3 **

NETWORK GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID- ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ALL 1ST HIGHEST VALUE IS 101.78458 AT ( 451600.00, 5231200.00, 388.26, 388.26, 1.50) DC 2ND HIGHEST VALUE IS 101.20578 AT ( 451500.00, 5231500.00, 392.01, 392.01, 1.50) DC 3RD HIGHEST VALUE IS 101.04583 AT ( 451400.00, 5230800.00, 394.30, 394.30, 1.50) DC 4TH HIGHEST VALUE IS 100.99621 AT ( 451400.00, 5230700.00, 394.27, 394.27, 1.50) DC 5TH HIGHEST VALUE IS 100.81868 AT ( 451400.00, 5230900.00, 391.66, 391.66, 1.50) DC 6TH HIGHEST VALUE IS 100.56230 AT ( 447200.00, 5235800.00, 408.28, 408.28, 1.50) DC 7TH HIGHEST VALUE IS 100.53629 AT ( 451400.00, 5230600.00, 393.35, 393.35, 1.50) DC 8TH HIGHEST VALUE IS 100.32812 AT ( 447100.00, 5235800.00, 405.28, 405.28, 1.50) DC 9TH HIGHEST VALUE IS 100.14551 AT ( 451600.00, 5231 100.00, 388.26, 388.26, 1.50) DC 10TH HIGHEST VALUE IS 100.14551 AT ( 451600.00, 5231100.00, 388.26, 388.26, 1.50) DC

*** RECEPTOR TYPES: GC = GRIDCART GP = GRIDPOLR DC = DISCCART DP = DISCPOLR

# Exhibit 6

## AERMOD Modeling of SO2 Impacts of the Otter Tail Hoot Lake Coal Plant

Final Report

October 4, 2011

Prepared for

SIERRA CLUB San Francisco, California

Prepared by Mr. Khanh T. Tran Principal



## AMI Environmental 206 Black Eagle Ave Henderson, NV 89002

Tel. (714)679-7363

### 2 Table of Contents

Page I. Introduction 3
II. Modeling Methodologies 3
III. Modeling Results 5

IV. Conclusions 9

V. References 9
Appendix A - Summary of 1-hr Modeling Results of Allowable Emissions 10 Appendix B - Summary of 1-hr Modeling Results of Actual Emissions 12

### 3 I. INTRODUCTION
This document presents the methodologies and results of an application of the AERMOD model to predict the air quality impacts of sulfur dioxide (SO2) emitted by the Hoot Lake Steam Station. Hoot Lake is a coal-fired power plant owned and operated by Otter Tail Power near Fergus Falls, Minnesota (Figure 1). It consists of two coal-fired boilers with a total electric generating capacity of 129 MW (gross). SO2 impacts were predicted by the AERMOD model according to the Sierra Club Modeling Protocol and compared against the 1-hour SO2 National Ambient Air Quality Standard (NAAQS) of 75 ppb (or 196 ug/m3) which was promulgated in June 2010 by the U.S. Environmental Protection Agency (EPA).

Figure 1. Otter Tail Hoot Lake Coal Plant

II. MODELING METHODOLOGIES
This section documents the methodologies and assumptions used in the generation of modeling inputs such as source emissions, stack parameters, receptors and meteorological data.

A. Model Version
Version 11103 of the AERMOD model has been used in the modeling study. It is currently the latest version of the model that has been approved by the US Environmental

### 4 Protection Agency ( US EPA, 2011). It predicts the 1-hour SO2 concentrations that can be compared against the 1-hour NAAQS which is attained when the 3-year average of the 99 th 

### percentile of the daily maximum 1-hour concentrations does not exceed 75 ppb (or 196 ug/m3) at each monitor within an area (USEPA, 2010a; 2010b).

B. Source Emissions
Three coal-fired boilers at the plant emit SO2. According to Permit Action 005 issued on April 27, 2011 by Minnesota Pollution Control Agency (MPCA), Unit 1 (EU001) will be permanently disabled and removed from the facility. Based on the facility's governing Title V permit issued by MPCA, maximum hourly allowable emissions for Units 2 and 3

are:

 1,770 lbs/hr for Unit 2 (EU002),

 2,550 lbs/hr for Unit 3 (EU003) and,

 a total of 4,320 lbs/hr for both boilers.

In addition to the above allowable emissions, the US EPA Clean Air Market database had been searched to identify the maximum plant-wide hourly emissions that actually occurred in the last five years (2006-2010). This search indicated that the maximum hourly emissions occurred on January 12, 2010, hour 20. The following actual emissions were retrieved from the US EPA Clean Air Market database:

 661.6 lb s/hr for Unit 2,

 1,172.0 lbs/hr for Unit 3 and

 a total of 1,833.6 lbs/hr for both boilers.
Both allowable and actual emissions were modeled as emitted from the plant's stack (SV002). They have been converted to grams per second (g/s) in Table 1 as required by the AERMOD model.

C. Stack Para meters
Stack parameters (stack height, diameter, temperature an d exit velocity) for stack SV002 are shown in Table 1. They were provided in the Facility Permit No. 11100002-005 (page 41) issued by MPCA on April 27, 2011 and used in modeling both the maximum allowable and 2010 actual emissions.

Table 1. Plant SO2 Allowable and 2010 Actual Emissions & Stack Parameters

Stack Allowable SO2 (g/s ) Actual SO2 (g/s) Height (m) Diameter (m) T emperature (K) Velocity (m/s)

Stack 1 544.32 231.0336 68.58 4.08 43 8.71 2 7. 88

### 5 D. Receptors
The current AERMOD modeling uses a Cartesian grid of discrete receptors that are located within a radius of 50 km around the Hoot Lake plant. The receptor grid has varying resolutions: 100 m within the first 10 km and 500 m between 10 km and 50 km. Receptors located on-site within the plant boundaries have been removed from consideration. A total of 80,818 receptors have been used in the AERMOD modeling. A flagpole height of 1.5 m was also assigned to the modeled receptors. The preprocessor AERMAP has been employed to obtain terrain elevations at these receptors using the NED data and the NAD83 datum.

E. Meteorological Data
The AERMOD modeling uses the 2006-2010 surface meteorological data from Fergus Falls and upper-air data from Chanhassen. This dataset has been processed by MPCA. It has 4,942 calm hours and 2,015 hours with missing data (4.6% of possible 43,824 hours).

F. Background Concentration
For comparison with the SO2 1-hour NAAQS, background concentrations at a monitoring station are added to the concentrations predicted by the AERMOD model. There is no monitoring near Fergus Falls. Monitoring data from the EPA AirData indicate that the 2007 maximum 1-hour SO2 of 10 ppb (26.2 ug/m3) was measured in Fargo, Cass County, North Dakota. This value is appropriate as a background since Hoot Lake is an existing facility so that "double counting" should be minimized.

III. MODELING RESULTS
In June 2010, US EPA announced a new 1-hour NAAQS which is attained when the 3- year average of the 99 th 

### percentile of the daily maximum 1-hour SO2 concentrations does not exceed 75 ppb (or 196 ug/m3) at each monitor within an area. Subsequently, US EPA issued in August 2010 a modeling guidance for using the AERMOD model with one year or five year s of meteorological data (USEPA, 2010b). According to the US EPA, the 4 th 

### highest maximum daily 1-hour concentrations obtained with one year of onsite data or averaged over the modeled five years of offsite data should be used in the NAA QS comparison.

### 6 A. Predicted Impacts by Allowable Emissions

An AERMOD modeling run with the 2006-2010 meteorological data and maximum allowable emissions was performed. SO2 modeling results for the 4 th 

### highest concentrations are summarized in Appendix A and presented in Table 2. The AERMOD model has predicted a 4 th 

### highest (99 th 

### percentile) concentration of 349.2 ug/m3 from the plant emissions alone. This concentration s largely e xceed s the NAAQS of 196 ug/m3. With the background of 26.2 ug/m3, the maximum total 4 th 

### highest concentration is 375.4 ug/m3 which is 92% above the 1-hour NAAQS of 196 ug/m3. The maximum 99 th 

### percentile has been predicted to occur at about 20.5 km (about 13 mi.) north of the plant. A plot of the contour of 196 ug/m3 is shown in Figure 2. This figure shows receptors located near the plant, 20 km (about 12.5 mi.) north and 40 km (about 25 mi.) southeast of the facility with concentrations exceeding 196 ug/m3, i.e. violating the 1-hr NAAQS due to the plant emissions alone.
The emission reduction required to mitigate the NAAQS exceedances can be calculated from the formula R = [C-(196-B)]/C where C is the plant 4 th 

### highest concentration and B is the background. With C=349.2 ug/m3 and B=26.2 ug/m3, the required emission reduction is R= 0.51 or 51%. This 51% reduction will decrease the allowable emissions from 4,320 lbs/hr to 2,116.8 lbs/hr.

Table 2. Predicted 1-Hour SO2 Impacts by Allowable Emissions of the Otter Tail Hoot La ke Plant

Pollutant Project Conc. (ug/m3) Backgroun d Conc. (ug/m3) Total Conc. (ug/m3) NAAQS (ug/m3) NAAQS Exceed Percent Over NAAQS

1

- hour SO2 (4 th 

### highest) 3 49.2 26.2 3 75.4 196 YES 92 %

### 7 Figure 2. Area with 4 th 

### Highest SO2 Concentrations Exceeding the 1-Hour NAAQS of 196 ug/m3 by Plant Allowable Emissions Alone

### 8 B. Predicted Impacts by 2010 Actual Emissions
An AERMOD modeling run with maximum actual hourly emissions in 2010 was also performed. SO2 modeling results for the 4 th 

### highest concentrations are summarized in Appendix B and presented in Table 3. The AERMOD model predicted a 4 th 

### highest (99 th 

### percentile) concentration of 148.2 ug/m3 from the plant emissions alone. This concentration is below the NAAQS of 196 ug/m3. With the background of 26.2 ug/m3, the maximum total 4 th 

### highest concentration is 174.4 ug/m3 which is below the 1-hour NAAQS of 196 ug/m3. The maximum 99 th 

### percentile has been predicted to occur about 20.0 km (about 12.5 mi.) north of the plant.

Table 3. Predicted 1-Hour SO2 Impacts by 2010 Actual Emissions of the Otter Tail Hoot Lake Plant

Pollutant Project Conc. (ug/m3) Backgroun d Conc. (ug/m3) Total Conc. (ug/m3) NAAQS (ug/m3) NAAQS Exceed Percent Over NAAQS

1

- hour SO2 (4 th 

### highest) 148.2 26.2 174.4 196 NO

---

### 9 IV. CONCLUSIONS

Ai r quality impacts of SO2 emissions from the Otter Tail Hoot Lake facility have been analyzed with the AERMOD model. Using maximum allowable emissions in the MPCA permit, the 2006-2010 Fergus Falls meteorological data and the latest US EPA modeling guidance, the AERMOD model predicted large exceedances of the SO2 1-hour NAAQS of 196 ug/m3. These exceedances occur near the plant, 20 km (about 12.5 mi.) north and 40 km (about 25 mi.) southeast of the facility. Concentrations predicted with 2010 actual emissions are below the 1-hour standard. Thus, SO2 impacts from the Hoot Lake coal plant are significant since its SO2 allowable emissions alone cause exceedances of the 1-hour NAAQS. A 51% reduction in allowable SO2 emissions is required to mitigate these NAAQS violations.

V. REFERENCES

U.S. EPA, 2011. Addendum to User’ s Guide of the AMS/EPA Regulatory Model AERMOD version 11103, March 2011. Available at: http://www.epa.gov/ttn/scram/models/aermod/aermod_userguide.zip

U.S. EPA, 2010a. Guidance Concerning the Implementation of the 1-hour SO2 NAAQS for the Prevention of Significant Deterioration Program . Memorandum issued on August 23, 2010 from Stephen D. Page, Director of OAQPS. Available at http://www.epa.gov/region07/air/nsr/nsrmemos/appwso2.pdf

U.S. EPA, 2010b. Applicability of Appendix W Modeling Guidance for the 1-hour SO2 NAAQS . Memorandum issued on August 23, 2010 from Tyler Fox, Leader of Air Quality Modeling Group, OAQPS. Available at http://www.epa.gov/region07/air/nsr/nsrmemos/appwso2.pdf

-

### 10 Appendix A
Summary of AERMOD 1-hour Modeling Results of Allowable Emissions

### 11 *** AERMOD - VERSION 11103 *** *** Hoot Lake - SO2 Run with Allowable Emissions - 5 Year Run *** 10/01/11 *** *** 06:22:26 PAGE 5 **MODELOPTs: RegDFAULT CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 4TH-HIGHEST MAX DAILY 1-HR RESULTS AVERAGED OVER 5 YEARS ***

** CONC OF SO2 IN MICROGRAMS/M**3 **

NETWORK GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID- ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ALL 1ST HIGHEST VALUE IS 349.23164 AT ( 727200.00, 5151000.00, 490.90, 490.90, 1.50) DC 2ND HIGHEST VALUE IS 309.37226 AT ( 726700.00, 5151000.00, 485.62, 485.62, 1.50) DC 3RD HIGHEST VALUE IS 309.21742 AT ( 727200.00, 5150500.00, 483.15, 488.22, 1.50) DC 4TH HIGHEST VALUE IS 278.70640 AT ( 727200.00, 5151500.00, 481.24, 481.24, 1.50) DC 5TH HIGHEST VALUE IS 264.30199 AT ( 770700.00, 5122000.00, 523.22, 544.03, 1.50) DC 6TH HIGHEST VALUE IS 257.44991 AT ( 727500.00, 5131500.00, 392.49, 392.49, 1.50) DC 7TH HIGHEST VALUE IS 256.36298 AT ( 769700.00, 5122500 .00, 526.15, 526.86, 1.50) DC 8TH HIGHEST VALUE IS 255.49042 AT ( 727500.00, 5131400.00, 393.63, 393.63, 1.50) DC 9TH HIGHEST VALUE IS 254.99519 AT ( 727900.00, 5131500.00, 389.90, 389 .90, 1.50) DC 10TH HIGHEST VALUE IS 254.43793 AT ( 727800.00, 5131400.00, 389.71, 389.71, 1.50) DC

*** RECEPTOR TYPES: GC = GRIDCART GP = GRIDPOLR DC = DISCCART DP = DISCPOLR

### 12 Appendix B
Summary of AERMOD 1-hour Modeling Results of Actual Emissions

### 13 *** AERMOD - VERSION 11103 *** *** Hoot Lake - SO2 Run with Actual Emissions - 5 Year Run *** 10/01/11 *** *** 09:56:24 PAGE 5 **MODELOPTs: RegDFAULT CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 4TH -HIGHEST MAX DAILY 1-HR RESULTS AVERAGED OVER 5 YEARS ***

** CONC OF SO2 IN MICROGRAMS/M**3 **

NETWORK GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID- ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ALL 1ST HIGHEST VALUE IS 148.22943 AT ( 727200.00, 5151000.00, 490.90, 490.90, 1.50) DC 2ND HIGHEST VALUE IS 131.31134 AT ( 726700.00, 5151000.00, 485.62, 485.62, 1.50) DC 3RD HIGHEST VALUE IS 131.24561 AT ( 727200.00, 5150500.00, 483.15, 488.22, 1.50) DC 4TH HIGHEST VALUE IS 118.29538 AT ( 727200.00, 5151500.00, 481.24, 481.24, 1.50) DC 5TH HIGHEST VALUE IS 112.18151 AT ( 770700.00, 5122000.00, 523.22, 544.03, 1.50) DC 6TH HIGHEST VALUE IS 109.27318 AT ( 727500.00, 5131500.00, 392.49, 392.49, 1.50) DC 7TH HIGHEST VALUE IS 108.8118 4 AT ( 769700.00, 5122500.00, 526.15, 526.86, 1.50) DC 8TH HIGHEST VALUE IS 108.44149 AT ( 727500.00, 5131400.00, 393.63, 393.63, 1.50) DC 9TH HIGHEST VALUE IS 108.23129 AT ( 727900.00, 5131500.00, 389.90, 389.90, 1.50) DC 10TH HIGHEST VALUE IS 107.99477 AT ( 727800.00, 5131400.00, 389.71, 389.71, 1.50) DC

*** RECEPTOR TYPES: GC = GRIDCART GP = GRIDPOLR DC = DISCCART DP = DISCPOLR

# Exhibit 7

## AERMOD Modeling of SO2 Impacts of the Xcel Energy Sherbune County Coal Plant

Final Report

December 10, 2011

Prepared for

SIERRA CLUB San Francisco, California

Prepared by Mr. Khanh T. Tran Principal



## AMI Environmental 206 Black Eagle Ave Henderson, NV 89002

Tel. (714)679-7363

### 2 Table of Contents

Page I. Introduction 3
II. Modeling Methodologies 3
III. Modeling Results 5

IV. Conclusions 9

V. References 9
Appendix A - Summary of 1-hr Modeling Results of Allowable Emissions 10 Appendix B - Summary of 1-hr Modeling Results of Actual Emissions 12

### 3 I. INTRODUCTION
This document presents the methodologies and results of an application of the AERMOD model to predict the air quality impacts of sulfur dioxide (SO2) emitted by the Sherburne County (Sherco) Generating Station. Sherco is a coal-fired power plant owned and operated by Xcel Energy near Becker , Minnesota (Figure 1). It consists of three coal-fired boilers with a total electric generating capacity of 2,255 MW (gross). SO2 impacts were predicted by the AERMOD model according to the Sierra Club Modeling Protocol and compared against the 1-hour SO2 National Ambient Air Quality Standard (NAAQS) of 75 ppb (or 196 ug/m3) which was promulgated in June 2010 by the U.S. Environmental Protection Agency (EPA).

Figure 1. Sherbune County Coal Plant

II. MODELING METHODOLOGIES
This section documents the methodologies and assumptions used in the generation of modeling inputs such as source emissions, stack parameters, receptors and meteorological data.

A. Model Version
Version 11103 of the AERMOD model was used in the modeling study. It is the latest version of the model that has been approved by the US Environmental Protection Agency

### 4 ( US EPA, 2011). It predicts 1-hour SO2 concentrations that can be compared against the 1-hour NAAQS which is attained when the 3-year average of the 99 th 

### percentile of the daily maximum 1-hour concentrations does not exceed 75 ppb (or 196 ug/m3) at each monitor within an area (USEPA, 2010a; 2010b).

B. Source Emissions
Three coal-fired boilers at the Sherco plant emit SO2. Based on the facility's governing Title V permit issued by Minnesota Pollution Control Agency (MPCA), maximum hourly allowable emissions for Units 1, 2 and 3 are:

 18,080 lbs/hr for Units 1 and 2,

 10,834 lbs/hr for Unit 3 and

 a total of 28,914 lbs/hr for all three boilers.

In addition to the above allowable emissions, the US EPA Clean Air Market database had been searched to identify the maximum plant-wide hourly emissions in 2010. This search indicated that the maximum hourly emissions occurred on November 11, 2010, hour 8. Th e following actual emissions were retrieved from the US EPA Clean Air Market database:

 5,452.23 lb s/hr for Units 1 and 2,

 5,160.57 lbs/hr for Unit 3 and

 a total of 10,612.80 lbs/hr for all three boilers.
The Sherco plant has two stacks. Emissions of Units 1 and 2 are emitted from Stack 1 while emissions of Unit 3 from Stack 2. They have been converted to grams per second (g/s) in Table 1 as required by the AERMOD model.

C. Stack Para meters
Stack parameters (stack height, diameter, temperature an d exit velocity) for both stack s are shown in Table 1. They were taken from the US DOE Form EIA-860 database and used in modeling both the maximum allowable and 2010 actual emissions.

Table 1. Plant SO2 Allowable and 2010 Actual Emissions & Stack Parameters

Stack Allowable SO2 (g/s ) Actual SO2 (g/s) Height (m) Diameter (m) Temperature (K) Velocity (m/s)

Stack 1 2,278.08 686.981 198.12 9.91 352.59 32.00 Stack 2 1,365.08 650.232 198.12 7.92 352.59 25.60

### 5 D. Receptors
The current AERMOD modeling uses a Cartesian grid of discrete receptors that are located within a radius of 50 km around the Sherco plant. The receptor grid has varying resolutions: 100 m within the first 10 km and 500 m between 10 km and 50 km. Receptors located on-site within the plant boundaries have been removed from consideration. A total of 80,667 receptors were used in the AERMOD modeling. A flagpole height of 1.5 m was also assigned to the modeled receptors. The preprocessor AERMAP was employed to obtain terrain elevations at these receptors using the NED data and the NAD83 datum.

E. Meteorological Data
The AERMOD modeling uses the 2006-2010 surface meteorological data from St Cloud and upper-air data from Chanhassen. This dataset has been processed by MPCA. It has 378 calm hours and 1,354 hours with missing data (3.09% of possible 43,824 hours).

F. Background Concentration
For comparison with the SO2 1-hour NAAQS, background concentrations at a monitoring station are added to the concentrations predicted by the AERMOD model. Mon it oring data from the MPCA First Approximation Modeling Optimizing Useful Setups (FAMOUS) data indicate that, based on hour-of-day (HROFDY) values, the maximum 1-hour SO2 of 30 ug/m3 is appropriate as a background for the Sherco plant.

III. MODELING RESUL TS
In June 2010, US EPA announced a new 1-hour NAAQS which is attained when the 3- year average of the 99 th 

### percentile of the daily maximum 1-hour SO2 concentrations does not exceed 75 ppb (or 196 ug/m3) at each monitor within an area. Subsequently, US EPA issued in August 2010 a modeling guidance for using the AERMOD model with one year or five year s of meteorological data (USEPA, 2010b). According to the US EPA, the 4 th 

### highest maximum daily 1-hour concentrations obtained with one year of onsite data or averaged over the modeled five years of offsite data should be used in the NAA QS comparison.

### 6 A. Predicted Impacts by Allowable Emissions

An AERMOD modeling run with the 2006-2010 meteorological data and maximum allowable emissions was performed. SO2 modeling results for the 4 th 

### highest concentrations are summarized in Appendix A and presented in Table 2. The AERMOD model has predicted a 4 th 

### highest (99 th 

### percentile) concentration of 504.1 ug/m3 from the plant emissions alone. This concentration large ly e xceed s, by more than a factor of 2, the NAAQS of 196 ug/m3. With the background of 30.0 ug/m3, the maximum total 4 th 

### highest concentration is 534.1 ug/m3 which is 173% above the 1-hour NAAQS of 196 ug/m3. The maximum 99 th 

### percentile has been predicted to occur at about 3.75 km (abou t 2.3 mi.) southeast of the plant. A plot of the contour of 196 ug/m3 is shown in Figure 2. This figure shows receptors located within 20 km (about 12.5 mi.) of the facility with concentrations exceeding 196 ug/m3, i.e. violating the 1-hr NAAQS due to the plant emissions alone.
The emission reduction required to mitigate the NAAQS exceedances can be calculated from the formula R = [C-(196-B)]/C where C is the plant 4 th 

### highest concentration and B is the background. With C=504.1 ug/m3 and B=30.0 ug/m3, the required emission reduction is R= 0.67 or 67%. This 67% reduction will decrease the allowable emissions from 28,914 lbs/hr to 9,541.6 lbs/hr.

Table 2. Predicted 1-Hour SO2 Impacts by Allowable Emissions of the Xcel Sh erco Plant

Pollutant Project Conc. (ug/m3) Backgroun d Conc. (ug/m3) Total Conc. (ug/m3) NAAQS (ug/m3) NAAQS Exceed Percent Over NAAQS

1

- hour SO2 (4 th 

### highest) 504.1 30.0 534.1 196 YES 173 %

### 7 Figure 2. Area with 4 th 

### Highest SO2 Concentrations Exceeding the 1-Hour NAAQS of 196 ug/m3 by Plant Allowable Emissions Alone

### 8 B. Predicted Impacts by 2010 Actual Emissions
An AERMOD modeling run with maximum actual hourly emissions in 2010 was also performed. SO2 modeling results for the 4 th 

### highest concentrations are summarized in Appendix B and presented in Table 3. The AERMOD model predicted a 4 th 

### highest (99 th 

### percentile) concentration of 191.6 ug/m3 from the plant emissions alone. This concentration is below the NAAQS of 196 ug/m3. With the background of 30.0 ug/m3, the maximum total 4 th 

### highest concentration is 221.6 ug/m3 which is 13% above the 1- hour NAAQS of 196 ug/m3. The maximum 99 th 

### percentile has been predicted to occur about 3.6 km (about 2.25 mi.) southeast of the plant.

Table 3. Predicted 1-Hour SO2 Impacts by 2010 Actual Emissions of the Xcel Sherco Plant

Pollutant Project Conc. (ug/m3) Background Conc. (ug/m3) Total Conc. (ug/m3) NAAQS (ug/m3) NAAQS Exceed Percent Over NAAQS

1

- hour SO2 (4 th 

### highest) 1 91.6 30.0 221.6 196 YES 13%

### 9 IV. CONCLUSIONS

Ai r quality impacts of SO2 emissions from the Xcel Energy Sherco facility have been analyzed with the AERMOD model. Using maximum allowable emissions in the MPCA permit, the 2006-2010 St Cloud meteorological data and the latest US EPA modeling guidance, the AERMOD model predicted large exceedances of the SO2 1-hour NAAQS of 196 ug/m3. These exceedances occur within a large area with a radius of 20 km around the facility. Concentrations predicted with 2010 actual emissions also exceed the 1-hour standard. Thus, SO2 impacts from the Sherco coal plant are significant since its SO2 allowable and actual emissions cause exceedances of the 1-hour NAAQS. A 67 % reduction in allowable SO2 emissions is required to mitigate these NAAQS violations.

V. REFERENCES

U.S. EPA, 2011. Addendum to User’ s Guide of the AMS/EPA Regulatory Model AERMOD version 11103, March 2011. Available at: http://www.epa.gov/ttn/scram/models/aermod/aermod_userguide.zip

U.S. EPA, 2010a. Guidance Concerning the Implementation of the 1-hour SO2 NAAQS for the Prevention of Significant Deterioration Program . Memorandum issued on August 23, 2010 from Stephen D. Page, Director of OAQPS. Available at http://www.epa.gov/region07/air/nsr/nsrmemos/appwso2.pdf

U.S. EPA, 2010b. Applicability of Appendix W Modeling Guidance for the 1-hour SO2 NAAQS . Memorandum issued on August 23, 2010 from Tyler Fox, Leader of Air Quality Modeling Group, OAQPS. Available at http://www.epa.gov/region07/air/nsr/nsrmemos/appwso2.pdf

-

### 10 Appendix A
Summary of AERMOD 1-hour Modeling Results of Allowable Emissions

### 11 *** AERMOD - VERSION 11103 *** *** Sherco - SO2 Run with Allowable Emissions - 5 Year Run *** 12/07/11 *** *** 13:18:59 PAGE 5 **MODELOPTs: RegDFAULT CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 4TH-HIGHEST MAX DAILY 1-HR RESULTS AVERAGED OVER 5 YEARS ***

** CONC OF SO2 IN MICROGRAMS/M**3 **

NETWORK GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID- ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ALL 1ST HIGHEST VALUE IS 504.0878 3 AT ( 432400.00, 5022700.00, 289.58, 289.58, 1.50) DC 2ND HIGHEST VALUE IS 502.90720 AT ( 432500.00, 5022600.00, 289.22, 289.22, 1.50) DC 3RD HIGHEST VALUE IS 501.50027 AT ( 432500.00, 5022500.00, 289.18, 289.18, 1.50) DC 4TH HIGHEST VALUE IS 501.07718 AT ( 432300.00, 5022800.00, 290.24, 290.24, 1.50) DC 5TH HIGHEST VALUE IS 499.32797 AT ( 432600.00, 5022500.00, 289.82 , 289.82, 1.50) DC 6TH HIGHEST VALUE IS 498.82740 AT ( 432400.00, 5022600.00, 289.06, 289.06, 1.50) DC 7TH HIGHEST VALUE IS 497.61581 AT ( 432600.00, 5022400.00, 289.21, 289.21, 1.50) DC 8TH HIGHEST VALUE IS 496.30888 AT ( 432300.00, 5022700.00, 290.16, 290.16, 1.50) DC 9TH HIGHEST VALUE IS 496.30213 AT ( 432700.00, 5022300.00, 289.31, 289.31, 1.50) DC 10TH HIGHEST VALUE IS 496.10145 AT ( 432800.00, 5022200.00, 289.34, 289.34, 1.50) DC

*** RECEPTOR TYPES: GC = GRIDCART GP = GRIDPOLR DC = DISCCART DP = DISCPO LR

### 12 Appendix B
Summary of AERMOD 1-hour Modeling Results of Actual Emissions

### 13 *** AERMOD - VERSION 11103 *** *** Sherco - SO2 Run with Actual Emissions - 5 Year Run *** 12/08/11 *** *** 19:17:01 PAGE 5 **MODELOPTs: RegDFAULT CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 4TH-HIGHEST MAX DAILY 1- HR R ESULTS AVERAGED OVER 5 YEARS ***

** CONC OF SO2 IN MICROGRAMS/M**3 **

NETWORK GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID- ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ALL 1ST HIGHEST VALUE IS 191.61820 AT ( 432300.00, 5022800.00, 290.24, 290.24, 1.50) DC 2ND HIGHEST VALUE IS 191.06086 AT ( 432200.00, 5022900.00, 290.20, 290.20, 1.50) DC 3RD HIGHEST VALUE IS 190.92714 AT ( 432400.00, 5022700.00, 289.58, 289.58, 1.50) DC 4TH HIGHEST VALUE IS 190.33728 AT ( 432300.00, 5022700.00, 290.16, 290.16, 1.50) DC 5TH HIGHEST VALUE IS 190.31018 AT ( 4324 00.00, 5022600.00, 289.06, 289.06, 1.50) DC 6TH HIGHEST VALUE IS 190.27515 AT ( 432800.00, 5022200.00, 289.34, 289.34, 1.50) DC 7TH HIGHEST VALUE IS 189.78935 AT ( 432700.00, 5022300.00, 289.31, 289.31, 1.50) DC 8TH HIGHEST VALUE IS 189.34030 AT ( 432500.00, 5022600.00, 289.22, 289.22, 1.50) DC 9TH HIGHEST VALUE IS 189.15228 AT ( 432700.00, 5022400.00, 290.24, 290.24, 1.50) DC 10TH HIGHEST VALUE IS 188.99181 AT ( 432500.00, 5022500.00, 289.18, 289.18, 1.50) DC

*** RECEPTOR TYPES: GC = GRIDCART GP = GRIDPOLR DC = DISCCART DP = DISCPOLR

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# Exhibit 9

## ORAL ARGUMENT NOT YET SCHEDULED

UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT

____________________________________ ) NATIONAL ENVIRONMENTAL ) DEVELOPMENT ASSOCIATION’S ) CLEAN AIR PROJECT, ) ) Petitioner, ) ) v. ) Docket No. 10-1252 ) (and consolidated cases) UNITED STATES ENVIRONMENTAL ) PROTECTION AGENCY, ) ) Respondent. ) ___________________________________ )

RESPONDENT’S OPPOSITION TO MOTION OF THE STATE OF NORTH DAKOTA FOR A STAY OF EPA’S 1-HOUR SULFUR DIOXIDE AMBIENT STANDARD RULE
Respondent United States Environmental Protection Agency (“EPA”)
submits this Opposition to the Motion of the State of North Dakota for a Stay of

EPA’s 1-Hour Sulfur Dioxide Ambient Standa rd Rule (“Stay Motion”). In its Stay
Motion, North Dakota seeks a stay of the rule in its entirety or, in the alternative, a
stay of the statutory directive that States submit any recommendations for
attainment/nonattainment designations no later than June 3, 2011. The motion

should be denied because North Dakota has not satisfied the stringent requirements Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 1

## 2 for obtaining a stay of agency action. The motion fails to address any of the
elements for obtaining a stay with regard to any of the promulgated elements of the

rule, i.e. , the revised sulfur dioxide (“SO 2 

## ”) standard itself and the promulgated

revisions to the SO 2 

## monitoring network. Rather, th e motion is addressed solely to
an advisory discussion in the final ru le preamble regarding EPA’s anticipated
approach to implementing the revise d NAAQS. Thus, the motion provides no
basis to stay the rule as a whole.

The motion must also be denied with regard to the alternative relief
requested. First, North Dakota has not demonstrated a substantial likelihood of
success on the merits. It challenges only advisory statements in the final rule
preamble concerning EPA’s contemplated approach for making initial attainment
designations by the June 2012 statutory dead line, an approach the Agency will be
addressing in future actions. As the preamble makes clear, EPA has taken no final
action nor promulgated any regulatory requi rements regarding designations, and, in
particular, has taken no final action on its approach to making attainment
determinations. To the contrary, the preamble specifically preserves EPA’s ability
to make those decisions solely on the basis of monitoring data. 75 Fed. Reg.
35,520, 35,552 n.22 (June 22, 2010). Because these preamble statements are not
final agency action, the Court lacks juri sdiction to review them, and North Dakota
has no substantial likelihood of prevailing on the merits. Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 21 / 

## The date can be extended to June 2013 if EPA lacks sufficient information to act in 2012. 42 U.S.C. § 7407(d)(1)(B)(i).

3 Moreover, even if the challenged preambl e statements could be read as final
agency action, the Agency has historica lly relied on modeling to make designations

for sulfur dioxide. To the extent the proposal preamble reflected a possible change
to that practice, it clearly left open th e possibility that the Agency would choose
not to adopt the proposed change. Intere sted parties should have known that EPA
might retain its past practice, and had ample opportunity to comment on that
possibility. Thus, North Dakota cannot demonstrate a likelihood of success on its
claim that it lacked an opportunity to comment on the approach to initial
designations discussed in the preamble.
Second, North Dakota cannot demonstrate that it will suffer irreparable harm
from the statutory directive that it submit designation recommendations to EPA by
June 2011. North Dakota claims harm from an alleged bar to the use of monitoring
data as the sole basis for its designation recommendations. But, nothing in the SO 2 

## Rule prevents North Dakota from basing its recommendations solely on monitoring

data, and thus the Rule does not cause the harm North Dakota claims. Id.
Furthermore, designation recommendations have no independent legal effect. An
area is not designated until EPA promul gates the designation, which EPA is
required to do by June 2012 1 / 

## (a requirement that would not be affected by a stay of Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 3

## 4 the 2011 recommendation submission date). Moreover, EPA is not bound by the
State’s recommendations and must promulgate a designation for an area even if the

State submits no recommendation at all.
Finally, a stay of the SO 2 

## Rule will cause harm to other parties and is
contrary to the public interest. The rule under review revises the primary ambient
air quality standard for sulfur dioxide based on findings by EPA that the prior
standards were not requisite to protect hum an health with an adequate margin of
safety. A stay of the rule’s regulatory provisions promulgating the new standard
would delay implementation of the measures needed to achieve attainment with the
new standard, including requirements asso ciated with the permitting of new and
modified major stationary sources which became effective on the effective date of
the standard. A stay of the Rule would thus prolong the time during which existing
air quality causes adverse impacts to public health. A stay of the 2011 deadline for
States to submit recommendations to EPA would not alter EPA’s obligation to
promulgate designations by 2012, but would increase the burden on EPA to
develop the designations.

BACKGROUND
The consolidated petitions in this cas e seek review of an EPA regulation
revising the primary National Ambient Air Quality Standards (“NAAQS”) and
associated regulatory requirements for oxides of sulfur as measured by SO 2 

### Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 4

## 5 pursuant to section 109 of the Clean Air Act, 42 U.S.C. § 7409. 75 Fed. Reg.

35,520 (June 22, 2010) (“SO 2 

## Rule”). Those regulatory requirements took effect
on August 23, 2010, and are currently being implemented. The NAAQS
provisions of the Clean Air Act establish a comprehensive scheme to protect public
health and welfare from ubiquitous air pollutants. 42 U.S.C. § 7409. Primary

standards must be set at levels that, in the judgment of the Administrator, are
requisite to protect public health with an adequate margin of safety. Id.
§ 7409(b)(1). The Act requires periodic review of the NAAQS. Id. § 7409(d).

See generally American Lung Ass’n v. EPA , 134 F.3d 388, 388-89 (D.C. Cir.

1998).
EPA first promulgated a primary NAAQS for sulfur dioxide in 1971. 36
Fed. Reg. 8187 (April 30, 1971). In May 1996, after a lengthy review, EPA
announced a final decision not to revise the NAAQS. 61 Fed. Reg. 25,566 (May

22, 1996). Petitions for review of that deci sion were filed in this Court, and the
Court held that EPA had failed to adequa tely explain the basis for its conclusion

that short-term SO 2 

## exposures to asthmatics do not constitute a public health
problem. American Lung Ass’n v. EPA , 134 F.3d 388. In the rule under review

here EPA has addressed that issue by replacing the prior 24-hour and annual
primary standards with a new 1-hour prim ary standard. The new standard is now
in effect, and is being implemented in EP A’s prevention of significant deterioration Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 5

## 6 permitting program for new and modified major stationary sources. See 57 Fed.
Reg. at 35,580/1.
Within one year after promulgation of a new or revised NAAQS (or sooner
if required by EPA) States are directed to submit to EPA a list of all areas that the
State recommends be designated by EPA as attainment, nonattainment, or

unclassifiable for the new or revised NAAQS. 42 U.S.C. § 7407(d)(1)(A). In the

case of the revised SO 2 

## standards, such designations are due by June 3, 2011, one
year after EPA promulgated the revised NAAQS by signing and publicly
disseminating the notice of final rulemaking. Within two years of promulgation
(or three years if EPA lacks sufficien t information), the Act requires EPA to
promulgate designations. Id. § 7407(d)(1)(B)(i). EPA may modify any submitted
list of designations provided by a State if it gives the State 120 days notice, and
must promulgate designations as EPA d eems appropriate for any area for which no
designation recommendation is provided by a State. Id. § 7407(d)(1)(B)(ii).
Thus, EPA’s statutory obligation to prom ulgate designations is independent of

whether a State submits recommendations.

