Exhibit 1 
Calendar 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 : 1970
COMMITTEE 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 this
legislation 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 for
creating 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 this
authority. 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 whether
such 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 Secretary
should 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 issued
subsequent 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 imposition
of 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---2
level 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 year
before 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.
Pages omitted due to document size. 

Available upon request.
Exhibit 2 
December 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.

42381
CONGRESSIONAL 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.

42382
December 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

42384
December 18, 1970 CONGRESSIONAL RECORD - SENATE

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.

42385
42386 CONGRESSIONAL RECORD - SENATE

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, 1970
December 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

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CONGRESSIONAL 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

42388
December 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

42389
CONGRESSIONAL 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

42390
December 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

42391
CONGRESSIONAL 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

42392
December 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.

42393
42394 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 a
December 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 u and 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 20402
COMMITTEE 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 the
past 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 in
peer-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 revised
ozone 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 that
result 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 been
the 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 stationary
sources 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 that
Houston'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 mandated
if 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 area
that 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 also
read 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 organic
compound (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 reliable
control 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 serve
increasing 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-month
period 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.
Pages omitted due to document size. 

Available upon request.
Exhibit 14 
Source: 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           16,724
44 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             1,833
Sum 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 Burning                   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                 188
Mobile ‐ 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           93,231
AZ 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                   89
                   62                    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          173,619
GA 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                 372
                   90                      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            60,381
KY 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                 190
                   46                    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            74,000
MO 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                      3
                   78                    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            31,241
NJ 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                 106
                   55                    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            31,031
PA 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                      0
                   87                    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            17,884
TX 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                 122
                 115                    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          147,471
WV 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                 8,521
                   11                    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         6,557,033
STFIPS STATE_ABBR EI_SECTOR POLLUTANT_CODE

1 AL Fires ‐ Agricultural Field Burning 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 SO2
2 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 Burning 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 SO2
4 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 Burning 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 SO2
5 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 Burning 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 SO2
6 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 Burning 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 SO2
8 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 Burning 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 SO2
9 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 SO2
10 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 Burning 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 SO2
12 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 Burning 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 SO2
13 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 Burning 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 SO2
15 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 Burning 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 SO2
16 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 Burning 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 SO2
17 IL Solvent ‐ Industrial Surface Coating & Solvent Use SO2

17 IL Waste Disposal SO2

18 IN Bulk Gasoline Terminals SO2

18 IN Fires ‐ Agricultural Field Burning 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 SO2
19 IA Fires ‐ Agricultural Field Burning 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 SO2
19 IA Solvent ‐ Industrial Surface Coating & Solvent Use SO2

19 IA Waste Disposal SO2

20 KS Bulk Gasoline Terminals SO2

20 KS Fires ‐ Agricultural Field Burning 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 SO2
21 KY Fires ‐ Agricultural Field Burning 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 Burning SO2
22 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 Burning SO2

23 ME Fires ‐ Prescribed Fires SO2

23 ME Fires ‐ Wildfires SO2

23 ME Fuel Comb ‐ Comm/Institutional ‐ Biomass SO2
23 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 Burning 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 SO2
24 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 Burning 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 SO2
25 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 Burning 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 SO2
26 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 Burning 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 SO2
27 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 Burning 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 SO2
28 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 Burning 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 SO2
29 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 Burning 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 SO2
30 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 Burning 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 SO2
31 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 Burning 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 SO2
32 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 Burning 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 SO2
33 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 SO2
34 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 Burning 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 SO2
35 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 Burning 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 SO2
36 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 Burning 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 Burning SO2
38 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 Burning 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 SO2
39 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 Burning 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 SO2
40 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 Burning 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 SO2
41 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 Burning 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 SO2
42 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 Burning 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 SO2
44 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 Burning 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 SO2
45 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 Burning 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 SO2
46 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 Burning 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 SO2
47 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 Burning 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 SO2
48 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 Burning 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 SO2
49 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 Burning 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 Burning 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 SO2
51 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 Burning 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 SO2
53 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 Burning 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 SO2
54 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 Burning 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 SO2
55 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 Burning 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 SO2
56 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 SO2
78 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 Burning 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 SO2
POLLUTANT_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 0.13
Sulfur 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 63.98497718
Sulfur 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

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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 35.84627569
Sulfur 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 164.1416016
Sulfur 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 282.236361
Sulfur 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 11436.94937
Sulfur 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

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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 3.832134191
Sulfur 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 2500.335481
Sulfur 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 4554.723975
Sulfur 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 278.021
Sulfur 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 9.932819868
Sulfur 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

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Sulfur Dioxide TON 2011 3323.79805

Sulfur Dioxide TON 2011 0.0432

Sulfur Dioxide TON 2011 179.601904

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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 0.01
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Sulfur Dioxide TON 2011 3052.005078

Sulfur Dioxide TON 2011 0.07

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Sulfur Dioxide TON 2011 202.85815

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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

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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

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Sulfur Dioxide TON 2011 1009.738843

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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

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Sulfur Dioxide TON 2011 238.5813069

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Sulfur Dioxide TON 2011 626.015598

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Sulfur Dioxide TON 2011 44.73587132

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Sulfur Dioxide TON 2011 17770.883

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Sulfur Dioxide TON 2011 175.0049536

Sulfur Dioxide TON 2011 62.31507004

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Sulfur Dioxide TON 2011 100.6105282

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Sulfur Dioxide TON 2011 7.86146375

Sulfur Dioxide TON 2011 258.4776505

Sulfur Dioxide TON 2011 93.98411217

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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

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Sulfur Dioxide TON 2011 0.004
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Sulfur Dioxide TON 2011 39375.355

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Sulfur Dioxide TON 2011 46.96429887

Sulfur Dioxide TON 2011 155.0139075

Sulfur Dioxide TON 2011 22.32031

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Sulfur Dioxide TON 2011 2.5632305

Sulfur Dioxide TON 2011 89.74438423

Sulfur Dioxide TON 2011 1650.31

Sulfur Dioxide TON 2011 3063.537651

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Sulfur Dioxide TON 2011 196.2588864

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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

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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

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Sulfur Dioxide TON 2011 35.527841
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Sulfur Dioxide TON 2011 771.520917

Sulfur Dioxide TON 2011 754.497007

Sulfur Dioxide TON 2011 17.4194245

Sulfur Dioxide TON 2011 1161.894802

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Sulfur Dioxide TON 2011 2.01832922

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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

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Sulfur Dioxide TON 2011 6606.169503

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Sulfur Dioxide TON 2011 132.51916

Sulfur Dioxide TON 2011 208.4983814

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Sulfur Dioxide TON 2011 3.60773168