The SO 2 

## Rule, like its predecessors, includes regulatory provisions that
establish the NAAQS itself, as well as regulations governing the installation and

use of monitors utilized to measure ambient concentrations of SO 2 

## . See , e.g. , 40

C.F.R. §§ 50.4(e); 50.14(c)(2)(vi); 50.17; part 50 Appendices A-1 and T; part 53, Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 6

## 7 and part 58. Historically, to determine if an area is in attainment with the SO 2 

## NAAQS, EPA has used a combination of re sults from regulation-required monitors
and air quality modeling, even though in the NAAQS regulations themselves EPA
has not promulgated requirements that States or sources conduct modeling.
Instead, at 40 C.F.R. part 51, Appendix W, EPA has promulgated guidelines on air
quality models, to be used for regulatory purposes such as State Implementation
Plan (“SIP”) development and new source review and
prevention-of-significant-deterioration permitting actions. See , e.g. , 40 C.F.R. part
51, Appendix W, § 1.0. In the current rule EPA has revised the regulatory
requirements for the minimum number and placement of monitors and adopted a
new reference method for detecting ambient SO 2 

## , but did not promulgate or revise
any requirements regarding modeling.
In the preamble to the proposed SO 2 

## Rule, EPA discussed the revisions to
the monitoring network proposed to account for the revision of the standard, i.e.
, the change from the 24-hour and annual st andards to a single one-hour standard.
74 Fed. Reg. 64,810, 64,846-55 (Dec. 8, 2009). In the proposal EPA did not
discuss its historic and current uses of modeling in implementing the then-effective

annual and 24-hour SO 2 

## standards. In public comments on the proposal, numerous
parties suggested that the proposed m onitoring network was both inadequate in
scope and overly burdensome to administer, and some commenters suggested that Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 7

## 8 modeling should be used to relieve the administrative burden that a more extensive
monitoring regime would otherwise impose. 75 Fed. Reg. at 35,551/1.
In the preamble to the final rule, EP A explained in response to comments
that the Agency anticipated in subsequent actions to continue its historic practice of
relying on both modeling and monitoring for determining whether an area is in

attainment with the SO 2 

## NAAQS and adopted rules for a smaller monitoring
network than initially proposed. 75 Fe d. Reg. at 35,550-51. However, the
preamble makes clear that, except for the promulgated requirements relating to the
scope of the monitoring network and detection method, the Agency is still
developing its policy for such futu re actions as designations and SIP
approvals/disapprovals and intends to issu e further guidance in the future through a
notice-and-comment process. Id. The preamble also stat es EPA’s expectation that
any decisions about whether to base an attainment designation or determination on
monitoring alone, without reliance on modeling, would be made on a case-by-case

basis. Id. at 35,552 n.22.
Following promulgation of the rule, numerous parties filed petitions for

review with this Court, and each of those parties also submitted to EPA
administrative petitions for reconsiderati on of the rule under section 307(d)(7)(B)
of the Act, 42 U.S.C. § 7607(d)(7)(B). The petitions for reconsideration objected
to EPA’s final rulemaking preamble discussion explaining EPA’s anticipated Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 8

## 9 approaches in future designations and SIP actions. In addition, each requested that
EPA administratively stay the final rule pending such reconsideration. EPA is
currently evaluating the petitions for r econsideration and has not yet formally
responded to them, but, as the Agency stated in its pending motion filed with the
Court seeking a short-term abeyance of the instant litigation, EPA intends to
provide initial responses to the petitions for reconsideration, including the requests
for a stay of the rule, by January 8, 2011.

STANDARD OF REVIEW
A stay is a disfavored remedy. “On a motion for stay, it is the movant’s
obligation to justify the court’s exercise of such an extraordinary remedy.” Cuomo
v. United States Nuclear Regulatory Comm’n , 772 F.2d 972, 978 (D.C. Cir. 1985).
The factors for determining whether a st ay is warranted are: (1) whether the

movant has demonstrated a substantial lik elihood that it will prevail on the merits;
(2) the prospect of irreparable injury to the moving party if relief is withheld; (3)
the possibility of harm to other parties if relief is granted; and (4) the public

interest. Nken v. Holder , 129 S. Ct. 1749, 1761 (2009). These four prongs of the
stay standard are to be applied stringe ntly. Aberdeen & Ro ckfish R.R. Co. v.
Students Challenging Regulatory Agency Procedures , 409 U.S. 1207, 1218 (1972).
“A stay is not a matter of right, even if irreparable injury might otherwise result.”

Nken , 129 S. Ct. at 1760 (citation omitted). Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 9

## 10 To demonstrate a substantial likelihood of success on the merits, a petitioner
must show that it is likely to persuade this Court that EPA’s action is “arbitrary,
capricious, an abuse of discretion, or ot herwise not in accordance with law.” 42

U.S.C. § 7607(d)(9)(A). This narrow, defere ntial standard prohibits a court from
substituting its judgment for that of the ag ency and presumes the validity of agency

actions. Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co. , 463 U.S.
29, 43-44 (1983). Judicial deference also typically extends to an agency’s
interpretation of a statute it administ ers, United States v. Mead Corp. , 533 U.S.

218, 227-31 (2001); Chevron, U.S.A., Inc. v. Natural Res. Def. Council, Inc. , 467
U.S. 837, 842-45 (1984), and of its own regulations. Auer v. Robbins , 519 U.S.

452, 457 (1997).
To establish irreparable harm, a petitioner must demonstrate an injury that is
“both certain and great; it must be actual and not theoretical.” Wisconsin Gas Co.

v. FERC , 758 F.2d 669, 674 (D.C. Cir. 1985). A movant for injunctive relief must
show that “[t]he injury complained of [is] of such imminence that there is a clear
and present need for equitable relief to prevent irreparable harm.” Id. (citation

omitted). The movant must “substantiate the claim that irreparable injury is 'likely'
to occur,” and “show that the alleged harm will directly result from the action
which the movant seeks to enjoin.” Id ; see also Nken , 129 S. Ct. at 1761 (more
than a “mere possibility” of success on the me rits is required, and the standard for Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 10

## 11 irreparable harm is more than showing the “possibility” of harm); Winter v.

NRDC , 129 S. Ct. 365, 375-76 (2008) (holding that in a preliminary injunction
case, plaintiffs must demonstrate that irreparable injury is “likely,” not just
“possible”).

ARGUMENT

I. THE MOTION IS PREMATURE
Fed. R. App. Proc. 18(a) requires that a petitioner must ordinarily move first
before the agency for a stay of its orde r before seeking a stay in the Court of
Appeals, or else show that moving before the agency would be impracticable. In
this case, although North Dakota (and other Petitioners) have sought a stay of the

SO 2 

## Rule from EPA, EPA has not yet acted on that request, and North Dakota has
not demonstrated that it is impracticable to wait for EPA to act on those requests
before seeking a stay from this Court. As described in EPA’s Motion to Hold Case
in Abeyance, EPA intends to act on the pending administrative petitions for
reconsideration by January 8, 2011. At that time EPA will also act on the included
requests for a stay, as the Agency previous ly informed Petitioners. Implicit in Rule
18's requirements is that a petitioner must receive a response to its request for a
stay from the agency before seeking a judicial stay. North Dakota has neither
waited for that response, nor demonstrat ed why doing so would be impracticable
for submitting a recommendation that is not due until June 2011. Because North Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 11

## 12 Dakota’s request for a stay is still pending before the Agency and the Agency has
committed to responding in a timely fashion, North Dakota’s motion for stay in
this Court is premature and should be denied.

II. NORTH DAKOTA HAS PRESENTED NO BASIS FOR STAYING THE ENTIRE SO 2 

## RULE
In its motion, North Dakota asks the Court to stay the SO 2 

## Rule in its
entirety (including the standard itself and the associated monitoring provisions) or,
in the alternative, to stay the June 3, 2011 statutory deadline by which States may
submit recommended designations to EPA. North Dakota, however, identifies no
grounds for staying the entire rule. With regard to the merits, North Dakota
advances no objection to the promulga ted standard or the promulgated
requirements related to monitoring. Nor does it present any claim that it will suffer
irreparable harm from either the revise d standard or the revised requirements
related to monitoring. In fact, North Dakota does not address any aspect of the
Rule except the non-binding preamble discussion concerning how EPA expects to
use modeling in future area designations and SIP actions. Thus, North Dakota has
not met the stringent standard for obtaining a stay of the Rule as a whole, and that
request must be denied. Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 12

## 13 III. NORTH DAKOTA CANNOT DEMONSTRATE A SUBSTANTIAL LIKELIHOOD OF SUCCESS ON THE MERITS
The sole claim on the merits presente d in the Stay Motion is that the
preamble of the final rule allegedly re quires the use of air quality modeling for
determining whether an area is in attainment with the revised SO 2 

## NAAQS, that
this approach differs from the approach discussed in the preamble to the proposal,
and that the public did not have an opportunity to comment on the approach

discussed in the final rule. This claim lacks merit for two reasons.
First, North Dakota is not challenging any provision of the promulgated
regulations, but rather a discussion in the preamble, i.e. , 75 Fed. Reg. at 35,550-54.
Although some preamble discussions may constitute final agency action, it is clear
that this particular discussion does not. Rather, the challenged discussion
regarding the potential use of modeling is, at most, non-binding guidance that the
Court lacks jurisdiction to review. The preamble specifically states:
In many respects, both the overview discussion below and the subsequent more detailed discussions explain our expected and intended future action in implementing the 1-hour NAAQS – in other words, they constitute guidance, rather than final agency action – and it is possible that our approaches may continue to evolve as we, States, and other stakeholders pro ceed with actual implementation. In other respects, such as in the final regulatory provisions regarding the promulgated monitoring network, we are explaining EPA’s final conclusions regarding what is requi red by this rule. We expect to issue further guidance regarding implementation . . . . EPA intends to solicit public comment prior to finalizing this guidance.

Id. at 35,550/3 (emphasis added). Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 13

## 14 Moreover, nowhere in the preambl e (much less in any promulgated
regulation) does EPA state that modeling must be used for designating areas as

attainment, nonattainment or unclassifiable . Thus, the alleged requirement North
Dakota seeks to challenge does not exist. Rather, the preamble states: “We expect
that EPA’s final area designation decisions in 2012 would be based principally on
data reported from SO 2 

## monitors currently in pl ace today, and any refined
modeling the State chooses to conduct specifically for initial designations.” Id. at
35,552/1 (emphasis added). The preamble then goes on to say “EPA anticipates
making the determination of when monitoring alone is ‘appropriate’ for a specific
area on a case-by-case basis, informed by the area’s factual record, as part of the
designation process.” Id. at 35,552 n.22.
In short, EPA has simply not taken th e final agency action alleged by North

Dakota and there is no such action for the Court to review or to stay. To the
contrary, the preamble states that EPA be lieves that its historic approach to SO 2 

## designations continues to appear to be appropriate, while at the same time giving
States the flexibility to recommend the appropriate mix of data to rely on,
including the possibility of relying entirely on monitoring if supportable.
Second, even if the preamble could be construed as final agency action,
North Dakota’s claim that the public lack ed notice of the possibility that EPA
might continue to use modeling when making designations is without merit. As Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 14

## 15 EPA has frequently explained, because of the nature of SO 2 

## pollution, EPA has
historically relied on air quality modeling (in addition to any required monitoring)
to determine whether an area is violating the SO 2 

## NAAQS. 75 Fed. Reg. at

35,551/2-3, 35,559/2-3; see SO 2 

## Guideline Document (available at
www.epa.gov/ttn/oarpg/t1/memoranda/so2_guide_092109.pdf) at 2-5 (“For SO 2 

## attainment demonstrations, monitoring data alone will generally not be adequate.”)

and at 2-1 (“Attainment determinations for SO 2 

## will generally not rely on ambient
monitoring data alone, but instead will be supported by an acceptable modeling
analysis which quantifies that the SIP strategy is sound and that enforceable
emission limits are responsible for attainment.”) As a State responsible for
recommending whether an area should be designated attainment or nonattainment,
North Dakota certainly should have been aware of the Agency’s historical
approach.
Thus, to the extent the approach to designations described in the proposal
preamble was limited to monitoring, in de -emphasizing the role modeling has long
played in SO 2 

## implementation it represented a de parture from the Agency’s prior
practice. In such circumstances, affected parties are su rely aware that not adopting
the proposed change is a possibility. American Iron & Steel Inst. v. EPA , 886 F.2d
390, 400 (D.C. Cir. 1989) (“One logical outgr owth of a proposal is surely, as EPA
says, to refrain from taking the proposed st ep.”) In fact, the Agency did receive Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 152 / 

## If EPA were to determine that the monito ring data was not sufficient to determine an area’s attainment status, and thus that the area would have to be categorized as unclassifiable until sufficient monitoring da ta or modeling results were available, (continued...)

16 comments urging the Agency to retain its historic approach. 75 Fed. Reg. at
35,551/1. Accordingly, there is no basis for North Dakota’s claim that it lacked
notice that the Agency might choose not to adopt a more monitoring-focused
approach as discussed in the proposal pream ble, but instead to expect to retain its
historic approach in which modeling is generally, though not always, utilized.

IV. NORTH DAKOTA CANNOT DEMONSTRATE AN IMMINENT THREAT OF IRREPARABLE HARM
There is no merit to North Dakota’s claim that it will suffer irreparable harm

if the SO 2 

## Rule or the statutory deadline to submit designation recommendations is
not stayed. North Dakota first claims that it will be harmed because the SO 2 

## Rule
“casts a cloud” over its ability to use its monitoring data and “deprive[s] the state
of its right to manage its air resources.” Stay Motion at 17. As demonstrated

above, there is no factual basis for this claim because neither the SO 2 

## Rule itself
nor the preamble discussion prohibits North Dakota from basing its recommended
designations on its monitoring data alone. 75 Fed. Reg. at 35,552 n.22. Nor does
anything in the Rule or preamble prohibit EPA from basing its designations for
North Dakota on monitoring data alone if EPA determines that the monitoring data

is sufficient to determine North Dakota’s attainment status. 2 / 

### Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 162 / 

## (...continued) that designation would be result of the insufficiencies in the data, not of anything that EPA has done in the Rule.

3 / 

## While it might seem at first blush as if actual monitoring should be inherently more accurate than modeling, this is not necessarily the case. In fact, “[i]n the past, EPA used a combination of modeling and monitoring for SO 2 

## during permitting, designations and re-designations in recognition of the fact that a single monitoring site is generally not adequate to fu lly characterize ambi ent concentrations, including the maximum ground level concentrations, which exist around stationary SO 2 

## sources.” 75 Fed. Reg. at 35,559. This is especially important because “[t]he 1-hour NAAQS is intended to provide protection against short-term (5 minute to 24 hour) peak exposures”. Id. See American Lung Ass’n v. EPA , 134 F. 3d at 392-93 (remanding EPA’s determination that such exposures do not constitute a threat to public health) and 75 Fed. Reg. at 35,536 (5-10 minute SO 2 

## exposures can result in adverse health effects to asthmatics).

17 Moreover, the State’s recommended designations, which are due June 3,
2011, have no legal effect on sources. Not until EPA promulgates the actual
designations, which the statute requires it do by June 3, 2012 (or 2013 if extended),
will there be a designation in place that has legal effect. Thus, North Dakota can
suffer no actual harm from submitting its recommended designations.
North Dakota’s second claim of harm, that the use of modeling will result in
more areas being designated as nona ttainment because modeling is more
“conservative,” Stay Motion at 17-18, is purely speculative. North Dakota presents
no evidence at all to support its assertion that modeling will necessarily result in
areas of the State being designated as nona ttainment inappropriately, and thus there
is no basis on which the Court could find that North Dakota could suffer injury. 3 /



## Furthermore, as the preamble states, th e modeling guidance that EPA intends to Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 17

## 18 provide States for use in determining attainment of the revised SO 2 

## standard is still
under development. 75 Fed. Reg. at 35, 552-54. Thus, any statements about how
the use of modeling affects the designation process for the revised SO 2 

## standard are
necessarily speculative.
Finally, the actual designations will be made by EPA, an action that EPA
expects to take by June 3, 2012. Stat es have an opportunity under the Act to
provide input on the designations before they are made, and EPA’s designations
are subject to judicial review. Any clai m that modeling is inappropriately used by
EPA for a particular designation can and should be raised in that process.

V. A STAY WOULD HARM THIRD PARTIES AND IS CONTRARY TO THE PUBLIC INTEREST
A stay of the SO 2 

## Rule, whether in whole or in part, would cause harm to
third parties and is contrary to the public interest because it would delay
achievement of the public health benefits of the revised standard, which is now in
effect and being used for the Act’ s New Source Review and Prevention of
Significant Deterioration permitting programs. After an exhaustive review of the
existing data, EPA determined that the prior SO 2 

## standard was not adequately
protective of human health and required revision, a conclusion amply supported by
the record. EPA’s statutorily mandated science review committee, the Clean Air
Scientific Advisory Committee, recommended unanimously that the current
standard be revised because the current standards are not adequate to protect the Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 18

## 19 public health, and that EPA should adopt a one-hour standard in their place. 75
Fed. Reg. at 35,530, 35,538. Short-term exposure to SO 2 

## results in adverse
respiratory effects such as bronchoconstriction (narrowing of the airways) and

increased asthma symptoms. Id. at 35,525-26. Studies also show an association

between short-term SO 2 

## exposure and increased emergency department visits and
hospital admissions for respiratory illness, particularly among children, the elderly,

and asthmatics. Id. at 35,547.
Importantly, the data demonstrate that these adverse health effects can occur
at concentration levels that are allowed by the prior SO 2 

## NAAQS. Id. at
35,535-36. Thus, implementation of the revi sed standard is necessary to reduce the

adverse health effects associated with these exposures. North Dakota’s motion

does not address this issue at all, and t hus fails to address two of the elements
needed for a stay of agency action.
A stay of the SO 2 

## Rule, either in whole or in part, is likely to delay
attainment of the revised standard. A delay of the SO 2 

## Rule as a whole will delay
States’ implementation of th e control measures needed to achieve compliance with
the revised standard and the requirement for new or modified major stationary
sources to implement necessary controls pursuant to the Clean Air Act’s New
Source Review and Prevention of Significant Deterioration permit requirements. Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 19

## 20 A stay of the date for States to recommend designations for areas as
attainment, nonattainment, or unclassifiable will not delay EPA’s independent
obligation to promulgate designations. However, it could complicate the process
of establishing area designations and impose additional burdens on EPA if States
do not submit designation recommendations because EPA would not have the
States’ recommended designations as a starting point. Thus, a stay of the SO 2 

## Rule
will harm third parties and be adverse to the public interest by delaying the public

health benefits of the revised standard.

CONCLUSION
For the reasons stated above, North Dakota’s motion for a stay of the SO 2


## Rule should be denied.

R e s p e c t f u l l y s u b m i t t e d
,
IGNACIA S. MORENO Assistant Attorney General

/S/ Norman L. Rave, Jr. NORMAN L. RAVE, JR. Environmental Defense Section Environment & Natural Resources Division United States Department of Justice P.O. Box 23986 Washington, D.C. 20026-3986 (202) 616-7568 Counsel for Respondent Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 20

## 21 Of Counsel:

STEVEN SILVERMAN MICHAEL THRIFT Office of General Counsel U. S. Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, DC 20460

November 8, 2010 Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 21

## CERTIFICATE OF SERVICE
I hereby certify that on this 8th day of November, 2010, I caused a copy of the foregoing document to be served by the Court’s CM/ECF system on:

Andrea Bear Field Lucinda Minton Langworthy Hunton & Williams LLP 1900 K Street, N.W. Washington, DC 20006

Leslie Sue Ritts Ritts Law Group, PLLC 620 Fort Williams Parkway Carriage House Alexandria, Virginia 22304

Donald Trahan State of Louisiana Dept. of Environmental Quality P.O. Box 82282 Legal Affairs Division Baton Rouge, Louisiana 70884-2282

David S. Baron Seth Lee Johnson Earthjustice Legal Defense Fund 1625 Massachusetts Ave., NW Suite 702 Washington, DC 20036-2212

Roxanne Giedd Office of the Attorney General, State of South Dakota 1302 East Highway 14 Suite 1 Pierre, South Dakota 57501-8501
Nhu Q. Nguyen Office of the Attorney General, State of Nevada 100 North Carson Street Carson, Nevada 89701-4717 Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 22

## 2 Sandra Patricia Franco Robert N. Steinwurtzel Bingham McCutchen LLP 2020 K Street, NW Washington, DC 20006-1806
Margaret I. Olson Assistant Attorney General Office of the Attorney General State of North Dakota Solicitor General 500 North 9th Street Bismark, North Dakota 58501-4509
Paul M. Seby Marian C. Larsen Moye White, LLP 1400 16th Street 6th Floor Denver, Colorado 80202-1486
Nancy Elizabeth Olinger Assistant Attorney General Environmental Protection and Administrative Law Division P.O. Box 12548 (MC-018) Austin, Texas 78711-2548
Benjamin Joseph Alke Goetz, Gallik & Baldwin, PC 35 North Grand P.O. Box 6580 Bozeman, Montana 59771-6580

/S/ Norman L. Rave, Jr. Norman L. Rave, Jr. Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 23

# Exhibit 10

# Exhibit 11I l-45-i995 2,37at.1 FROi.1

,

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i , t I r ' -! | t / r\.-,,. l;lJ \/ 

# v/'v/Lf lJ

JOHN K. VAt{ DE KFr}{p, Attorney General. of the State of California ANDREA SHERIDA}I ORDTN Chief Assistant Attorney General THEODORA BERGER Assistant Attorney General CRAIG C. THOI.'PSON EDWARD G. WETL CLI FFORD RECH?SCHAFF € N Deputy Attorneys General 21ol webster Street Oakland, CA 94612 Telephone: (415) 464-0572 

# FILED
SUPERTOR CCURT SAfITA 8r'l"FrlilA 

## DEC 0

3 1990

xE}c{Erh A Pil ir ;, ouuf:/ ctsil'FrcoErf

PLE OF THE S?ATE I. JOHN K. VAIIT DE neral of the State Plaintiffs,

v.
A MARIA CHILI, rNc.
Defendant1. I am currently

Environruental protection
(hereafter the "Region', COUNTY OP SHITA BARBARA

oF CALIFORNfA ex. ) No. SM 64010 KAHP, Attorney

of California, ) (Case transferred to ) South County, Z/26/eol

DECI.ERATTON OF JOEN C. 

### vruo!|:l

DATE: Dec. 14, 1990 TIME: 9:oo a.m, Dept: To Be Assigned 

### ey: { yol.; (ls*

u u$*ane riootns. oc|fu crn'Frcort

Attorneyg for the peopte of the state of carifornia

SUPERIOR COTIRT OF THE STATE OF CALTFORNIA

T, John C. Vinont, declare:
enployed by the United States Agency (hereatter ilEpArr), Region IX

or rrRegional Officer') as the Regional Heteorologist. I have been ernployed in this posltion since June
1987.

a. As the Regional l{eteorologist f serve as the Regionrs expert on air guality nrodeling, neteorological
information and anbient air irnpact analyses. My position is1

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)

within the Air and Toxics Division of the Regional Office. f provide support to that dlvlslon; to the other divisions witnin the Region, such as the Haeardous waste oivision; and to state
and locar agencies vithin Region rX. one of the prinary duties
of ny position is to ensure that appropriate air quality rnodeling techniqres are used by this and other ageneies when conducting
anrbient air quality irrpact analyses.

b. There are a variety of ,'air guality models.il These include conceptual nrodels, qualitative descriptions of the
behavior of pollutants in tne atrnosphere; physical rnodels, scaled
nodels of pollution sources and their surroundings studied in a
conLrolled environment, Euch as a wind tunnelt statisticar modeLs, which encompags statisticalJ.y based descriptions of source-receptor relationships; and mathematical nodels, which are
mathehatical representations of the physical processes which lead

to transport and dispersion of pollutants in the atmosphere. The
focus of tbe remaining dlscussion is on mathematical. rrodelsi hereafter any reference to an air guarity rrodel is inpricitly

meant to refer to a mathematical air guality nodeI.

c. f perform, review and oversee air quality nodeling for a variety of different sources and source types. These include stationary aources with enissions emanating fron a stack, including st,ack sources with aerodynanlc downwash induced by nearby buildings; stationary sources htlth emLssions emanating
f,rom a broad area, coruoonly called area sgurces; mobile sources,

emissions from autonobiles, trucks, busses, al.rcraft, etc.; and

urban and regional scale roodeling, which enconpasses modeling aI).1

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of the above processes together on the scare of an entlre urban

area or over a number of urban areas together.
d. The pollutants modeled include both inert pollutants, those which renain cheurically stable for long periods of tine in the atnosphere, and chemicarry reactive pollutants,
those which undergo relatively rapid chemlcal transformation and t'hose which are not directry enitted, but rather forrn through a series of chemical reactions withln the atnosphere.
2. Previous to rny ernployrnent at EpA, I worked from Marcir
1982 to June 1987 as an Environrnental Engineering Specialist in the Air Quality Bureau of the State of New Mexico. My primary responsibillties there htere very siurilar to rny current position
at EPA. f performed, anbient inrpact analyses of various air porlution sources and conducted engineering analyses of the

sources to deternine ernission characteristics. The prinary focus of the analyses was on inert pollutants from stationary sources.

a- prom August 1978 to March 1982 r worked for the Atnospheric science Departnent at Colorado State University (csu)
as a Research Assistant. r vorked on a varlety of baeic
scientific researc.h projects dealing with croud physics. My prirrary area of research dealt with the uptake of acidic pollutants in snow,

b- Fron Novernber Lg77 to August LgTg r worked as a Physlcar science Aide for the pacj.fic Marine Environrnentar Laboratory of the National oceanographic and Atrnospheric
Adninistration. My duties there involved writing a1

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27 1 r-45-1995 2,39Af"1 FROt"t

a f.u

climatological suEaar)r of h.rget Sound and analyzing the affects
of r.rlnds on o11 spill transport in hrget Sound.

3. I received a Bachelor of Science Degree ln Atnospheric
sciences fron the university of waEhington 1n 1978 and a Haster of Science Degree in Atnospheric Science froro Colorado State University.

4. As the Regional Meteorologiet, I routlnely evaluate the adequacy of air cruality nodering on a technical basis and with respect to its acceptability in the reguLatory fraroework. Acceptable air quality rnodeling and analysis procedures are

outlined in The Guideline on Alr ouatitv Hodels (Revised) (EPA 450/2-78-027R, July 1986, supplement A, July tggz) (hereafter the 'rcuidelinen). The Guideline was first published in April 19?B to satisfy the requirenents of g32O of the 1977 aruendrnents to the
Cl-ean Air Act. The Guideline specifies appropriate modele to use
and provides guidance on their appropriate apptication. The
Guideline provides a common basis for estinating the air quarity

concentrations used in assessing control strategies and developing emission linits. The nodeling technigr:es ernbodied in
the Guideline are subjected to public, scientific revierr in
aeeordanee with 5320 of the CAA.
a, EPA has four prinary, on-going activities to provide direct input for consistency in inplementation and for

revisions to the Guideline. The first is a series of annual EPA workshops conducted for the purpose of ensuring consistency and providing clarification in the applicatlon of nodels. The second activity, directed toward the inprovenent of nodeling procedures,1 l-45-1995 2,39At'1 FROi'1 P 5

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27 is the cooPerative agreenent that EPA has vlth the scj.entlfic
co-'r'runity represented by the Anerican Heteorological Society.

This agreement provides scientific assessDent of procedures and
proposed techniques and EPonsors workshops on key technical

iseues. The third activity is the solicitation and reviev of new

models fron the technical and user connunity. In the lilarch 27,

19Bo Feder4l..Register, a procedure was outlined for the subnittal
to EpA of privately developed models. After extensive evaluation

and scientifj.c review, these models, as well as those made

available by EPA, are considered for recognltlon ln the

Guideline. The fourth activity is the extensive, on-going

research efforts by EPA and others in air quality and
meteoroloqrical nodel lng.

b. From the aforementioned process a number of models

vere selected as being refined ruodels, suitable for regulatory
application. Each refined urodeL unde:rrent intensive evaluation.

The evaluation exercises include statistical measures of model
perfomance in conrparison with Deasured air quality data and,

where possible, peer scientific reviews.

c. After a model has been selected as a refined nodel

for a partieular € ype of apPlication, EPA considers the model
appropriate for general use for that type of application without
undergoinlt case-by-case evaluatlon, provided that the application

fol.Ior"rs the EPA reeonnendations specified in the Cuideline.

5. The fndustrial Source Conplex models (hereafter ISC) '

have been deened refined rnodels by EPA for application to

industrial complexes. The fSC nodels consist of a short tetm1

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EodeL (rscsr) and a long tern nodel (rscLT). r,ong teln rnoders,
such as rsclT, are only appropriate for sarcul.ating anblent
concentrations for averaging periods of months to a year. short term urodels, such as rscsT, can be used for averaging tines fron
one hour up to a year. (Hereafter my connents referring to rsc apply to both fScST and fSCLT, unless othelrrise speclfied- ) I'he

rse model is appropriate for sinulating the emisslons of a variety of industriaL air enissions. These would, inctude
ernissions from rree standing stac)<s and vents; stacks and vents
which are infruenced by the aerodynarnic effects of nearby structures; enissions fron area sourcee, such as storage piles or evaporative emissions frorn open tanlcr; line sources, such as roaduays; and volume souree,s, such as rarge openings in buildings
from which enissions emanate. The noder is approprlate for siruulating the anbient inpacts of relativery inert pollutants,
such as ethyrene oxide, vhich do not undergo rapid chemical
transfonratlon in the atnosphere. ?he rnoder will ealcurate the
anbient concentrations at a number of user-specified rrreceptor',

locations.

a- For simulating a stack-type 6ource, rsc requires tbe input of the location, emission rate, physical stack height,
stack gas exit verocity, stack inside diameter, and stack gas temperature. rf the source l"s affected by the aerodynanic
effects of buildings then inputs would alao lnclude information
about the building dinensions.

b. The ISC nodel also requires meteorological data as input- These data include the wind speed, wind direclion, P.61

2

3

4

5

5

7

8

9

1 0

1 1

L2

1 3

14

1 5

1 5

L 7

1 8

1.9

2 0

2 1

2 2

2 3

2 4

2 5

2 6

2 7 1 l-o5-1995 2'.14At.1 trRot.l

tenperatrrre, stablllty class and nixing height. The
meteorological data nust be representative of the geographic area being modeled to be accepted for a refined regulatory
application.

c. The fSC nodel has gone through a nunber of
perfotrorance evaluation studieE, as outlined above. The following

are several references of evaluation studies invoLving fSC: (1) Bowers, J, F., and A, J. Anderson, 1991. A n Evaluation Study for the Industrial Source Conplex (fSC)
Disperslon ltodel, EPA PubLication No. EPA-AiO/{-81.-002. U. S.

Environmental Protection Agency, Research Triangle Park, .Nc.
(2, Bowers, J. F.; A. J. Anderson, and W. R .
Hargraves, 1982. Tests of the fndustrial Source Conplex (ISC)
Dispersion Model at the Armco Hiddle-town, Ohio Steel UiIL, EpA
Publication No, EPA-450/4-82-006. U. S. Envj.ronmental Protection
Agency, Research Triangle Park, NC.
(3) Seire, J. S., and L. L. Schulman, 1981.

Evaluation of the BLP and rsc Models with sF5 Tracer Data and soz

Measurements at Aluninum Reduction Plants. Air Pollution Control

Association Specia,Ity Conferenee on Dispersion Modeling for
Complex Sources, St. LouiE, MO.
(4) Schulman, L. L. and S. R. Hanna, 1986.

Evaluation of Downwash Modifications to the Industrial Source
CompLex Model. Journal of the Air Pollution Control Association,

36:258-264

.
d. fn uy experlence of conductlng and reviening air
quality modeling analyses, I have found that of the EPA approvedI

2

3

4

5

6

7

8

9

1 0

1 l

L 2

1 3

1 4

1 5

1 5

L 7

1 8

19

2 0

2 L

2 Z

2 3

2 4

2 5

2 6

2 7 1 1-45-1995 2,.19Ar.1 FROtl

models, the ISC nodel is the most widely used nodel for determining the aubient concentrations of emissions from

industrlal sources. This is prinarily due to its abillty to
simulate alnost any t)T)e of lndustrial conflgnrratl.on and its
status aa a refined model under EPA giuidelines. EPA considers it appropriate for use without undergoing case by case perforruance

evaluation.

6. When EPA has a refined nodeL appropriate for a specific
type of applicati,on, sueh as the ISC nodel, the nodeling results, based on the appropriate input data, are generally preferred by EPA over ambient rnonitoring data for detenuinl-ng emission

lirnitations for both new and existing sources. Nornrally, EPA

does not accept aonitoring data as the sole basis for deternining

an emission liroitation. When a refined nodel is available, EPA generally considers the nodel results alone (including background concentrations) sufficient for deteraining anbient concentrations

of enissions from industrial sources and setting appropriate

emission Lirnitations.

a. Monitoring data suffers frora a nunber of

limitations. One of the prinary linitations is that any given
nonitor can only neasure what is happening at the location where

the rnonitsor is physically located and at the tine it is operating. In order to adequately detect the naxinun inpact of

any particular source, many nonitors would have to be run gver a
nurnber of years. A monitoring progran designed to adeguately

detect a naximum concentratlon and to adequately characterize the

concentration field would be very expensive. A nurnber of years P.a

8 -1

2

3

4

5

6

7

I

9

1 0

1 1

L 2

1 3

l 4

1 5

1 5

L 7

1 8

1 9

2 0

2 t

2 2

2 3

2 4

2 5

2 6

2 7 1 I -85- I 995 2 : 4l Ar"1 FROI.1

of data qrould be necessar-y to collect enough sanples to cover aII
possible rneteorological situations in conbination vlth the

different operating conditions of the facility. A monLtoring

progran slth only one or tso monitors or of a ve!')t short duration

would be inadequate to e,nsure that naximun anbient inpacts would

be detected.
b, The usual intent of conducting an arabient inpact
analysis of an air pollution source is to deteraine if the

emissions are likely to affect hunan health or affect the

environrnent. The arnbient coneentrations are compared against

health or environmental affects data. Rather than helping to

resolve a problem, a prolonged ambient monitoring study allons

continued air guatity degradation, which in turn affects the

health or environrnental guality which vas to be protected. For a

new source being proposed, it is inpossible to measure its
impacts, since it is not yet builtc. The rnethod of analysis preferred by EPA for
determining the ambient concentrations resultlng from emissions

into the atmosphere of industrial sources, including toxic air

emissions, is ruodeling. As discussed above, before EPA

determines a model', such as ISC, to be a refined model,
appropriate for general use. the rnodel undergoes rigorous

evaluation and is determined to yield accurate estimates of the

ambient air concentratlonE resulting fron emission sources under
a variety of eonditione. With a model, the Bource can be

simulated under the full range of its potential operating and

eruission conditions, rather than being linited to the specific P.9

9 .1

2

3
{

5

6

7

8

9

1 0

L 1

L 2

1 3

1 4

1 5

1 6

t 7

1 8

1 9

2 0

2 L

2 2

2 3

2 4

2 5

2 6

2 7 1 1 -85- 1 995 2 : 4l At'l FROI'I P. 1 E

operating conditions occurring durlng the period of a linitea
nonitorlng study. Tlre uodel can also yleLd anbient concentration

data at any nunber of receptor loeationsr'rather than only at the

linited nunber of locations where a tronltor is physically
located. Also, iD air quality uodel provldes the only practical

nethod of estirnating the anbient lnpacts of a new source. A

model provides flexibility in an analysis and ean be :ltn
relatively quickly, at relativety little expense. d. Modeling also allops source contributions to a particular anbient concentration to be ascertained- If two

sources each eroit tbe sane pollutant, it is impossible to tell

from an anbl,ent meaEureDent of the specific pollutant, the

relative contributions to the measured arnbient concentration,

unless there is sone unigue surrogiate being ernitted fron one of

the facilities. Also, there is the uncertainty of whether a

heretofore unknown source of the pollutant of concern has
contributed to the measurernent. Hodeling, allows the impact of

each source to be calculated separately and in combination.
e. The use of rnonitoring data also Pre-suPposes that

there are acceptable and reliable nronitoring techniques available

for the pollutant^of interest. fn the past, this has generally

been the case. EPA has established acceptable and reliable

methods of rneasuring a nurnber of pollutants whtcn were regulated

under the Clean Air Act. Recently, howcver, the issue of toxic

air contarninants has arisen. Ambient heasurement techniques,

which can adeguately and accurately detect a speciflc toxic air

contarninant, are not necessarily available. The transport and11-05-1995 2 42AM FROM P. 11



### 1 dispersion of buoyant or neutral plumes of gaseous pollutants,

2 which are relatively inert in the atmosphere, is the same,
3 regardless of the specific chemical constituents of the gas.
4 Therefore, modeling provides a useful technique for detecting

5 levels of pollutants in the air if reliable ambient measurement

6 techniques are not available.

7 

### f. EPA does recognize the usefulness of ambient

8 measurements for information on background concentrations,

9 provided reliable monitoring techniques are available. EPA does

10 not recommend, however, that ambient measurements be used as the

11 sole basis of setting emission limitations or determining the

12 ambient concentrations resulting from emissions from an
13 industrial source. These should be based on an appropriate

14 modeling analysis.

15 I declare under penalty of perjury that the foregoing is

16 true and correct.

17 DATED: 

# #o ..JO 

### /f90 ./ 

### 18

19

20



### 21

22

23

24



### 25

26



### 27

# Exhibit 12

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 1



### ORAL ARGUMENT NOT YET SCHEDULED

UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

NATIONAL ENVIRONMENTAL

DEVELOPMENT ASSOCIATION'S

CLEAN AIR PROJECT,



### Petitioner,



## v.

UNITED STATES ENVIRONMENTAL

PROTECT ION AGENCY,



### Respondent. 

### )

Docket No. 10-1252
(and consolidated cases)

DECLARATION OF ROGER W. BRODE

1. My name is Roger W. Brode. I hold B.S. and M. S. degrees in Atmospheric Sciences and I

am currently assigned as a physical scientist in the Air Quality Modeling Group within the

Air Quality Assessment Division of the Office of Air and Radiation 's Office of Air Quality

Planning and Standards at th e U .S. Environmen tal Protection Agency ("EPA"), where my

1

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 2

responsibilities include t he development
, evaluation and applicatio n of air quali ty dispersion

models and the development of gu id ance associated wi th application of such models in

support of EPA regulations governing the Prevention of Significan t Deteriora ti on
("PSD")_permit t ing program. I ha ve bee n involved in the dev e lopment
, evaluation
, testing,

and documentation of the American Me t eorological Society EPA Regu l atory Model

("AERMOD ") throughout its history. I currently serve as co-chair of the AMS / EP A
Regulatory Model Improvement Committee (AERM I C) consisting of atmospheric scienti s ts

and dispersion model experts overseeing the further t echn i cal development of the model
, and

as co-chair of the AERMOD Implementation Workgroup consisting of EPA Reg i onal Office

and State dispers i on mode l ers whose charge has bee n to indentify and as s ess potential is sues

with implementation of the AE RMOD model as EPA 's preferred model under Appendix W

of Part 51 of the Code ofF ederal Regulat i ons.

2. The revised primary nat i onal ambient air quality standard for oxides of sulfur (" S02

NAAQS ") requires that the three year ave r age ofthe annual 99 111 

### percentile of the daily

maximum 1-hour average concentrations ofS02 be less than or equal to 75 parts per billion.

In add iti on, owners and operators of a new major stationary source or a major source
undergoing a major modification l ocated in areas not designated " nonattainment " for the S02

NAAQS must obtain a PSD permit
, and to do so must demonstrate (among other things) that

the emissions increases f rom the new or modified source will not cause or contribute to a

violation ofthe revi s ed S02 NAAQS. E xisting air quality models
, including AERMOD
, are
readily capab le of accurately predicting whether the re vised primary S02 N AAQS is at tained

and whether individual s ources cause or contribu te to a violation of the S02 NAAQS.
Specifically
, dispersion models that are used to demonstrate compliance with the S02 (and

2

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 3

other) NAAQS, including under PSD permitting programs, use sequentia l hourly
meteorological data as the basis for estimating ambient concentration levels. These data are

combined with other inputs (chiefly source emission information, background emissions, and

receptor information) to predict transport and dispersion of emitted pollutant plumes. Since

the key varying inputs to these models are input on an hourly basis
, all applications of these

models under the guidance in Appendix W (40 CFR Part 51) are predicated upon the models '
ability to predict hourly amb i ent concentrations. These models thus generate one-hour air
quality distributions from which the three year average of the annual 99th percentile of daily

maximum 1-hour average concentration of S02 can be readily calculated or otherwise
reasonably approximated

.

3. As part ofthe basis for EPA adopting the AERMOD model as the preferred model for nearfield applications in the 

### Guideline on Air Quality Models, Appendix W to 40 CFR Part 51,

the performance ofthe AERMOD model was extensive ly evaluated based on a total of 17

fie ld study data bases (AERMOD: Latest Features and Evaluation Results. EPA

- 454 / R-03-

003. U.S. Environmental Protection Agency, Research Triangle Park (2003), portions of

which are attached to this affidavit) ("EPA 2003")

. The scope of the model evaluations

conducted for AERMOD far exceeds the scope of evaluations conducted on any other model

that has been adopted in Appendix W to Part 51. These evaluations demonstrate the overall
good performance of the AERMOD model based on techn i ca ll y sound model evaluation
procedures, and also illustrate the significant advancement in the science of dispersion
modeling represented by the AERMOD model as compared to other models that have been

used in the past. In particular, adoption of the AERMOD model has significantly reduced the

3

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 4

potential for overestimation of ambient impacts from elevated sources in complex terrain
compared to other-models.

4. Some of the field studies used to evaluate AERMOD model performance involved ambient
sampling of S02 for a period of one year or more at several (typically about 1 0) monitors

sited around operating power plants. Other field s tudies involved sampling of controlled

releases of non-reactive tracers, typically SF6, generally over a shorter duration than the
operational studies, but with more robust sam pling to facilitate more detailed diagnosis of

model performance. Al t hough the long-term field studies associated with operating power
plants included assessments of 3-hour, 24-hour and even annual average impacts from the

model, evaluation re sults for 1-hour averages were routinely included for all of the field

studies. As shown in Tables 2 and 3 of EPA 2003
, modeling and monitored results for 1-

hour averages are in exce ll en t correlation in t he se studies, with the ratio of predicted to

observed performance approaching 1: 1 in most instances. Thus, in my opinion
, the

per forma nce of the AERMOD model for estima ting 1-hour ambient concentrations is welldocumented and the form of the new 1-hour S02 standard raises no questions or concerns
regarding the appropriateness of AERMOD.

5. The S02 NAAQS Coalition states that the revised S02 NAAQS is a "p robabilistic " s tandard

and asserts that this makes modeling more problematic, especially as compared to the
previous " determinis tic" standard. (C oalition p. 5.) The terms "probabilistic" and

"deter minis t ic" do no t have an ordinarily understood meaning in this context, but it appears

that the assertion is t hat predictive models like AERMOD are not suitable for a standard

which includes a percentile-based form (where the relevant comparison is to a percentile of

air quality from an air quality distribution), as opposed to an expected exceedance form

4

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 5

(whereby a standard may exceeded on a given number of days and compliance is assessed

based on air quality on the designated day once the allowed exceedance days are removed

from the distribution ). I know of no reason that AERMOD and other similar types of models

is suitable for one type of form and not the other. As just state d in paragraph 2, the models
readily generate air quality distribu t ions from which either percentiles (for th e revised S02

NAAQS, the 99 1 h 

### percentile) or exceeding days can be determined. In fact, the percentile

form of th e 1 -hour S02 NAAQS is a more "s tab le" metric than a sta nd ard based on the 1 51

- 

### highest or 2"d

- high est concentrations
, since the potential impact of "outliers" in the

distribution is mitigated, especially when the multi-year average aspect of the S02 NAAQS

is accounted for.

6. Both the S02 NAAQS Coalition and their affiant Mr. Paine raise a number of points

r egarding the issue of whether allowable or actual source emissions should be modeled,
stating that use of allowable emissions overstates sources' impacts. See, e.g. Paine Decl. at 1[



### 11-14. This issue is independent of th e predictive accuracy of AERMOD or other models.

7. EPA's rules and guidance provide significant flexibility in th e choice of which models to use

in determining if sources cause of contribute to NAAQS violations for purposes ofPSD
permitting. EPA's rules specify that "where an air quality model s pec ified in Appendix W of

th is part

.. . is inappropriate, the model may be modified or another model substituted" with

written approval from EPA

. 40 C.F .R. §51. 166 (1)(2). The rules t herefore allow flexibility
, subject to appropriate requirements, for alternative modeling techniques to be applied on a
case-by-case basis subject to appro v al by appropriate reviewing authority.

8. The declaration of Michael E. Long voices concerns regarding the use of the AERMOD
dispersion model to support implementation of the 1-hour S02 standard
, and asserts that

5

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 6

"AERMOD significantly over predic ts the ac tual one -hou r ambien t concentrations in our

ar ea when the available information is used in the model as directed by EPA." Long Decl. at

8. This assertion is based on a comparison bf model -pre dicted ambient concentrations to

amb i ent 

### 802 concentrations reported for 2008 at local EPA monitoring stations in the
vicinity of the ArcelorMitta l facilities b ei ng mode le d. Mr. Long reports that the "AERMOD

model predicted one -ho ur concentrations that were higher than the monitored va l ues 90% of

th e time and the predicted values were as much as 373,131 ti mes higher than the actual

monitored values." I d. Lackin g any additional details re ga rdin g the model-to

- monitor
comparisons cited by Mr. Long, t he response here is necessarily limited to a genera l

d iscuss ion of issues involved in such comparisons. A number of factors can affect the
comparison of a modeled concentration with a monitored concentration, including th e

accuracy of the emission rate and other source characteristics in put to the model, the
representativeness of the meteorological data inpu t to the model, and th e influence of lo cal
geographical features and land us e characteristics on the tr anspo rt and dispersion of the
plume. Another key factor that affects comparisons of modeled vs. monito red

concentrations, paired 

### in time and space, is the potential error or uncertainty in the wind

direction input to the model for that hour since the wind direction w ill determ i ne the

transpo rt direction of the plume

. Slight errors in the trans port wind direction may account for
significant dif ferences in modeled vs. monitored concentrations for a sp ecific hour,
especially for elevated plumes under stable atmospheric conditions where the latera l spread

of the plume can be very limi ted for relatively long transport di s tanc es, and errors of a few
degrees in wind direction can be the difference in the plume directly impacting the moni to r

for a particular hour or the plume missing the moni to r completely. In such cases, a factor of

6

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 7

3 73,131 differe n ce between modeled and monitored concen t rations could easily be

attributable to error or uncertainty in the wind direction

. Note that wind di rections reported

from routine meteorological monitor i ng stat i ons l ocated at airports, the most common source

of meteoro l ogical data used in air qua li ty modeling applications, are reported to the nearest

10 degrees. In addition, the comparison may reflect issues related to use of a ll owab le versus

actual em i ssions, which is irrelevant for purposes of determining whether the AERMOD

mode l itself is biased.

9. The declaration of Robert J. Paine addresses practical issues in applying the AERMOD

model that allegedly arise due to the form of the 1 -hour S02 standard, as well as concerns
regarding the conservatism of the assumptions on source emissions based on Appendix W

guidance in relation to the 1- hou r S02 standard. Responses to these issues are summar i zed

below, numbered according to Mr. Paine's declarat i on, with some responses applying to
multip le comments:

(a)

Paine Decl. 9. : The AERMOD model "does not yet provide results that allow permit

applicants to follow EPA 's guidance for determining whether they comply with the 1 -hour S02

NAAQS because of the un i que statistica l form of that NAAQS ."

Paine Dec l. 

### 11 10.: "The form ofthe 1-hour S02 NAAQS requires the applicable guideline

dispersion model to compute the highest 1-hour concentration for each day at each modeled

receptor point, and to keep track of this dai ly 1-hour maximum concentration st atistic for each of

the 365 days for each year modeled independently at each location modeled

.

7

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 8

Paine De cl. 1 1. : " In the case for which a cumulative modeling analysis is required, this same
procedure must be applied to the combined contributions of th e in d ividua l source being
permitted, nearby sources and reg ion al background."

Response: As stated in paragraph 2 above
, all of these metrics are readily obtainable from model

outputs . Al though th e existing version of AERMOD does not contain an algorithm f rom which

the se metrics emerge au to matically as model outputs , this does not change the result that all of

these metrics are obtainable. In fact, we are aware that Mr

. Paine, along with other priv a te sector
parties, developed po st -processing tools to compute the 1- hour S02 design va l ue based on the

fo rm of th e revised S02 NAAQS utiliz ing model output options available at the time.

(b)

Paine Decl. 

## 'II 11. : "Furtherm ore , E PA in most cases requires a conservatively high regional
background concentration to be added for all hours modeled, rather than the actual va l ues

measured during each hour of the modeling simulation ."

Response: EPA issued guidance on a range of issues re l ated to the new 1-hour S02 standard on
August 23,2010, including a recommendation that the overall hi g hes t 1 -ho ur monitored S02

concentration from a representative monitor could be u sed to account for the monitored
background component in a cumulative impact assessment "without further j us tificat ion. " We
recognize that use of the overall highest 1-hour monitored value may entail a degree of

conservatism tha t could prevent a source from demonstrat i ng comp li ance with NAAQS;

however
, tha t conservatism forms the basis for allowing the approach to be used without further
justification. The Augus t 23 memorandum further stated that " Additional refinements to this

'first ti er ' approach based on some level of t emporal pairing of modeled and monitored values

8

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 9

may be considered on a case-by-case basis, subject to approval by the r eviewing authority, with

adequate justificat i on and documentation." However, we also note that Appendix W explicitly

makes "no attempt" to "comprehensively define" the criteria involved in determining which
nearby sources to include in an analysis "owing to both the uniqueness of each modeling

situation and the large number of variables involved in identifying nea r by sources." See
Appendix W section 8.2.3.b.

(c)

Paine Decl. 1! 12.: "Following EPA's regulatory requirements for PSD modeling, the modeled
predictions of hourly concentrations of a probabilistic standard such as the 

### 99th percentile daily

maximum hourly S02 concentrations produced by a single source for which a permit is sought

can be much higher than concentrations that a ctually occur in the ambient air."

Response: As noted in paragraph 6 above, the issue of allowable versus actual emissions is
independent to the question of the accuracy of AERMOD or other models. Also
, as stated in
paragraph 5 abo Y e, there is no reason that AERMOD (or other similar models) is not equally

accurate in predicting percentile air quality distributions or expected exceedances on a given day

.
The underlying data which are input to the model generate air quality di str i butions which are
equally suitable for either type of form.

(d)

Paine Decl. 12. : " Modeling of peak S02 emissions as if they occur continuously is a

distortion of reality and will overestimate the ambient air concentrations. This is especially true

for 1-hour averages, since the variation of emissions for such a short averaging period is

9

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 10

potentially much higher than that for th e other S02 NAAQS averaging periods. This makes th e
assumption of constant peak emissions a critical issue for this new standard."

Response: The purpo se of dispers i on modeling in the context of th e PSD permitting program is

to demonstrate t hat the pr oposed new or modified emissions will not cause or contribute to

vio la t ions of t he standard if the permit is granted. This is inh erently a predictive exercise since it

entails an assessment of proposed future emissions. EPA's guidance for conducting s uch
analyses is dictated by and consistent with that purpose. Mr. Paine's stateme nt that 1 -hour

averages are more var ia ble than longer averaging periods again does not relate to potential model

bias a nd in any case makes a sweeping generalization for situations that differ case-by-case. The

statement that peak S02 emissions should not be modeled is a restatement 

### of the dispute as to

use of allowable or actual emissions, and does not relate to the issue of model bias.

(e)



### Paine Decl.
, 13. : "The model overprediction t endency is even more likely to be a prob lem in a

cumulative impact analysis because numerous sources (i.e.
, the source being permitted and
potentially thousands of other nearby sou rces) are all modeled at peak em is sions at all t imes and

added to a regional background l eve l of S02

... leading to unrealistic predictions that the 1-hour

S02 NAAQS will be exceeded."

Response: As no te d, the issue of allowable versus actual emissions is independent ofthe issue of

models' predictive accuracy. However, EPA's August 23,2010 clarification memo regarding

the applicability of A ppe ndix W guidance for the 1-hour S02 NAAQS cautioned "against the

literal and uncritical app lication of very prescriptive procedures for identifying which

background sources should be included in the mode led emission inventory for NAAQS

10

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 11

compliance demonstrations, including those described in Chapter C, Section IV. C.l of the draft

New Source Review Wo r kshop Manual (EPA
, 1990)
, noting [again] that Appendix W
emphasizes the importan ce of professional judgment in this process." One motivation for that

caution was a concern that application of such procedures could lead to an overly conservative

result by including too many background sources in th e cumulative impact assessment. As noted

elsewhere, Section 8.2.3.b of Appendix W suggests that "the number of such sources is expected

to be small excep t in unusual situations. "

(f)

Paine Decl. 13. : "Moreover, since th e nearby so urc es will be modeled individually (but their

emissions are already accounted for in t he regional monitoring), there will inevitably be doublecounting of the background impacts between the component s of the "nearby sources " and the
"regiona l background", especially for the common situation of the s tate requiring a single peak
regional b ackground value to be used for all modeled hours. "

Response: As noted in several responses above, there are many a pplication-specific factors that

need to be considered in determining how to conduct an adequate assessment of cumulative
impacts
, accounting for contributions from nearb y backgroun-d sources explicitly in the mode l as

well as a monitored contribution
, while avoiding or minimizing the potential for double-counting

of modeled and monitored impacts.

(g)

Paine Decl. 14. : "T he distribution of total peak daily emissions over the three-yea r period of

2000-2002 [from major S02 sources in central North Dako ta ] was found to overpredict the

second-highest monitored 24-hour concentrations by roughly a factor of2 because the emissions

11

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 12

on average are l ower than peak va l ues assumed in the modeling

. For the probabilistic 1- hour

standard

. . . and for closer receptors , the overprediction ratio would likely be even higher than

for a 24

- hour average, caus i ng extens i ve areas of fictitious mode l ed NAAQS vi olations ."

Response: The first statement in this comment merely confirms what was i ndicated in an earlier

response, namely that modeled impacts based on maximum allowable emissions should not be
expected to accurately predict ambient monitored concentrations in most cases, since monitored

concentrations can only reflect i mpacts from actual emissions. Overprediction by a factor of 2

does not suggest a significant degree of conservatism given that modeled emissions reflected
peak emissions. No rationale is offered to support the assertion that the overprediction ratio

would likely be even higher for the 1 -h our sta n dard, and we see no reason to expect that
necessarily to be t he case.

(h)



### Paine Decl., 1 4. : "Based on my experience with modeling t he 1-hou r NAAQS for nitrogen

di oxide - a NAAQS that is

. similar in form to the 1-hour S02 NAAQS

- this overprediction rat io

could approach a factor of 10 in areas with numerous sources mode l ed together."

Response: Although the form of the 1-hour N02 standard is very similar to the form of t he 1-

hour S02 standard, the ro le ofNOx chemis t ry in modeling ambient N02 impacts associated with

NOx emissions makes 

### it difficult to draw comparisons between the two standards in terms of the
potentia l for the model to overestimate ambient impacts as compared to mon i tored

concentrations. The comment does no t indicate what assumptions were made in the N02
modeling analyses regarding the conversion ofNO emissions to ambient N02. An overly

conservative assump t ion in relation to that conversion could introduce a significant bias in the

12

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 13

modeled concentrations relative to monitored concentrations ofN02 that would have no

relevance to modeling 1-hour 802 impac ts.

(i)



### Paine Decl. 15. : "If a cumulative modeling assessment shows violations of the NAAQS, then

the PSD permit applicant can still obtain a permit for its source by s howing that the proposed

source does not contribute significantly to the modeled viol ation

. EPA, however, has not yet

defined a procedure for determining whether a proposed source that conducts a cumulative
modeling analysis and finds modeled violations due to other sou rces is by itself causing or
contributing to these predic ted (and possibly false) 1-hour 802 NAAQS violations. This "sa fety

valve" thus does not yet exist for applicants tryi ng to demonstrate that their proposed 802-
emitting sources will n ot cause or contribute to any modeled violations of the .l -hour 802

NAAQS."

Response: Recognizing the importance of the significant contribution t est within the PSD
permitting program , EPA recommended an interim Significant Impact Level (SIL) in its August

23 guidance memorandum regarding the 1-hour 802 NAAQS. This interim SIL provides the

"s afety valve" that may allow a permit applicant to obtain a permit in cases where the cumulative
impact assessment shows modeled vio lations of the 1-hour 802 NAAQ8
, if it can be

demonstrated that the proposed em is sion increa ses do not contribute sig nificantly to those

modeled violations, paired in time and space. Although the form of the 1-hour 802 standard

may complicate the "bookkeeping " needed to make such a demonstrat ion, the principle of the
significant contribution tes t based on the SIL has not changed under the 1-hour 802 NAAQS.

13

### Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 14

Pursuant to 28 U.S.C. § 1746, and under penalty of perjury, I declare the foregoing is
true and correct to the best of my knowledge.

Date Roger W. Brode



### 14

# Exhibit 13

## Camille Sears 502 W. Lomita Ave., Ojai, CA 93023
Tel: (805) 646-2588 e-mail: camille.marie@sbcglobal.net



### ambient air locations, should n 

### June 28, 2012

EPA Docket Center 1301 Constitution Ave., NW., Room 3334 Washington DC 20004

Re: Docket#: EPA-HQ-OAR-2010-1059 Comments on USEPA’s Guidance for One-Hour SO 2 

### NAAQS SIP Submissions

Thank you for the opportunity to comment on USEPA’s guidance for one-hour SO 2 

### NAAQS SIP submissions. In the 9/22/2011 public draft of th eir guidance, USEPA summarizes their planned program elements as follows:

In addition to this guidance document, EPA is also planning a rulemaking to address some of the 1-hour SO 2 

### NAAQS implementation program elements. These elements include: (1) establishing that compliance with the 1-hour SO 2 

### NAAQS is appropriately based on the re sults of both air quality modeling and monitoring; (2) establishing the modeling requirements necessary to determine compliance with the 1-hour SO 2 

### NAAQS; (3) establishing the minimum scope of analysis required to demonstrate attainment and maintenance of the 1-hour SO 2 

### NAAQS to comply with th e SIP requirements in C AA section 110(a)(1); (4) establishing a reasonable time period fo r sources to comply with any new emissions limitations states need to esta blish in the 110(a)(1) SIPs to demonstrate attainment and maintenance of the 1-hour SO 2 

### NAAQS; (5) to set an attainment date for areas designated as unclassifiable ; and (6) establishing the criteria for redesignating areas from “unc lassifiable” to “attainment.” 1



### This document goes on to say:

EPA will also propose a rulemaking that would codify the hybrid modeling and monitoring implementation approach in or der to ensure compliance with the 1- hour SO 2 

### NAAQS in a timely manner. 2



### In summary, I believe that air dispersion modeling should be the preferred method for determining one-hour SO 2 

### impacts from existing sources. Monitoring should be used only in specific cases to supplement modeled impacts, and the monitored data, which cannot cover all ot be given more weight than the modeled concentrations. In

1 USEPA, Guidance for One-Hour SO 2 NAAQS SIP Submissions, Public Review Draft, September 22, 2011, pp. iiiiv. ( http://www.epa.gov/airquality/sulfurdioxide/pdfs/DraftSO2Guidance_9-22-11.pdf ) 2 Id., p. iv.Docket#: EPA-HQ-OAR-2010-1059 June 28, 2012 Page - 2



### essence, USEPA’s proposed hybrid modeling and monitoring implementation approach should be heavily weighted towards modeling.

Air dispersion modeling has been used for decad es to assess ambient air impacts from proposed and existing sources, and for SO 2 

### NAAQS SIP purposes, monitoring alone (or a program based predominantly on monitoring) is not a viable alternative. I recently submitted a subset of these comments to USEPA’s 10 th 

### Conference on Air Quality Modeling docket.

I specialize in atmospheric di spersion modeling, which uses regulatory-approved computer programs to estimate chemical concentrations in the air and deposition fluxes to the ground. In the past 30 years I have prepared over 1,000 ai r dispersion modeling analyses. I hold B.S. (1978) and M.S. (1980) degrees in Atmospheric Science from the University of California at Davis. A copy of my curri culum vitae is attached.

My comments on this docket concentrate on the issue of modeling vs. monitoring for verifying compliance with the one-hour SO 2 

### NAAQS (attainment determinati ons). My comments are in response to USEPA’s “key que stions” presented in their Implementation of the 2010 Primary 1- Hour SO 2 

### NAAQS: Draft White Paper for Discussion . I address key questions a. and b. on monitoring and key questions a., b., c., and d. on modeling.

Monitoring key questions:
a. Are the conceptual monitoring networks described above sufficient to determine whether ambient SO 2 

### levels meet the NAAQS and are protective of public health without the need for additional modeling? If not, then what enhancements should be made to them? In what situations should meteorological data co llection also be required?
b. What is an appropriate number of monitors to site around a source to assess air quality?

I am providing a combined response to the above questions.

I do not believe that it is feasib le for monitoring alone to verify compliance with the one-hour SO 2 

### NAAQS. A suitable monitoring program w ould require many monitors and data would need to be collected for at least several year s. The number of required monitors would be prohibitively expensive and the duration of the monitoring program, while compounding the expense, also delays the implementation needed to protect public health from any unhealthy SO 2 

### exposures.Docket#: EPA-HQ-OAR-2010-1059 June 28, 2012 Page - 3 

### The question of modeling or monitoring was discussed in a California Proposition 65 enforcement declaration by John Vimont, wh en he was USEPA’s Region IX Regional Meteorologist:

Monitoring data suffers from a numb er of limitations. One of the primary limitations is that any given monitor can only measure what is happening at the location where the monitor is physically located and at the time it is operating. In order to adequately detect the maximum impact of any particular source, many monitors would have to be run over a number of years. A monitoring program designed to adequately detect a maxi mum concentration and to adequately characterize the concentration field would be very expensive. A number of years of data would be necessary to collect enough samp les to cover all possible meteorological situations in combinati on with the different operating conditions of the facility. A monitoring program with only one or two monitors or of a very short duration would be inadequate to ensure that maximum ambient impacts would be detected. 3



### Mr. Vimont also declared:

EPA does recognize the usefulness of am bient measurements for information on background concentrations, pr ovided reliable monitoring techniques are available. EPA does not recommend, however, that ambient measurements be used as the sole basis of setting emission limitations or determining the ambient concentrations resulting from emissions from an industrial source. These should be based on an appropriate modeling analysis. 4



### I agree with Mr. Vimont on the disadvantages of relying on air monitoring to verify compliance with ambient air quality standards. This sentiment is also e xpressed by the State of California, in their Air Toxics Hot Spots Health Risk Assessment (HRA) guidelines:

Pollutant concentrations are required in HRA calculations to estimate the potential cancer risk or hazard indices associated with the emissions of any given facility. Although monitoring of a pollutant provide s excellent characterization of its concentrations, it is ti me consuming, costly, and typically limited to a few receptor locations and snapshots in tim e. Air dispersion modeling has the advantage of being relatively inexpensive and is less time consuming, provided that all the model inputs are available. In addition, air dispersion modeling provides greater flexibility for placement of receptors, assessment of individual

3 Vimont, John, People of the State of California v. Santa Maria Chili, Declaration, November 30, 1990. (see attached file: Vimont-John-Declaration.pdf) 4 Id.Docket#: EPA-HQ-OAR-2010-1059 June 28, 2012 Page - 4 

### and cumulative source contributions, and characterization of concentration over greater spatial extents. 5



### In addition, it is not always po ssible to place monitors where maximum project or cumulative impacts may be occurring. I have first-hand expe rience with the problem of siting monitors to ensure that maximum project impacts are being measured. While I was an employee with the Santa Barbara County Air Pollution Control Distri ct, I sited over 30 pre- and post-construction air quality PSD monitoring systems. These monitors were required by permit conditions for various oil and gas processing facilities, and severa l monitors were to be sited for each project. Using air dispersion modeling, we determined wh ere the peak project impacts were likely to occur and then attempted to place the air qual ity monitoring systems at those locations. In virtually every case, it was not possible to place th e air quality monitor in the desired location. Impediments to siting the monitors where we wanted to place them included: power or communication constraints, lack of security, denial of landowner permission, lack of access, and terrain and vegetation restrictions. In other words, it’s one thing to have an adequate number of monitors; it’s quite another thing to place them where they are needed.

Part of the problem is that there are relatively few existing monitors that can be used for SO 2 

### NAAQS attainment determinations. There are not nearly enough SO 2 

### monitors in place to determine attainment status of the existing major SO 2 

### emission sources. Moreover, very few, if any, of these monitors are “well-placed” for m easuring the maximum ambient air impacts from these existing SO 2 

### sources. This situation dictates that in virtually every instance, a monitoring program needs to be started from scratch, or air dispersion modeling must be used as the method for determining SO 2 

### ambient air concentrations a nd resulting attainment status.

The lack of existing major source-specific SO 2 

### monitoring is partly due to a failure of State air agencies requiring pre-and post-c onstruction air quality monitoring. In the past few years I have reviewed and commented on major SO 2 

### emission source PSD permit applications in Texas, Louisiana, Oklahoma, Nevada, Kentucky, North Carolina, South Carolina, Missouri, Kansas, South Dakota, Illinois, and Arkans as. With the exception of Nevada, the State air agencies have not required pre- or post-cons truction air quality monitoring, even though the PSD significant monitoring concentrations were exc eeded. This is the norm for th ese major sources, and it is one of the key reasons that there is a paucity of ambient air quality monitoring data that could be used to help determine attainment status surround ing these facilities. It is self-serving if a facility that could (should) ha ve been collecting am bient air quality data now argues that SO 2 

### NAAQS attainment determinations must be based on monitoring, not modeling.

5 California Office of Environmental H ealth Hazard Assessment, Air Toxics Hot Spots Program Risk Assessment Guidelines: The Air Toxics Hot Spot s Program Guidance Manual for Preparation of Health Risk Assessments, August 2003, p. 4-1. ( http://www.oehha.org/air/hot_spots/pdf/HRAguidefinal.pdf )Docket#: EPA-HQ-OAR-2010-1059 June 28, 2012 Page - 5



### This same issue applies to pre-construction monitoring for meteorological data. On many occasions I have commented that States should require major source facilities, as part of their PSD permit analysis, to collect site-specific me teorological data rather than rely on National Weather Service (NWS) airport da ta. On every occasion, my comments were disregarded, even though the PSD significant monitoring concentrati ons were exceeded for the proposed project. The State’s response and comment denial followe d a common theme, summarized as follows: site-specific meteorological data monitoring is unnecessary for modeling purposes and that NWS airport data are appropriate for permit applic ation analyses. Although it’s water under the bridge, site-specific data could have been collected during thes e application processes without causing time delays to permit issuance.

USEPA asked the question “ In what situations should meteor ological data collection also be required?” I believe the time has passed when these da ta could or should have been collected. Of course it would be ideal to have additional site-specific meteorological data for modeling major SO 2 

### emissions sources. But such a monitoring system will take at least two years to implement, and then the modeling will still have to be performed. The data collection itself will take a minimum of one year. It will take at least another year for developing the data collection protocol, review and approval of the protocol, siting of the syst em, installation, and afterwards post-processing of the data for modeling. Starting a site-specific meteor ological data collection effort from scratch contributes to an unreasonabl e delay of the measures that may be needed to protect ambient air from any excessive SO 2 

### exposures.

While I feel that site-specific meteorological data are preferable to NWS airport data, USEPA’s AERMINUTE program allows significant improve ments to the NWS data in that calms and variable wind hours that were previously unusab le by AERMOD can now be recaptured. In lieu of requiring new site-specific data collection efforts, modeling of SO 2 

### emissions for NAAQS SIP submissions should be performed using NWS data prepared with AERMET, in conjunction with AERMINUTE. The use of one-minute ASOS data should be a requirement, not a recommendation. If available high -quality site-specific meteorologi cal data already exist, then I believe they should be used in preference to NWS airport data.

Based on my experience, site-specific meteorologi cal data tends to resu lt in higher modeled impacts than NWS airport data, even when th e NWS data is processed with AERMINUTE and one-minute ASOS data. For example, I modeled the Homer City, PA power station with three different meteorological data sets: One year of site-specific data from the Manor monitoring station; 2006 through 2010 NWS data from Johnstown PA, including one-minute ASOS data processed with AERMINUTE (KJST); and 2006 through 2010 NWS data from Pittsburgh PA, including one-minute ASOS data processed with AERMINUTE (KAGC). All three data setsDocket#: EPA-HQ-OAR-2010-1059 June 28, 2012 Page - 6



### conditions are included in the 

### used Pittsburgh upper air soundings. The peak receptor grid ambient air impacts from AERMOD modeling using Manor site -specific data were about tw ice as high as the KJST or KAGC results. And even at specific receptor locations, such as Homer City High School, the Manor site-specific data resu lted in significantly higher im pacts than the NWS/AERMINUTE data sets.

In other words, using available NWS airport data, processed with AERMINUTE, will not likely over-predict modeled impacts, as suggested by some stakeholders. Moreover, these data have the advantage of being readily available on NCDC data DVDs for years 2007 through 2011, thus meeting The Guideline on Air Quality Modeli ng requirements of at least five years of consecutive data from the most recent, readily available five-year period. 6



### Modeling key questions:
a. Should some criteria (e.g., the PWEI concept) be used to identify priority sources to be modeled in an area where there is no nearby monitor?

I do not believe that a population weighted emi ssions index (PWEI) should be used to identify priority sources. The NAAQS, by definition, apply to ambient air, or "... that portion of the atmosphere, external to buildings, to which the general public has access." 7 

### Ambient air is the defining criteria, and it is not based on the number of people who are exposed, but whether anyone could have access to given locations. This includes waterways and unpopulated areas of all sorts, so long as someone in the public has access.

b. How should the modeling be performed – i.e., what changes to the March 24, 2011 guidance should be made, such as the use of size cut-offs and use of actual emissions?

Some stakeholders have suggested that one-hour SO 2 

### modeling analyses used for nonattainment SIP modeling should use actual emissions, and not th e potential to emit. I understand that using allowable emissions may result in higher impacts than the facility’s actual emissions. I have modeled many coal-fired EGUs where I analyzed both allowable and actual emissions obtained from USEPA’s Clean Air Markets Database (CAMD). The facility permitted emissions are often, though not always, greater than the reported actual emissions. This is because the permitted allowable emissions are often based on 30-day averaging periods and peak hourly emission limits were not set by the State agency in question. Also, startup, shutdown, and upset CAMD that may represent quite high actual emission rates.

6 USEPA, Revision to the Guideline on Air Quality Models: Adoption of a Preferred Ge neral Purpose (Flat and Complex Terrain) Dispersion Model and Other Revisions , Appendix W to 40 CFR Part 51, November 9, 2005. ( http://www.epa.gov/ttn/scram/guidance/guide/appw_05.pdf ) 7 40 CFR Part 50.1 (e) ( http://ecfr.gpoaccess.gov/cgi/t/text/textidx?c=ecfr&rgn=div5&view=text&node=40:2.0.1.1.1&idno=40#40:2.0.1.1.1.0.1.1 )Docket#: EPA-HQ-OAR-2010-1059 June 28, 2012 Page - 7



### If actual emissions are used for nonattainment SIP modeling, a condition mu st be added to the facility’s permit requiring that emissions must not be greater than the le vel used in the modeling analysis. In other words, a fac ility that wants to use actual emissions in their modeling analysis must agree to an enforceable permit condition li miting their emissions, by unit, to that quantity modeled. Also, actual emissions cannot be modeled using full load stack parameters. Stack gas exit velocity and temperature will be reduced under less than full load conditions, affecting plume rise and resulting modeled impacts. Any AERMOD modeling using actual emission levels must use corresponding actual stack gas ex it velocity and temperature. I suggest that USEPA should develop a method for calculating st ack gas exit velocity and temperature as a function of load, for use in cases where these data are not directly measured and reported.

I believe that any emission limits based on actual operating conditions must be rather straightforward and enforceable. For example, the actual emission rates could be based on the maximum hourly emissions, by stack, for the late st calendar year (or perhaps the maximum for the past three years). Maximum actual emission s could also be for shorter time periods (by season, for example), but emission limits by portion of the year may be more difficult to enforce, or the facility may not wish to be restricted by this condition. And while it is possible to model hour-by-hour actual emissions (using HOU REMIS in AERMOD) coupled with contemporaneous meteorological data, this an alysis does not ensure that the one-hour SO 2 

### NAAQS will be protected in the future. This is because combinations of meteorology and facility emissions that result in peak impacts are virtually unenforceable.

I believe that USEPA should be ve ry careful in considering emissi on rate cut-off levels. Without modeling, it is very difficult to determine the combined effects that emission rate, stack height, source-to-receptor distance and elevation di fferences, building downwash, background air quality, and plume rise will have on ambient air concentrations and NAAQS compliance. Obviously not every source will require modeling, but any cut-off criteria should consider all parameters that affect air concen tration, not simply emission rate.

c. Are there situations where m odeling is preferable to monitoring? If so, then what are these situations? Should EPA require modeli ng in certain situations, or is monitoring alone always a sufficient option for areas of concern?