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Sulfur Dioxide TON 2011 235.6294792

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Sulfur Dioxide TON 2011 158.0474556

Sulfur Dioxide TON 2011 45.90844817

Sulfur Dioxide TON 2011 14.5645058

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Sulfur Dioxide TON 2011 88.06533586

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Sulfur Dioxide TON 2011 21.78939312

Sulfur Dioxide TON 2011 388.5680073

Sulfur Dioxide TON 2011 0.02

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Sulfur Dioxide TON 2011 160.683154

Sulfur Dioxide TON 2011 0.459997

Sulfur Dioxide TON 2011 639.4938111
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Sulfur Dioxide TON 2011 1401.85962

Sulfur Dioxide TON 2011 3.45349949

Sulfur Dioxide TON 2011 0

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Sulfur Dioxide TON 2011 4.21868004

Sulfur Dioxide TON 2011 12.81820797

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Sulfur Dioxide TON 2011 6347.015

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Sulfur Dioxide TON 2011 340.2520423

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Sulfur Dioxide TON 2011 20886.53384

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Sulfur Dioxide TON 2011 25.09583378

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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

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Sulfur Dioxide TON 2011 2.158728878

Sulfur Dioxide TON 2011 23.1588496

Sulfur Dioxide TON 2011 394.5615581

Sulfur Dioxide TON 2011 0.007

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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 22.9608745
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Sulfur Dioxide TON 2011 2675.818343

Sulfur Dioxide TON 2011 10.26280151

Sulfur Dioxide TON 2011 25.1842945

Sulfur Dioxide TON 2011 17.9204002

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Sulfur Dioxide TON 2011 53.85184579

Sulfur Dioxide TON 2011 990.7101431

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Sulfur Dioxide TON 2011 2716.546555

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Sulfur Dioxide TON 2011 0.422655

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Sulfur Dioxide TON 2011 1.8737595

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Sulfur Dioxide TON 2011 243.4864328

Sulfur Dioxide TON 2011 0.1078885

Sulfur Dioxide TON 2011 696.694576

Sulfur Dioxide TON 2011 0.15

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Sulfur Dioxide TON 2011 28.09213093

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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

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Sulfur Dioxide TON 2011 2.54175

Sulfur Dioxide TON 2011 331.20031

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Sulfur Dioxide TON 2011 2293.412176

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Sulfur Dioxide TON 2011 31465.177

Sulfur Dioxide TON 2011 27.634291

Sulfur Dioxide TON 2011 438.9805759

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Sulfur Dioxide TON 2011 22003.1

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Sulfur Dioxide TON 2011 31.672418

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Sulfur Dioxide TON 2011 3105.4123

Sulfur Dioxide TON 2011 44.112391

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Sulfur Dioxide TON 2011 0

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Sulfur Dioxide TON 2011 0.7167033

Sulfur Dioxide TON 2011 674.3202015

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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

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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

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Sulfur Dioxide TON 2011 34.209036

Sulfur Dioxide TON 2011 7.6365019

Sulfur Dioxide TON 2011 0

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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 515.5247
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Sulfur Dioxide TON 2011 53.038

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Sulfur Dioxide TON 2011 18.3483

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Sulfur Dioxide TON 2011 30.6801

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Sulfur Dioxide TON 2011 13501.81

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Sulfur Dioxide TON 2011 210.9627263

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Sulfur Dioxide TON 2011 240.24047

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Sulfur Dioxide TON 2011 0

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Sulfur Dioxide TON 2011 20.8358386

Sulfur Dioxide TON 2011 244.4127028

Sulfur Dioxide TON 2011 1324.599687

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Sulfur Dioxide TON 2011 37.78501121

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Sulfur Dioxide TON 2011 15.02467697

Sulfur Dioxide TON 2011 39.42517874

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Sulfur Dioxide TON 2011 20.23791073

Sulfur Dioxide TON 2011 464.1499092

Sulfur Dioxide TON 2011 7.7

Sulfur Dioxide TON 2011 0.0008

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Sulfur Dioxide TON 2011 5.3005

Sulfur Dioxide TON 2011 937.1420773

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Sulfur Dioxide TON 2011 153.593768

Sulfur Dioxide TON 2011 85.578036

Sulfur Dioxide TON 2011 77.66408586

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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

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Sulfur Dioxide TON 2011 643.4560105

Sulfur Dioxide TON 2011 3495.286177

Sulfur Dioxide TON 2011 94.7

Sulfur Dioxide TON 2011 331.18

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Sulfur Dioxide TON 2011 3288.459191

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Sulfur Dioxide TON 2011 474.451245

Sulfur Dioxide TON 2011 40.09849

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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

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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 309.0456387
Sulfur 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 26.16
Sulfur 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 32.21669987
Sulfur 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 397.9166
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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 4.359093601
Sulfur 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 0.002200006
Sulfur 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 0.03939
Sulfur 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 308.7962097
Sulfur 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 1.079771593
Sulfur 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 1141.270187
Sulfur 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 1902.03391
Sulfur 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 20.15550147
Sulfur 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 128.111
Sulfur 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 11.322
Sulfur 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

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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

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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 144.6285
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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

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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

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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

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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 173.691025
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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 4350.460154
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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

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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

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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

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Sulfur Dioxide TON 2011 2.7

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Sulfur Dioxide TON 2011 0.429367875

Sulfur Dioxide TON 2011 26.70678859
Sulfur 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

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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 59.11691494
Sulfur 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 38.69772822
Sulfur 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

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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

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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 52.37457059
Sulfur 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

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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

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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

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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 20.3512234
Sulfur 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

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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

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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 2.4335
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Sulfur Dioxide TON 2011 1136

Sulfur Dioxide TON 2011 8.9831

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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 0
Sulfur 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 40337.8803
Sulfur 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 21.38106632
Sulfur 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 51.35384723
Sulfur 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 (USEPA, 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 

99th 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 coal-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 Units 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 lbs/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 stacks 

(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 model. 

C. Stack Parameters

Stack parameters (stack height, diameter, temperature and 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)

Velocity

(m/s)

SV03 2446.9 364.707 192.44 8.84 361.48 12.64

SV04 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 99th 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 years of meteorological data (USEPA, 2010b). According to the US 

EPA, the 4th 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 

NAAQS 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 4th highest 

concentrations are summarized in Appendix A and presented in Table 2. The AERMOD 

model has predicted a 4th highest (99th percentile) concentration of 533.0 ug/m3 from the 

plant emissions alone. This concentrations largely exceeds, by more than a factor of 2, 

the NAAQS of 196 ug/m3. With the background of 26.2 ug/m3, the maximum total 4th

highest concentration is 559.2 ug/m3 which is 185% above the 1-hour NAAQS of 196 

ug/m3. The maximum 99th percentile has been predicted to occur at about 3.75 km 

(about 2.3 mi.) south 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 4th 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)

Background

Conc. 