As discussed above, modeling is preferable to monitoring for determining ambient air concentrations and for verifying compliance with the one-hour SO 2 

### NAAQS. I cannot envision a feasible air monitoring network that would verify compliance for a major SO 2 

### emission source – too many monitors would be needed and the delay in attainment demonstration and resulting controls would be unacceptably long.Docket#: EPA-HQ-OAR-2010-1059 June 28, 2012 Page - 8 

### I think it is beneficial to cons ider how California’s Air Toxics Hot Spots program, also known as AB 2588, determined ambient air concentrations of air toxics. This program required thousands of facilities in California to quantify emissions of scores of hazardous air pollutants, when virtually no inventory of these pollutants previo usly existed. AB 2588 also required at least 1,000 facilities state-wide to pr epare health risk assessments, which are based on ambient air concentrations of the air toxics in question. In all in stances, these facilities used air modeling as the basis for determining ambient air concentrat ions. This is based not only on State of California guidance (see the Air Toxics Hot Spots program citation in the air monitoring comments above), but on the practicality of actually quantifying air concentrations in a reasonable fashion.

I believe that the AB 2588 program required as much or more modeling work than will be needed for the one-hour SO 2 

### NAAQS SIP determinations. For example, in Santa Barbara County, where I was the Air Toxics Program Coor dinator, we prepared air dispersion modeling analyses for up to 50 facilities per year. Many of these facilities were very complicated andinvolved numerous toxic air pollutants. Plus, we calculated excess cancer risk and noncarcinogenic health effects from i nhalation and all other pathways of exposure. In other words, I think State air agencies should be able to handl e the effort required in modeling the major SO 2 

### emission sources within their jurisdiction.

Some stakeholders have expressed concern that AERMOD will over-predict air impacts, compared to monitoring results. While this may be true in some circumstances, e.g., at one location at a given time, the true value in modeling is the ability to calculate air concentrations at many more places and under many physical conditi ons that cannot be hand led by air monitoring. On the other hand, there are likely many s ituations where AERMOD underpredicts air concentrations compared to monitoring data.

USEPA should rely on the detailed AERMOD eval uations that were performed during the model development phase. I agr ee with Roger Brode’s 10 th 

### Modeling Conference presentation, where he concluded: “AERMOD model performance ha s been extensively evaluated and shown to provide generally unbiased estimates of 1-hr SO 2 

### concentrations across a wide range of scenarios.” 8

8 Roger Brode, USEPA/OAQPS, AERMOD Evaluations Under the 1-hour NO 2 and SO 2 NAAQS, 10 th Conference on Air Quality Modeling. ( http://www.epa.gov/ttn/scram/10thmodconf/presentations/2-8- Brode_10thMC_AERMOD_Evals_1hr-NO2-SO2_NAAQS_Final_3-25.pdf )Docket#: EPA-HQ-OAR-2010-1059 June 28, 2012 Page - 9 

### I believe that the concerns about AERMOD over-predicting air concentrati ons are, on the whole, without merit. At the 2012 RSL Modelers’ Workshop, George Bridgers and Roger Brode presented a summary of AERMOD’s performance evaluation results. They document that AERMOD provided better model predictions than ISCST3, ISC-Prime, and CTDMPLUS. In addition, they point out that the average ratio of predicted to observed one-hour and three-hour robust highest concentration values across all field studies for AERMOD was 0.995. 9 

### This is clearly an unbiased estimate of AERMOD’s predictive performance.

It is also evident that most of the large SO 2 

### emission sources have tall stacks, which were rigorously evaluated during AERMOD’s development process. From USEPA’s Compendium of Reports from the Peer review Process for AERMOD:

Concerning the model evaluation, we reiter ate that AERMOD has been evaluated against 10 substantial data bases, including: 1) four data sets for tall stack buoyant plumes in flat terrain (Kincaid SO2, Kincaid SF6, Baldwin, and Clifty Creek), 2) four data sets for tall stacks in complex terrain or near elevated terrain (Lovett, Martins Creek, Tracy, and Westvaco), 3) a buoyant elevated release in an urban environment (Indianapolis), and 4) a nonbuoyant surface release (Prairie Grass). We agree that more evaluation would be desirable (as always) especially for downwash conditions, urban sources, and surface releases. However, there is a key question to the AERMOD development process: Has there been enough evaluation already to justify replaci ng ISC3 by AERMOD? AERMIC believes that there has been. 10



### Thus, any argument that AERMOD is not applicable to tall stack emission sources should be dismissed based on the studies used for deve loping AERMOD. In particular, AERMOD has been extensively evaluated for power plant emissions:
It is worth noting in this regard that all of the AERMOD evaluation data bases (except for Prairie Grass) involved tall, non-downwa shed, highly buoyant power plant stacks (the shortest stack in th e group was 84 meters in Indianapolis). 11



### AERMOD’s evaluation process ultimately comprised 17 separate data sets. I believe that any concerns from stakeholders that AERMOD over-pre dicts power plant impact s, or over-predicts impacts from other source types represented in the evaluation databases, should be dismissed.

9 George Bridgers and Roger Brode, USEPA/OAQPS, Challenges in Modeling Compliance for New NAAQS: 1- hour NO 2 & SO 2 and PM 2.5 , 2012 RSL Modelers’ Workshop. ( http://www.cleanairinfo.com/regionalstatelocalmodelingworkshop/archive/2012/presentations/Tues/3- 1_2012RSL_ModelingChallenges_Bridges.pdf ) 10 USEPA OAQPS, Compendium of Reports from the Peer review Process for AERMOD, February 2002, pdf page 38/69. ( http://www.epa.gov/scram001/7thconf/aermod/dockrpt.pdf ) 11 Id., pdf page 49/69.Docket#: EPA-HQ-OAR-2010-1059 June 28, 2012 Page - 10 

### I would also add that AERMOD’s evaluation analyses included a number of site-specific meteorological data sets that incorporate low wind speed conditions. For example, the Tracy evaluation included meteorological data with wind speeds as low as 0.39 meter/second (m/s); the Westvaco evaluation included wind speeds as low as 0.31 m/s; the Kincaid SO 2 

### evaluation included wind speeds as low as 0.37 m/s; and the Lovett evaluation included wind speeds as low as 0.30 m/s. 12 

### Concerns raised by stakeholders rega rding AERMOD’s ability to model low wind speed conditions seem to neglect the da ta used in actual AERMOD evaluations.

Some stakeholders are concerned that AERMOD is inaccurate in areas with extreme topography, such as complex river valleys and steep hillside s. This concern has already been addressed by USEPA in their response to the New Jersey Department of Environmen tal Protection (NJDEP) section 126 petition for SO 2 

### emissions from the Portland Generating Station. In their review of NJDEP’s petition, USEPA found that AERMOD is the most appropriate model for determining air impacts in the complex terrain and comple x wind fields surrounding the Portland facility. 13 

### USEPA also recognizes that “the performan ce of the AERMOD model for estimating impacts associated with tall stacks in complex terrain settings has been exte nsively evaluated and documented in peer-review journals... and has consistently been shown to perform better than competing models.” 14



### Air monitoring of SO 2 

### is not a feasible alternative to modeling for steep hillsides and other complex terrain conditions. Proper air quality m onitor siting is extremely difficult in these settings, and any siting would depend on prior air dispersion modeling in the first place.

While I have used CALPUFF to model emissions in complex river valleys, I was able to do so only because there were multiple site-specific me teorological monitors to provide the needed data to develop the CALMET wind fields. For facilities where adequate meteorological data exist to run CALPUFF, I believe this is a possible alternative to running AERMOD. Otherwise, AERMOD should be used due to the problems asso ciated with siting and operating an adequate monitoring network in these complex terrain environments.

12 The AERMOD evaluations and modeled meteorological data are at: http://www.epa.gov/ttn/scram/dispersion_prefrec.htm 13 USEPA, Air Quality Modeling Technical Support Document: NJ 126 Petition of September 17, 2010, April 2011, p. 12 of 63. ( http://www.epa.gov/ttn/scram/reports /EPA-HQ-OAR-2011-0081-0026.pdf ) 14 Id., p.11 of 63.Docket#: EPA-HQ-OAR-2010-1059 June 28, 2012 Page - 11 

### d. Are there situations where m onitoring is preferable to modeli ng? If so, then what are these situations? Should EPA require monito ring in certain situations, or is modeling alone always a sufficient option for areas of concern?

As discussed above, I believe that modeling alone is sufficient for verifying compliance with the one-hour SO 2 

### NAAQS. If monitoring is used, as in USEPA’s proposed hybrid modeling and monitoring approach, it should be only as a supplement to modeling and the modeling and monitoring results should be given equal weight.

I think it is important to remember that all NO 2 

### , PM 2.5 

### , and SO 2 

### NAAQS and PSD increment permit application analyses are performed w ith air dispersion modeling, such as running AERMOD in a manner consistent with the Guideline on Air Quality Models. In order to ensure consistency in how air impacts are determin ed, both existing sources and newly permitted sources should be assessed using the same meth ods. From the Guideline on Air Quality Models:

The Guideline is used by EPA, States, and indus try to prepare and review new source permits and State Implementation Plan revisions. The Guideline is intended to ensure consistent air quality analyses for activities regulated at 40 CFR 51.112, 51.117, 51.150, 51.160, 51.166, and 52.21. 15



### Allowing existing sources to use monitoring (assuming adequate monitoring even exists or could exist), results in a lower standard of compliance verification than that being used for new permit applicants.

Concluding Remarks

Using AERMOD for one-hour SO 2 

### NAAQS SIP submissions is reasonable and reliable. AERMOD has undergone rigorous model evaluations, was subjected to numerous peer-reviewed studies, and has already been used in hundreds, if not thousands, of air quality impact analyses of major emission sources. USEP A must not exchange their ex isting guideline model for an ambient air monitoring program whic h will never be able to verify compliance with the one-hour SO 2 

### NAAQS.

Based on my experience with both modeling and monitoring, I believe that air modeling, using AERMOD, is the best available method for verifying compliance with the one-hour SO 2 

### NAAQS. I suggest that USEPA’s proposed hybrid modeling and monitoring implementation

15 USEPA, Revision to the Guideline on Air Quality Models: Adoption of a Preferred General Purpose (Flat and Complex Terrain) Dispersion Model and Other Revisions , Appendix W to 40 CFR Part 51, November 9, 2005, Section II. ( http://www.epa.gov/ttn/scram/guidance/guide/appw_05.pdf )Docket#: EPA-HQ-OAR-2010-1059 June 28, 2012 Page

- 12



### approach for one-hour S02 NAAQS SIP submissions should be heavily weighted towards modeling.

Thank you for the opportunity to submit these comments on USEP A s guidance for one-hour S02 NAAQS SIP submissions.

Sincerely,

Camille Sears

### Camille Marie Sears 502 W. Lomita Ave., Ojai, CA 93023
Tel: (805) 646

- 2588 e
- mail: cam ille.marie@sbcglobal.net

Summary I have over 30 years of regulatory and private

- sector experience in air quality impact analyses, health risk assessments, meteorological monitoring, and geographic information systems. I specialize in litigation support; I have successfully provided testimony in numerous cases, both as an individual consultant and as pa rt of a team of experts.

E ducation

 M.S., Atmospheric Science, University of California, Davis, 1980.

 B.S., Atmospheric Science, Uni versity of California, Davis, 1978.
Air Dispersion Modeling

 I am experienced in applying many different air dispersion models , including programs still in the development phase. I have prepared well over 1,000 air dispersion mod eling analyses requiring the use of on

- site or site

- specifi c meteorological data. T hese runs were made with the USEPA ISC, OCD, MESOPUFF, INPUFF, CALPUFF, ISC

- PRIME, AERMOD , COMPLEX

- I, MPTER, and other air dispersion models.

 I pr epared and submitted technical comments to the USEPA on beta

- testing versions of AERMOD; these comments are being addressed and will be incorporated into the model and instructions when it is ready for regulatory application.

 I am experienced in performing air dispersion modeling for virtually every emission source type imaginable

. I have modeled: Refineries and associated activities; Mobile sources, including cars, trains, airplanes, trucks, and ships; Power plants, incl udi ng natural gas and coal

- fired ; Smelting operations; Area sources, such as housing tracts, biocides from agricultural operations, landfills, highways, fugitive dust sources, airports, oil and gas seeps, and pond s; Volume sources, including fugitive em issions from buildings and diesel construction combustion emissions; Small sources, including dry cleaners, gas stations, surface coating operations, plating facilities, medical device manufacturers , coffee roasters, ethylene oxide sterilizers, degreasin g operations, foundries, and printing companies; Cooling towers and gas compressors ; Diatomaceous earth, rock and gravel plants, and other mining operations; Offshore oil platforms, drilling rigs, and processing activities; Onshore o il and gas expl oration, storage, proce ssing, and transpor t facilities; Fugitive dust emissions from roads, wind erosion, and farming activities; Radionuclide emissions from actual and potential releases.

 I have extensive experience in modeli ng plume depletion and deposition from air releases of particulate emissions.

 As a senior scientist , I developed the Santa Barbara County Air Pollution Control District (SBAPCD) protocol on air quality modeling. I developed exten sive modeling capabilities for the SBAPCD on VAX 8600 and Intel I

- 860 computer systems; I acted as systems analyst for the SBAPCD air quality modeling system; I served as director of air quality analyses for numerous major energy projects; I performed air quality impact analyses using inert and photochemical models, including EPA, ARB and private

- sector models; I performed technical review and evaluating air quality and wind field models; I developed software to prepare model inputs consistent with the SBAP CD protocol on air quality modeling for OCD, OCDCPM, MPTER, COMPLEX

- I/II and ISC.

 I p rovided detailed review and comments on the development of the Minerals Management Service OCD model. I d eveloped the technical requirements for andCamille Marie Sears, Page

- 2

supervised the development of the OCDCPM model, a hybrid of the OCD, COMPLEX

- I and MPTER models.

 I p repared the "Modeling Exposures of Hazardous Materials Released During Transportation Incidents" report for the Cali fornia Office of Environmental Health Hazard Assessment (OEHHA). This report examines and rates the ADAM, ALOHA, ARCHIE, CASRAM, DEGADIS, HGSYSTEM, SLAB, and TSCREEN models for transportation accident consequence analyses of a priority list of 50 chemical s chosen by OEHHA. The report includes a model selection guide for adequacy of assessing priority chemicals, averaging time capabilities, isopleth generating capabilities, model limitations and concerns, and model advantages.

 I a m experienced in assessing uncertainty in emission rate calculations, source release, and dispersion modeling. I have developed numerous probability distributions for input to Monte Carlo simulations, and I was a member of the External Advisory Group for the California EPA Air Toxics Hot Spots Program Risk Assessment Guidelines, Part IV, Technical Support Document for Exposure Assessment and Stochastic Analysis

. Health Ri sk Assessment

 I have prepared more than 300 health risk ass essments of major air toxics sources

. These assessments were prepared for AB 2588 (the Air Toxics "Hot Spots" Information and Assessment Act of 1987), Proposition 65, and other exposure analysis activities. More than 120 of these exposure assessments wer e prepared for Propositi on 65 compliance verification in a litigation support setting.

 I r eviewed approximately 300 other health risk assessments of toxic air pollution sources in California . The regulatory programs in t his review include AB 2588, Proposition 65, the California Environmental Quality Act, and other exposure analysis activities. My c lients include the California Attorney General's Office, the Los Angeles County District Attorney's Office, the SBAPCD , the S outh Coast Air Quality Management District, numerous environmental and community groups, and several plaintiff law firms.

 I am e xperienced in assessing public health risk from continuous, intermittent, and accidental rele as es of toxic emissions. I am e xperienced in generating graphical presentations of risk results, and characterizing risks from carcinogenic and acute and chronic noncarcinogenic pollutants.

 I am e xperienced in communicating adver se health risks discovered through the Proposition 65 and AB 2588 processes. I have p resented risk assessment results in many public settings

-- to industry, media, and the affected public.

 For four years, I was the A ir Toxics Pr ogra m Coordinator for the SBAPCD. My d uties included: developing and managing the District air toxics program; supervising District staff assigned to the air toxics program; developing District air toxics rules, regulations, policies and procedures; mana gement of all District air toxics efforts, including AB 2588, Proposition 65, and federal activities; developing and tracking the SBAPCD air toxics budget.

 I have prepared numerous calculations of exposures from indoor air polluta nts. A few examples include: diesel PM 10 inside school buses, formaldehyde inside temporary school buildings, lead from disturbed paint, phenyl mercuric acetate from water

- based paints and drywall mud
, and tetrachloroethene from recently dry

- cleaned cloth es. Litigation Support

 I have p repared numerous analyses in support of litigation, both in Federal and State Courts. I am e xperienced in preparing F.R.C.P. Rule 26(a)(2) expert r eports and providing deposition and trial testimon y (I have prepared eight Rule 26 reports) . Much of my work is focused on human dose and risk reconstruction resulting from multiple air emission sources (lifetime and specific events).Camille Marie Sears, Page

- 3

 I am e xperienced in preparing decla rations (many dozens) and providing expert testimony in depositions and trials (see my testimony history)

.
 I am experienced in providing support for legal staff. I have assisted in preparing numerous interrogatories, que stions for depositions, deposition reviews, various briefs and motions, and general consulting.

 Recent e xamples of my work include : DTSC v. Interstate Non

- Ferrous; United States District Court, Eastern Dist rict of California (2002). In this case I perfor med air dispersion modeling, downwind soil deposition calculations
, and resultant soil concentrations of dioxins (TCDD TEQ) from historical fires at a smelting facility. I prepared several Rule 26 Reports in my role of assisting the California Attorney General’s Office in trying this matter. Akee v. Dow et al.; United States District Court, District of Hawaii (2003

- 2004). In this case I performed air dispersion modeling used to qua ntify air concentrations and reconstruct intake, dose, excess cancer risk, and noncancer chronic hazard indices resulting from soil fumigation activities on the island of Oahu, Hawaii. I modeled 319 separate AREAPOLY pineapple fields for the following che micals: DBCP, EDB, 1,3

- trichloropropene, 1,2

- dichloropropane, and epichlorohydrin. I calculated chemical flux rates and modeled the emissions from these fumigants for years 1946 through 2001 (56 years) for 34 test plaintiffs and 97 distinct home, school, and work addresses. I prepared a Rule 26 Expert Report, successfully defended against Daubert challenges, and testified in trial. Lawrence O’Connor v. Boeing North America, Inc., United States District Court, Central District of California, Western Divis ion (2004

- 2005). In this case I performed air dispersion modeling, quantified air concentrations, and reconstructed individual intake, dose, and excess cancer risks resulting from approximately 150 air toxics sources in Los Angeles and Ventura Counties, California. I prepared these analyses for years 1950 through 2000 (51 years) for 173 plaintiffs and 741 distinct home, school, and work addresses. I prepared several Rule 26 Reports, and the case settled on the eve of trial in September, 2005

. Defendant s did not attempt a Daubert challenge of my work.

 I have prepared hundreds of individual and region

- wide health risk assessments in support of litigation. These analyses include specific sub

- tasks, including: calculating emission rates, choosing proper meteorological data inputs, performing air dispersion modeling, and quantifying intake, dose, excess cancer risk, and acute/chronic noncancer health effects.

 I have prepared over 120 exposure assessments fo r Proposition 65 litigation support

. In these analyses, my tasks include: reviewing AB 2588 risk assessments and other documents to assist in verifying compliance with Proposition 65; preparing exposure assessments consistent with Proposition 65 Regulati ons for carcinogens and reproductive toxicants; using a geographic information system (Atlas GIS) to prepare exposure maps that display areas of required warnings; calculating the number of residents and workers exposed to levels of risk requiring warnings (using the GIS); preparing declarations, providing staff support, and other expert services as required. I have also r eviewed scores of other assessments for verifying compliance with Proposition 65. My proposition 65 litigation c lients include the Cali fornia Attorney General's Office, the Los Angeles County District Attorney's Office, As You Sow, California Community Health Advocates, Center for Environmental Health, California Earth Corps, Communities for a Better Environment, Environmental Defense Fun d, Environmental Law Foundation, and People United for a Better Oakland.
Geographic Information Systems

 ArcGIS : I am e xperienced in preparing presentation and tes timony maps using ArcView versions 3 through 9.3 . I d eveloped m ethods to convert AutoCAD DXF files to ArcView polygon theme shape files for use in map overlays.Camille Marie Sears, Page

- 4

 I have created many presentation maps with ArcView using MrSID DOQQ and other aerial photos as a base and then overlaying exposure r egions. This provides a detailed view (down to the house level) of w here air concentrations and heal th risks are projected to occur.

 Using ArcView, I have created numerous presentations using USGS Topographic maps (as TIFF files) as the base on to which exposure regions are overlaid

.  MapInfo for Windows: I p repared numerous presentation maps including exposure isopleths, streets and highways, and sensitive r eceptors, labels . I d eveloped procedures for importing Surfer isopleths in AutoCAD DXF format as a layer into MapInfo.

 Atlas GIS : I am e xperienced in preparing presentation maps with both the Windows and DOS versions of Atlas GIS. In addition to preparing maps, I use Atla s GIS to aggregate census data (at the block group level) within exposure isopleths to determine the number of individuals living and w orking within exposure zones. I am also e xperienced in geocoding large numbers of addresses and performing statistical
a nalyses of exposed populations.

 I am experienced in preparing large

- scale graphical displays, both in hard

- copy and for PowerPoint presentations. These displays are used in trial testimony, public meetings, and other lit igation support.

 I developed a Fortran program to modify AutoCAD DXF files , including batch

- mode
coo rdinate shifting for aligning overlays to different base maps

. Ozone and Long

- Range Transport

 I d evelop ed emission reduction strategies and identified appropriate offset sources to mitigate project emissions liability. For VOC offsets, I d eveloped and implemented procedures to account for reactivity of organic compound species for ozone impact mitigation. I wrote Fortran programs and developed a chemical database to calculate ozone formation potential using hydroxyl radical rate constants and an alkane/non

alkane reactive organic compound method

.  I p rovided technical support to th e Joint Interagency Modeling Study and South Central Coast Cooperative Aerometric Monitoring Program. With the SBAPCD, I p rovided technical comments on analyses performed with the EKM A, AIRSHED, and PARIS models. I was responsible for developing emission s inventory for input into regional air quality planning models.

 I was the p roject manager for the Santa Barbara County Air Quality Attainment Plan Envir onmental Impact Report (EIR). My d uties included: preparing initial study; preparation and release of the EIR Notice of Preparation; conducting public scoping hearings to obtain comments on the initial study; managing contractor efforts to prepare the draft EIR.

 I modified, tested, and compiled the Fortr an code to the MESOPUFF model ( the precursor to CALPUFF) to incorporate critical dividing streamline height algorithms

. The model was then applied as part of a PSD analysis for a large copper

- smelting facility

.  I am experienced i n developing and analyzing wind fields for use in long

- range transport and dispersion modeling.

 I have run CALPUFF numerous times. I use CALPUFF to assess visibility effects and both near

- field and mesoscale air concentrations fr om various emission sources, including power plants.

Emission Rate Calculation s

 I d eveloped methods to estimate and verify source emission rates using air pollution measurements collected downwind of the emitting facilit y, local meteorological data, and dispersion models. This technique is useful in determining whether reported source emission rates are reasonable, and based on monitored and modeled air concentrations, revised emission rates can be created

.Camille Marie Sears, Page

- 5

 I am e xperienced in developing emission inventories of hundreds of criteria and toxic air pollutant source s. I d eveloped procedures and programs for quantifying emissions from many air emission sources, including: landfills, diesel exhaust so urces, natural gas combustion activities , fugitive hydrocarbons from oil and gas facilities, dry cleaners, auto body shops, and ethylene oxide sterilizers

.  I have calculated flux rates (and modeled air concentrations) from hundred s of biocide applications to agricultural fields

. Emission sources include aerial spraying, boom applications, and soil injection of fumigants

.  I am experienced in calculating emission rates using emission factors, source

- test re sults, mass

- balance equations, and other emission estimating techniques.
Software Development

 I am s killed in computer operation and programming, with an emphasis on Fortran 95.

 I am e xperienced with num erous USEPA dispersion models, modifying them for system

- specific input and output, and compiling the code for personal use and distribution. I own and am experienced in using the following Fortran compilers: Lahey Fortran 95, Lahey Fortran 90 DOS

- Extend ed; Lahey F77L

- EM32 DOS

Extended; M icrosoft Power Station 32

- bit DOS

- Extended; and Microsoft 16

- bit.

 I c onfigured and operated an Intel I

- 860 based workstation for the SBAPC D toxics program. I c reated control files and recoded pro grams to run dispersion models and risk assessments in the 64

- bit I

- 860 environment (using Portland Group Fortran).

 Using Microsoft Fortran PowerStation , I wrote programs to extract terrain elevations from both 10

- meter and 30

- met er USGS DEM files

. Using a file of discrete x,y coordinates, these programs extract elevations within a user

- chosen distance for each x,y pair. The code I wrote can be run in steps or batch mode, allowing numerous DEM files to be processed at once.

 I have written many hundreds of utilities to facilitate data processing, entry, and quality assurance. These utility programs are a “tool chest” from which I can draw upon to expedite my work.

 While at the SB APCD, I designed the ACE2588 model

- the first public domain multi

source, multi

- pathway, multi

- pol lutant risk assessment model. I co

- d eveloped the structure of the ACE2588 input and output files, supervised the coding of the model, tested the model for q uality assurance, and for over 10 years I provided technical support to about 200 users of the model. I was r esponsible for updating the model each year and ensuring that it is consistent with California Air Pollution Control Officer’s Association ( CAPCOA ) Risk Assessment Guidelines.

 I d eveloped and coded the ISC2ACE and ACE2 programs for distribut ion by CAPCOA. These programs we re widely used in California for preparing AB 2588 and other program health risk assessments. ISC2ACE and ACE2 contain "compression" algorithms to reduce the hard drive and RAM requirement s compared to ISCST2/ACE2588. I also d eveloped ISC3ACE/ACE3 to incorporate the revised ISCST3 dispersion model requirements.

 I develo ped and coded the "HotSpot" system

- a series of Fortran programs to expedite the review of air toxics emissions data, to prepare air quality modeling and risk assessment inputs, and to prepare graphical risk presentations.

 I cust omized ACE2588 and developed a mapping s ystem for the SBAPCD. I modified the ACE2588 Fortran code to run on an Intel I

- 860 RISC workstation; I updated programs that allow SBAPCD staff to continue to use the "HotSpot" system

– a series of programs that s treamline preparing AB 2588 risk assessments; I developed a risk assessment mapping syste m based on MapInfo for Windows which linked the MapInfo mapping package to the "HotSpot" system

.  I d eveloped software for electronic submitt al of all AB 2588 reporting requirements for the SBAPCD . As an update to the "HotSpot" system software, I created software that allows facilities to submit all AB 2588 reporting data, including that needed for risk prioritization, exposure assessment, and presentation mapping. The data submittedCamille Marie Sears, Page

- 6

by the facility is then reformatted to both ATDIF and ATEDS formats for transmittal to the California Air Resources Board.

 I d eveloped and coded Fortran programs for AB 2588 risk prioriti zation; both batch and interactive versions of the program were created. These programs we re used by several air pollution control districts in California.
Air Quality and Meteorological Monitoring

 I was r esponsible for the desi gn, review
, and evaluation of an offshore source tracer gas study

. This project used both inert tracer gas and a visible release to track the onshore trajectory and terrain impaction of offshore

- released buoyant plumes.

 I d evelop ed the technical requirements for the Santa Barbara County Air Quality/Meteor ological Monitoring Protocol. I d eveloped and implemented the protocol for siting pre
- and post

- construction air quality and meteorolo gical PSD monitoring systems. I d etermined the instrumentation requirements, and designed and sited over 30 such PSD monitoring systems. Meteorological parameters measured included ambient temperature, wind speed, wind direction, sigma

- theta (standard deviation of horizontal wind direction fluctua tions), sigma

- phi (standard deviation of vertical wind direction fluctuations), sigma

- v (standard deviation of horizontal wind speed fluctuations), and sigma

- w (standar d deviation of vertical wind spe ed fluctuations). A ir pollutants measured included PM 10 , SO 2 , NO, NO x , NO 2 , CO, O 3 , and H 2 S.

 I was r esponsible for data acquisition and quality assurance for an offshore meteorological monitoring station. Parameters measured included ambient temperature (and delta

- T), wind speed, win d direction, and sigma

- theta.

 In coordination with consultants performing air monitoring for verifying compliance with Proposition 65 a nd other regulatory programs, I w rote software to convert raw meteorological data to h ourly

- averaged values formatted for dispersion modeling input.

 Assisting the Ventura Unified School District, I collected air, soil, and surface samples and had them analyzed for chlorpyrifos contamination ( caused by spra y drift from a nearby citrus orchard ) . I also coordinated the analysis of the samples, and presented the results in a public meeting.

 Using summa canisters, I collected numerous VOC samples to characterize background and initial conditions for use in Santa Barbara County ozone attainment modeling. I also collected samples of air toxics (such as xylenes downwind of a medical device manufacturer) to assist in enforcement actions.

 For the California Attorney General’s Office, I purchased, calibrated, and operated a carbon monoxide monitoring system

. I measured and reported CO air concentrations resulting from numerous types of candles, gas appliances, and charcoal briquettes.
Support, Tra ining , and Instruction

 For 10 years, I provided ACE2588 risk assessment model support for CAPCOA. My t asks include d : updating the ACE2588 risk assessment model Fortran code to increase user efficiency and to maintain consistency with the CAPCOA Risk Assessment Guidelines; modifying th e Fortran code to the EPA ISC model to interface with ACE2588; writing utility programs to assist ACE2588 users; updating toxicity data files to maintain consistency with the CAPCOA Risk Assessment G uidelines; developing the distribution and installation package for ACE2588 and associated programs; providing technical support for all users of ACE2588

.  I i nstructed approximately 20 University Professors through the National Sc ience Foundation Faculty Enhancement Program. Instruction topics included: dispersion modeling, meteorological data, environmental fate analysis, toxicology of air pollutants, and air toxics risk assessment; professors were also trained on the use of the ISC2ACE dispersion model and the ACE2 exposure assessment model.

 I was the in structor of the Air Pollution and Toxic Chemicals course for the University of California, Santa Barbara, Extension certificate program in Hazardous Mat erials Management. Topics covered in this course include: detailed review of criteria andCamille Marie Sears, Page

- 7

noncriteria air pollutants; air toxics legislation and regulations; quantifying toxic air contaminant emissions; criteria and noncriteria pollutant monitoring; air quality modeling; health risk assessment procedures; health risk management; control/mitigating air pollutants; characteristics and modeling of spills and other short

term releases of air pollutants; acid deposition, precipitation and fog; indoor/occupatio nal air pollution; the effect of chlorofluorocarbons on the stratospheric ozone layer. I taught this course for five years.

 I have trained numerous regulatory staff on the mechanics of dispersion modeling, health risk assessments , emission rate calculations, and presentation mapping

. I provided detailed training to SBAPCD staff in using the HARP program, and in comparing and contrasting ACE2588 analyses to HARP.

 Through UCSB Extension, I taught a three

- d ay course on dispersion modeling, preparing health risk assessments, and presentation mapping with Atlas GIS and MapInfo

.  I hold a lifetime California Community College Instructor Credential (Certificate No. 14571); Subject Matter Area: Physics

.  I have presented numerous guest lectures

– at universities, public libraries, farm groups, and business organizations

. Indoor Air Quality

 I prepared mercury exposure assessments caused by applying indoor latex paints containing phenylmercuric acetate as a biocide

.  Using a carbon monoxide monitor, I examined CO concentrations inside rooms of varying sizes and with a range of ventilation rates

. Indoor sources of CO emissions included gas appliances and candles. I also examined CO concentrations within parking garages.

 I calculated air concentrations of tetrachloroethene inside homes and cars from offgassing dry

- cleaned clothes

.  I examined air concentrations of formaldehyde inside manufactured homes and school buildings. I also calculated formaldehyde exposures from carpet emissions within homes.

 I assessed lead air exposures and surface d eposition from deteriorating lead

- based paint applications within apartments

. I also calculated lead air concentrations and associated exposures resulting from milling of brass pipes and fittings.

 While employed by the SBAPCD, I assisted with exposure assessment and awareness activities f or Santa Barbara County high

- exposure radon areas

.  I calculated BTEX air concentrations and health risks inside homes from leaking underground fuel tanks and resultant co ntaminated soil plumes. I also assessed indoor VOC exposures and remediation options with the AERIS model.

 I have assessed indoor air concentrations from numerous volatile organic compound sources, including printing operations, microprocessor manufacturing, and solvent degreasing activities.

 I calculated indoor emission flux rates and air concentrations of elemental mercury for plaintiff litigation support purposes. This analysis included an exposure re construction (home, school, workplace, outside, and other locations) for 16 plaintiffs who had collected spilled mercury in their village. The study required room volume calculations, air exchange rates, exposure history reconstruction, mercury quan tity a nd droplet size estimation , elemental mercury flux rate calculations (including decay with time), and resultant air concentration calculations. I calculated both peak acute (two

- hour) and 24

- hour average concentrations.

 I calcula ted emission rates of lead from disturbed paint surfaces. I then calculated indoor air concentrations of lead for plaintiff litigation support purposes.Camille Marie Sears, Page

- 8

P ublications

 To establish a legal record and to assist in environmental review, I prepared and submitted dozens of detailed comment letters to regulatory and decision

- making bodies

.  I have contributed to over 100 Environmental Impact Statements/Reports and other technical documents required for regul atory decision

- making.

 I p repared two software review columns for the Journal of the Air and Waste Management Association

.  Correlations of total, diffuse
, and direct solar radiation with the percentage of possible sunshine for Davis, California. Solar Energy, 27(4):357

- 360 (1981).

E mployment History

 Self

- Employed Air Quality Consultant 1992 to 20 1 2

 Santa Barbara County APCD , Senior Scientist 1988 to 1992

 URS Consultants , Senior Scientist 1987 to 1988

 Santa Barbara County APCD , Air Quality Engineer 1983 to 1987

 Dames and Moore , Meteorologist 1982 to 1983

 UC Davis, Research Associate 1980 to 1981
Testimony History

 P eople of the State of California v. McGhan Medical, Inc

. Deposi tion: Two dates: June

- July 1990

 People of the State of California v. San ta Maria Chili Deposi tion: Two dates: August 1990

 California Earth Corps v. Johnson Controls , Inc

. Deposition: October 26, 1995

 Larry Dale Anderson v. Pacific Gas & Electric Deposition: January 4, 1996 Arbitration: January 17, 1996

 Adams v. Shell Oil Company Deposition: July 3, 1996 Trial: August 21 , 1996 Trial: August 22 , 1996

 California Earth Corps v. Teledyne Battery Products Depositio n: January 17, 1997

 Marlene Hook v. Lockheed Martin Corporation Deposition: December 15, 1997

 Lawrence O’Connor v. Boeing North America, Inc

. Deposition: May 8, 1998

 Bristow v. Tri Cal Deposition: June 15, 1998

 Abeyta v. Pacific Refining Co

. Deposition: January 16, 1999 Arbitration: January 25, 1999

 Danny Aguayo v. Betz Laboratories , Inc

. Deposition: July 10, 2000 D eposition: July 11, 2000

 Marlene Hook v. Lockheed Martin Corporation Deposition: September 18, 2000 Deposition: September 19, 2000

 Tressa Haddad v. Texaco Deposition: March 9, 2001Camille Marie Sears, Page

- 9

 California DTSC v. Interstate Non

- Ferrous United States District Court, Eastern District of California, Case No. CV

- F

- 97 50160 OWW LJO Deposition: April 18, 2002

 Akee v. Dow et al. United States District Court, Distr ict of Hawaii
, Case No. CV 00 00382 BMK Deposition: April 16, 2003 Deposition: April 17, 2003 Deposition: January 7, 2004 Trial: January 17, 2004 Trial: January 20, 2004

 Center for Environmental Health v. Virginia Clean ers Superior Court of the State of California County of Alameda
, Case No. 2002 07 6091 Deposition: March 4, 2004

 Application for Certification for Small Power Plant Exemption

– Riverside Energy Resource Center. Docket No. 04

- SPPE

- 01. Evidentiary Hearing Testimony before the California Energy Resource Conservation And Development Commission : August 31 , 2004

 Lawrence O’Connor v. Boeing North America, Inc. United States District Court, Central Dist rict of California, Western Division. Case No. CV 97

- 1554 DT (RCx) Deposition: March 1, 2005 Deposition: March 2, 2005 Deposition: March 3, 2005 Deposition: March 15, 2005 Deposition: April 25, 2005

 Clemente Al varez, et al, v. Western Farm Service, Inc. Superior Court of the State of California County of Kern, Metropolitan Division. Case No. 250 621 AEW Deposition: April 11, 2005

 Gary June et al. v. Union Carbide Corporation & UME TCO Minerals Corporation United States District Court, District of Colorado, Case No. 04

- CV

- 00123 MSK

- MJW Deposition: January 9, 2007

 Alberto Achas Castillo, et al. v. Newmont Mining Corporation, et al. District Court, D enver County, Colorado, Case No. 01

- CV

- 4453 Deposition: February 19, 2007 Deposition: February 20, 2007 Arbitration : March 6, 2007 Arbitration : March 7, 2007

 Jacobs Farm/Del Cabo Inc. v. Western Farm S ervice, Inc. Superior Court of the State of California County of Santa Cruz, Case No. CV 157041 Deposition: May 8, 2008 Deposition: August 26, 2008 Trial: September 18, 2008 Trial: September 24, 2008Camille Marie Sears, Page

- 10

 Environmental Law Foundation et al. v. Laidlaw Transit Inc. et al. Superior Court of the State of California County of San Francisco, Case No. CGC

- 06

- 451832 Deposition: July 8, 2008

 Application of NRG Texas Power, LLC for State Air Quality Pe rmit No. 79188 and Prevention of Significant Deterioration Air Quality Permit PSD

- TX

- 1072. State Office of Administrative Hearings Docket No. 582

- 08

- 0861; TCEQ Docket No. 2007

- 1820

- AIR. Deposition: February 12, 2009 Hearing : February 24 , 2009

 Application of IPA Coleto Creek, LLC for State Air Quality Permit No. 83778 and Prevention of Significant Deterioration Air Quality Permit PSD

- TX

- 1118 and for Hazardous Air Pollutant Major Source [FCAA § 112(G)] P erm it HAP

- 14

. State Office of Administrative Hearings Docket No. 582

- 09

- 2045; TCEQ Docket No. 2009

- 0032

- AIR. Deposition: September 21, 2009 Hearing: October 16, 2009

 Application of Las Brisas Energy Center, LLC for State Air Quality Permit No. 85013 and Prevention of Significant Deterioration Air Quality Permit PSD

- TX

- 1138 and for Hazardous Air Pollutant Major Source [FCAA § 112(G)] P erm it HAP

- 48 and Plantwide Applicability Permit PAL41

. State Office of Administrativ e Hearings Docket No. 582

- 09

- 200 5; TCEQ Docket No. 2009

- 0033

- AIR. Deposition: October 9, 2009 Hearing: November 5, 2009 Hearing: November 6, 2009

 Abarca, Raul Valencia, et al. v. Merck & Co., Inc., et al. United States District Court, Eastern Distr ict of California, Case No. 1:07

- CV

- 00388

- OWW

- DLB Deposition: April 13, 2010 Daubert Hearing : October 7, 2010 Daubert Hearing : October 13, 2010 Daubert Hearing : October 14, 2010 Rule 706 Expert Hearing : December 2, 2010 Tria l : February 10, 201 1

 Commonwealth of Kentucky, Energy and Environment Cabinet, File No. DAQ

- 41109

- 048. Sierra Club, Kentucky Environmental Foundation, and Kentuckians for the Commonwealth v. Energy and Environment Cabinet, Division for Air Quality, and East Kentucky Power Cooperative, Inc. Deposition: August 31, 201011-05-1995 2 37AM FROM P 1



### ,



### DEC 0 3 1990 

# FILED SUPERIOR COURT

sArnA E'.t,l""V'.RA 

### 1 JOHN K. VAN DE KAMP, Attorney General of the state of California 2 

### ANDREA SHERIDAN ORDIN Chief Assistant Attorney General 3 

### THEODORA BERGER Assistant Attorney General 4 CRAIG C. THOMPSON EDWARD G. WEIL 5 

### CLIFFORD RECHTSCHAFFEN Deputy Attorneys General 6 

### 2101 Webster street Oakland, CA 94612 7 

### Telephone: (415) 464-0572

8 

### Attorneys for the people of the State of California

9 SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 COUNTY OF SANTA BARBARA



### v.

Defendant. Plaintiffs,

ANTA MARIA CHILI, INC. Dec. 14, 

### 1990 9:00 

### a.m. To Be Assigned DATE: TIME: Dept: No. SM 64010 (Case transferred to South County, 2/26/90)



### DECLARATION OF JOHN C. VIMONT EOPLE OF THE STATE OF CALIFORNIA ex. el. JOHN K. VAN DE KAMP, Attorney eneral of 

### the State of California, ) ) ) ) ) ) ) ) ) ) } ) ) 

### 12

16

IS 11

17 13

15 

### 14

19 I, John C. Vimont, declare:

20 1. 

### I am currently employed 

### by the United states

21 Environmental Protection Agency (hereafter "EPA"), Region IX

22 (hereafter the "Region" or "Regional Office!') as the Regional

23 Meteorologist. I have been employed 

### in this position since June


### 24 1987.

2S 

### a. As the Regional Meteorologist I serve as the

26 Region's expert on air quality meteorological

27 information and ambient air impact analyses. My position is11-05-1995 2 38AM FROM P 2



### 1 within the Air and Toxics Division of the Regional Office. I

2 provide support to that division; to the other divisions within

3 the Region, such as the Hazardous Waste Division; and to state

4 and local agencies vithin Region IX. One of the primary duties

5 of my position is to ensure that appropriate air quality modeling

6 techniques are used by this and other agencies when conducting

7 ambient air quality impact analyses.

8 b. There are a variety of "air quality models."

9 These include conceptual models, qualitative of the

10 behavior of pollutants in the atmosphere; physical models, scaled

11 models of pollution sources and their surroundings studied in a
12 controlled environment, such as a wind tunnel; statistical

13 models, which encompass statistically based descriptions of

14 

### source-receptor relationships; and mathematical models, vhich are
15 mathematical representations of the physical processes which lead

16 to transport and dispersion of pollutants 

### in the atmosphere. The

17 focus of the remaining discussion is on mathematical models;

18 hereafter any reference to an air quality model is implicitly

19 meant to refer to a mathematical air quality model.

20 c. I perform, review and oversee air 

### quality modeling

21 for a variety of different sources and source types. These

22 include stationary sources vith emissions emanating from a stack,

23 inclUding stack sources with aerodynamic downwash induced by

24 nearby buildings; stationary sources with emissions emanating

25 from a broad area, commonly called area sources; mobile sources,
26 emissions from automobiles, trucks, busses, aircraft, etc.; and

27 urban and regional scale modeling, which encompasses modeling all11-05-19952:38AM FPOt·1 P 3



### 1 of the above processes together on the scale of an entire urban

2 area or over a number of urban areas together.

3 d. The pollutants modeled include both inert

4 pollutants, those which remain chemically stable for long periods

5 of time in the atmosphere, and chemically reactive pollutants,

6 those which undergo relatively rapid chemical transformation and

7 those which are not directly emitted, but rather form through a
8 series of chemical reactions within the atmosphere.

9 2. Previous to my employment at EPA, I worked from March

10 1982 to June 1987 as an Environmental Engineering Specialist in

11 the Air Quality Bureau of the State of New Mexico. My primary

12 responsibilities there were very similar to my current position

13 at EPA. I performed ambient impact analyses of various air

14 pollution sources and conducted engineering analyses of the

15 sources to determine emission characteristics. The primary focus

16 of the analyses was on inert pollutants from stationary sources.
17 a. From August 1978 to March 1982 I worked for the

18 Atmospheric Science Department at COlorado state University (CSU)

19 as a Research Assistant. I worked on a variety of basic

20 scientific research projects dealing with cloud physics. 

### My

21 primary area of research dealt with the uptake of acidic

22 pollutants in snow.
23 b. From November 1977 to August 1978 I worked as a
24 Phys'ical Science Aide for the Pacific Marine Environmental

25 Laboratory of the National oceanographic and Atmospheric

26 Administration. My duties there involved writing a

2711-05-1995 2:39AM FROM P.d



### 1 climatological summary of Puget Sound and analyzing the affects

2 of winds on oil spill transport in Puget sound.

J J. 

### I received a Bachelor of Science Degree in Atmospheric

4 Sciences from the university of Washington in 1978 and a Master

5 of Science Degree in Atmospheric Science from Colorado State

6 University.

7 4. As the Regional MQteorologist, I routinely evaluate the

8 adequacy of air quality modeling on a technical basis and with

9 respect to its acceptability in the regulatory framework.

10 Acceptable air quality modeling and analysis procedures are
11 outlined in Ahe Guideline on Air Quality Models (Revised) (EPA

12 450/2-78-027R, 3uly 1986, Supplement A, 

### JUly 1987) 

### (hereafter the

13 "Guideline"). The Guideline was first pUblished in April 1978 to

14 satisfy the requirements of §320 of the 1977 amendments to the

15 Clean Air Act. The Guideline specifies appropriate models to use
16 and provides gUidance on their appropriate application. The

17 Guideline provides a common basis for estimating the air quality

18 concentrations used in assessing control strategies and

19 developing emission limits. The modeling techniques embodied in

20 the Guideline are subjected to public, scientific review in

21 accordance with §320 of the CAA.

22 a. EPA has four primary, on-going activities to

23 provide direct input for consistency in implementation and for

24 revisions to the Guideline. The first is a series of annual EPA

25 workshops conducted for the purpose of ensuring consistency and

26 providing clarification in the application of models. The second

27 activity, directed toward the improvement of modeling procedures,11-05-1995 239AM FROM P5

1. 

### is the cooperative agreement that EPA has 

### with the scientific

2 community represented by the American Meteorological Society.

3 This agreement provides scientific assessment of procedures and

4 proposed techniques and sponsors workshops on key technical

5 issues. The third activity is the solicitation and review of new

6 models from the technical and user community. In the March 27,

7 1980 Federal Register, a procedure was outlined for the submittal

8 to EPA of privately developed models. After extensive evaluation

9 and scientific review, these models, as well as those made

10 available by EPA, are considered for recognition in the

11 Guideline. The fourth activity is the extensive, on-going

12 research efforts by EPA and others in air quality and

13 meteorological modeling.

14 b. From the aforementioned process a number of models

15 were selected as being refined models, suitable for regulatory

16 application. Each refined model underwent intensive evaluation.

17 The evaluation exercises include statistical measures of model

18 performance in comparison with measured air quality data and,

19 Where possible, peer scientific reviews.

20 c. After a model has been selected as a refined model

21 for a particular type of application, EPA 

### considers the model

22 appropriate for general use for that type of application without

23 undergoing case-by-case evaluation, provided that the application

24 follows the EPA recommendations specified in the Guideline.

25 5. The Industrial Source Complex models (hereafter ISC),

26 have been deemed refined models by EPA for application to

27 industrial complexes. The ISC models consist of a short term11-05-1995 2.d0AM P.6



### 1 model (ISCST) and a long term model (ISCLT). Long term models,

2 such as ISCLT, are only appropriate for calculating ambient

3 concentrations for averaging periods of months to a year. Short

4 term models, such as ISCST, can be used for averaging times frOm

5 one hour up to a year. (Hereafter my comments referring to ISC

6 apply to both ISCST and ISCLT, unless otherwise specified.) The

7 ISC 

### model is appropriate for simUlating the emissions of a
8 variety of industrial air emissions. These would include

9 emissions from free standing stacks and vents; stacks and vents

10 which are influenced by the aerodynamic effects of nearby

11 structures; emissions from area sources, such as storage piles or
12 evaporative emissions from open tanks; line sources, such as
13 roadways; and volume sources, such as large openings in buildings

14 from which emissions emanate. The model is appropriate for

15 simulating the ambient impacts of relatively inert pollutants,

16 such as ethylene oxide, Which do not undergo rapid chemical

17 transformation in the atmosphere. The model will calculate the

18 ambient concentrations at a number of user-specified "receptor"

19 locations.

20 a. For simulating a stack-type source, ISC requires

21 the input of the location, emission rate, physical stack height,

22 stack gas exit velocity, stack inside diameter, and stack gas
23 temperature. If the source is affected by the aerodynamic

24 effects of buildings then inputs would also include information

25 about the building dimensions.

26 b. The ISC model also requires meteorological data as
27 input. These data include the wind speed, wind direction,11-05-1995 240AM FROM P. 7



### 1 temperature, stability class and mixing height. The

2 meteorological data must be representative of the geographic area
3 being modeled to be accepted for a refined regulatory

4 application.

5 c. The ISC model has gone through a number of

6 performance evaluation studies, as outlined above. The fOllowing

7 are several references of evaluation studies involving ISC:

8 (1) Bowers, 

### J. F., and A. 

### J. Anderson, 1981. An

9 Evaluation study for the Industrial Source Complex elSe)

10 Dispersion Model, EPA Publication No. EPA-450/4-81-002. U. S.

11 Environmental Protection Agency, Research Triangle Park, ·NC.

12 (2) Bowers, J. A. J. Anderson, and W. R.

13 Hargraves, 1982. Tests of the Industrial Source Complex (lSC)

14 Dispersion Model at the Armco Middle-town, Ohio Steel Mill, EPA

15 Publication No. EPA-450/4-82-006. U. S. Environmental Protection

16 Agency, Research Triangle Park, NC.

17 (3) Scire, J. 5., and L. L. Schulman, 1981.

18 Evaluation or the BLP and ISC Models with SF 6 

### Tracer Data and S02



### 19 Measurements at Aluminum Reduction Plants. Air Pollution Control

20 Association Specialty Conference on Dispersion Modeling for

21 Complex Sources, St. Louis, MO.

22 (4) Schulman, L. L. and S. R. Hanna, 1986.

23 Evaluation of Downwash Modifications to the Industrial Source

24 Complex Model. Journal of the Air Pollution Control Association,

25 36:258-264.

26 d. In my experience of conducting and reviewing air

27 quality modeling analyses, I have found that of the EPA approved11-05-19952d0AM FROt1 P.8



### 1 models, the ISC model is the most widely used model for

2 determining the ambient concentrations of emissions from

3 industrial sources. This is primarily due to its ability to

4 

### simulate almost any type of industrial configuration and its

5 status as a refined model under EPA guidelines. EPA considers it



### 6 appropriate for use without undergoing case by case performance

7 evaluation.

S 6. When EPA has a refined model appropriate for a specific

9 type of application, such as the ISC model, the modeling results,

10 based on the appropriate input data, are generally preferred by

11 

### EPA over ambient monitoring data for determining emission

12 limitations for both new and existing sources. Normally, EPA

13 does not accept monitoring data as the sole basis for determining

14 an emission limitation. When a refined model is available, EPA

15 generally considers the model results alone (including background

16 

### concentrations) sufficient for determining ambient concentrations

17 of emissions from industrial sources and setting appropriate

18 emission limitations.

19 a. Monitoring data suffers from a number of

20 limitations. One of the primary limitations is that any given

21 monitor can only measure what is happening at the location where

22 the monitor is physically located and at the time it is

23 operating. In order to adequately detect the maximum impact of

24 any partiCUlar source, many monitors would have to be run over a
25 number of years. A monitoring program designed to adequately

26 detect a maximum concentration and to adequately characterize the

27 concentration field would be very expensive. A number of years

R.11-05-1995 2:d1AM FROt.' P.9



### 1 of data would be to collect enough samples to cover all

2 possible meteorological situations in combination with the

3 different operating conditions of the facility. A monitoring

4 program with only one or two monitors or of a very short duration

5 would be inadequate to ensure that maximum ambient impacts would

6 be detected.

7 b. The usual intent of conducting an ambient impact

8 analysis of an air pollution source is to determine if the

9 emissions are likely to affect human health or affect the

10 environment. The ambient concentrations are compared against

11 health or environmental affects data. Rather than helping to

12 

### resolve a problem, a prolonged ambient monitoring study allows

13 continued air quality degradation, which in turn affects the

14 health or environmental quality which was to be protected. For a
15 new source being proposed, it is impossible to measure its

16 impacts, since it 

### is not yet built.

17 c. The method of analysis preferred by EPA for

18 determining the ambient concentrations resulting from emissions

19 into the atmosphere of industrial sources, including toxic air

20 emissions, is modeling. As discussed above, before EPA

21 determines a model, such as ISC, to be a refined model,

22 appropriate for general use, the model undergoes rigorous

23 evaluation and is determined to yield accurate estimates of the

24 ambient air concentrations resulting from emission sources under

25 a variety of conditions. With a model, the source can be

26 simulated under the full range of its potential operating and

21 emission conditions, rather than being limited to the specific

9.11-05-1995 2:d1AM FROt,1 P.10



### 1 operating conditions occurring during the period of a limited

2 monitoring study. The model can also yield ambient concentration

3 data at any number of receptor locations; rather than only at the

4 limited number 

### Of locations where a monitor is physically

5 located. Also, an air quality model provides the only practical

6 method of estimating the ambient impacts of a new source. A

7 model provides flexibility in an analysis and can be run
8 relatively quickly, at relatively little expense.
9 d. Modeling also source contributions to a
10 particular ambient concentration to be ascertained. If two

11 sources each emit the same pollutant, it is impossible to tell

12 from an ambient measurement of the specific pollutant, the

13 relative contributions to the measured ambient concentration,

14 unless there is some unique surrogate being emitted from one of

15 the facilities. Also, there is the uncertainty of whether a
16 heretofore unknown source of the pollutant of concern has

17 contributed to the measurement. Modeling, allows the impact of

18 each source to be calculated separately and in combination.



### 19 e. The use of monitoring data also pre-supposes that

20 there are acceptable and reliable monitoring techniques available

21 for the pollutant-of interest. In the past, this has generally

22 been the case. EPA has established acceptable and reliable

23 methods of measuring a number of pollutants which were regulated

24 under the Clean Air Act. Recently, the issue of toxic

25 air contaminants has arisen. Ambient techniques,

26 Which can adequately and accurately detect a specific toxic air

27 contaminant, are not necessarily available. The transport and11-05-1995 2 42AM FROM P.11



### 1 dispersion of buoyant or neutral plumes of gaseous pollutants,

2 which are relatively inert in the atmosphere, is the same,
3 regardless of the specific chemical constituents of the gas.
4 Therefore, modeling provides a useful technique for detecting

5 levels of pollutants in the air if reliable ambient measurement

6 techniques are not available.

7 

### f. EPA does recognize the usefulness of ambient

8 measurements for information on background concentrations,

9 provided reliable monitoring techniques are available. EPA does

10 not recommend, however, that ambient measurements be used as the

11 sole basis of setting emission limitations or determining the

12 ambient concentrations reSUlting from emissions from an
13 industrial source. These should be based on an appropriate

14 modeling analysis.

15 I declare under penalty of perjury that the foregoing is

16 true and correct.

17 DATED:;tJ6 

# 30 /f90 ./ 

### 18

19

20



### 21

22

23

24



### 25

26



### 27

# Exhibit 14

# Exhibit 15

## AMBIENT AIR QUALITY IMPACT REPORT (NSR 4-1-3, AZP 04-01)

This document serves as the st atement of basis and fact sheet required by 40 CFR 124.7 and 124.8. This document sets forth the legal and factual basis for the permit conditions and provides references to applicab le statutory or regulatory pr ovisions, including provisions under 40 CFR 52.21. This document is intended for us e by all parties interested in the permit.

I. APPLICANT

Sithe Global Power, LLC Desert Rock Energy Project Three Riverway, Suite 1100 Houston, TX 77056

II. PROJECT LOCATION
Sithe Global Power, LLC (“Sithe”or “applican t”), under a development agreement with the Navajo Nation’s Diné Powe r Authority, is proposing to construct a 1,500 megawatt (“MW”) mine-mouth, coal-fired power plant (“Facility” or “DREF”). The Facility will be located in the Northeastern Area of the Na vajo Nation adjacent to Navajo Nation coal reserves at a mine operated by BHP Billit on. Sithe submitted an application for a Prevention of Significant Deterioration (“PSD”) permit to allow construction and operation of the coal-fired, nominal 1500 MW F acility on the Navajo Indian Reservation. The project is generally calle d the Desert Rock Energy F acility (“DREF”). The proposed 580 acre site is located a pproximately 25 miles southwes t of Farmington, New Mexico.
The proposed DREF is located within the New Mexico portion of the Four Corners Interstate Air Quality Control Region. The area is currently designated as attainment for all regulated pollutants: nitrogen dioxide (NO 2 

### ), sulfur dioxide (SO 2 

### ), carbon monoxide (CO), particulate matter less than 10 microns in aerodynamic diameter (PM 10 

### ), lead, and ozone (regulated as volatile organic compounds (VOC) and oxides of nitrogen (NOx)). For purposes of this PSD permit and anal ysis, EPA will refer to NOx, which is functionally equivalent to NO 2, 

### for both pollutants. The Faci lity’s surrounding area is classified as Class II. The nearest Class I ar ea is the Mesa Verde National Park, which is located approximately 75 kilometers (km) nor th of the site. The Grand Canyon National Park is located approximatel y 290 km west of the site.

III. PROJECT DESCRIPTION
The proposed PSD permit, if finalized after EPA receives and considers significant comments from the public, will allow Sithe to construct two supercritical pulverized coal fired boilers designed for a total nominal ge neration capacity of 1,500 MW (gross). Each of the two units will be 750 MW (gross) an d 683 MW (net). Sithe’s Facility will use a

### once through, supercritical steam cycle and other design features that will enable this Facility to achieve a net efficiency greater than 40% based on the lower heating value of the fuel. Sithe will install and operate Best Available Control Technology (BACT) emission controls to minimize the Facility ’s emissions of regulated air pollutants. Sithe’s Facility will minimize its water consumption by using a Heller system, dry natural draft cooling tower. The Facility’s solid wast es produced by combustion of the coal and the air pollution control system will be returned to the mine.

Pulverized Coal-fired Boilers
The proposed PSD permit, if fi nalized, will allow Sithe to construct two supercritical pulverized coal fired boilers de signed for a total nominal generation capacity of 1,500 MW (gross) divided into two units of 750 MW (gross) and 683 MW (net) each. Each boiler will have a heat input capacity of approximately 6,800 MMBTU/hr (extreme maximum) and will burn up to 382 tons/hour of coal. In the supe rcritical cycle, each boiler will produce steam at 3,626 psi and 1,112 

###  F at a rate of 4,636,000 lb/hour. The boilers will feed the high-pressure steam through a steam turbin e generator to produce electricity and then to a di rect contact jet condenser.
The proposed PSD permit’s BACT air polluti on controls for Sithe’s supercritical pulverized coal-fired boilers consist of the following:
Low-NOx burners and selective cataly tic reduction (SCR) to reduce NOx emissions;
Low sulfur coal, hydrated lime injection before a fabric filter, and wet limestone flue gas desulfuris ation to reduce SO 2 

### emissions;
Hydrated lime injection before a fabric filter, and wet limestone flue gas desulfurisation to reduce acid gas emi ssions including sulfuric acid mist;

A fabric filter to reduce particulate emissions; and

Good combustion controls to reduce CO and VOC emissions.
Auxiliary Boilers
The proposed PSD permit, if fi nalized, will also allow Sith e to construct and operate three auxiliary steam generators to provide auxiliary steam during startup and shutdownof the main steam generator. Sithe will use auxiliary steam generators that are firetube/smoke-tube type (package boilers, shell ty pe). Each auxiliary steam generator will have a heat input capacity of 86.4 MMBTU/ hour. Sithe will reduce emissions from these units by only burning low sulfur (0.05% su lfur) distillate oil, operating Low-NOx

2

### burners, practicing good combustion, and limiting operation to an average of 1,650 hours/year for the three boilers (equivalent to a total max imum annual fuel use in the three boilers of 142,560 MMBTU/y ear at full load operation).
Coal Handling
As a mine mouth facility, Sithe will burn only the low sulfur, blended coal from the Navajo Nation mine operate d by BHP Billiton. The coal will be delivered to the Facility by an enclosed conveyor system . Sithe will build a passive or inactive coal pile on the site for emergency purposes. Normal preparat ion and storage will be handled by BHP Billiton at the mine site. The conveyor from the Navajo Nation/BHP Billiton mine will move the coal through a series of enclosed transfer houses where the coal will drop onto conveyors for transport to bunke rs provided for each boiler. From the bunkers, Sithe will feed the coal through pulverisers to the boilers. The Sithe Facility on-site coal piles will be covered or sealed to pr event emissions and spontane ous combustion. All of the conveyors that Sithe will operate will be totally enclosed to prevent emissions. The proposed PSD permit, if finalized, will require Sithe to opera te dust suppression, enclosures, or baghouses to reduce emissions from material transfer points and the coal bunkers.
Cooling Towers
The PSD permit, if finalized, w ill require Sithe to install an d operate a direct contact jet condenser with a Heller dry c ooling tower system. In this cooling system, the process steam from the steam turbine is fed to the condenser and condensed by direct cooling with the cooling water coming from the cool ing cycle. The blended cooling water and condensate are collected in the hot-well and extracted by circulating water pumps. Approximately 2% of this flow – corresponding to the steam condensed – is fed to the boiler feed water system by c ondensate pumps. The major part of the flow is returned to the cooling tower for recooling. The coolin g duty is performed by the cooling deltas, divided into parallel sectors, where cooling air flow is i nduced by a natural draft dry cooling tower. Sithe has applie d to use, and the PSD permit is proposing to require, the Heller-type hybrid cooling tower to minimize water cons umption. When the ambient temperature is below 80 

###  F, the cooling tower will operate like a natural draft dry cooling tower. When the temperature exceeds 80 

###  F, the Facility has the option of applying water oversprays on the heating surfaces inside of the cooling tower to provide additional cooling. This type of cooling tower does not emit any particul ate matter or other pollutants.
Ash Handling
Sithe will reduce emissions of fly ash by coll ecting the fly ash in the main fabric filter. The pulverized coal-fired boilers will also generate bottom ash. Fly ash and bottom ash

3

### will be mixed in an ash silo. The proposed PSD permit, if finalize d, will require any particulate matter emissions from the ash silo to be reduced by a fabric filter. Gypsum, with a water content in the 10% to 20% range, will be ge nerated by the wet flue gas desulfurisation system. The gypsum fly ash and bottom ash will be mixed together and then transported back to the mine by an enclosed conveyor.

IV. EMISSIONS FROM THE PROPOSED PROJECT
The proposed Facility’s estimated maximum annual potential emissions are summarized in Table 1 and are based on ve ndors’ data, Sithe’s design cr iteria, EPA emission factors from AP-42, and established emission calculation procedures. The estimated maximum annual potential emissions include emissions from the two supercriti cal pulverized coal boilers, the three auxiliary boilers, the em ergency generators, the fire pumps, and materials handling. The est imated maximum annual potential emissions assume a 95% annual capacity factor at full load and include emissions from an anti cipated 60 startups per year, with an average of 30 startups pe r boiler (4 cold, 10 warm and 16 hot). The Facility’s startup and shutdown operations will not result in any excess daily or annual emissions compared to norma l continuous operation. EPA ha s determined that Sithe’s 95% capacity factor assumption and estimate of 60 startups per y ear is conservative, which means these assumptions are likely to lead to estimating higher potential emissions than the Facility will actually emit.

V

. V. APPLICABILITY OF THE PREVENTION OF SIGNIFICANT DETERIORATION (PSD) REGULATIONS
The PSD regulations define a "m ajor stationary source" as any source type belonging to a list of 28 source categories wh ich emits or has the "potential to emit" 100 tons per year (tpy) or more of any pollutant regulated under the Clean Air Ac t, or any other source type which emits or has the potential to emit such pollutants in amounts equal to or greater than 250 tpy. 40 CFR 52.21(b)(1). Sithe has applied to construct a fossil fuel-fired steam electric plant of more than 250 MMBTU/hr h eat input. It is, therefore, one of the 28 source categories specified in EPA regulati ons and the 100 tpy threshold applies for purposes of PSD applicability. The proposed F acility has the potential to emit over 100 tpy and is a major stationary source for all regulated pollutants except lead, fluorides and sulfuric acid mist.
Under the PSD regulations, a significant emissi ons increase is defined as an increase in emissions greater than the threshold prescribed for any pollutant subject to the regulation. 40 CFR 52.21(a)(1)(d). The significance thres holds prescribed by the PSD regulations at 40 CFR 52.21(b)(23) for lead, fluorides and sulfuric acid mist are listed in Table 2.

4

### Table 1 Estimated Maximum Annual Potential Emissions

Pollutant PC Boilers (tpy) Auxiliary Boilers

(tpy) Emergency Generators (tpy) Fire Water Pumps

(tpy) Material Handling (tpy) Project Estimated Emissions
NOx 3,315 7.13 2.26 0.41 n/a 3,325
CO 5,526 2.55 0.17 0.031 n/a 5,529

VOC 166 0.17 0.11 0.019 n/a 166

SO 2 

### 3,315 3.61 0.068 0.012 n/a 3,319

PM 553 1.02 0.083 0.015 16.1 570

PM 10 

### 1,105 1.68 0.077 0.014 12.9 1,120

Lead 11.1 0.00064 0.00012 0.0000022 n/a 11.1 Fluorides 13.3 neg neg neg neg 13.3

H 2 

### SO 4 

### 221 0.062 0.002 0.0004 n/a 221 Mercury 0.057 0.000071 neg neg n/a 0.057

Note: 1. tpy - tons per year 2. PM is defined as filterable particulat e matter as measured by EPA Method 5. 3. PM 10 

### is defined as solid particulate matter smaller than 10 micrometers diameter as measured by EPA Method 201 or 201A plus condensable part iculate matter as measured by EPA Method 202. EPA is treating PM 10 

### as a surrogate for PM 2.5 

### . PSD review applies to all pollutants that exceed the major stationary source threshold (100 tpy) or that exceed the significance thresholds for which the applicable federal National Ambient Air Quality Standards (NAA QS) have not been exceeded (attainment areas), or areas where the stat us of the area is uncertain (unclassified). The proposed Facility will be located in an area in th e New Mexico Air Qualit y Control Region, which currently has a designation of attainment for all pollutants.

5

### Table 2 Comparison of the Project Annual Emissions to the PSD Thresholds

Pollutant PSD Significance Level (tpy) Project Emissions (tpy)
CO 100 5,529
NOx 40 3,315

SO 2 

### 40 3,315

TSP/PM 25 570

PM 10 

### 15 1,120 Ozone (VOC) 40 166

Lead 0.6 11.1

Fluorides 3 13.3 Sulfuric Acid Mist (H 2 

### SO 4 

### ) 7 221

The estimated maximum annual potential emi ssions profile in Tabl e 2 shows that the Facility is a major stationary source becau se its potential to emit exceeds 100 tpy for NOx, CO, SO 2 

### , PM, PM 10 

### and VOC. Table 2 also shows that the Facility’s potential to emit lead, fluorides and sulfuric acid mist ex ceeds the significance thresholds. Therefore, all of these pollutants are subject to PSD review and must satisfy the following requirements:
1. Application of Best Availa ble Control Technology (BACT);
2. Analysis of ambient air quality impacts from the project;
3. Analysis of air quality and visibility impacts on Class I areas; and
4. Analysis of impacts on soils and vegetation.

VI. BEST AVAILABLE CONTROL TECHNOLOGY (BACT)

Section 169(3) of the Clean Air Act (CAA) defines BACT as follows:
The term "best available control technolog y" means an emissi on limitation based on the maximum degree of reduction of e ach pollutant subject to regulation under the Clean Air Act emitted from or which re sults from any major emitting facility.

6

### The permitting authority, on a case-by- case basis, taking into account energy, environmental, and economic impact s and other costs, makes a BACT determination through application of pr ocesses and availabl e methods, systems, and techniques, including fuel cleanin g or treatment or innovative fuel combustion techniques for control of each such pollutant. In no event shall application of BACT result in emissions of any pollutant which will exceed the emissions allowed by any applicable sta ndard established pursuant to section 7411 (NSPS) or 7412 (NESHAP) of the Clean Air Act.
For attainment pollutants be ing regulated in a PSD permit, EPA evaluates emissions control requirements through a “top-down” BACT determinati on, which is described in EPA’s New Source Review Workshop Manua l, Draft October 1990 (“PSD Manual”), page B-6. The top-down approa ch to the BACT review pro cess involves identifying all demonstrated and potentially applicable control technolog y alternatives. PSD Manual, page B.11. EPA would typically review information in EPA’s BACT/LAER (Lowest Achievable Emission Rate) Cl earinghouse, federal/state/local new source review permits, technical journals and other such sources . PSD Manual, page B.11. After broadly identifying potential control technology alte rnatives, EPA can el iminate any control alternatives that are not technically feasible because the alternative is either not available or not applicable. PSD Manual, page B.17. Next, EPA ranks each technically feasible control alternative to establish a hierarchy. PSD Manual, page B. 22. In the next step, the process either “validates the suitability of th e top control option in the listing for selection as BACT, or provides clear justification wh y the top candidate is inappropriate as BACT.” PSD Manual, page B. 26. If the PSD applicant, Sithe in this instance, accepts the top (most stringent) c ontrol technology alternative as BACT, and that control alternative is not eliminated based on collateral environmental impacts, then the BACT analysis is complete and the top control t echnology alternative is selected. PSD Manual, page B.26. The top-down BACT analysis is a case-by-case exercise for the particular source under evaluation. In summary, the five steps involved in a top-down BACT evaluation are:
1. Identify all available control options with practical potential for application to the specific emission unit for the regu lated pollutant under evaluation;
2. Eliminate technically in feasible technology options;
3. Rank remaining control technol ogies by control effectiveness;
4. Evaluate most effective control alternative and document results; if top option is not selected as BACT, evaluate next most effective control option; and
5. Select BACT, which will be the most effective practical option not rejected based on energy, environmental, and economic impacts.

7

### Sithe provided BACT analyses for NOx, CO, PM 10 

### , SO 2 

### , VOC, lead, hydrogen fluorides, and sulfuric acid mist and EPA independently evaluated the information Sithe submitted. The analysis and our evaluation for each pollutant is presented below.
A. Nitrogen Oxides (NOx)/Nitrogen Dioxide

1. Pulverized Coal-Fired Boilers
NOx is formed during the combustion of fossil fuels, including coal, and is generally classified as either thermal NOx or fuel NOx. Thermal NOx is formed when elemental nitrogen reacts with oxygen in the combustion air within the high temperature environment of the furnace. Th e rate of formation of thermal NOx is a function of residence time and free oxygen, and is ex ponential with peak flame temperature. Fuel NOx is generated when ni trogen contained in the coal itself is oxidized. The rate of formation of fuel NOx is primarily a function of fuel bound nitrogen content of the coal but is also affected by fuel air mixing.

NOx emissions can be reduced using either combustion controls (i.e., staged combustion techniques such as Low-NOx burners (LNB), flue gas recirculation (FGR), overfire air (OFA), natural gas re burn, or flue gas treatment including selective non-catalytic reducti on (SNCR) or selective cat alytic reduction (SCR). .
In accordance with the top-down BACT process, Sithe’s PSD application first identified all of the potentially availabl e control technologies for pulverized coal fired boilers , eliminated technically infeasible options, and then ranked the remaining control technologies, beginning wi th the technologies th at will result in the most stringent control and the lowest emissions. EPA agrees that Sithe considered all of the potentially availabl e controls, as shown below in Table 3, for pulverized coal-fired boilers. They include:

Table 3 NOx Control Technologies for Pulverized Coal Boilers

Pulverized Coal Control Technologies Control Efficiency Range (% Removal) Typical Emission Rate (lb/MMBTU)

SCR and Low-NOx Burners 80 - 90 0.06 - 0.15

SNCR 40 - 60 0.2 - 0.3Staged Combustion and LowNOx Burners 30 - 50 0.15 - 0.5

Gas Reburn 40 - 60 0.15 - 0.3

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### Selective Catalytic Reduction
SCR is a process that involves post-com bustion removal of NOx from flue gas with a catalytic reactor. In the SCR proc ess, ammonia injected into the exhaust gas reacts with nitrogen oxides and oxygen to form nitrogen and water. The reactions take place on the surface of a catal yst. The function of the catalyst is to effectively lower the activation energy of the NOx decomposition reaction. Technical factors related to this technology include th e catalyst reactor design, optimum operating temperature, sulfur content of the fu el, catalyst de-activation due to aging or poisoning, ammonia slip emissions, and design of the ammonia injection system.
The SCR system is comprised of a numbe r of subsystems. These include the SCR reactor and flues, ammonia injection sy stem and ammonia storage and delivery system. The SCR reactor with necessary inlet and outlet duct work will be located downstream of the economizer and upstream of the air heater and the particulate control system. From the economizer outlet, the flue gas will first pass through a low-pressure ammonia/air injection grid designed to provide optimal mixing of ammonia with flue gas. The ammonia treate d flue gas will then flow through the catalyst bed and exit to the air heater.
The SCR system for a pulverized coal boile r typically utilizes a fixed bed catalyst in a vertical downflow multi-stage reactor. The reactor will include a seal system to prevent gas from bypassing the catalyst bed. Access openings for catalyst loading/removal and periodic internal inspection will be provided. The reactor will contain multiple stages of catalyst with room for loading a future stage. For each stage, a soot blowing system will be provided. Each stage will be equipped with a platform with monorails and hoi sts to accommodate catalyst loading and unloading.
Reduction catalysts are divided into two groups: base metal (lower temperature, primarily vanadium, platinum or titanium) and zeolite (higher temperature). Both groups exhibit advantages and disadvantag es in terms of operating temperature, reducing agent/NOx ratio, and optimum ox ygen concentration. A disadvantage common to base metal catalysts is the na rrow range of temperatures in which the reactions will proceed. Platinum group cat alysts have the advantage of requiring lower ignition temperature, but have been shown to also have a lower maximum operating temperature. Operating above the maximum temperature results in oxidation of ammonia to either nitrogen oxides (thereby actually increasing NOx emissions) or ammonium nitrate.
Optimum operating temperature for a vana dium-titanium catalyst system has been shown to be in the range of 550 

###  to 800 

###  F, which is significantly higher than for

9

### platinum catalyst systems. However, the vanadium-titanium catalyst systems begin to break down when continuously ope rating at temperatures above this range. Consequently, opera ting above the maximum temperature for the catalyst system again results in the oxidation of ammonia to either nitrogen oxides (increasing NOx emissions) or ammonium nitrate.