(ug/m3)

Total

Conc. 

(ug/m3)

NAAQS

 (ug/m3)

NAAQS

Exceed

Percent

Over

NAAQS

1-hour SO2

(4th highest)

533.0 26.2 559.2 196 YES 185%
7

 

Figure 2. Area with 4th 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 4th highest concentrations are summarized in 

Appendix B and presented in Table 3. The AERMOD model predicted a 4th highest (99th

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 4th highest concentration is 128.0 ug/m3 which is below the 1-hour 

NAAQS of 196 ug/m3. The maximum 99th percentile has been predicted to occur about 

3.3 km (about 2 mi.) southeast 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

(4th highest)

101.8 26.2 128.0 196 NO ---
9

IV. CONCLUSIONS 

Air 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 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 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 ( 451400.00, 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 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 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, 5231100.00, 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 (USEPA, 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 

99th 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 lbs/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 Parameters

Stack parameters (stack height, diameter, temperature and 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)

Temperature

(K)

Velocity

(m/s)

Stack 1 544.32 231.0336 68.58 4.08 438.71 27.88
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 99th 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 years of meteorological data (USEPA, 2010b). According to the US 

EPA, the 4th 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 

NAAQS 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 4th highest 

concentrations are summarized in Appendix A and presented in Table 2. The AERMOD 

model has predicted a 4th highest (99th percentile) concentration of 349.2 ug/m3 from the 

plant emissions alone. This concentrations largely exceeds the NAAQS of 196 ug/m3. 

With the background of 26.2 ug/m3, the maximum total 4th highest concentration is 

375.4 ug/m3 which is 92% above the 1-hour NAAQS of 196 ug/m3. The maximum 99th

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 4th 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 Lake 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

(4th highest)

349.2 26.2 375.4 196 YES 92%
7

 

Figure 2. Area with 4th 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 4th highest concentrations are summarized in 

Appendix B and presented in Table 3. The AERMOD model predicted a 4th highest (99th

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 4th highest concentration is 174.4 ug/m3 which is below the 1-hour 

NAAQS of 196 ug/m3. The maximum 99th 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)

Background

Conc. 

(ug/m3)

Total

Conc. 

(ug/m3)

NAAQS

 (ug/m3)

NAAQS

Exceed

Percent

Over

NAAQS

1-hour SO2

(4th highest)

148.2 26.2 174.4 196 NO ---
9

IV. CONCLUSIONS 

Air 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 108.81184 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

(USEPA, 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 99th 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. 

The following actual emissions were retrieved from the US EPA Clean Air Market 

database: 

 5,452.23 lbs/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 Parameters

Stack parameters (stack height, diameter, temperature and exit velocity) for both stacks 

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. 

Monitoring 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 RESULTS

In June 2010, US EPA announced a new 1-hour NAAQS which is attained when the 3-

year average of the 99th 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 years of meteorological data (USEPA, 2010b). According to the US 

EPA, the 4th 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 

NAAQS 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 4th highest 

concentrations are summarized in Appendix A and presented in Table 2. The AERMOD 

model has predicted a 4th highest (99th percentile) concentration of 504.1 ug/m3 from the 

plant emissions alone. This concentration largely exceeds, by more than a factor of 2, the 

NAAQS of 196 ug/m3. With the background of 30.0 ug/m3, the maximum total 4th

highest concentration is 534.1 ug/m3 which is 173% above the 1-hour NAAQS of 196 

ug/m3. The maximum 99th percentile has been predicted to occur at about 3.75 km 

(about 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 4th 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 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

(4th highest)

504.1 30.0 534.1 196 YES 173%

 
7

 

Figure 2. Area with 4th 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 4th highest concentrations are summarized in 

Appendix B and presented in Table 3. The AERMOD model predicted a 4th highest (99th

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 4th highest concentration is 221.6 ug/m3 which is 13% above the 1-

hour NAAQS of 196 ug/m3. The maximum 99th 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

(4th highest)

191.6 30.0 221.6 196 YES 13%
9

IV. CONCLUSIONS 

Air 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 504.08783 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 = DISCPOLR
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 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 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 ( 432400.00, 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 
Exhibit 8 
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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 Standard 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 (“SO2”) standard itself and the promulgated

revisions to the SO2 monitoring network. Rather, the motion is addressed solely to

an advisory discussion in the final rule preamble regarding EPA’s anticipated

approach to implementing the revised 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 deadline, 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 requirements 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 jurisdiction 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: 2
1/

 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 preamble statements could be read as final

agency action, the Agency has historically 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 the possibility that the Agency would choose

not to adopt the proposed change. Interested 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 SO2

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 promulgates the designation, which EPA is

required to do by June 20121/

 (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 SO2 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 human 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 associated 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 case 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 SO2

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) (“SO2 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 decision were filed in this Court, and the

Court held that EPA had failed to adequately explain the basis for its conclusion

that short-term SO2 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 primary standard. The new standard is now

in effect, and is being implemented in EPA’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 SO2 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 sufficient 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 deems 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 promulgate designations is independent of

whether a State submits recommendations.

The SO2 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 SO2. 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 SO2

NAAQS, EPA has used a combination of results 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 SO2, but did not promulgate or revise

any requirements regarding modeling.

In the preamble to the proposed SO2 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 standards 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 SO2 standards. In public comments on the proposal, numerous

parties suggested that the proposed monitoring 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, EPA 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 SO2 NAAQS and adopted rules for a smaller monitoring

network than initially proposed. 75 Fed. 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 future actions as designations and SIP

approvals/disapprovals and intends to issue further guidance in the future through a

notice-and-comment process. Id. The preamble also states 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 reconsideration 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 reconsideration 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 stay is warranted are: (1) whether the

movant has demonstrated a substantial likelihood 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 stringently. Aberdeen & Rockfish 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 otherwise not in accordance with law.” 42

U.S.C. § 7607(d)(9)(A). This narrow, deferential standard prohibits a court from

substituting its judgment for that of the agency 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 administers, 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 merits 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 order 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

SO2 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 previously 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 demonstrated 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 SO2 RULE

In its motion, North Dakota asks the Court to stay the SO2 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 promulgated standard or the promulgated

requirements related to monitoring. Nor does it present any claim that it will suffer

irreparable harm from either the revised 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 presented in the Stay Motion is that the

preamble of the final rule allegedly requires the use of air quality modeling for

determining whether an area is in attainment with the revised SO2 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 proceed 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 required 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 preamble (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 SO2 monitors currently in place 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 the 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 believes that its historic approach to SO2

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 lacked 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 SO2 pollution, EPA has

historically relied on air quality modeling (in addition to any required monitoring)

to determine whether an area is violating the SO2 NAAQS. 75 Fed. Reg. at

35,551/2-3, 35,559/2-3; see SO2 Guideline Document (available at

www.epa.gov/ttn/oarpg/t1/memoranda/so2_guide_092109.pdf) at 2-5 (“For SO2

attainment demonstrations, monitoring data alone will generally not be adequate.”)

and at 2-1 (“Attainment determinations for SO2 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 SO2 implementation it represented a departure from the Agency’s prior

practice. In such circumstances, affected parties are surely 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 outgrowth of a proposal is surely, as EPA

says, to refrain from taking the proposed step.”) In fact, the Agency did receive

Case: 10-1252 Document: 1276211 Filed: 11/08/2010 Page: 15
2/

 If EPA were to determine that the monitoring 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 data 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 preamble, 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 SO2 Rule or the statutory deadline to submit designation recommendations is

not stayed. North Dakota first claims that it will be harmed because the SO2 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 SO2 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: 16
2/

(...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 SO2 during permitting,

designations and re-designations in recognition of the fact that a single monitoring

site is generally not adequate to fully characterize ambient concentrations,

including the maximum ground level concentrations, which exist around stationary

SO2 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 SO2 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 nonattainment 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 nonattainment 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, the 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 SO2 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 SO2 standard are

necessarily speculative.

Finally, the actual designations will be made by EPA, an action that EPA

expects to take by June 3, 2012. States 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 claim 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 SO2 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 SO2 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 SO2 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 SO2 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 SO2 NAAQS. Id. at

35,535-36. Thus, implementation of the revised 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 thus fails to address two of the elements

needed for a stay of agency action.

A stay of the SO2 Rule, either in whole or in part, is likely to delay

attainment of the revised standard. A delay of the SO2 Rule as a whole will delay

States’ implementation of the 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 SO2 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 SO2

Rule should be denied.

 Respectfully submitted,

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 11 
I l-45-i995 2,37at.1 FROi.1

,

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A,,A,fl,:r 7 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 03 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 is
1

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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

2

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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 a
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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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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 tetm
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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.6
1

2

3

4

5

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9

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1 1

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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 approved
I

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 and
11-05-1995 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 

PROTECTION 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 the U.S. Environmental Protection Agency ("EPA"), where my 

1 
Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 2

responsibilities include the development, evaluation and application of air quality dispersion 

models and the development of guidance associated with application of such models in 

support of EPA regulations governing the Prevention of Significant Deterioration 

("PSD")_permitting program. I have been involved in the development, evaluation, testing, 

and documentation of the American Meteorological Society EPA Regulatory Model 

("AERMOD") throughout its history. I currently serve as co-chair of the AMS/EP A 

Regulatory Model Improvement Committee (AERMIC) consisting of atmospheric scientists 

and dispersion model experts overseeing the further technical development of the model, and 

as co-chair of the AERMOD Implementation Workgroup consisting of EPA Regional Office 

and State dispersion modelers whose charge has been to indentify and assess potential issues 

with implementation of the AERMOD model as EPA's preferred model under Appendix W 

of Part 51 of the Code ofF ederal Regulations. 

2. The revised primary national ambient air quality standard for oxides of sulfur ("S02 

NAAQS") requires that the three year average ofthe annual 99111 percentile of the daily 

maximum 1-hour average concentrations ofS02 be less than or equal to 75 parts per billion. 

In addition, owners and operators of a new major stationary source or a major source 

undergoing a major modification located 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 from the new or modified source will not cause or contribute to a 

violation ofthe revised S02 NAAQS. Existing air quality models, including AERMOD, are 

readily capable of accurately predicting whether the revised primary S02 NAAQS is attained 

and whether individual sources cause or contribute 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 sequential 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 ambient 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 extensively evaluated based on a total of 17 

field 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 technically 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 studies involved sampling of controlled 

releases of non-reactive tracers, typically SF6, generally over a shorter duration than the 

operational studies, but with more robust sampling to facilitate more detailed diagnosis of 

model performance. Although 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 results 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 excellent correlation in these studies, with the ratio of predicted to 

observed performance approaching 1: 1 in most instances. Thus, in my opinion, the 

performance of the AERMOD model for estimating 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 "probabilistic" standard 

and asserts that this makes modeling more problematic, especially as compared to the 

previous "deterministic" standard. (Coalition p. 5.) The terms "probabilistic" and 

"deterministic" do not have an ordinarily understood meaning in this context, but it appears 

that the assertion is that 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 stated in paragraph 2, the models 

readily generate air quality distributions from which either percentiles (for the revised S02 

NAAQS, the 991h percentile) or exceeding days can be determined. In fact, the percentile 

form of the 1-hour S02 NAAQS is a more "stable" metric than a standard based on the 1

51-

highest or 2"d -highest 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 

regarding 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 the predictive accuracy of AERMOD or other models. 

7. EPA's rules and guidance provide significant flexibility in the 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 specified in Appendix W of 

this 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 therefore allow flexibility, 

subject to appropriate requirements, for alternative modeling techniques to be applied on a 

case-by-case basis subject to approval 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 predicts the actual one-hour ambient concentrations in our 

area 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-predicted ambient concentrations to 

ambient 802 concentrations reported for 2008 at local EPA monitoring stations in the 

vicinity of the ArcelorMittal facilities being modeled. Mr. Long reports that the "AERMOD 

model predicted one-hour concentrations that were higher than the monitored values 90% of 

the time and the predicted values were as much as 373,131 times higher than the actual 

monitored values." Id. Lacking any additional details regarding the model-to-monitor 

comparisons cited by Mr. Long, the response here is necessarily limited to a general 

discussion of issues involved in such comparisons. A number of factors can affect the 

comparison of a modeled concentration with a monitored concentration, including the 

accuracy of the emission rate and other source characteristics input to the model, the 

representativeness of the meteorological data input to the model, and the influence of local 

geographical features and land use characteristics on the transport and dispersion of the 

plume. Another key factor that affects comparisons of modeled vs. monitored 

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 will determine the 

transport direction of the plume. Slight errors in the transport wind direction may account for 

significant differences in modeled vs. monitored concentrations for a specific hour, 

especially for elevated plumes under stable atmospheric conditions where the lateral spread 

of the plume can be very limited for relatively long transport distances, and errors of a few 

degrees in wind direction can be the difference in the plume directly impacting the monitor 

for a particular hour or the plume missing the monitor completely. In such cases, a factor of 

6 
Case: 10-1252 Document: 1288492 Filed: 01/18/2011 Page: 7

3 73,131 difference between modeled and monitored concentrations could easily be 

attributable to error or uncertainty in the wind direction. Note that wind directions reported 

from routine meteorological monitoring stations located at airports, the most common source 

of meteorological data used in air quality modeling applications, are reported to the nearest 

10 degrees. In addition, the comparison may reflect issues related to use of allowable versus 

actual emissions, which is irrelevant for purposes of determining whether the AERMOD 

model 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-hour S02 standard. Responses to these issues are summarized 

below, numbered according to Mr. Paine's declaration, with some responses applying to 

multiple 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 unique statistical form of that NAAQS." 