Sulfur content of the fuel can be a concer n for systems that employ SCR. Catalyst systems promote partial oxidation of su lfur dioxide to sulfur trioxide (SO 3 

### ), which combines with water to form sulfuric acid. At typical SCR operating temperatures, SO 3 

### and sulfuric acid react with excess ammonia to form ammonium salts. These ammonium salts may condense as the flue gases are cooled and can lead to increased uncontrolled emissions of PM 10 

### entering the particulate collector. Fouling may eventually lead to decreased NO x 

### reduction performance, increased system pressure drop over time and decreased heat transfer efficiencies.
The SCR process is subject to catalys t deactivation over time. Catalyst deactivation occurs through two primary mechanisms: physical deactivation and chemical poisoning. Physical deactivation is generally the result either of prolonged exposure to excessive temperatur es or masking of the catalyst due to entrainment of particulate from ambient ai r or internal contaminants. Chemical poisoning is caused by the irreversible r eaction of the catalyst with a contaminant in the gas stream and is a permanent c ondition. Catalyst suppliers typically only guarantee a limited lifetime to very low emission level, high performance catalyst systems.
SCR manufacturers typically estimate 10 ppmvd of unreacted ammonia emissions (ammonia slip) when making guarantees at very high efficiency levels. To achieve high NO x 

### reduction rates, SCR vendors suggest a higher ammonia injection rate than stoichiometrically required, which conversely results in ammonia slip. Thus an emis sions trade-off between NO x 

### and ammonia may occur in high NO x 

### reduction applications.
The potential environmental impacts asso ciated with the us e of SCR include:

• Unreacted ammonia would be emitted to the atmosphere (ammonia slip).
• Ammonium salts would increase loading to the particulate collection stage as PM 10 

### (and PM 2.5 

### ).
• Safety issues and Risk Management Planning may be required relative to the transportation, handling, and storage of ammonia (aqueous or anhydrous).

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### Selective Non-Catalytic Reduction
SNCR has been applied to a number of different type s of combustion sources, including petroleum heaters, utility and industrial boilers fire d with natural gas and oil, as well as PC boilers and to coal-fired Circulating Fluidized Bed (CFB) boilers.
The SNCR process is based on a gas- phase homogeneous reaction, within a specified temperature range, between NO x 

### in the flue gas and either injected NH 3 

### or urea to produce gaseous nitrogen and water vapor. SNCR systems do not employ a catalyst; the NO x 

### reduction reactions are driven by the thermal decomposition of ammonia and the subse quent reduction of NOx. Consequently, the SNCR process operates at higher temperatures than the SCR process.

Critical to the successful reduction of NO x with SNCR is the temperature of the flue gas at the point where the reagent is injected. For the ammonia injection process, the necessary temper ature range is 1,700 - 1,900 

##  F; for the urea injection process the nominal temperat ure range is 1,600 - 2,100 

##  F. Also critical to effective application of these processe s are gas mixing, residence time at temperature, and ammonia slip.
Theoretically, one mole of ammonia (or one-h alf mole of urea) will react with one mole of NOx, forming elemental nitrogen and water. In reality, not all the injected reagent will react due to imperfect mixing, uneven temperature distribution, and insufficient residence time. These physical limitations may be compensated for by injecting a large am ount of excess reagent and essentially achieving low NOx emissions at the expense of emissions of unreacted reagent, referred to as ammonia slip. These emissi ons represent an a dverse environmental impact and can lead to formation of ammonium salts and may contribute to regional haze as a precursor to PM 2.5 

### . Thus, for a given boile r configuration, there is a limit on the degree of NOx reducti on which can be achieved with SNCR while maintaining acceptable levels of ammonia slip.

Pulverized coal-fired units have a limit ed furnace temperature window and poor lateral mixing, conditions wh ich render SNCR le ss effective in these units. SNCR has been applied to PC boi lers more often to achieve 30 – 50% reductions in response to Reasonably Available Cont rol Technology (RAC T) requirements since the technology can be retrofit more easily than other add-on controls. Due to mixing limitations and a brief temperature window in which to react, SNCR is fundamentally less effective at controlling NOx from PC’s as compared with other combustion processes.

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### Staged Combustion
A number of techniques have been employed to reduce the formation of NOx by reducing peak flame temperatur e and/or starving the hotte st parts of the flame for oxygen. By staging the combustion process, a longer, cooler fl ame results, which forms less NOx. Staged combustion te chniques include Low-NOx burners, flue gas recirculation, overfi re air, burners out of service, and combinations of these. A collateral impact of stag ed combustion is an increas e in emissions of products of incomplete combustion includi ng CO, VOC and carbon in ash.

Gas Reburn
Natural gas reburn is a control technique that has shown promise as a potential retrofit to existing boilers, and may be capable of reducing emissions of NOx to 0.15 lb/MMBTU simply by starving the coal burners for excess oxygen and completing combustion with 12-15% gas in the upper furnace. Application of this technology assumes that natural gas in subs tantial quantity is already available on site – otherwise it is technically infeasible. In any event, the level of NOx control that may be achieved is less than for the other add-on cont rol technologies and therefore it is not considered further in this analysis.
Proposed Pulverized Coal-Fired Boiler BACT for NOx
Sithe has proposed to constr uct and operate the Facilit y with a combination of LNB and SCR for each of the two proposed boilers. Sithe is proposing to achieve a BACT NOx emission rate of 0.06 lb/MMBTU as a 24-hour average during operation based on using Navajo Nation coal from the BHP mine. Sithe’s application for the PSD Permit containe d a top-down BACT analysis which EPA has independently evaluated.
EPA’s independent analysis of available control technol ogies for pulverized coal fired boilers included reviewing the DOE/NETL (National Energy Technology Laboratory) database, EPA’s RACT/BACT/LAER Clearinghouse, EPA’s National Coal BACT Workgroup database, the EPA spreadsheet of recently permitted and proposed coal-fired power pl ants, review of issued permits or applications for permits, di scussions with EPA and Stat e permitting staff, trade journals, information from industry conferences and vendor guarantees.

EPA’s review of all availa ble data and technologies de monstrates that Sithe’s proposed choice of LNB and SCR is the most stringent combination of control technologies available for pul verized coal fired boilers. The NOx emission rate of 0.06 lb/MMBTU that Sithe has proposed, particularly because Sithe has proposed to meet 0.06 lb/MMBTU as a 24-hour aver age, is lower than other NOx emissions

12

### rates that have been proposed for or ach ieved by pulverized coal fired boilers recently.
The National Coal Workgroup database shows that the NOx BACT emissions limits in recent PSD permits for pulverize d coal fired boilers using LNB and SCR range from 0.07 lbs/MMBTU to 0.10 lb s/MMBTU, often as a 30-day average. Similarly, the information contained in th e DOE/NETL’s database of information for pulverized coal fired boilers shows th at 0.06 lbs/MMBTU is below the lowest NOx BACT emission limits for recently per mitted facilities. Further examples of NOx BACT emissions limits for recently pe rmitted pulverized coal boilers using LNB and SCR, or solely LNB for the Sa nd Sage facility, is shown below.

Examples of Recently Permitted/Proposed Coal-Fired Power Plants Facility Size (MW) Emission Controls NOx Emission Rate (lbs/MMBTU) Thoroughbred (Kentucky) 1500 SCR 0.08 (30-day avg.)

Prairie State (Illinois) 1500 SCR 0.10

Intermountain Power (Utah) 950 SCR 0.07 (30-day avg.)

Longleaf 1200 SCR 0.07 (30-day avg.) Sand Sage 660 LNB 0.12 - 0.08 (30-day avg.) Roundup Power (Montana) 780 SCR 0.07 (24-hr avg.)

Longview 600 SCR 0.08 (24-hr avg.)

EPA has also reviewed the decisions of EPA’s Environmental Appeals Board (EAB) and the Wisconsin Division of Hear ings and Appeals on challenges to the NOx BACT decisions in PSD permitting act ions for pulverized coal fired boilers. The Nevada Department of Environmenta l Protection issued a PSD permit to Newmont Nevada Energy Center LLP. The PSD Permit for that facility, which is a 200 MW pulverized coal fired boiler, established a BACT emission limit for NOx at 0.067 lbs/MMBTU as a 24 hour average, using LNB and SCR. The Newmont facility will burn coal from the Powder River Basin (PRB) The appropriateness of Newmont’s NOx BACT emission limit of 0.067 lbs/MMBTU was appealed to the EAB. The petitione r challenged whether 0.067 lbs/MMBTU (24 hour average) was BACT because Si the had applied for a lower NOx BACT

13

### limit (0.06 lbs/MMBTU as a 24 hour aver age) for DREF. The petitioner also cited a report for Baldwin Generating Station in Illinois, a determination by the Texas Natural Resource Conservation Commission discussing potentially achievable lower NOx emissions limits and a few other sources. See In Re: Newmont Nevada Energy Investment, LLC , 12 E.A.D. (June 3, 2005). The EAB recognized the importance of the type of coal being combusted and other relevant case-specific factors in a BACT deter mination. The EAB was not persuaded by citations to lower NOx emissions rates in trade journals and permits that only required such operation during the ozone season. The EAB recognized that the precise conditions, including the selection of coal type, surrounding the operation of the facility under PSD review should dictate the NOx BACT emissions limit, and held that 0.067 lbs/MMBTU as a 24 hour average was BACT.
The Wisconsin Division of Hearings and Appeal upheld the State’s PSD NOx BACT determination during a permit a ppeal. The Wisconsin Department of Natural Resources (WDNR) determined that a NOx emission limit of 0.06 lbs/MMBTU as a 30 day average was BACT. The WDNR initially permitted the facility with a NOx BACT emission li mit of 0.06 lbs/MMBTU as a 30 day average and 0.07 lbs/MMBTU as an annua l average. The Judge in that appeal found 0.06 lbs/MMBTU was “consistent with or lower than other BACT NOx emission limits established for other coal -fired utility boilers which were issued air permits contemporaneous with [the Wi sconsin facility].” Decision at 10. The Judge modified the PSD permit to remove the higher emissions limit (0.07 lbs/MMBTU) for the annual average so that the permittee was required to meet a NOx BACT emission limit of 0.06 lbs/ MMBTU as a 30 day and annual average.
In summary, the two lowest BACT e missions limits for NOx are 0.067 lbs/MMBTU as a 24 hour average for Ne wmont and 0.06 lbs/MMBTU as a 30 day average for the Wisconsin facility. The NOx BACT emissions limit in the proposed permit for DREF is 0.06 lbs/MM BTU as a 24 hour average, making the proposed NOx BACT emissions limit for DREF the lowest in an issued PSD permit for a pulverized coal fired boiler. When an emission limit is averaged over a shorter period of time (e .g. 24 hours rather than 30 days), it reduces the number of spikes that a facility can experience while still maintaining compliance with the emissions limit. Therefore, the NOx emi ssion limit of 0.06 lbs/MMBTU as a 24 hour average is lower than any other reported BACT emission limit. EPA is proposing BACT for NOx for DREF to be LNB and SCR, meeting an emission limit of 0.06 lb/MMBTU on a 24 hour average.
2. Auxiliary Boilers
The Desert Rock Energy Facility includes three small distillate oil-fired auxiliary boilers with heat input capacities of approximately 86.4 MMBTU/hour. These

14

### boilers will be subject to NSPS 40 CFR 60, Subpart Dc. Total annual fuel use in the three boilers will be limited to 142,560 MMBTU/year, which is equivalent to an average of 550 hours of operation per y ear per boiler at full load. Based on a review of recent permits for similar boilers and EPA’s RACT/BACT/LAER Clearinghouse, the applicant has conclude d that BACT for NOx for these boilers is 0.10 lb/MMBTU using Low-NOx bur ners. After reviewing the submitted materials, EPA agrees and proposes BACT for NOx for the auxiliary boilers to be Low-NOx burners and an emission rate of 0.10 lb/MMBTU.
3. Emergency Generators
The Desert Rock Energy Facility includes two emergency diesel generators (1,000 kW each) and two diesel generator powered firewater pumps (180 kW each). These emergency diesel engines will not operate for more than 100 hours/year each. NOx emissions during operation will be controlled by only burning low sulfur distillate oil and ignition timing retard with turbocharging and aftercooling. Based on review of recent permits for similar emergency diesel engines and EPA’s RACT/BACT/LAER Clearinghouse, th e top level of control or lowest NOx emission rate is approximately 6.5 g/hp-hr. The applicant has concluded that this level of control represents BACT for the emergency diesel engines. After reviewing the submitted mate rials, EPA concurs and propos es the use of ignition timing retard with turbocharging and afte rcooling with an emission rate of 6.5 g/hp-hr to be BACT for NOx for the emergency generators.

B. Sulfur Dioxide (SO 2 

### )

1. Pulverized Coal-Fired Boilers
Emissions of sulfur dioxide are genera ted in fossil fuel-fired sources from the oxidation of sulfur present in the fuel. A pproximately 98% of sulfur in solid fuels is emitted upon combustion as gaseous su lfur oxides. Uncontrolled emissions of SO 2 

### are thus affected by fuel sulfur content alone, and not by the firing mechanism, boiler size, or operation. Many coal-fired boi lers limit emissions of SO 2 

### through the use of low sulfur western coals, including PRB coal. Compared with a high sulfur eastern bituminous coal that may contain as much as 4% sulfur, burning western coal can reduce SO 2 

### emissions by approximately 70% to 90%. The selection of coal type and sulfur cont ent is therefore one of the aspects that must be considered when ma king a determination of SO 2 

### BACT and needs to be considered in conjunction with add-on control altern atives when performing the top-down analysis.
Generally, there are two type s of add-on control applicab le to a coal-fired boiler: in-situ combustion control (sorbent inject ion) and post-combustion control (flue

15

### gas desulfurisation). In-situ control is us ed effectively in CFB boilers, and may be used in a PC boiler by using limestone injection into the furnace, however the level of control that is achievable is not comparab le to post-combustion SO 2 

### control systems. Post-combustion controls applicable to PC boilers are a wet scrubbing system or spray dryer absorber (SDA) using reagents such as lime, limestone, sodium bicarbona te or magnesium oxide.
A comparative ranking of available SO 2 

### control technologies (see Table 4) must take into consideration multiple variab les including coal sulfur content, % removal and the resulting emission rate (lb/MMBTU) in addition to collateral impacts on other pollutants, energy imp acts, and other envi ronmental impacts.

Table 4 SO 2 

### Control Technologies for Pulverized Coal Boilers

Pulverized Coal Control Technologies Control Efficiency Range (% Removal) Typical Emission Rate (lb/MMBTU)

Wet Flue Gas Desulfurisation 90 - 9 8 Depends on coal sulfur content (lower with western coal) Limestone Injection 25 - 35 Depe nds on coal sulfur content (lower with western coal) Spray Dryer Absorber 70 - 92 De pends on coal sulfur content (lower with western coal)

Use of Low Sulfur Coal 30 - 90

Wet Flue Gas Desulfurisation
The most frequently utilized wet flue ga s desulfurisation (FGD) technology is the wet limestone spray tower system. Typically , flue gas enters at the bottom of the absorber tower, continues vertically through the limestone/water spray, passes through a mist eliminator to control the re-entrained slurry drops, and then exits the tower. Limestone (calcium carbonate) r eacts with the sulfur dioxide to form calcium sulfite. The calcium sulfite may then be oxidized to form calcium sulfate, since it is easier to de-water than ca lcium sulfite. This can be achieved by blowing compressed air into the slurry in the retention tank in the base of the tower or in an external oxidation tank.
To fully utilize the limestone, the slurry is re-circulated through the tower and a bleed stream is taken off for de-watering. The bleed stream can be de-watered using a variety of techniques, including th ickeners, centrifuges and vacuum filters.

16

### The final slurry may contain 10% to 40% water by weight.

Wet scrubbers can also utilize limestone rather than lime. Some of the lime (calcium oxide) becomes calcium hydrox ide in water. The slurry of calcium hydroxide and lime is fed to the spray to wer. Since the cost of limestone is much less than lime, the limestone alternative is much more common. This is especially the case for medium to high sulfur coals.
Spray Dryer Absorber/Limestone Injection
The spray dryer absorber is located upstr eam of the particulate collection system, typically fabric filters. The flue gas pa sses through a spray dr yer vessel where it encounters a fine mist of lime slurry. The lime slurry is injected into the spray dryer absorber through either a rotary atomizer or fluid nozzles. The moisture in the droplets evaporates and reacts with the SO 2 

### in the flue gas to form insoluble calcium salts. The flue gas is c ooled to approximately 18 to 30 

###  F above the adiabatic saturation of the flue gas. The calcium salts have a moisture content of approximately 2 to 3%, which falls to 1% before reaching the particulate control device. When a fabric filter is used as th e particulate control de vice, it allows for further reaction of the lime with the sulfur (and other acid gases) in the flue gas. This is due to the layer of porous filter cake on the surface of the filter that contains the reagent that all flue gas must pass through. This allows for increased efficiency of control of sulfuric acid mist, hydrogen chloride and mercury as compared to wet scrubbers.

Use of Low Sulfur Coal
Any discussion of the relative effectiveness of add on SO 2 

### control must also take into account the level of uncontrolled SO 2 

### to be handled, which is highly dependent on the sulfur c ontent of the coal to be burned. Higher removal efficiencies tend to be more practical when there is a high concentration of SO 2 

### in the flue gas, and vice versa. This is re flected in a comparison of the resulting emission rate in units of lb of SO 2 

### per MMBTU of fuel burned (or lb of SO 2 

### per kW produced). For example, a proposed project with a BACT limit of 0.16 lb/MMBTU using an 80% removal control sy stem is environmentally superior to another project with a BACT limit of 0.32 lb/MMBTU and 95% removal. For a project located in the Western U.S., BACT generally includes use of low sulfur western coal as a part of a strategy to limit SO 2 

### to BACT levels in combination with add-on control.
Proposed Pulverized Coal-Fired Boiler BACT for SO 2


### Sithe has proposed to constr uct and operate the Facility using a combination of

17

### low sulfur western coal and wet limestone flue gas desulfurisation. Sithe is proposing to achieve an SO 2 

### BACT emission rate of 0.06 lb/MMBTU as a 24- hour average during operation.
EPA’s independent analysis of available control technol ogies for pulverized coal fired boilers included reviewing the DOE/NETL (National Energy Technology Laboratory) database, EPA’s RACT/BACT/LAER Clearinghouse, EPA’s National Coal BACT Workgroup database , and the EPA spreadsheet of recently permitted and proposed coal-fired power pl ants as well as the other sources discussed above for NOx.

EPA’s review of all availabl e data and technologies dem onstrates that the choice of low sulfur coal and wet limestone desulfurisation is the most stringent combination of control technologies avai lable for pulverized coal fired boilers. The emission rate of 0.06 lb/MMBTU that Sithe has proposed, as a 24-hour average, is lower than other SO 2 

### emission rates that have been proposed for pulverized coal fired boilers recently.

The PSD Permit that Nevada Department of Environmen tal Protection issued to Newmont Nevada Energy Center, LLP last year allowed dry scrubbing rather than requiring wet limestone desulfurisation. Newmont’s PSD permit established an SO 2 

### BACT emission limit of 0.065 to 0.09 lbs/MMBTU.
EPA is also persuaded that 0.06 lbs/MMBTU SO 2 

### is BACT for DREF based on the information in the National Coal Wo rkgroup database. Th e database shows that SO 2 

### emission limits for recent PSD permit s for pulverized coal fired boilers range from 0.09 to 0.30 lb/MMBTU (30- day average). Similarly, the information contained in the Department of Energy’s compilation of information for pulverized coal fired boilers shows that 0.06 lbs/MMBTU is below the lowest SO 2 

### BACT emission limit for recently permitted facilities.

Examples of Recently Permitted/Pr oposed Coal-Fired Power Plants Facility Size (MW) Emission Controls SO 2 

### Emission Rate (lbs/MMBTU) Thoroughbred 1500 Wet scrubber 0.167 (30-day avg.) 0.41 (24-hr avg.)

Prairie State 1500 Wet scrubber 0.30

Intermountain Power 950 Wet sc rubber 0.09 (30-day avg.) 0.12 (24-hr avg.) Longleaf 1200 Dry scrubber 0.12 (30-day avg.)

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### Sand Sage 660 Dry scr ubber 0.15 (30-day avg.) Roundup Power 780 Dry scrubber 0.12 (24-hr avg.)

2. Auxiliary Boilers
The Desert Rock Energy Facility also includes three small distillate oil-fired auxiliary boilers with heat input capac ities of approximately 86.4 MMBTU/hour. Total annual fuel use in the three boilers will be limited to 142,560 MMBTU/year, which is equivalent to an average of 550 hours/year per boiler at full load. SO 2 

### emissions will be controlled by only bur ning low sulfur distillate oil with a maximum sulfur content of 0.05%. No add-on SO 2 

### controls have ever been applied to similar sources. The burning of low sulfur fuels such as low sulfur distillate oil is the only available SO 2 

### control option and is the top level of control. Therefore, the applicant is proposing to onl y burn low sulfur distillate oil (0.05% sulfur maximum) and to restrict to tal annual fuel consumption to 142,560 MMBTU/year as BACT for the auxiliary boilers. After reviewing the submitted materials we concur with the applicant and propose BACT for SO 2 

### for the auxiliary boilers to be the burning of low sulfur distillate oil not to exceed 0.05% sulfur content and no more than 142,560 MMBTU/year.
3. Emergency Diesel Engines
The project includes two emergency diesel generators (1,000 kW each) and two diesel generator powered firewater pumps (180 kW each). These emergency diesel engines will not be operated for more than 100 hours/year each. No add-on SO 2 

### controls have ever been applied to similar sources. The burning of low sulfur fuels such as low sulfur distillate oil is the only available SO 2 

### control option and represents the top level of control. Ther efore, the applicant proposes to only burn low sulfur distillate oil (0.05% sulfur ma ximum) and to restrict operation to 100 hours per year each as BACT for the pr oposed emergency diesel engines. EPA concurs and proposes BACT for SO 2 

### for the emergency diesel engines to be burning low sulfur distillate oil and limiti ng operation to no more than 100 hours per year per engine.

C. Carbon Monoxide (CO)

1. Pulverized Coal-Fired Boilers

Carbon monoxide is formed as a result of incomplete combustion of a hydrocarbon fuel. Control of CO is accomplished by providing adequate fuel residence time, excess oxygen and high temperature in th e combustion zone to ensure complete combustion. These control factors, however , also tend to result in increased

19

### emissions of NOx. Conversely, a low NOx emission rate achieved through combustion modification techniques such as Low-NOx Burners can result in higher levels of CO formation. Thus, a compromis e is established to achieve the lowest NOx formation rate possible while keeping CO emission rates at acceptable levels.
CO emissions from pulverized coal-fired boilers are a function of oxygen availability (excess air), flame temperature, residence time at flame temperature, combustion zone design, and turbulen ce. All pulverized coal-fired boilers identified utilize front-end methods such as good combustion control wherein CO formation is suppressed within th e boiler. All listings in EPA ’ 

### s RACT/BACT/LAER Clearinghouse for pul verized coal-fired boilers utilize combustion control techniques for CO (see Table 5). Wh ile gas-fired combustion turbines have been widely equipped with oxidation catalys t control technology, this technology has not been applied to coal-fire d boilers. In addition to oxidizing CO, an oxidation catalyst would oxidize SO 2 

### to produce SO 3 

### , which would exacerbate sulfuric acid mist emissions. The SO 2 

### oxidation rate would be in the range of 5% or more resulting in very high sulfuric acid mist emissions if an oxidation catalyst were to be applied to a coal-fired boiler.

Table 5 CO Control Technologies for Pulverized Coal Boilers

Pulverized Coal Control Technologies Emission Rate (lb/MMBTU) Technical Feasibility for Pulverized Coal-Fired Boilers

Combustion Controls 0.05 - 0.15 Yes Oxidation Catalyst Not determined May not be feasible

Combustion Controls
Combustion control refers to controlling emissions of CO through the design and operation of the boiler in a manner so as to limit CO formation. In general, a combustion control system seeks to ma intain the proper c onditions to ensure complete combustion through one or mo re of the following operation design features: providing sufficient excess air, staged combustion to complete burn out of products of incomplete combustion, su fficient residence time, and good mixing. All of these factors also tend to re duce emissions of VOC as well as CO. However, this process must be opti mized with the efforts to reduce NOx emissions, which may increase when steps to lower CO are taken.
Catalytic Oxidation
Catalytic oxidation is the technology th at has been used to obtain the most

20

### stringent control level for CO from natural gas-fired turbine combustion units. This technology has never been applied to a coal-fired unit. It is evaluated here to determine if it could be c onsidered transferable technol ogy for application to the proposed pulverized coal-fired boilers. In this alternative, a catalyst would be situated in the flue gas stream to lowe r the activation energy required to convert products of incomplete combustion (CO an d VOC) in the presence of oxygen (O 2 

### ) to carbon dioxide and water. The catalyst permits combination of the reactant species at lower gas temperatures and re sidence times than w ould be required for uncatalyzed oxidation.
The catalyst would have to be located at a point where the gas temperature is within an acceptable range. The effective temperature range for CO oxidation is between 600 

###  F and about 1,000 

##  F. Catalyst non-selectivity is a problem for sulfur containing fuels such as co al. Catalysts promote oxidation of SO 2 

### to SO 3 

### as well as CO to CO 2 

### . The amount of SO 2 

### conversion is a functi on of temperature and catalyst design. Under optim um conditions, formation of SO 3 

### can be minimized to 5% of inlet SO 2 

### . This level of conversion would result in a large collateral increase in H 2 

### SO 4 

### emissions which aside from the increased ambient air impacts, could result in unacceptable am ounts of corrosion to the fabric filter particulate collector, air preheater, ductwork and stack.
The applicant contacted an oxidation catalyst system vendor to determine the technical feasibility of installing this system on a coal-fired boiler. Due to the high particulate loading of the flue gas, variab le trace element concentration in the flue gas and the SO 2 

### loading before air pollution contro l systems, the vendor stated that they could not provide a catalyst system for coal-fired applicat ions. Consequently, the applicant has determined that oxidation catalyst systems are considered technically infeasible for applicatio n to the proposed coal-fired boilers.
Proposed Pulverized Coal-Fired Boiler BACT for CO
Sithe has proposed, and EPA’s analysis supports, that the only practical or demonstrated in practice me asure to control CO from coal-fired boilers is good combustion practices. Combustion control, and the resulting optimized emission rate to minimize formation of CO while al so minimizing NOx, therefore represents BACT for the proposed boilers. BACT for CO from the proposed Facility is 0.10 lb/MMBTU. This level is c onsistent with or lower th an recent permits for new coal-fired boilers.
2. Auxiliary Boilers
The Desert Rock Energy Facility includes three small distillate oil-fired auxiliary boilers with heat input capacities of approximately 86. 4 MMBTU/hour. Total

21

### annual fuel use in the three boilers will be limited to 142,560 MMBTU/year, which is equivalent to an averag e of 550 hours/year per boiler at full load. A BACT limit for CO emissions of 0.036 lb/MMBTU an d the annual total fuel restriction of 142,560 MMBTU/year are proposed for thes e boilers, which reflect the lowest emission limits listed in EPA’s RA CT/BACT/LAER Clearinghouse. After reviewing the submitted mate rials, EPA concurs with the applicant and proposes BACT for CO from the auxiliary boilers to be an emission limit of 0.036 lb/MMBTU and a fuel limit of 142,560 MMBTU/year.
3. Emergency Diesel Engines
The project includes two emergency diesel generators (1,000 kW each) and two diesel generator powered firewater pumps (180 kW each). The diesel engines will not be operated for more than 100 hour s/year each. The a pplicant proposes a BACT emission limit for these diesel engine s of 0.5 g/hp-hr and a limitation of 100 hours of operation per year (each). After reviewing the submitted materials, EPA agrees and proposes BACT for CO from the emergency diesel engines to be a limit of 0.5 g/hp-hr and a limit of 100 hour s of operation per year per engine.
D. Volatile Organic Compounds (VOC)

1. Pulverized Coal-Fired Boilers

VOCs are also emitted from coal-fired boilers as a result of incomplete combustion of the fuel. Control of incomplete combustion is accomplished in the same way CO emissions are controlled: by providing adequate fuel residence time and high temperature in the combustion zone to ensure complete combustion.

VOC emissions from coal-fired boilers are a function of oxygen availability (excess air), flame temperature, residence time at flame temperature, combustion zone design, and turbulence. All coal-fire d boilers identified utilize front-end methods such as combustion control wher ein VOC formation is suppressed within the boiler. All listings in EPA’s RACT /BACT/LAER Clearinghouse for coal-fired boilers utilize combustion control techniques for VOC. While gas-fired combustion turbines have been widely equipped with oxidatio n catalyst control technology, this technology is not easily applied to coal-fired boilers.

A review of EPA's RACT/B ACT/LAER Clearinghouse, an d the applicant's review of recent permit decisions, indicates levels of VOC control which may be achieved for pulverized coal-fired boile rs. Emission levels and control technologies have been identified and ranked in Table 6.

22

### Table 6 VOC Control Technologies for Pulverized Coal Boilers

Pulverized Coal Control Technologies Emission Rate (lb/MMBTU) Technical Feasibility for Pulverized Coal-Fired Boilers

Combustion Controls 0.002 - 0.01 Yes Oxidation Catalyst Not determined May not be feasible

Combustion Control
Combustion control refers to controlling emissions of VOC through the design and operation of the boiler in a manner so as to limit VOC formation. In general, a combustion control system seeks to ma intain the proper c onditions to ensure complete combustion through one or mo re of the following operation design features: providing sufficient excess air, staged combustion to complete burn out of products of incomplete combustion, su fficient residence time, and good mixing. All of these factors also have the by-p roduct of reducing th e emissions of CO. Pulverized coal-fired boilers are designed specifically for efficient fuel combustion with thorough mixing and residence time at temperature, plus staged combustion. The applicant believes that this level of combustion control represents BACT for the proposed boilers.

Add-On Emission Controls
Catalytic oxidation and othe r add-on controls are not applicable to coal-fired boilers as discussed in th e CO BACT section above.
Proposed Pulverized Coal-fired Boiler BACT for VOC
Sithe has proposed, and EPA’s analysis supports, that the only practical or demonstrated in practice m easure to control VOC emissi ons from coal-fired boilers is good combustion. Combustion contro l, and the resulting optimized emission rate to minimize formation of VOC while also minimizing NO x 

### , therefore represents BACT for the proposed boilers . Sithe is proposing a VOC BACT limit of 0.003 lb/MMBTU, which is lower than the lowest emission rate in recent permits for new coal-fired boilers.

23

### 2. Auxiliary Boilers
The project includes three smal l distillate oil-fired auxili ary boilers with heat input capacities of approximatel y 86.4 MMBTU/hour. Total annual fuel use in the three boilers will be limited to 142,560 MMBTU/yea r, which is equivalent to an average of 550 hours/year per boiler at full lo ad. The applicant proposes BACT for VOC emissions from the auxiliary boilers to be an emission limit of 0.0024 lb/MMBTU and a total fuel restriction of 142,560 MMBTU/year based on EPA’s RACT/BACT/LAER Clearinghouse. After reviewing the submitted materials, EPA concurs with the applicant and pr oposes BACT for VOC from the auxiliary boilers to be an emission limit of 0.0024 lb/MMBTU and a fuel limit of 142,560 MMBTU/year.
3. Emergency Diesel Engines
The project includes two emergency diesel generators (1,000 kW each) and two diesel generator powered firewater pumps (180 kW each). The diesel engines will not be operated for more than 100 hour s/year each. The applicant proposes a BACT emission limit for these diesel en gines of 0.3 g/hp-hr and an operating restriction of 100 hours per year (each) for VOC from these units. After reviewing the submitted materials, EPA agrees and proposes BACT for VOC from the emergency diesel engines to be a limit of 0.3 g/hp-hr and a limit of 100 hours of operation per year per engine.

E. Particulate Matter

1. Pulverized Coal-Fired Boilers
The composition and amount of particulat e matter emitted fro m coal-fired boilers are a function of firing configurati on, boiler operation, coal properties and emission controls. Particulat e matter will be emitted from the pulverized coal-fired boilers as a result of entrainment of incombustible inert matter (ash) and condensable substances such as acid ga ses. Both particulate matter (PM), and particulate matter smaller than 10 micrometer diameter (PM 10 

### ) require the application of BACT under th e Federal PSD program. Part iculate matter is total filterable particulate matter as dete rmined by EPA Method 5 or 17. PM 10 

### includes filterable particulate matter smaller than a 10 micrometer diameter as determined by EPA Method 201 or 201A and condensable particulate matter as determined by EPA Method 202.

A review of EPA's RACT/B ACT/LAER Clearinghouse indi cates several levels of particulate control that may be achieved for pulverized boilers. Emission levels and control technologies have been identi fied and ranked in Table 7. There are

24

### almost 50 coal-fired boilers listed in the EPA's BACT/LAER Clearinghouse with emission limits for filterable particulate matt er that are less than or equal to 0.02 lb/MMBTU. All but one of these listings repor t that a fabric filter is utilized (the AES Puerto Rico facility is the only ex ception). The control of PM using fabric filtration is clearly demonstrated for coal-fired boilers. We t control techniques (venturi or other high-energy scrubbers), on the other hand, do not represent a recently applied or demonstrated control te chnique for coal-fired boilers and do not offer more stringent levels of control of particulate ma tter than fabric filters.

Table 7 Particulate Control Technologies for Pulverized Coal Boilers

Pulverized Coal Control Technologies Typical Emission Rate (lb/MMBTU) Technical Feasibility for Pulverized Coal-Fired Boilers

Fabric Filter 0.01 - 0.02 Yes Electrostatic Precipitator 0.015 - 0.025 Yes High Energy Wet Scrubber Not deter mined No applications for recent coal-fired boilers

Note: Emission levels represent steady-state va lues at base load, for front-half (filterable) only.

Fabric Filter
Fabric filters are widely used for part iculate control from PC boilers and are capable of over 99% control efficiency. According to EPA’s Fabric Filter Fact sheet (EPA, 2000), “flue gas is passed thr ough a tightly woven or felted fabric, causing PM in the flue gas to be collect ed on the fabric by sieving and other mechanisms. Fabric filters may be in the fo rm of sheets, cartridges, or bags, with a number of the individual fabr ic filter units housed together in a group. Bags are most common type of fabric filter. The dust cake that forms on the filter from the collected PM can significantly increase collection efficiency. Fabric filters are frequently referred to as baghouses because the fabric is usua lly configured in cylindrical bags. Bags may be 6 to 9 m (20 to 30 ft) long and 13 to 31 centimeters (cm) (5 to 12 inches) in diameter. Gr oups of bags are placed in isolatable compartments to allow cleaning of the bags or replacement of some of the bags without shutting down the entire fabric filter.
The advantages of fa bric filters include:
1) High collection efficiency for a broad range of particle sizes;

25

### 2) Flexibility in design (various me thods of cleaning methods and filter media);
3) Wide range of volumetric capacities;
4) Reasonable pressure drops and power requirements; and
5) Handles a wide rang e of solid materials.
Some disadvantages of fabr ic filters are as follows:
1) Danger of explosion in the presence of a spark; or catastrophic bag damage due to fire; and
2) Wet particles can agglomerate on a fi lter cloth if the wa ste gases are at a temperature close to their dew point.
Proposed Pulverized Coal-fired Boiler BACT for Particulate Matter
Fabric filters and electrostatic precipitat ors (ESP’s) represent technically feasible options for the control of particulate matter from coal-fired boilers. Wet control techniques (scrubbers), on th e other hand, do not repres ent a demonstrated control technique and do not offer mo re stringent levels of cont rol of particulate matter than fabric filters or ESP’s. ESP’s are ge nerally less effective at controlling fine particulate, and are generall y incapable of any additional control of other pollutants such as acid gases or mercury, and are not considered to represent the top level of available control technology.
Based on numerous projects using fabric filt ers, Sithe has proposed to use a fabric filter as BACT to limit PM emissions to 0.010 lb/MMBTU. In addition, Sithe proposes to limit total PM 10 

### (including condensable PM 10 

### ) emissions to 0.02 lb/MMBTU. Very little data ar e available on condensable PM 10 

### emissions from coal-fired boilers burn western coal, and for that reason Sithe has proposed a condensable PM 10 

### limit of 0.02 lb/MMBTU as BACT for total PM 10 

### , but requests a trial period of three years to determine the feasibility of this exceptionally low limit. The proposed PM emission rate is lower than the lo west emission level for a new coal fired boiler (Wygen 2 in Wyom ing) listed in EPA’s RACT/BACT/LAER Clearinghouse or the other re ference materials di scussed in the BACT analysis for NOx and SO 2 

### . EPA’s independent review of the materials supports Sith e’s analysis that proposed BACT for PM emissions from the coal-fired boilers is a fabric filter with an emission limit of 0.01 lb/MMBTU. In a ddition, EPA is proposing BACT for total

26

### PM 10 

### emissions to be a fabric filter with an emission limit of 0.02 lb/MMBTU. However, EPA does not believe that a th ree year trial period of the 0.02 lb/MMBTU emission limit is warranted. EP A believes that the feasibility of the 0.02 lbMMBtu emission limit can be dete rmined during the first 18 months of operation and will propose an 18 mont h trial period comme ncing upon initial startup.
2. Auxiliary Boilers
The project includes three smal l distillate oil-fired auxili ary boilers with heat input capacities of approximately 86.4 MMBTU/hour. Total annual fuel use in the three boilers will be limited to 142,560 MMBTU/y ear, which is equivalent to an average of 550 hours/year per boiler at full load . The applicant is proposing BACT limits for PM and PM 10 

### based on the use of very low sulfur distillate oil, the total annual fuel limitation of 142,560 MMBTU/year, and EPA emission factors published in AP-42 and EPA’s RACT/BACT/LAER Cl earinghouse. For PM, BACT for the auxiliary boilers is the annual fuel limitation, the use of 0. 05% sulfur distillate oil, and an emission limit of 0.014 lb/MMBTU based on the EPA emission factor of 2 lb/1000 gal. For PM 10 

### , BACT includes an emission limit of 0.024 lb/MMBTU based on adding the condensable PM 10 

### emissions of 0.01 lb//MMBTU (1.3 lb/1,000 gal based on AP-42) to the PM emission rate. After reviewing the submitted materials, EPA concurs and proposes BACT for PM emissions from the auxiliary boilers to be an emission rate 0.014 lb/MMBTU, the use of 0.05% sulfur distillate oil, and an annual fuel l imitation of 142,560 MMBTU/year. For PM 10 

### , EPA is proposing BACT to be an emission limit of 0.024 lb/MMBTU, the use of 0.05% sulfur distillate oil, and an a nnual fuel limitation of 142,560 MMBTU/year.
3. Emergency Diesel Engines
The project includes two emergency diesel generators (1,000 kW each) and two diesel generator powered firewater pumps (180 kW each). The diesel engines will not be operated for more than 100 hours/ year each. The applicant proposes that BACT emission limits include the 100 hour per year (each) operating restriction, and limits of 0.19 g/hp-hr and 0.22 g/hp-hr PM and PM 10 

### , respectively, based on EPA emission factors in AP-42. After reviewing the submitted materials, EPA concurs and proposes BACT for PM and PM 10 

### from the emergency diesel engines to be emission limits of 0.19 g/hp-hr an d 0.22 g/hr-hr respectively and an operating limit of not more than 100 hours/year per engine.
4. Material Handling Sources
Sithe has proposed that its material handling sources w ill be controlled by dust suppression systems, enclosures and/or fabr ic filters. For example, conveyors will be constructed of enclosed design in or der to eliminate wind- blown dust emissions.