Paine Decl. 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 daily 1-hour maximum concentration statistic 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 Decl. 11. : "In the case for which a cumulative modeling analysis is required, this same 

procedure must be applied to the combined contributions of the individual source being 

permitted, nearby sources and regional background." 

Response: As stated in paragraph 2 above, all of these metrics are readily obtainable from model 

outputs. Although the existing version of AERMOD does not contain an algorithm from which 

these metrics emerge automatically 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 private sector 

parties, developed post-processing tools to compute the 1-hour S02 design value based on the 

form of the revised S02 NAAQS utilizing model output options available at the time. 

(b) 

Paine Decl. 'II 11. : "Furthermore, EPA in most cases requires a conservatively high regional 

background concentration to be added for all hours modeled, rather than the actual values 

measured during each hour of the modeling simulation." 

Response: EPA issued guidance on a range of issues related to the new 1-hour S02 standard on 

August 23,2010, including a recommendation that the overall highest 1-hour monitored S02 

concentration from a representative monitor could be used to account for the monitored 

background component in a cumulative impact assessment "without further justification." We 

recognize that use of the overall highest 1-hour monitored value may entail a degree of 

conservatism that could prevent a source from demonstrating compliance with NAAQS; 

however, that conservatism forms the basis for allowing the approach to be used without further 

justification. The August 23 memorandum further stated that "Additional refinements to this 

'first tier' approach based on some level of temporal 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 reviewing authority, with 

adequate justification 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 nearby 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 actually 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 aboYe, 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 distributions 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 the other S02 NAAQS averaging periods. This makes the 

assumption of constant peak emissions a critical issue for this new standard." 

Response: The purpose of dispersion modeling in the context of the PSD permitting program is 

to demonstrate that the proposed new or modified emissions will not cause or contribute to 

violations of the standard if the permit is granted. This is inherently a predictive exercise since it 

entails an assessment of proposed future emissions. EPA's guidance for conducting such 

analyses is dictated by and consistent with that purpose. Mr. Paine's statement that 1-hour 

averages are more variable than longer averaging periods again does not relate to potential model 

bias and 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 tendency is even more likely to be a problem in a 

cumulative impact analysis because numerous sources (i.e., the source being permitted and 

potentially thousands of other nearby sources) are all modeled at peak emissions at all times and 

added to a regional background level of S02 ... leading to unrealistic predictions that the 1-hour 

S02 NAAQS will be exceeded." 

Response: As noted, 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 Appendix W guidance for the 1-hour S02 NAAQS cautioned "against the 

literal and uncritical application of very prescriptive procedures for identifying which 

background sources should be included in the modeled 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 Workshop Manual (EPA, 1990), noting [again] that Appendix W 

emphasizes the importance 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 the 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 except in unusual situations." 

(f) 

Paine Decl. 13. : "Moreover, since the nearby sources will be modeled individually (but their 

emissions are already accounted for in the regional monitoring), there will inevitably be doublecounting of the background impacts between the components of the "nearby sources" and the 

"regional background", especially for the common situation of the state requiring a single peak 

regional background value to be used for all modeled hours." 

Response: As noted in several responses above, there are many application-specific factors that 

need to be considered in determining how to conduct an adequate assessment of cumulative 

impacts, accounting for contributions from nearby backgroun-d sources explicitly in the model as 

well as a monitored contribution, while avoiding or minimizing the potential for double-counting 

of modeled and monitored impacts. 

(g) 

Paine Decl. 14. : "The distribution of total peak daily emissions over the three-year period of 

2000-2002 [from major S02 sources in central North Dakota] 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 lower than peak values 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, causing extensive areas of fictitious modeled NAAQS violations." 

Response: The first statement in this comment merely confirms what was indicated 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 impacts 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-hour standard, and we see no reason to expect that 

necessarily to be the case. 

(h) 

Paine Decl., 14. : "Based on my experience with modeling the 1-hour NAAQS for nitrogen 

dioxide - a NAAQS that is .similar in form to the 1-hour S02 NAAQS - this overprediction ratio 

could approach a factor of 10 in areas with numerous sources modeled together." 

Response: Although the form of the 1-hour N02 standard is very similar to the form of the 1-

hour S02 standard, the role ofNOx chemistry in modeling ambient N02 impacts associated with 

NOx emissions makes it difficult to draw comparisons between the two standards in terms of the 

potential for the model to overestimate ambient impacts as compared to monitored 

concentrations. The comment does not indicate what assumptions were made in the N02 

modeling analyses regarding the conversion ofNO emissions to ambient N02. An overly 

conservative assumption 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 impacts. 

(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 showing that the proposed 

source does not contribute significantly to the modeled violation. 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 sources is by itself causing or 

contributing to these predicted (and possibly false) 1-hour 802 NAAQS violations. This "safety 

valve" thus does not yet exist for applicants trying to demonstrate that their proposed 802-

emitting sources will not cause or contribute to any modeled violations of the.l-hour 802 

NAAQS." 

Response: Recognizing the importance of the significant contribution test 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 

"safety valve" that may allow a permit applicant to obtain a permit in cases where the cumulative 

impact assessment shows modeled violations of the 1-hour 802 NAAQ8, if it can be 

demonstrated that the proposed emission increases do not contribute significantly 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 demonstration, the principle of the 

significant contribution test 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 SO2 NAAQS SIP Submissions 

Thank you for the opportunity to comment on USEPA’s guidance for one-hour SO2 NAAQS SIP 

submissions. In the 9/22/2011 public draft of their 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 SO2 NAAQS implementation program elements. 

These elements include: (1) establishing that compliance with the 1-hour SO2

NAAQS is appropriately based on the results of both air quality modeling and 

monitoring; (2) establishing the modeling requirements necessary to determine 

compliance with the 1-hour SO2 NAAQS; (3) establishing the minimum scope of 

analysis required to demonstrate attainment and maintenance of the 1-hour SO2

NAAQS to comply with the SIP requirements in CAA section 110(a)(1); (4) 

establishing a reasonable time period for sources to comply with any new 

emissions limitations states need to establish in the 110(a)(1) SIPs to demonstrate 

attainment and maintenance of the 1-hour SO2 NAAQS; (5) to set an attainment 

date for areas designated as unclassifiable; and (6) establishing the criteria for 

redesignating areas from “unclassifiable” 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 order to ensure compliance with the 1-

hour SO2 NAAQS in a timely manner.2

In summary, I believe that air dispersion modeling should be the preferred method for 

determining one-hour SO2 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 SO2 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 decades to assess ambient air impacts from proposed 

and existing sources, and for SO2 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 10th Conference on Air Quality Modeling docket. 

I specialize in atmospheric dispersion 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 air 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 curriculum vitae is attached. 

My comments on this docket concentrate on the issue of modeling vs. monitoring for verifying 

compliance with the one-hour SO2 NAAQS (attainment determinations). My comments are in 

response to USEPA’s “key questions” presented in their Implementation of the 2010 Primary 1-

Hour SO2 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 SO2 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 collection 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 feasible for monitoring alone to verify compliance with the one-hour 

SO2 NAAQS. A suitable monitoring program would require many monitors and data would 

need to be collected for at least several years. 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 SO2

exposures. 
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The question of modeling or monitoring was discussed in a California Proposition 65 

enforcement declaration by John Vimont, when he was USEPA’s Region IX Regional 

Meteorologist: 

Monitoring data suffers from a number 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 maximum concentration and to adequately 

characterize the concentration field would be very expensive. A number of years 

of data would be necessary to collect enough samples to cover all possible 

meteorological situations in combination 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 ambient measurements for information on 

background concentrations, provided 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 expressed 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 provides excellent characterization of its 

concentrations, it is time consuming, costly, and typically limited to a few 

receptor locations and snapshots in time. 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. 
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and cumulative source contributions, and characterization of concentration over 

greater spatial extents.5

In addition, it is not always possible to place monitors where maximum project or cumulative 

impacts may be occurring. I have first-hand experience 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 District, 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 several monitors were to be sited for each project. 

Using air dispersion modeling, we determined where the peak project impacts were likely to 

occur and then attempted to place the air quality monitoring systems at those locations. In 

virtually every case, it was not possible to place the 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 SO2

NAAQS attainment determinations. There are not nearly enough SO2 monitors in place to 

determine attainment status of the existing major SO2 emission sources. Moreover, very few, if 

any, of these monitors are “well-placed” for measuring the maximum ambient air impacts from 

these existing SO2 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 SO2 ambient air concentrations and resulting attainment status. 

The lack of existing major source-specific SO2 monitoring is partly due to a failure of State air 

agencies requiring pre-and post-construction air quality monitoring. In the past few years I have 

reviewed and commented on major SO2 emission source PSD permit applications in Texas, 

Louisiana, Oklahoma, Nevada, Kentucky, North Carolina, South Carolina, Missouri, Kansas, 

South Dakota, Illinois, and Arkansas. With the exception of Nevada, the State air agencies have 

not required pre- or post-construction air quality monitoring, even though the PSD significant 

monitoring concentrations were exceeded. This is the norm for these 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 surrounding these facilities. It is self-serving if a 

facility that could (should) have been collecting ambient air quality data now argues that SO2

NAAQS attainment determinations must be based on monitoring, not modeling. 

5

 California Office of Environmental Health Hazard Assessment, Air Toxics Hot Spots Program Risk Assessment 

Guidelines: The Air Toxics Hot Spots 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 

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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 meteorological data rather than rely on National 

Weather Service (NWS) airport data. On every occasion, my comments were disregarded, even 

though the PSD significant monitoring concentrations were exceeded for the proposed project. 

The State’s response and comment denial followed 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 application analyses. Although it’s water under the 

bridge, site-specific data could have been collected during these application processes without 

causing time delays to permit issuance. 

USEPA asked the question “In what situations should meteorological data collection also be 

required?” I believe the time has passed when these data could or should have been collected. 

Of course it would be ideal to have additional site-specific meteorological data for modeling 

major SO2 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 system, installation, and afterwards 

post-processing of the data for modeling. Starting a site-specific meteorological data collection 

effort from scratch contributes to an unreasonable delay of the measures that may be needed to 

protect ambient air from any excessive SO2 exposures. 

While I feel that site-specific meteorological data are preferable to NWS airport data, USEPA’s 

AERMINUTE program allows significant improvements to the NWS data in that calms and 

variable wind hours that were previously unusable by AERMOD can now be recaptured. In lieu 

of requiring new site-specific data collection efforts, modeling of SO2 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 meteorological data already exist, then I 

believe they should be used in preference to NWS airport data. 

Based on my experience, site-specific meteorological data tends to result in higher modeled 

impacts than NWS airport data, even when the 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 sets 
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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 twice 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 resulted in significantly higher impacts 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 Modeling 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 emissions 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 SO2 modeling analyses used for nonattainment 

SIP modeling should use actual emissions, and not the 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 General 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) 
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If actual emissions are used for nonattainment SIP modeling, a condition must be added to the 

facility’s permit requiring that emissions must not be greater than the level used in the modeling 

analysis. In other words, a facility that wants to use actual emissions in their modeling analysis 

must agree to an enforceable permit condition limiting 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 exit velocity and temperature. I suggest that 

USEPA should develop a method for calculating stack 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 latest calendar year (or perhaps the maximum for 

the past three years). Maximum actual emissions 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 HOUREMIS in AERMOD) coupled with 

contemporaneous meteorological data, this analysis does not ensure that the one-hour SO2

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 very careful in considering emission 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 differences, 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 concentration, not simply emission rate. 

c. Are there situations where modeling is preferable to monitoring? If so, then what are these 

situations? Should EPA require modeling 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 SO2 NAAQS. I cannot envision a 

feasible air monitoring network that would verify compliance for a major SO2 emission source – 

too many monitors would be needed and the delay in attainment demonstration and resulting 

controls would be unacceptably long. 
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I think it is beneficial to consider 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 previously existed. AB 2588 also required at least 

1,000 facilities state-wide to prepare health risk assessments, which are based on ambient air 

concentrations of the air toxics in question. In all instances, these facilities used air modeling as 

the basis for determining ambient air concentrations. 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 SO2 NAAQS SIP determinations. For example, in Santa Barbara 

County, where I was the Air Toxics Program Coordinator, we prepared air dispersion modeling 

analyses for up to 50 facilities per year. Many of these facilities were very complicated and 

involved numerous toxic air pollutants. Plus, we calculated excess cancer risk and noncarcinogenic health effects from inhalation and all other pathways of exposure. In other words, I 

think State air agencies should be able to handle the effort required in modeling the major SO2

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 conditions that cannot be handled by air monitoring. 