27

### Conveyors will lead to transfer towers, bunkers or silos that will include a “coal drop”. Such structures will also be of en closed design and will be evacuated (when operating) through fabric filt er units, sometimes referred to as “bin vent filters”. Enclosed design of materials handling sy stem and evacuation through bin vent filters represents BACT for material handling equipment.
In addition, coal handling systems will be subject to NSPS Subpart Y and limestone handling systems wi ll be subject to NSPS S ubpart OOO. A review of the EPA RACT/BACT/LAER Clearinghouse gi ves a range of cont rol efficiencies from baghouses. Although the most recent permits for coal fi red power plants, Bull Mountain and Roundup Power Projects, determined that BACT was 0.01 gr/dscf for all sources, the Mid Americ a permit identified 0.005 gr/dscf for baghouses associated with coal sources an d 0.01 gr/dscf for ot her material handling activities. The applicant proposes to also specify these filterable PM/PM 10 

### emissions limits of 0.005 gr/dscf for coal and 0.01 gr/dscf for limestone and other materials.
The applicant also pointed out that as a mine-mouth power plant, the Desert Rock Energy Facility will avoid fugitive dust emissions associated with rail unloading operations and active on-site storage piles. The inactive storage pile will be covered with soil, geotextile or che mical crusting agents to prevent both weathering of the coal and fugitive dus t emissions. When coal is added to or reclaimed from the inactive pile, which is ex pected to be very infrequently, the coal will be wetted and/or treated with chemic al agents to minimize any emissions of fugitive dust. The Applicant believes that these operational meas ures, and those of the NSPS for coal handling operations (S ubpart Y), represent BACT for inactive storage and associated coal handling ope rations. After reviewing the submitted materials, EPA concurs and proposes as BACT for PM/PM 10 

### from materials handling sources that all conveyors, transfer towers and silos be enclosed and vent to a fabric filter with emission limits of 0.005 gr/dscf for coal and 0.01 gr/dscf for limestone and other material s. In addition, the inactive coal storage pile will covered with soil or other crusting agents and when coal is added or reclaimed it will be wetted and/or treated with ch emical agents to minimize fugitive dust emissions.

F. Sulfuric Acid Mist (H 2 

### SO 4 

### )

1. Pulverized Coal-Fired Boilers

Emissions of sulfuric acid mist are generated in fossil fuel-fired sources from the oxidation of sulfur present in th e fuel. The amounts of sulfur or SO 2 

### that are oxidized to sulfuric acid mist may be affected by trace metal catalysis.
In addition to applying BACT, the applican t recognizes that sulfuric acid mist is a

28

### precursor to the formation of regional ha ze, and for this reason is proposing to include active control of sulfuric acid mist in the design of the Desert Rock Energy Facility. As a result, an a dditional stage of acid gas rem oval using hydrated lime (a proprietary technology) has be en included upstream of the fabric filter to remove sulfuric acid mist before it enters th e wet scrubber. The application of this technology will result in emission le vels lower than those permitted for Thoroughbred (with an add-on WESP), and represents a sulfuric acid mist emission rate of 0.004 lb/MMBTU. After reviewing the submitted materials, EPA concurs and proposes BACT for sulfuric acid mist from the PC boilers to be the use of hydrated lime in jection and an emission limit of 0.004 lb/MMBTU.
2. Auxiliary Boilers and Diesel Generators

No control alternatives beside the use of very low sulfur fuels have been identified for controlling emissions of sulfuric aci d mist from industrial boilers or emergency diesel generators. BACT for sulfuric aci d mist for the proposed auxiliary boilers and emergency diesel engines is the use of low sulfur (0.05% S) distillate oil. After reviewing the submitted materials, EPA agrees and proposes BACT for the control of sulfuric acid mist from the au xiliary boilers and the emergency diesel generators to be the use of distillate fuel oil with a sulfur content less than 0.05%.
G. Hydrogen Fluoride (HF)
Emissions of hydrogen fluoride are genera ted in fossil fuel-fired sources from the oxidation of fluorine present in the fuel. For the PC boilers, the same proprietary acid gas pre-control technology proposed for the control of sulfuric acid mist will control hydrogen fluoride emissions through the injection of hy drated lime before the fabric filter, with additional removal expected from the wet lime stone scrubbing. The applicant is proposing a hydrogen fluoride emission rate of 0.00024 lb/MMBTU based on an assumed concentration of fluorine in the coal of 100 ppm (estimated 98% cont rol) as BACT. This emission rate is consistent with or lower than all recent BACT decisions.
No appreciable HF is emitte d from distillate oil-fired i ndustrial auxiliary boilers or emergency diesel engines, and the use of low fluorine bearing fuel (very low sulfur distillate oil) represents BACT for HF fo r these emission sources. After reviewing the submitted materials, EPA conc urs and proposes BACT for emis sions of hydrogen fluoride to be the use of hydrated lime injection and an emission limit of 0.00024 lb/MMBTU.

H. Lead (Pb)
Emissions of lead are generate d in fossil fuel-fired sources from the impurities present in the fuel. Since lead is emitted as solid particulate from coal-fired boilers, it is already included in the PM and PM 10 

### emission rates selected as BACT. BACT for lead emissions from the proposed PC boilers is the control of PM emissions using fabric filtration

29

### (baghouse), and the emission limits de termined to represent BACT for PM 10


### .
For distillate oil-fired industria l auxiliary boilers and emergency diesel engines, the use of low ash fuel such as distillate oil represents BACT.
I. Summary of BACT Emission Levels
The BACT levels determined through this eval uation for the Desert Rock Energy Facility are summarized in Tables 8 thru 11.

Table 8 Summary of Proposed BACT Emission Limits for Pulverized Coal Boilers

Pollutant Emission Limit (lb/MMBTU) Control Technology

NOx 0.06, 24-hour average Low NOx Burners and SCR

SO 2 

### 0.06, 24-hour average Low sulfur western coal, hydrated lime injection before the fabric filter, and wet limestone desulfurisation CO 0.10, 24-hour average Good combustion practices VOC 0.003, 3-hour average Good combustion practices PM 0.01, 6-hour average Baghouse

PM 10 

### 0.02, 6-hour average Baghouse

H 2 

### SO 4 

### 0.004, annual average Low sulfur western coal, hydrated lime injection before the fabric filter,

and wet limestone desulfurisation HF 0.00024, annual average Hydrated lime injection before the fabric filter, and wet limestone desulfurisation
Pb 0.00020, quarterly Baghouse

Note: EPA test methods require that th e emission limits in the permit for H 2 

### SO 4 

### , HF, and Pb be measured as 3-hour averages.

30

### Table 9 Summary of Proposed BACT Emission Limits for the Auxiliary Boilers

Pollutant Emission Limit (lb/MMBTU) Control Technology

NOx 0.10, 3-hour average Low NOx Burners

SO 2 

### 0.05, 3-hour average Low sulfur distillate fuel (0.05%) CO 0.036, 3-hour average Good combustion practices VOC 0.0024, 3-hour average Good combustion practices PM 0.01, 3-hour average Low sulfur distillate fuel oil and good combustion practices

PM 10 

### 0.024, 3-hour average Low sulfur distillate fuel oil and good combustion practices

H 2 

### SO 4 

### 0.00087, annual average Low sulfur distillate fuel (0.05%)

Notes: 1) PM is defined as filterable particulate matter as measured by EPA Method 5. 2) PM10 is defined as solid particulate matter smaller than 10 micrometers diameter as measured by EPA Method 201 or 201A plus condensable particulate matter as measured by EPA Method 202. Because PM10 includes condensable particulat e matter and PM does not include condensable particulate matter, PM10 emissions are higher than PM emissions.



### Table 10 Summary of Proposed BACT Emission Limits for the Emergency Generators

Pollutant Emission Limit (lb/MMBtu) Control Technology

NOx 6.5 g/hp-hr Ignition timing re tard, turbo-charging and aftercooling

SO 2 

### 0.19 g/hp-hr Low sulfur distillate fuel (0.05%) CO 0.5 g/hp-hr Good combustion practices VOC 0.3 g/hp-hr Good combustion practices

PM/PM 10 

### 0.24 g/hp-hr Low sulfur distillate fuel oil and good combustion

H 2 

### SO 4 

### 0.006 g/hp-hr Low sulfur distillate fuel (0.05%)

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### Table 11 Summary of Proposed BACT Emission Limi ts for the Materials Handling System

Pollutant Emission Limit (lb/MMBTU) Control Technology

PM/PM 10 

### 0.005 gr/dscf (filterable) for coal handling baghouses and 0.01 gr/dscf (filterable) for other materials Enclosures, dust suppression, and fabric filters

J. Circulating Fluidized Bed Technology
Normally, for each pollutant being regulated in a PSD permit, EPA evaluates control technologies through a “top-down” BACT de termination process for each unit at the facility that emits the regu lated pollutant (see Section VI above). However, EPA is comparing the emissions from Circulating Fl uidized Bed Technology (CFB) separately because an applicant must choose either a pulve rized coal boiler or CF B for all pollutants. Therefore, EPA in this permitting evaluation is comparing the two t echnologies separately.

Table 12 Range of Emissions Control from Coal Combustion Technologies

Coal Technology Efficiency (%) % NOx Controlled % SO 2 

### Removed

Sub-critical PC 34 to 37% 90% (add-on) 92 to 96% (add-on) Super-critical PC 39 to 45% 90% (add-on) 92 to 96% (add-on)

CFB 34 to 37% 50 to 80% 75 to 92%

Notes: CFB control efficiencies are dependent on sorbent activity and injection rates.
CFB suspends crushed coal in upward flowing ai r and a “bed” of inert solids, enhancing the turbulent mixing of the air with the coal. In a CFB, the average temperature within the combustion zone can be mainta ined at less than 2,000 de grees F, while contact with fluidized solids can increase combustion reaction rate and h eat transfer. This technology was first introduced to efficiently utilize a wide variety of off-spec, variable or waste fuels and also as a way to decrease inhere nt pollutant emissions. In a CFB, NO x 

### formation is limited by maintaining low temperatures (1,600 

###  F to 2,000 

###  F) within the combustion zone. The hot cyclone of the CFB is an ideal location for injection of ammonia (called selective non-catalytic reduction) for additional NOx control. A sulfur-adsorbing reagent,

32

### such as limestone or dolomite, is added to the bed which can achieve a 90-92% capture of SO 2 

### within the CFB boiler process itself. Efficien cies for standard atmospheric circulating fluidized bed combustion units range from 36 to 38%.
The most recent atmospheric CFB pl ants currently operating include:



###  Tractebel Red Hills in Choctaw, MS (operating since mid 2001)



###  First Energy Bay Shore power plant in Oregon, OH (operating since May, 2000)



###  AES Warrior Run in Cumberland, MD (operating since February, 2000)



###  AES Guayama, PR (operating with very low SO 2 

### limits)



###  JEA Northside (an earlier generation Foster Wheeler unit)
The majority of support systems for fluidized bed boilers are ve ry similar to pulverized coal operations; however, CFB technolog y has inherent advantages in flexibility to utilize low grade fuels and, as a result, ma y have lower fuel costs relati ve to other coal technologies because they are able to burn le ss expensive fuels. CFBs have long been considered “Clean Coal” technology due to the inhere nt limitation of emissions of SO 2 

### and NOx from within the process itself, without the need for add- on pollution control equipment. Disadvantages include limited unit size (about 300 MW ma ximum), somewhat more complex equipment and operations, and the generatio n of large quantities of lime -rich dry CFB residue solid waste.
The conclusions and concerns regarding CFB technology that were expressed in Sithe’s supplemental analysis are listed below:
• Five or six CFB units would be required instead of two pulverized coal boilers to achieve the planned Desert Rock power output. The loss of economy of scale would significantly increase the capital and operational costs of a CFB plant.

• On a lb/MMBTU basis, most emissions fro m a CFB plant would be similar to or in some cases higher than the proposed Facility’s emissions.

• Sithe estimates the heat rate for a CFB plant would be about 9,950 Btu/kWh while the heat rate for Desert Rock is 8,792 Btu/kWh (net, higher heating value basis). For the same net electricity production an d emission rates, a CFB plant would generate 11% more emissions than Desert Rock.
• On an annual ton/yr basis, all emissions from a CFB plan t would be higher than the proposed Facility’s emissions due to the higher heat rate.

33

### Table 14 Proposed Desert Rock Emission Comparison to a New CFB Plant

Parameter Desert Rock CFB Units Comments

Average heat rate 8,792 9,775 Btu/kWh Sub-critical CFB. Supercritical CFBs are under development.


### SO 2 

### emission rate 0.060 0.0576 lb/MMBTU Sevier Power October 12, 2004 permit limits SO2 emissions to 0.05 lb/MMBTU as a 24-hr average and 0.022 lb/MMBTU as a 30-day average. Desert Rock design fuel contains 2.62 times as much sulfur on a lb/MMBTU basis.


### SO 2 

### emissions 2,998 3,258 tons/yr 1,366 net MW, 95% capacity factor


### NOx emission rate 0.060 0.10 lb/MMBTU Sevier Power October 12, 2004 permit. 

### NOx emissions 2,998 5,656 tons/yr 1,366 net MW, 95% capacity factor



### PM 10 

### emission rate 0.010 0.010 lb/MMBTU Filterable PM10 only, no condensable PM10 data are available. Filterable PM emissions from a baghouse will be similar for both combustion technologies.



### PM 10 

### emissions 500 566 tons/yr 1,366 net MW, 95% capacity factor


### VOC emission rate 0.0030 0.005 lb/MMBTU VOC emissions 150 283 tons/yr 1,366 net MW, 95% capacity factor


### CO emission rate 0.10 0.10 lb/MMBTU CO emissions 4,997 5,656 tons/yr 1,366 net MW, 95% capacity factor



### 34

### Sulfuric acid mist emission rate 0.0040 0.0063 lb/MMBTU Sevier Power October 12, 2004 permit limits H 2 SO 4 emissions to 0.0024 lb/MMBTU as a 24-hr average. Desert Rock design fuel contains 2.62 times as much S on a lb/MMBTU basis.


### Sulfuric acid mist emissions 200 356 tons/yr 1,366 net MW, 95% capacity factor



### Note: EPA is aware of permit th at was recently proposed by EPA Region 8 for Deseret Power that contains emission rates slight ly lower than the above for SO 2 

### and NOx.
After reviewing the submitted materials, as well as our own coal-fi red boiler databases, EPA concludes that CFB is not an appropriate technology for this project and will result in higher emissions than the Facility as proposed.
K. Integrated Gasification Combined Cycle Technology
Consideration of Integrated Gasification Co mbined Cycle (IGCC) technology, as an alternative to a pulverized coal fired boiler, has not been included in Step 1 of the BACT analyses above, since IGCC woul d be redefining the source. In preparing the draft permit, EPA did consider whether IGCC is a BACT opt ion, but concluded it is not because it would fundamentally change the basic design of the proposed s ource. Prior to reaching this conclusion, EPA did, however, request detailed information from Sithe regarding whether or not IGCC would be technically feasible using Navajo Nation coal from the BHP mine. Correspondence from Sithe on this topic has been included in the Administrative Record for this permit action.

VII. AIR QUALITY IMPACTS
The PSD regulations require an air quality analysis to determine the impacts of the proposed project on ambient air quality. For all regulated pollu tants emitted in significant quantities, the analysis must consider whethe r the proposed Facility will cause a violation of (1) the National Ambient Ai r Quality Standards (NAAQS), and (2) the applicable PSD increments. A discussion of the general appro ach, air quality model selection, significant impact levels, PSD increment c onsumption, and the project’s compliance with ambient air quality standards is presented below.

EPA’s conclusion is that Si the used appropriate modeling procedures and followed applicable guidance documents demonstrating that the proposed project will not violate any NAAQS or PSD increment, and will not have an adverse impact on an y Air Quality Related Value (AQRV) at any Class I area.

35

### In summary, the proposed Facility’s impact will be well below the si gnificant impact level for NO 2 

### and CO. The proposed Facility’s impact wi ll exceed the significant impact level for SO 2 

### and PM10, thereby triggering a cumulative impact analysis. The cumulative impact analysis Sithe submitted, howev er, demonstrated that the propos ed Facility will not cause or contribute to an exceedance of the SO 2 

### or PM10 NAAQS or PSD increments. The proposed Facility will not exceed the NAAQS for lead (Pb). Finally, the proposed Facility will not have a significant impact on acid de position at any Class I area, or on the acidneutralizing capacity of sensi tive lakes. Sithe provided substa ntial additional modeling in response to requests from the Fede ral Land Managers (FLMs) to address potential concerns about visibility impacts at Class I areas. The FLMs did not find that the proposed Facility will result in an adverse impact on visibility in the Class I areas.
A. Meteorological and Backgro und Ambient Air Quality Data
The ambient impact analysis required Sithe to pr ovide representative me teorological data as an input into the air quality model. Recently, EPA updated its Guidance to allow applicants to use three years of prognos tic meteorological data (i.e ., data from a weather model), providing a full three-dimensional wind field, in lieu of data collected from one fixed station. This kind of data is a necessary i nput to the chosen air quality model, CALPUFF (see below). Sithe originally used data fro m RUC2 ("Rapid Update Cycle"), a National Weather Service model that incorporates data from many sources, including regular weather stations, NEXRAD rada r stations, and satellites. After consultation with and concurrence by the National Pa rk Service, Sithe updated the modeling using data from the MM5 meteorological model at a higher spatia l resolution. CALMET is a preprocessor that prepares the meteorological fi elds for input to CALPUFF by incorporating local weather observations, and also local terrain effect s on the wind flow. Various CALMET input options for accomplishing this, such as radius of influence of obser vation stations, were provided by the National Park Service (NPS). These approaches meet EPA Guidance requirements for mete orological data.
Sithe was also required to pr ovide representative background air quality data. For the NAAQS compliance analysis, Sithe adde d background concentration to modeled concentrations, and compared the total to the NAAQS. To determine the background concentration, Sithe used the cl osest monitors to the site of the proposed Facility which are 22-24 km away in Farmington, New Mexico for SO 2, 

### NOx, PM10, and O 3 

### and 136 km away in Rio Rancho, New Mexico for CO. EPA has determined that these monitors will record higher background concentrations of pollutants than we woul d expect closer the DREF site because Farmington and Rio Ra ncho have much greater residential and commercial activity than the project site on th e Navajo Nation. We ha ve also determined that the Farmington and Rio Rancho monitors are regionally representative because they record the multi-day buildup of pollutants in the general Four Corners area which is important since pollution te nds to mix throughout the ba sin over several days. The background data recorded by the Farmington an d Rio Rancho monitors is used only to add to the modeled impact for comparison to the NAAQS, and not for comparison to the PSD

36

### increments. The information from the monitors and Sithe’s modeling demonstrates that the total project impact, including background, will be at most 44% of the NAAQS.
B. Modeling Methodology
The model recommended by the Fe deral Land Managers (FLMs) for analyzing impacts on Class I areas, which are typically rather distant, is CALPUFF. EPA guidance also recommends the use of CALPUFF in near-field Class II analyses if there are complex winds, for which the standard plume models ISCST3 or AE RMOD would be inadequate. In CALPUFF, the individual puffs composin g a plume may follow independent paths, which is a much more realistic simulation th an the single straight line plume assumed in ISCST3 and AERMOD. As shown by Sithe, th e area surrounding the site for the proposed Facility is subject to complex winds. The va rying strengths of competing regional flows and the more local upslope / downslope flows driven by solar heating mean that flow reversals can occur. This condition is exacerba ted by the complex terrain in the area and its non-uniform slopes. Multi-day st agnation is also an issue. These conditions can be handled by CALPUFF, but not by the standard plume models. Therefore, Sithe’s choice of CALPUFF for the Class II analysis as well as the Class I analysis is correct and provides consistency with the approach required for Class I areas.
In addition to the meteorolog ical inputs discussed above, an air quality model needs inputs characterizing emissions sources. Sithe modeled the proposed Facility’s emissions at their proposed maximum allowable emi ssion rates. Sithe’s approach guarantees a conservative air quality assessment meaning that the assessment will predict higher impacts than will occur. (For example, for the 3-hour SO 2 

### NAAQS, Sithe modeled th e main stack at 50% higher than the proposed PSD permit’s allo wable 24-hour average maximum, i.e. Sithe modeled the SO 2 

### emissions at 0.09 lb/MMBtu althoug h the proposed PSD permit will only allow the Facility to emit SO 2 

### at 0.06 lbs/MMBtu). Sithe chose to model the proposed Facility’s emissions conservatively to account for short-term variabil ity that might occur during any 24-hour period. Sithe also used input s for the proposed Facility’s stack height, temperature, and exit veloc ity, which determine the plume' s buoyancy and momentum, and hence the emissions’ distance from the ground. Because these factors vary with the work load of the source, Sithe performed load scr eening, which is an estimate of impacts under different load conditions, with the SCREEN3 m odel, and then with CALPUFF itself. Sithe then used the worst case scenario, assuming 100% load, for the rest of the modeling.
EPA recognizes that nearby buildings can caus e plume downwash, leading to high pollutant concentrations. Sithe used the model option to simulate this effect for the proposed project's auxiliary boilers, diesel generators and fire pumps. Sithe did not use this model option for the main stacks of the two proposed pulverized coal fired boilers, because Sithe has proposed to construct a stack that will be sufficiently tall to avoid downwash. Sithe’s proposed stack height of 917 feet was dete rmined through a Good Engineering Practice (GEP) stack height analysis, using the BPIP software EPA provides for that purpose. The procedures that Sithe followed meet EPA guidelines.

37

### The final inputs are the locations , or receptors, at which the model will compute pollutant concentrations. Sithe followed good receptor placement procedures that are in accordance with EPA guidelines. This procedure includes a set of receptors out to 50 km from the source, which is standard for Class II area an alyses, but Sithe also included additional sets of receptors that are progressively more clos ely spaced nearer the source, and also fence line receptors. Sithe used dense receptor grids in areas with potentially high impacts, i.e. hillsides where plume im paction can occur. Other sets of receptors are prescribed by the FLMs for each Class I area; al l 15 Class I areas within 300 km of the proposed Facility were modeled. Finally, receptors were modeled at 26 distant sensitive Class II areas, such as National Historic Parks, Wi lderness Areas, and National Monuments; while these are not Class I areas, they are of sp ecial concern to the FLMs.
The proposed Facility’s modele d impacts are shown in Table 15 and 16 below. The PSD regulations do not allow a project to make a "significant" cont ribution to a violation of the NAAQS or of the PSD increment. That is, the applicant must show that its own impact is below the Significant Impact Level (SIL), or else show that there is no violation at locations where its impact is above the SIL. The proposed Facility’s impact does not exceed the SIL for NO 2 

### and CO, which demonstrates the proposed Facility’s compliance with the NAAQS and PSD increment for those pollutants.
The proposed Facility’s mode led impacts from PM10 and SO 2 

### exceeded the SIL, triggering the requirement for a cumulative analysis fo r those two pollutants. Sithe’s cumulative analysis demonstrated that the proposed Faci lity would remain well below the NAAQS and PSD Class II increment.
For Class I areas, Sithe's modeling showed that the emissions from the Facility could potentially have an impact on an Air Quality Related Value (AQRV). Specifically, Sithe's modeling indicated that the Facility's emissions would result in greater than 5% extinction of visibility on at least 1 day at 11 of th e surrounding 15 Class I areas. The FLMs requested Sithe to perform additional modeling. Sith e performed several rounds of additional modeling to evaluate if the Facility's emissi ons would have an adverse impact on Class I area visibility. On April 25, 2006, the United States Forest Serv ice (USFS) sent a letter to EPA referring to a "mitigation strategy" that Sithe had proposed to the FLMs. The USFS letter indicated that Sithe's performance of th e mitigation strategy would be sufficient to alleviate its concerns about visibility. The USFS letter requested EPA to include the mitigation strategy in Sithe' s PSD permit so that Sithe' s proposal would be federally enforceable. EPA had subsequent discussions wi th the FLMs to explain EPA's preference for the mitigation strategy to remain in a side agreement between Sithe and the FLMs rather than in Sithe's PSD permit. We understand that Sithe and the FLMs are continuing to discuss appropriate mechanis ms other than the PSD permit to memorialize Sithe's commitment to perform the mitigation strategy. Accordingly, EPA has concluded it is appropriate to propose a pproval of the PSD per mit while Sithe and the FLMs continue to discuss memorializing Sithe's commitment to pe rform the agreed upon mitigation strategy.

38

### Table 15 Maximum Predicted Air Quality Impa cts from the Proposed Project

Pollutant Averaging Period Modeled Impact SIL (ug/m 3 

### ) PSD Class II Increment

(ug/m 3 

### ) NAAQS (ug/m 3 

### )

NOx Annual 0.56 1 25 100

SO 2 

### 3-hour 271.2 25 512 1300

24-hour 23.6 5 91 365

Annual 0.41 1 20 80

PM10 24-hour 27.73 5 30 150

Annual 1.75 1 17 50

CO 1-hour 1375.7 2000 N/A 40000

8-hour 465.2 500 N/A 10000 Pb Quarterly 0.0028 N/A N/A 2

Note: For 3-hour averages, an SO 2 

### emission rate of 0.09 lb/MMBTU was assumed to account for short term variability.

Table 16 Maximum Predicted Air Quality Impacts from the Project at Class I Areas

Pollutant and Averaging Time

Class I Area NOx SO 2 

### PM10
Annual 3-hour 24-hour Annual 24-hour Annual

Arches NP 0.0021 0.720 0.172 0.008 0.062 0.004
Bandelier NM 0.0074 1.268 0.273 0.017 0.092 0.006 Black Canyon of the 0.0026 0.929 0.180 0.008 0.050 0.003 Gunnison NM Canyonlands NP 0.0045 1.479 0.476 0.013 0.184 0.005 Capitol Reef NP 0.0010 0.711 0.159 0.005 0.072 0.002

39

### Grand Canyon NP 0.0003 0.447 0.127 0.002 0.053 0.001
Great Sand Dunes NM 0.0018 0.547 0.147 0.006 0.050 0.002
La Garita WA 0.0028 0.761 0.151 0.007 0.053 0.003
Mesa Verde NP 0.0261 4.706 0.790 0.044 0.263 0.016

Pecos WA 0.0041 0.690 0.190 0.011 0.068 0.004
Petrified Forest NP 0.0008 0.939 0.212 0.004 0.091 0.002
San Pedro Parks WA 0.0169 2.379 0.533 0.030 0.187 0.011
Weminuche WA 0.0086 1.803 0.270 0.017 0.093 0.007
West Elk WA 0.0016 0.722 0.173 0.006 0.049 0.002
Wheeler Peak WA 0.0028 0.727 0.092 0.008 0.046 0.003
Proposed Class I SIL 0.1 1.0 0.2 0.1 0.3 0.2
PSD Class I Increment 2.5 25.0 5.0 2.0 8.0 4.0

Note: Bold values indicate pred icted values above the proposed Class I Significant Impact Levels.
C. NAAQS Compliance
As discussed above in genera l, to show NAAQS compliance, Sithe performed cumulative analyses for PM10 and SO 2 

### by including the emissions of nearby sources. Sithe used data on source allowable emissions from State emission inventorie s where available, and Sithe supplemented this data by using EPA's Nationa l Emissions Inventory (NEI). Sithe used a "distance rule", agreed upon with EPA and the NPS, to simplify the cumulative analyses and allow for reasonable model run times. For SO 2 

### , if a source's emissions in tons per year are less than 0.8D, where D is distance in km , then it is deemed small enough to omit from the modeling. The 0.8 in the rule was sugges ted by NPS and is ba sed on past modeling work and experience showing that the impact of such small and distant sources to be negligible. A 40 tpy source w ould be omitted only if it were 50 km or more away, which illustrates the conservati veness of the distance rule used by Sithe.
The results of the cumulative NAAQS analyses are shown in Table 17 below. The results, including the monitored background concentrati on, are less than half the NAAQS in every case. Sithe has thus demonstrated compliance with all the NAAQS.

40

### Table 17 Predicted Cumulative Air Qu ality Impacts on the NAAQS

Pollutant Averaging Period Modeled Impact (ug/m 3 

### ) Background Concentrations (ug/m 3 

### ) Total Impact (ug/m 3 

### ) NAAQS (ug/m 3 

### )

SO 2 

### 3-hour 403.56 6.2 409.7 1300
24-hour 98.3 6.2 104.5 365
PM10 24-hour 8.55 20 28.5 150
Annual 1.9 20 21.95 50

Note: For the cumulative analysis, because of the way the NAAQS are defined, the second highest predicted concentration is compared to the NAAQS level. Thus some values in this table may be lower than in Table 15, where the first high is used, to provide a more conservative assessment of whether the Facility has any impacts above the SIL.
D. Increment Consumption Analysis
The cumulative analysis for PSD increment, which is discussed gene rally above, is more complicated than the analysis for the NAAQS, because not all emissions "count" toward, or consume, increment. EPA’s regulations provi de that the only emissions changes that consume increment are those em issions that have occurred si nce the "baseline date". The reason for this provision is th at the PSD program is aimed at the preventing the significant deterioration of the air quality in an area relative to the baseline conditions of that area. In addition, emissions decreases in the same area expand or increase the available increment, because the emissions decreases tend to improve air quality relative to the baseline date of the area.
For the PSD increment analysis, Sithe used St ate databases for much of the required data. Sithe also used a conservative procedure (i.e. likely to overestimate emissions) to simplify the analysis for major sources. Sithe’s procedur e assumed that all of the emissions at major sources, with two exceptions discussed below, c onsumed increment, regardless of when the emissions began to occur rela tive to the baselin e date. PSD increment consumption is based on changes in actual emissions (not maximum allowable emissions), of which records are kept. Continuous Emis sions Monitors (CEMs) in th e stack of each major source are required under various regula tory programs, such as the Acid Rain Program. EPA, therefore, provided Sithe with nearby sources' maximum actua l emission rates that were representative of th eir normal operation.
In some cases, the PSD increment analysis is more complicated than that needed in this

41

### case. For example, the emissions from minor sources are often omi tted or undercounted in State databases. That potential problem is not present for this permitting action because the area surrounding the site of the proposed Facili ty is sparsely populated, and has relatively little commercial or industrial activ ity or growth. Therefore, this issue is not of concern for Sithe’s Class II increment analysis. For the Class I increments, Sithe agreed to a much larger modeling domain encompassing all Class I areas within 300 km. EPA and Sithe consulted with the State air agencies of the Four Corners States of Arizona, Colorado, New Mexico, and Utah. In each case, based on ge neral knowledge of the areas, minor source permitting programs, and previous studies of th e status of the increment, State regulators concluded that minor source gr owth had a negligible impact on the PSD increment. Thus, EPA has determined that emissions from minor sources and the potential for minor source growth will not have any effect on either the Class II or Class I increment analysis.
A second potentially complicating factor for PS D increment analysis is that the "baseline date" may be different for different areas, becau se the baseline date is triggered by the issuance of the first major source permit in each area. This means that each source could have different fractions of its emissions count toward increm ent depending on which Class I area was being evaluated; in the worst case this would require different combinations of emissions estimates and differe nt modeling runs for every Class I area. Sithe, however, handled this issue by applying the conservative procedure mentioned above, which assumes that all emissions at each major source cons ume increment regardless of baseline date. This procedure is considered conservative because it overestimates potential emissions.
Sithe applied two exceptions to this conservative procedure. The two nearest major sources of emissions to the site of the proposed Faci lity are the Four Corners Power Plant (FCPP), and the San Juan Generating St ation (SJGS). FCPP is 22 km away from the site of the proposed Facility and SJGS is 35 km away. Both FCPP and SJGS have reduced their emissions substantially in the past two decades by installing pollution control equipment and improving operations. The emissions reductions from FCPP and SJGS have expanded the available increment in the area surrounding the site of the proposed Facility, leaving more of the increment availa ble. Although some of the e missions reductions from FCPP and SJGS were required by EPA to remedy SO 2 

### NAAQS violations m onitored in the 1970s, the actual reductions were far greater than required to cure th e NAAQS violation.
EPA provided Sithe with the emission rates promulgated in 46 FR 43152-43154 (Aug. 27, 1981) and 46 FR 30653-30654 (June 10, 1981), for FCPP and SJGS that were required for attainment of the SO 2 

### NAAQS. Sithe then modeled onl y the emissions reductions from FCPP and SJGS that went beyond those required for NAAQS attainment.

The results of the cumulative PSD increment analysis are shown in the table below. The results, including the monitored background c oncentration, are well below the Class I and Class II increments where they are respectiv ely applicable. Sithe ha s thus demonstrated compliance with the PSD increments.

42

### Table 18 Predicted Cumulative Air Quality Impacts on the Class II Increments

Pollutant Averaging Period Modeled Impact (ug/m 3 

### ) Increment (ug/m 3 

### )

SO 2 

### 3-hour 67.3 512
24-hour 10.75 91
PM10 24-hour 8.47 30
Annual 1.82 17

Table 19 Predicted Cumulative Im pacts on the Class I SO 2 

### Increments

Class I Area SO 2 

### impacts, μ g/m 3



### 3-hour 24-hour Annual

Bandelier NM 6.76 2.15 0.054 Canyonlands NP 6.76 2.15 0.097

Mesa Verde NP 12.84 2.15 -0.034

Petrified Forest NP 16.38 3.72 0.374
San Pedro Parks WA 2.54 0.90 -0.028
Weminuche WA 3.51 0.45 0.009
PSD Class I Increment 25 5 2

Note: Proposed Facility impacts exceeded the proposed Class I Significant Impact Level only for SO2, and only at six Class I areas. Negative num bers indicate incremen t expansion, due to emission reductions at FCPP and SJGS.

VIII. ADDITIONAL IMPACT ANALYSIS
In addition to assessing the ambient air quality impacts expect ed from a proposed new source or modification, the PSD regulations require that certain other impacts be considered. These include impacts on visi bility, soils and vegetation, and growth.