On the other hand, there are likely many situations where AERMOD underpredicts air 

concentrations compared to monitoring data. 

USEPA should rely on the detailed AERMOD evaluations that were performed during the model 

development phase. I agree with Roger Brode’s 10th Modeling Conference presentation, where 

he concluded: “AERMOD model performance has been extensively evaluated and shown to 

provide generally unbiased estimates of 1-hr SO2 concentrations across a wide range of 

scenarios.”8

8

 Roger Brode, USEPA/OAQPS, AERMOD Evaluations Under the 1-hour NO2 and SO2 NAAQS, 10th 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) 
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I believe that the concerns about AERMOD over-predicting air concentrations 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 SO2 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 reiterate 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 replacing 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 developing 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-downwashed, highly buoyant power 

plant stacks (the shortest stack in the 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-predicts power plant impacts, 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 NO2 & SO2 and PM2.5, 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. 
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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 SO2 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 regarding AERMOD’s ability to model low wind 

speed conditions seem to neglect the data 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 hillsides. This concern has already been addressed by 

USEPA in their response to the New Jersey Department of Environmental Protection (NJDEP) 

section 126 petition for SO2 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 complex wind fields surrounding the Portland facility.13 

USEPA also recognizes that “the performance of the AERMOD model for estimating impacts 

associated with tall stacks in complex terrain settings has been extensively evaluated and 

documented in peer-review journals... and has consistently been shown to perform better than 

competing models.”14

Air monitoring of SO2 is not a feasible alternative to modeling for steep hillsides and other 

complex terrain conditions. Proper air quality monitor 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 meteorological 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 associated 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. 
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d. Are there situations where monitoring is preferable to modeling? If so, then what are these 

situations? Should EPA require monitoring 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 SO2 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 NO2, PM2.5, and SO2 NAAQS and PSD increment 

permit application analyses are performed with 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 determined, both existing sources and newly permitted 

sources should be assessed using the same methods. From the Guideline on Air Quality Models: 

The Guideline is used by EPA, States, and industry 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 SO2 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. USEPA must not exchange their existing guideline model for an 

ambient air monitoring program which will never be able to verify compliance with the one-hour 

SO2 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 SO2

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) 
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approach for one-hour S02 NAAQS SIP submissions should be heavily weighted towards

modeling.

Thank you for the opportunity to submit these comments on USEPA 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: camille.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 part of a team of experts.

Education

 M.S., Atmospheric Science, University of California, Davis, 1980.

 B.S., Atmospheric Science, University 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 

modeling analyses requiring the use of on-site or site-specific meteorological data. 

These runs were made with the USEPA ISC, OCD, MESOPUFF, INPUFF, CALPUFF, 

ISC-PRIME, AERMOD, COMPLEX-I, MPTER, and other air dispersion models.

 I prepared 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, including 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 ponds;

Volume sources, including fugitive emissions 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, 

degreasing 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 oil and gas exploration, storage, processing, and transport facilities;

Fugitive dust emissions from roads, wind erosion, and farming activities;

Radionuclide emissions from actual and potential releases.

 I have extensive experience in modeling 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 extensive 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 

SBAPCD protocol on air quality modeling for OCD, OCDCPM, MPTER, COMPLEX-I/II 

and ISC.

 I provided detailed review and comments on the development of the Minerals 

Management Service OCD model. I developed the technical requirements for and 
Camille Marie Sears, Page - 2

supervised the development of the OCDCPM model, a hybrid of the OCD, COMPLEX-I 

and MPTER models.

 I prepared the "Modeling Exposures of Hazardous Materials Released During 

Transportation Incidents" report for the California 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 chemicals 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 am 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 Risk Assessment

 I have prepared more than 300 health risk assessments 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 were prepared for 

Proposition 65 compliance verification in a litigation support setting.

 I reviewed approximately 300 other health risk assessments of toxic air pollution 

sources in California. The regulatory programs in this review include AB 2588, 

Proposition 65, the California Environmental Quality Act, and other exposure analysis 

activities. My clients include the California Attorney General's Office, the Los Angeles 

County District Attorney's Office, the SBAPCD, the South Coast Air Quality 

Management District, numerous environmental and community groups, and several 

plaintiff law firms.

 I am experienced in assessing public health risk from continuous, intermittent, and 

accidental releases of toxic emissions. I am experienced in generating graphical 

presentations of risk results, and characterizing risks from carcinogenic and acute and 

chronic noncarcinogenic pollutants.

 I am experienced in communicating adverse health risks discovered through the 

Proposition 65 and AB 2588 processes. I have presented risk assessment results in 

many public settings -- to industry, media, and the affected public.

 For four years, I was the Air Toxics Program Coordinator for the SBAPCD. My duties 

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; management 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 pollutants. A few 

examples include: diesel PM10 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 clothes.

Litigation Support

 I have prepared numerous analyses in support of litigation, both in Federal and State 

Courts. I am experienced in preparing F.R.C.P. Rule 26(a)(2) expert reports and 

providing deposition and trial testimony (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 experienced in preparing declarations (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, questions for depositions, deposition reviews, various briefs 

and motions, and general consulting.

 Recent examples of my work include:

DTSC v. Interstate Non-Ferrous; United States District Court, Eastern District of 

California (2002).

In this case I performed 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 quantify 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 chemicals: 

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 Division (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. Defendants 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 for 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 Regulations 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 reviewed scores of other assessments for verifying compliance with 

Proposition 65. My proposition 65 litigation clients include the California 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 Fund, 

Environmental Law Foundation, and People United for a Better Oakland. 

Geographic Information Systems

 ArcGIS: I am experienced in preparing presentation and testimony maps using 

ArcView versions 3 through 9.3. I developed methods 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 regions. This provides a 

detailed view (down to the house level) of where air concentrations and health 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 prepared numerous presentation maps including exposure 

isopleths, streets and highways, and sensitive receptors, labels. I developed 

procedures for importing Surfer isopleths in AutoCAD DXF format as a layer into 

MapInfo.

 Atlas GIS: I am experienced in preparing presentation maps with both the Windows 

and DOS versions of Atlas GIS. In addition to preparing maps, I use Atlas GIS to 

aggregate census data (at the block group level) within exposure isopleths to 

determine the number of individuals living and working within exposure zones. I am 

also experienced in geocoding large numbers of addresses and performing statistical 

analyses 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 litigation support.

 I developed a Fortran program to modify AutoCAD DXF files, including batch-mode 

coordinate shifting for aligning overlays to different base maps.