43

### A. Visibility
Sithe modeled the proposed Faci lity’s potential impact on vi sibility and other AQRVs, which are defined by the FLM for each Class I area. As me ntioned above, Sithe conducted several rounds of additional modeling, after extensive c onsultations on modeling procedures with the FLMs.
The "Federal Land Managers' Air Quality Related Values Workgroup (FLAG) Phase I Report" (USFS, NPS, US F&WS, December , 2000), also known as the "FLAG document" prescribes procedures for a ssessing impacts on Class I areas. Sithe followed the FLM’s recommended procedures for us ing CALPUFF along with th e post-processing program CALPOST, for assessing acid de position impacts and regional haze impacts. The modeled sulfur and nitrogen deposition were below the FLMs' "Deposition Analysis Thresholds" (DATs) of 0.005 kg/ha (kilograms per hect are). Therefore, the FLMs concluded that further analysis was not required and have not made any finding of adverse impact on AQRVs related to deposition or vi sibility. For visibility, see page 38 for a discussion of the USFS letter dated April 25, 2006.
At the request of the USFS, Sithe also perfo rmed an analysis of the proposed Facility’s effect on the acid-neutralizing capacity (ANC) of 10 lakes in four Class I areas. Using the Forest Service screening met hodology, which is based on th e modeled acid deposition and the lakes' size and rainfall, Sithe showed that the proposed Facility’s impacts were below the USFS level of concern.
For assessing regional haze impacts, the FLAG document prescribes a screening procedure based on changes in extinction, which is defined as changes in the attenuation of transmitted light, per unit distance, caused by the proposed Facility project. CALPUFF predictions for sulfate, nitrate, and particulat e matter are multiplied by the light extinction capacity of each, then the daily averages of the resulting to tal extinction increase above natural background is compared to the 5% leve l. The 5% level of extinction indicates an amount of haze just perceptible to an observer. If the 5% level of extinction is exceeded on any day the FLAG document recommends additional analysis to assess whether there is an adverse impact.
Sithe carried out the FLAG screening procedur e and found days over the 5% concern level at 11 of the 15 Class I areas; six areas had at least one day over 10% extinction. Sithe then conducted an additional analysis. The most significant part of this alternative analysis was an examination of individual hours within each daily average, to check for times when visibility was already naturall y obscured by rainy or cloudy weather. Sithe concluded that excluding those problematic hours from the averages brings the proposed Facility’s emissions impact project back under the 5% le vel, so that its visibility impacts are acceptable.
Sithe also performed a supplemental analysis to assess th e impact of the proposed Facility

44

### on requirements for progress toward natural visibility conditions. Sithe modeled the emission changes at FCPP and SJGS, added the emissions from the proposed Facility and evaluated the change in visibili ty at Class I areas using the sa me metric that is used under the Regional Haze Rulemaking (extinction improvement in th e best 20% and worst 20% of the days). This modeling showed that visibility would improve in the area regardless of the emissions from the proposed Facility. Sithe’s an alysis showed that the resulting visibility improvement exceeded the 10% Regional Haze Rulemaking progress requirement through 2010 (based on a six year period, 10% of the way to the final goal in 2064). In addition, Sithe has agreed to perform addi tional mitigation that will more than offset any potential contribution to visibility impairment.

EPA has concluded that construc tion and operation of the propos ed Facility is consistent with the requirements for visibility im provement under the Re gional Haze Rule.
B. Soils and Vegetation
The PSD regulations require anal ysis of air quality impacts on sensitive vegetation types, with significant commercial or recreational value, and sensitive types of soil. Evaluation of impacts on sensitive vegetation were performed by comparing the predicted impacts attributable to the project with the screening levels presented in A Screening Procedure for the Impacts of Air Pollution Sources on Plants, Soils, and Animals (EPA 1980).
The modelling analysis showed all impacts to be well below the screening levels. Most of the designated vegetation scr eening levels are equivalent to or less stringent than the NAAQS and/or PSD increments, therefore sa tisfaction of NAAQS and PSD increments assures that sensitive vegetation will not be negatively affected.

C. Growth
Growth impacts due to the propos ed project are not expected to be significant. There will be little new growth in the area due to the small work force (200-225 employees) expected during plant operation. The emissi ons associated with the workforce will be primarily the result of motor vehicle exhaus t emissions associated with the commute of workers to and from the plant site.

IX ENDANGERED SPECIES
Pursuant to Section 7 of the Endangered Sp ecies Act (ESA), 16 U.S.C. § 1536, and its implementing regulations at 50 C.F.R. Part 402, EPA is required to ensure that any action authorized, funded, or carried out by EPA is not likely to jeopardize the continued existence of any endangered species or threatened speci es or result in the destruction or adverse modification of such species’ designated criti cal habitat. EPA has dete rmined that this PSD permitting action triggers ESA Section 7 consultation requirements. EPA is therefore required to consult with the U.S. Fish and Wildlife Service (FWS) and/or the National

45

### Marine Fisheries Service (NMFS) if an endang ered species or threatened species may be present in the area affected by the permit project and EPA’s action (i.e., permit issuance) may affect such species. EPA is also required to confer with the Services on any action which is likely to jeopardize the continued existence of any species proposed for listing (as endangered or threatened) or result in the destruction or adverse modification of habitat proposed to be designated as critical for such species.

When a Federal action involves more than one agency, consultation and conference responsibilities may be fulfille d through a lead agency pursuant to 50 CFR § 402.07. Since the land, electrical transmissi on lines, and access roads re quired for the proposed project are located on the Navajo Indi an Reservation and lands under th e jurisdiction of the Bureau of Indian Affairs (BIA), the BIA will act as the lead Federal agency for purposes of fulfilling the responsibilities under Se ction 7 of the ES A for the project.
EPA may proceed with the final permit issuance upon conclusion of c onsultation, review of FWS’s Biological Opinion, and our determinat ion that issuance of the permit will be consistent with th e ESA requirements.

X. NATIONAL HISTORIC PR ESERVATION ACT (NHPA)
Section 106 of the NHPA requires responsible Federal officials to take into account the effects of their decisions on hi storic properties eligible for th e National Register of Historic Places, and consult with appropriate State or Tr ibal Historic Preservation Officers and other interested parties to avoid, re duce, or mitigate any identified adverse effects. The applicant has retained a consul tant to conduct cultural resource studies to support Section 106 consultations. On 17 February 2004, the consultant contacted the Navajo Nation Tribal Historic Preservation Office r (THPO) to provide initial notification about the proposed Facility, inform him of the purpose of the projec t, and briefly describe the elements of the project. As a follow up to the in itial contact, the applicant is prepared to work with the BIA in consulting with the Navajo Nation THPO about defining the area of potential effect, identifying other potentially interested partie s who should be involved in the consultations, and developing an appropriate strategy to inventory and eval uate cultural resources that could be affected.

XI. TITLE IV (ACID RAIN PERMIT)
The applicant must apply for and obtain an aci d rain permit. The appl icant will apply for this permit prior to facility operation.

XII. ENVIRONMENTAL JUSTICE
On February 11, 1994, Executive Order 12898, “F ederal Actions to Address Environmental Justice in Minority Populations and Low-Inco me Populations,” was signed. EPA defines environmental justice as the fair treatment and meaningful involvement of all people

46

### regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environm ental laws, regulations, and policies. EPA has this goal for all communities and pers ons across this Nation. In addition, EPA published guidance entitled, “F inal Guidance For Incorporating Environmental Justice Concerns in EPA's NEPA Comp liance Analyses” in April 1998.
With respect to the proposed Facility, EPA is aware that the public is raising environmental justice concerns in the NEPA process. Please see our June 15, 2005 letter which reflects our comments on the May 2005 Draft Summary Scoping Re port for the Desert Rock Energy Project. In this letter, we note that the public has identified five issues of concern. These issues are:
1) Lack of jobs provided to people of Navajo Nation,
2) Social impacts,
3) Use of local water sources as dispropor tionately damaging to local communities,
4) Disproportionate exposure to pollutants, potential health problems (respiratory, heavy metals in fish), and
5) Impacts without benefits: power goes to other locations and is not distributed locally.
In response to the concerns li sted above, EPA is conducting additional outreach on the PSD aspects of the proposed Facility in the form of workshops with Dine translators, radio announcements in Dine, and tran slations of fact sheets in Dine. The applicant has also prepared a data presentation to better charact erize the issues raised in the NEPA scoping effort regarding environmental justice and EPA expects that these issues will be addressed through the NEPA process.

XIII. CONCLUSION AND PROPOSED ACTION
Based on the information supplied by Sithe, our review of the analys es contained in the permit application, and our i ndependent evaluation of the information contained in our Administrative Record, it is our determination that the pr oposed Facility will employ BACT and will not cause or contribute to a vi olation of the NAAQS, or an exceedance of PSD increments. Therefore, EPA is proposing to issue Sithe a PSD permit for the Facility, subject to the PSD permit conditions specified he rein. This permit is subject to review and comments. A final decision on issuance of the permit will be made by EPA after considering comments received during the public comment period and upon completion of the ESA consultation process.

47

# Exhibit 16!"#$%$&'(')*+$%, - G.T. Bielawski

J.B. Rogan D.K. McDonald The Babcock & Wilcox Company Barberton, Ohio, U.S.A.

Presented to: The U.S. EPA/DOE/EPRI Combined Power Plant Air Pollutant Control Symposium: “The Mega Symposium” August 20-23, 2001 Chicago, Illinois, U.S.A. 

# !"#$%"#$&'($)*$+", !"#$%"&&'#()*+',,'"#,)'#)-./)!"0&12'%.3)4"/.%)4&0#$,

BR-1715



### !"#$%&'$ There is currently a demand for new coal-fired generation in the USA. The few coal-fired plants that have been permitted within the last ten years have been required to meet emission levels considerably less than NSPS. The realities of permitting a new coal-fired plant today will require low emissions. The need for ultra-high removal efficiency technologies for NO
x , SO 2 , sulfuric acid mist, PM 2.5 , mercury, and particulate is here. There is also the potential need to lower CO 2 emissions by utilizing more efficient steam cycles than have been used in this country to date. This paper will examine in detail cost-effective advancements in known, proven emissions control technologies that achieve synergistic multi-pollutant capture and will briefly discuss steam cycle options to reduce CO 2 . Emission control technologies for eastern bituminous high sulfur fuels that can achieve 0.016 lb/ MBtu NO
x , 0.04 lb/MBtu SO 2 , and 0.006 lb/MBtu particulate(including acid mist) are examined. For PRB coal, emission levels down to 0.008 lb/MBtu NO
x , 0.04 lb/MBtu SO 2 , and 0.006 lb/MBtu particulate with a high level of mercury capture can be achieved. This level of NO
x is less than the permit levels of many of today’s new gas turbine combined-cycle units.



### ()$%*+,'$-*)When it comes to coal-fired technologies for power generation, only three technologies promising high efficiency are sufficiently developed to have any impact on the industry over the next two or three decades: pulverized coal-fired boilers (PC), pressurized fluidized bed combustion (PFBC) and integratedgasification combined cycle (IGCC). When net plant efficiencies are compared based on the same site and ambient conditions and using the same units, first generation PFBC, IGCC and PC with state-of-the-art steam conditions can currently achieve comparable net plant heat rates approaching 8200 Btu/ kWh (41-42% HHV efficiency). Similarly, with the advances in emissions control devices, a modern pulverized coal plant can achieve comparable emissions to PFBC and IGCC plants. However, on a capital cost basis, the pulverized coal technology has a clear advantage and will be the technology of choice for the near and intermediate term. This paper discusses the emissions and efficiency performance of a modern pulverized coal-fired plant.



### ./0.1&)$023&$04&$3 Over the last ten years, higher efficiency pulverized coal plants have gone into commercial operation outside the U.S. The higher efficiencies are due to not only advanced steam cycles, but also improvements in turbines and reductions in power requirements for plant auxiliary equipment. Materials are currently available for some coals to allow steam conditions as high as 4500 psi and 1100F/1100F which, depending on site conditions and coal characteristics, can achieve heat rates as low as 8050 Btu/kWh (42.5% HHV efficiency). Materials are currently being developed to permit steam temperatures of 1200F and higher, depending on the corrosiveness of the coal ash. Pulverized coal power plant heat rate improvements versussteam cycle conditions are shown in Figure 1. (The actual operating plants have steam cycles close to the examples under which they are listed.). !"#$%$&'(')*+$%,The point is that higher efficiency cycles are now being demonstrated with commercially required availability and reliability. Higher efficiency cycles will reduce electric production cost through lower fuel consumption, reduce CO 2 emissions per kWh of energy generated, and result in lower capital and operating costs for all the environmental equipment (on a $/kW basis). The ambient air emissions (NO
x , SO
x , particulate, and mercury) are a function of the emissions control device (SCR, scrubber, fabric filter, etc.). However, more efficient, lower heat rate plants will provide additional marginal emissions reductions as well. For the U.S. market, the economically optimum cycle efficiency is very project specific. However, today, even though advancedcycles are now available and have been demonstrated commercially, they will only be applied where project economics dictate. !" ! #$%" " #$&" ! $'()$*'+,-./0',1$23-44-5(4$647 81',$9',1 The key drivers to increasing efficiency are reduced fuel cost and reduced CO 2 emissions. Because of the abundance and low cost of coal in the U.S., fuel cost savings do not provide as significant a motivation as in many other countries. Though not yet widely regulated in the U.S., greenhouse gas emissions and concern for global warming have recently sparked considerable interest in higher efficiency cycles. Figure 2 shows that CO 2 emissions can be significantly reduced by increasing plant efficiency. However, as Figures 3, 4 and 5 show, improving efficiency has only a minimal impact on the other key emissions. Figure 3 shows the NO
x emissions in lb/MWh for selective catalytic reduction (SCR) removal rates of 25% to 95% and net plant heat rates varying from 9300 Btu/kWh (36.7% net plant effi-

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Figure 5 shows the outlet particulate emission in lb/MWh as a function of the particulate in the flue gas in lb/MBtu. Againthe conclusion is that as fabric filters and other particulate removal devices become more efficient, the impact of improved heat rates on emissions is nearly negligible.Figures 3 through 5 show that projects requiring low ambient air emissions will primarily achieve those low levels throughthe performance of the emissions control devices (SCR, scrubber, ESP/fabric filter); cycle heat rate has minimal impact. More efficient heat rate cycles will primarily be justified by lower fuel consumption and the potential future benefit of lower CO 2 emissions. !"#$%&', /01"$2'%3'45"2'6"25'%7'F9 ! '50*::*%7:;

ciency) to 8050 Btu/kWh (42.4%). The graph shows that as a higher removal rate SCR is selected, the impact of the cycle heat rate declines. Although current removal rates are typically 90%, as high as 93% has been demonstrated, and even higher removal is possible with improved mixing and additional catalyst. At these high removal rates, improving heat rate (or cycle efficiency) has little impact on the further reduction of NO
x emissions. Figure 4 shows the same comparison for SO 2 . A typical removal in a wet scrubber is 90% with some today as high as 95% to 98%. Again, as the SO 2 removal rate in the scrubber increases, the effect of cycle heat rate improvement on further SO 2 removal decreases.@ !"#$%$&'(')*+$%, 

### 56-##-*)#07-6-$#80!09%-3:02-#$*%; In 1971, the New Source Performance Standards for new coal-fired power plants in the U.S. were 0.7 lb NO
x /MBtu, 1.2 lb SO 2 /MBtu, and 0.1 lb particulate /MBtu. These regulations were tightened in 1979. For NOx, the regulation was 0.5 or 0.6 lb NO
x /MBtu depending on the type of coal. The regulation for SO 2 was a sliding scale from 1.2 down to 0.3 lb SO 2 /MBtu depending on the coal sulfur. The particulate limit was lowered to 0.03 lb/MBtu. The few new coal-fired power plants that received permits in the 1990s typically had permit levels less than the New Source Performance Standards as shown on Table 1. The technology of emission control equipment has advanced such that even lower emissions goals can be sought today. This should make coal more environmentally acceptable and more frequently the choice for future power generation needs. :)6'(.1)$*0'(,$!5(;-</+',-5(4 Possible configurations of environmental control equipment for new coal plants will now be examined. One such configuration is for high sulfur bituminous coal and another configuration is for low sulfur western coal from the Powder River Basin.The plant configuration for high sulfur bituminous coal consists of low NO
x burners, an advanced high removal efficiency selective catalytic NO
x removal system, fabric filter, and limestone wet flue gas desulfurization (FGD) with integral wet electrostatic precipitator (ESP) and additive for mercury control. The plant configuration is shown in Figure 6. -./0&') G560*2'H*0*2:'%3'I5$572'E5J'K;F; 8%"+LC*65='K7*2:M'+#BN!2?

12 ! 32 " 45 #$ G+"72'<'O-PPDQ A;-R A;.. A;A-A G+"72'!'O-PP@Q A;-R A;-S A;A-T G+"72'8'O-PPUQ A;-R A;-R A;A-T G+"72'V'O-PPSQ A;-A A;-A A;A-T G+"72'W'O.AA-Q A;AP A;-U A;A-- G+"72'C'O.AA-Q A;AT A;-. A;A-T The plant configuration for low sulfur western coal consists of low NO
x burners, limestone injection into the furnace, partial particulate collection upstream of the SCR, an advanced high removal efficiency SCR, spray dry absorber FGD system and fabric filter. The plant configuration is shown in Figure 7. The emissions goals for these advanced PC plants are as shown in Table 2.
=/0,->?500/,'(,$:??+5'.@ Each of the unit operations or systems that is utilized in a flue gas cleaning train has normally been associated with the treatment of one particular pollutant. An example would be that a selective catalytic reduction system is used to reduce NO
x .However, the synergistic effects of each unit operation or system in the train on all the pollutants must now be recognized. Some of t hese effects are positive and some may be negative. For example, it is known that an SCR oxidizes elemental mercury into ionic mercury. Oxidized mercury is much easier to remove in an FGD system. Thus, making the SCR larger will increase mercury removal in the FGD downstream. However, an SCR also oxidizes SO 2 to SO 3 , which becomes sulfuric acid, H 2 SO 4 . Sulfuric acid forms a very fine mist, which is very difficult for a wet FGD to

remove. The two plant configurations are summarized in Table 3.



### 2-<=0>,1:,%09-$,6-)*,#0/*&10.1&)$ /*):-<,%&$-*)

%" " $!5(,+50 NO
x is controlled by advanced low NO
x burners and an advanced selective catalytic NO
x reduction system. Figure 8 shows the NO
x performance goal in comparison with existing coalfired technology and how it compares with emissions from existing natural gas combined cycle power generation. Table 4 shows the NO
x emissions performance in several different equivalent measurements and how it compares to a state-ofthe-art natural gas combined cycle plant using dry low NO
x combustion and with a nominal emissions rate of 9 ppm @ 15% O 2 .

!"#$%&'6 G8'1+"72'3%6'4*X4':?+3?6'#*2?0*7%?:'$%"+;!"#$%$&'(')*+$%, U As can be seen, the NO
x levels from this plant will be significantly lower than the current state-of-the-art for natural gas combined cycle technology using dry low NO
x combustion.

!"#$%& ! $'()*+)$,+-.*"/"01 The NO
x level leaving the boiler and entering the SCR is a function of the coal being burned, the burner design, the degree of air staging, and mixing of the air and fuel. For high sulfurcoal applications, little or no air staging is used to avoid corrosion of the furnace tubes due to local sub-stoichiometric conditions. Although variations in the coal can have substantial impact on the NO
x level leaving the boiler, a typical eastern bituminous coal with the best low NO
x burner and minimal staging can achieve approximately 0.31 lb/MBtu leaving the boiler. The B&W DRB-4ZTM burner is designed to produce lower NO
x emissions without significant impact on unburned carbon by featuring a patented transition zone. This zone acts as a buffer between the fuel-rich flame core and secondary combustion air streams. This design improves mixing and flame stability by limiting recirculation between air streams. The DRB-4ZTM burner, developed as part of the U.S. Department of Energy’sCombustion 2000 program, is the product of extensive numerical modeling using B&W’s proprietary combustion modelingtechnology. The prototype burner was refined through a program of large-scale combustion tests performed in B&W’s Clean Environment Development Facility (CEDF) and is the newestand most advanced coal burner B&W has commercially available. These burners are already in successful operation. !"#$%&'7 G8'1+"72'3%6'+%J':?+3?6'GI!'$%"+;

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% '"==*2*%7S !"#$%$&'(')*+$%, 234$'5-60)"(*7 The basic principle of conventional selective catalytic NO
x reduction is the reduction of NO
x to N 2 and H 2 O by the reaction of NO
x and ammonia (NH 3 ). In the presence of the catalyst, the following NO
x reduction reactions occur: NO Reduction: 4 NO + 4 NH 3 + 0 2 → 4 N 2 + 6 H 2 0 NO 2 Reduction: 6 NO 2 + 8 NH 3 → 7 N 2 + 12 H 2 0 2 NO 2 + 4 NH 3 + 0 2 → 3 N 2 + 6 H 2 0 Secondary reactions that can occur in the presence of the catalyst are the oxidation of SO 2 to SO 3 according to: SO 2 + 1⁄2 O 2 → SO 3 and the oxidation of elemental mercury according to: Hg 0 Hg 2+ catalyst The synergistic impacts of these secondary reactions will be described. Commercial SCR installations on gas, oil, and coal-fired power plants have demonstrated that NO
x reductions of 90% can routinely be achieved with low ammonia slip. The critical parameters to consider in the design of an SCR are the level of flyash, SO 2 and SO 3 in the flue gas, the trace metals present in the flyash, and the injection, distribution and mixing of the ammonia. Over the course of designing nearly 12,000 MW of installed SCR systems, B&W has determined that achieving very high NO
x removal efficiencies requires increasingly uniform NH 3 /NO
x molar ratio profiles entering the reactor. 234$,+-.*"/"01$8795*-+:+*;< Today, it is possible to design an SCR to provide 95% NO
xcontrol if the mixing issues are adequately addressed. The degree of maldistribution in a NH 3 /NO
x molar ratio profile is referred to as the coefficient of variation (Cv). The Cv is the standard deviation of the distribution of measured values, expressed as a percentage of the average. The greater the Cv, the broader the distribution, with maximum and minimum values located farther out from the mean. Values less than the mean result in insufficient NH 3 to achieve the design reduction. Values higher than the mean will meet the reduction required but will exceed the design NH 3 slip. A coefficient of variation of 5% is the current industry standard for NH 3 /NO
x molar ratio uniformity on high efficiency SCR systems. The objective for the advanced plant is to achieve 95% NO
x removal with 2 ppm average outlet ammonia slip. If this goal is approached by the conventional means, catalyst volume needed to compensate for the maldistribution becomes excessive.To minimize the catalyst volume requirement while maintaining low outlet ammonia slip, a blend uniformity of < 3% Cv is targeted for the 95% removal SCR design. The methods to achieve high blend uniformity are based on a combination of advanced ammonia injection and mixing techniques developed by B&W. The development of the advanced mixing system not only considers the injection technique but also the equipment arrangement. Numerical 3D modeling is used to evaluate theimpacts of plant arrangement and the injection and mixing techniques on the NH 3 /NO
x molar ratio profile. 234$=:>5-;$"*$2& " $&?@75;@"* The high level of sulfur in typical bituminous coals presents a challenge to minimizing the formation of sulfuric acid (H 2 SO 4 ). A small portion of SO 2 is oxidized to SO 3 in the boiler. Additional SO 2 oxidation occurs across the SCR due to the presenceof vanadium in the catalyst. The amount of oxidation is dependent upon the catalyst formulation, catalyst volume, and operating conditions. The SO 3 combines with H 2 O vapor to form H 2 SO 4 , which can cause corrosion of air heaters, fabric filter

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+#BN)4 A;-DU A;..@ +#BN!2? A;A-S A;ADD 110>='['DZ9 ! -. .R 110>='['-UZ9 ! @ P !"#$%&'H E9 " '50*::*%7:'1563%60"7$5;!"#$%$&'(')*+$%, R components, flue work, and stack. One method of preventing this corrosion is to raise the air heater outlet temperature. This approach is detrimental to the thermal efficiencies of the boiler and power plant. To counteract the amount of SO 3 formed both by the catalyst and within the boiler and permit low air heater outlet temperatures, an alkali reagent is injected upstream of the SCR to selectively react with the SO 3 . The reagent injection will reduce the SO 3 loading to the air heater. As discussed in the next section, considerable H 2 SO 4 removal is also expected in the pulse-jet fabric filter. Final polishing of the H 2 SO 4 takes place in the downstream wet ESP component of the wet FGD absorber tower to meet the combined particulate and sulfuric acid emission target of 0.006 lb/MBtu. 234$=:>5-;$"*$A+)-()1$2>+-@5;@"* In addition, the SCR favorably impacts mercury control in the wet FGD absorber tower. The SCR increases the relative amount of oxidized mercury, thus improving mercury control in the wet FGD. Measurements from several European boilersindicate that SCR catalysts oxidize elemental mercury. Essentially all coal-fired power boilers in Germany are equipped with both SCR systems and limestone-based wet scrubbers. Total mercury capture in these systems exceeds 80% system-wide. 1 The International Energy Agency (IEA) has summarized the experience of several power plants equipped with SCRs and has noted an elemental mercury range from 40 to 60% of the total vapor phase mercury upstream of the SCRs and only 2 to 12% downstream of the SCR. 2 Although the conversion of the form of vaporous mercury across an SCR had been reported as earlyas 1994, the recent EPA sponsored Information Collection Request (ICR) did not examine the impact of SCR on mercury speciation. Of the approximately 75 power plants characterized for mercury behavior in the EPA ICR study, very few included an SCR. In those studies, speciation measurements across the SCR were not conducted. McIlvaine has recently identified 179 planned SCR systems in 22 states. 3 B&W views SCR as an important element in the development of an overall mercury control strategy for the utility industry and B&W has sponsored internal studies on the conversion of mercury across SCRs. B&W has performed tests at flue gas temperatures of 750F and 350F using an SCR catalyst designed for coal applications at B&W’s Research Center and observed substantial mercury oxidation. Figure 9 illustrates the mercury oxidation that was observed at 750F based on the Ontario Hydro analysis methodat the SCR inlet and outlet. On average, the percentage of oxidized mercury in the flue gas increased from 51% at the SCRinlet to 93% at the SCR outlet, facilitating removal by downstream scrubbing.

A'B+-.$A-0,1+ Fabric filters operate by passing flue gas through a woven or felted fabric. The particulate in the flue gas is collected on the fabric surface. The cake which forms on the fabric from thecollected particulate contributes significantly to collection efficiency. There are two types of fabric filters for utility applications: reverse air and pulse-jet. Today, the pulse-jet type is usually chosen over the reverse air type due to a pulse-jet’s smaller size and lower cost. In a pulse-jet fabric filter, cake forms on the outside of the bags. Particulate collected on the outside of the bags is removed by a reverse pulse of high-pressure air.Pulse-jet fabric filters are often capable of 99.9% removal efficiencies and can commonly reduce utility boiler particulate emissions to 0.015 lb/MBtu. A pulse-jet fabric filter is located downstream of the SCR for primary particulate control. The SO 3 removal process initiated with reagent injection upstream of the SCR continues inthe pulse-jet fabric filter. The flyash and residual unreacted reagent absorb SO 3 as the reagent accumulates on the bag surface while protecting the bags from deterioration by acid attack. C(,1<+',1)$:)6'(.1)$:B45+B1+$D5E1+The integrated advanced absorber tower illustrated in Figure 10 combines wet scrubbing and wet electrostatic precipita-

!"#$%&'I 9,*="2*%7'%3'056$?6\'"$6%::'F8I'$"2"+\:2'"2'RUAC;T !"#$%$&'(')*+$%, tor (WESP) technologies for simultaneous SO 2 , sulfuric acid mist, fine particulate and mercury control. An advanced plant can be designed to achieve 99.5% SO 2 removal with high sulfur coals. An SO 2 emissions performance comparison is shown on Figure 11. The wet ESP incorporated in the top of the wet scrubber serves to collect the scrubber gypsum carryover, residual flyash, and sulfuric acid, enabling extremely low particulate emission goals. The advanced plant makes provision for the removal of sulfuric acid mist, which at this time is not reported or widely regulated. As the traditional solid particulate pollutants of flyashand scrubber carryover (gypsum) are controlled to very low levels, the sulfuric acid emissions, which are a product of SO 2 to SO 3 conversion in both the combustion process and in the SCR catalyst, become the dominant part of the total particulate. In such plants, solid particulate is controlled to levels below 0.03 lb/MBtu and SO 2 removal is 90%+. The conventional wet FGD absorber tower on such a plant typically removes 50%+ of the remaining particulate. Sulfuric acid can cause visible whiteplumes trailing from the stacks of these plants after the dissipation of the water vapor. This problem has been noted at numerous high sulfur coal-fired units with conventional wet FGD systems with and without SCR systems. As little as 3-5 ppmv ofsulfuric acid can cause such a plume. In today’s environmentally conscious world, any visible plumes from existing plants do not promote the acceptability of new coal-fired generation. The particulate emission target level of 0.006 lb/MBtu, which includes sulfuric acid mist, is approximately 50% below the most stringent level permitted today, which does not include sulfuric acid mist. As Figure 12 shows, when additionally considering the sulfuric acid, the particulate emissions of an advanced plant could be 90% below a limit for solid particulate only of 0.015 lb/MBtu. B+;$2-)(CC+)$'5-60)"(*7 Conventional wet scrubbers utilize a wet limestone process with in-situ forced oxidation to remove flue gas SO 2 and produce a gypsum by-product according to the following overall reaction:

CaCO 3 + SO 2 + 1/2 O 2 + 2H 2 O → CaSO 4 • 2H 2 O + CO 2

The SO 2 removal process begins as hot flue gas enters the absorber tower and is cooled and saturated by the scrubber slurry. The flue gas then flows upward through the scrubber tray, which uniformly distributes flue gas across the scrubber cross-sectional area. As the gas passes through the layer of slurry on the scrubber tray, the increased gas velocity, caused by the tray perforations, generates a frothing action, promoting intimate gas-liquid contact. The flue gas then passes through the scrubber spray zone, wherescrubber slurry is sprayed countercurrent to the flue gas flow, completing the SO 2 removal process. The SO 2 removal process includes an in-situ forced oxidation system which converts calcium sulfite (CaSO 3 • 1⁄2 H 2 0) formed by the SO 2 removal process to calcium sulfate (CaSO 4 • 2H 2 0) or gypsum. Limestone forced oxidation systems have achieved SO 2 removal efficiencies as high as 96 to 98% in a variety of power plants firing a variety of fuels. The high removal efficiencies are typically ob- !"#$%&')J /725X6"25='"=>"7$5='"#:%6#56'2%J56; !"#$%&')) F9 ! '50*::*%7:'1563%60"7$5'$%01"6*:%7;!"#$%$&'(')*+$%, Ptained through the use of costly additives. It is possible, however, to meet low SO 2 emission targets without additives while minimizing additional capital and operating costs. B+;$DEF$,+-.*"/"01$8795*-+:+*;< The wet scrubber portion of the integrated advanced absorber tower is a logical extension of existing technologies. In order to achieve 99.5% removal efficiency, uniform gas distribution is necessary to maximize gas-slurry contact in the absorber. One cause of poor SO 2 control is the bypass of the flue gas in areas of low slurry concentration. Even very low levels of flue gas bypass can adversely impact overall SO 2 control. Inherent physical limitations in the arrangement of the spray headers in the tower result in non-uniform distribution of the slurry in the spray zone, with low slurry concentrations at the circumference. The B&W-patented variable open tray is used to direct flue gas away from the walls towards the center of the tower where a higher concentration of slurry is present. A wet scrubber contains multiple spray levels. The driving force for mass transfer in the scrubber is the difference in thepartial pressure between the gas and the slurry. Due to the reduction of SO 2 by the initial spray zones, the driving force for mass transfer in the last spray zone is retarded. In order to meet the high SO 2 control target, fresh limestone feed is added to the last spray zone header to provide additional driving force for the SO 2 reactions to occur. B+;$G2H$=*;+0)5;@"* Integration of a wet ESP within the wet scrubber is in itself a technology development. Very fine sulfuric acid mist is formed in the scrubber as the flue gas containing H 2 SO 4 is quenched at the inlet of the absorber tower. The wet scrubber does not effectively remove the resulting droplets due to their very small size. Particulate emissions from a wet scrubber operated on coal-fired flue gas are typically 40% H 2 SO 4 by weight. Another significant portion of the particulate emissions from a wet scrubber can be gypsum carryover due to entrainment of scrubber slurry in the outlet flue gas. The wet ESP functions in a manner that is very similar to themore familiar dry-type electrostatic precipitator, where charging of the particulate in a flue gas stream causes the charged particles to be collected at the wetted wall surface by the strongfield strength near the wall. As in a dry system, there are independent charging and collection systems contained within the collecting device and there are subsystems for power supplies with controls, electrical isolation, purging, and water spray cleaning. Although the collecting mechanisms for the wet and dry type precipitators are similar, the advantages of the wet ESP technology include the following:1. Acid mist and solid particulate collection are not dependent on particulate resistivity.2. The technology can be highly effective on the sub-micron particles and acid mist.3. The collection surface cleaning by water washing prevents the re-entrainment of particulate back into the gas
stream.4. The compact design of the wet ESP allows the integration of design with the wet scrubber. 5. Integration with the wet scrubber provides handling of the wash water and solids from the wet ESP with the scrubber slurry rather than in a separate tank and blowdown system. The acidic water from cleaning the wetESP falls into the alkaline scrubber slurry and is neutralized. =1+./+F$!5(,+50 At least 90% mercury removal can be achieved through thecombined contributions of particulate removal in the fabric filter and oxidation of mercury in the SCR for subsequent capture in the integrated advanced absorber tower by using additivesspecifically selected for mercury removal. Because the additives are inexpensive, used in very small quantities, and there is no separate mercury control device, the cost of mercury removal will be an order of magnitude lower than with activated carbontechnologies. In addition, the mercury in the flyash and gypsum is in an insoluble form at concentrations sufficiently lowto be typically considered non-hazardous and suitable for utilization as a by-product. The proprietary process of adding low-cost reagents to thewet scrubber has been developed by B&W as a method to increase mercury capture in a wet scrubber to 90%. Mercury collection in a wet scrubber cannot be considered successful if the collected mercury can be re-emitted into the environment. The potential for re-emission of mercury from the by-products has been investigated. Tests performed by B&W to date indicate the form of mercury is normally stable and re-release to theenvironment is not expected given the types of disposal practices or by-product uses for spent material from wet scrubber systems. The extremely low concentration of mercury contained in the gypsum is insoluble, thermally stable and not expected toadversely impact its use for wallboard or for disposal in a landfill. In general, the mercury concentration in the scrubber gypsum will be lower than the mercury levels in naturally occurring gypsum mined for commercial use. !"#$%&')( 8%01"6"2*>5'1"62*$?+"25'650%>"+'*7$+?=*7X'"$*='0*:2;-A !"#$%$&'(')*+$%, 

### 7*?0>,1:,%0@3#$3%)0A.49B0/*&10.1&)$ /*):-<,%&$-*) The configuration of the low sulfur western coal-fired plant was depicted in Figure 7.

%" " $!5(,+50 Today’s low NO
x burners, as discussed above, can achieve0.16 lb/MBtu burning PRB fuel with moderate staging. A typical SCR removal efficiency on a PRB unit today is 60% with 2ppm of ammonia slip. As discussed above, the issue with achieving high NO
x removal efficiency is mixing of the flue gas with the ammonia. With a 95% removal SCR, an outlet NO
x level of 0.008 lb/MBtu can be achieved on PRB fuel.

&" ! $!5(,+50 For the PRB coal-fired advanced plant, SO 2 will be controlled by the E-LIDS process or Enhanced Limestone Injection Dry Scrubbing as shown in Figure 13. 4 SO 2 removal of 98% can be achieved with a nominal 0.8% sulfur, 8,000 Btu/lb coal. Limestone (CaCO 3 ) is injected in the upper part of the furnace where it is calcined into lime (CaO) and SO 2 removal begins. Low sulfur PRB coal contains naturally occurring calcium oxide in the ash that supplies much of the reagent needed for SO 2 removal. The amount of limestone that must be injected into the furnace as a supplemental reagent is therefore low. Thismitigates the concern of increasing the ash solids loading going through the boiler’s convection pass and the concern for increased erosion and slagging/fouling. The first evolution of this process was the so-called LIDS process. In this process, limestone is injected into the furnace, is calcined into lime, passes through the spray dry absorber where some of the lime reacts with SO 2 , and the dry powder is then collected in the fabric filter downstream of the spray dryer. It is known from earlier work performed at B&W’s Research Center that limestone that is calcined in the furnace and then subsequently collected in a fabric filter downstream of a spray

!"#$%&')* W74"7$5='H*05:2%75'/7_5$2*%7'V6\'F$6?##*7X'G6%$5::'OWLH/VFQ; dry absorber tends to be of low reactivity. This is because the CaO that is produced in the furnace receives a layer of CaSO 4 on its surface by the reactions which take place in the spray dry absorber. B&W’s earlier work demonstrated that CaO produced in the furnace is best separated from the flue gas, slaked, and then injected into the spray dry absorber. In the E-LIDS process, a nominal 80% removal efficiency particulate collector is installed upstream of the SCR. This has the additional benefit of reducing the ash solids loading going through the SCR catalyst. The material collected is sent to the lime slaking system to produce the fresh slurry feed for the spray dry absorber. The spray dry absorber is illustrated in Figure 14. The dry powder carried with the flue gas from the spray dryabsorber is collected in the fabric filter. A portion of the material collected is recycled to the slaking system, and the remainder is sent to disposal. =1+./+F$!5(,+50 The speciation of mercury from low sulfur coal-fired units tends to favor the elemental form, which is the most difficultform of mercury to remove from the flue gas stream. The benefits of the SCR in converting e lemental mercury into oxidized mercury have been previously discussed. The larger amount of SCR catalyst that is utilized in this advanced plant further enhances the conversion of elemental mercury into oxidized mercury. Another technology that can be utilized to boost mercury removal is to inject small amounts of chloride with the coal fuel. 5 This process of “salting the coal” has been demonstrated in Europe on spray dry absorber FGD systems.

A'B+-.$A-0,1+ A distinct advantage of spray dryer FGD technology versus conventional wet FGD technology (without a wet ESP) is that the spray dry FGD system puts the very efficient dust collector(the fabric filter) as the last unit operation in the flue gas cleaning train before the stack. The spray dryer has also cooled the