Ozone and Long-Range Transport

 I developed emission reduction strategies and identified appropriate offset sources to 

mitigate project emissions liability. For VOC offsets, I developed 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/nonalkane reactive organic compound method.

 I provided technical support to the Joint Interagency Modeling Study and South Central 

Coast Cooperative Aerometric Monitoring Program. With the SBAPCD, I provided 

technical comments on analyses performed with the EKMA, AIRSHED, and PARIS 

models. I was responsible for developing emissions inventory for input into regional air 

quality planning models.

 I was the project manager for the Santa Barbara County Air Quality Attainment Plan 

Environmental Impact Report (EIR). My duties 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 Fortran 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 in 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 from various emission sources, 

including power plants.

Emission Rate Calculations

 I developed methods to estimate and verify source emission rates using air pollution

measurements collected downwind of the emitting facility, 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 experienced in developing emission inventories of hundreds of criteria and toxic 

air pollutant sources. I developed procedures and programs for quantifying emissions 

from many air emission sources, including: landfills, diesel exhaust sources, 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 hundreds 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 

results, mass-balance equations, and other emission estimating techniques.

Software Development

 I am skilled in computer operation and programming, with an emphasis on Fortran 95.

 I am experienced with numerous 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-Extended; Lahey F77L-EM32 DOSExtended; Microsoft PowerStation 32-bit DOS-Extended; and Microsoft 16-bit.

 I configured and operated an Intel I-860 based workstation for the SBAPCD toxics 

program. I created control files and recoded programs 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-meter 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 SBAPCD, I designed the ACE2588 model - the first public domain multisource, multi-pathway, multi-pollutant risk assessment model. I co-developed the 

structure of the ACE2588 input and output files, supervised the coding of the model, 

tested the model for quality assurance, and for over 10 years I provided technical 

support to about 200 users of the model. I was responsible 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 developed and coded the ISC2ACE and ACE2 programs for distribution by CAPCOA. 

These programs were 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 requirements compared to 

ISCST2/ACE2588. I also developed ISC3ACE/ACE3 to incorporate the revised 

ISCST3 dispersion model requirements.

 I developed 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 customized ACE2588 and developed a mapping system 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 streamline preparing AB 2588 risk assessments; I developed

a risk assessment mapping system based on MapInfo for Windows which linked the 

MapInfo mapping package to the "HotSpot" system.

 I developed software for electronic submittal 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 submitted 
Camille 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 developed and coded Fortran programs for AB 2588 risk prioritization; both batch and 

interactive versions of the program were created. These programs were used by 

several air pollution control districts in California.

Air Quality and Meteorological Monitoring

 I was responsible for the design, 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 developed the technical requirements for the Santa Barbara County Air 

Quality/Meteorological Monitoring Protocol. I developed and implemented the protocol 

for siting pre- and post-construction air quality and meteorological PSD monitoring 

systems. I determined 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 fluctuations), sigma-phi (standard deviation of vertical wind 

direction fluctuations), sigma-v (standard deviation of horizontal wind speed 

fluctuations), and sigma-w (standard deviation of vertical wind speed fluctuations). Air 

pollutants measured included PM10, SO2, NO, NOx, NO2, CO, O3, and H2S.

 I was responsible for data acquisition and quality assurance for an offshore 

meteorological monitoring station. Parameters measured included ambient 

temperature (and delta-T), wind speed, wind direction, and sigma-theta.

 In coordination with consultants performing air monitoring for verifying compliance with 

Proposition 65 and other regulatory programs, I wrote software to convert raw 

meteorological data to hourly-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 spray 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, Training, and Instruction

 For 10 years, I provided ACE2588 risk assessment model support for CAPCOA. My 

tasks included: updating the ACE2588 risk assessment model Fortran code to 

increase user efficiency and to maintain consistency with the CAPCOA Risk 

Assessment Guidelines; modifying the 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 Guidelines; 

developing the distribution and installation package for ACE2588 and associated 

programs; providing technical support for all users of ACE2588.

 I instructed approximately 20 University Professors through the National Science 

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 instructor of the Air Pollution and Toxic Chemicals course for the University 

of California, Santa Barbara, Extension certificate program in Hazardous Materials 

Management. Topics covered in this course include: detailed review of criteria and 
Camille 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 shortterm releases of air pollutants; acid deposition, precipitation and fog; 

indoor/occupational 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-day 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 deposition 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 for Santa Barbara County high-exposure radon areas.

 I calculated BTEX air concentrations and health risks inside homes from leaking 

underground fuel tanks and resultant contaminated 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 reconstruction 

(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 quantity and 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 calculated 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

Publications

 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 regulatory decision-making.

 I prepared 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).

Employment History

 Self-Employed Air Quality Consultant 1992 to 2012

 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

 People of the State of California v. McGhan Medical, Inc.

Deposition: Two dates: June - July 1990

 People of the State of California v. Santa Maria Chili

Deposition: 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

Deposition: 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

Deposition: July 11, 2000

 Marlene Hook v. Lockheed Martin Corporation

Deposition: September 18, 2000

Deposition: September 19, 2000

 Tressa Haddad v. Texaco

Deposition: March 9, 2001
Camille 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, District 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 Cleaners

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 District 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 Alvarez, 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 & UMETCO 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, Denver 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 Service, 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, 2008
Camille 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 Permit 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)] Permit 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)] Permit HAP-48 and Plantwide 

Applicability Permit PAL41.

State Office of Administrative Hearings Docket No. 582-09-2005;

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 District 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

Trial: February 10, 2011

 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, 2010
11-05-1995 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,

)

)

)

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)

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}

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)

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 is
11-05-1995 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 all
11-05-19952:38AM 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

27
11-05-1995 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 term
11-05-1995 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 SF6 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 approved
11-05-19952d0AM 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 and
11-05-1995 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 statement 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 applicable statutory or regulatory provisions, including provisions under 

40 CFR 52.21. This document is intended for use 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 “applicant”), under a development agreement with 

the Navajo Nation’s Diné Power 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 Navajo Nation adjacent to Navajo Nation coal 

reserves at a mine operated by BHP Billiton. Sithe submitted an application for a 

Prevention of Significant Deterioration (“PSD”) permit to allow construction and 

operation of the coal-fired, nominal 1500 MW Facility on the Navajo Indian Reservation. 

The project is generally called the Desert Rock Energy Facility (“DREF”). The proposed 

580 acre site is located approximately 25 miles southwest 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 (NO2), sulfur dioxide (SO2), carbon monoxide 

(CO), particulate matter less than 10 microns in aerodynamic diameter (PM10), lead, and 

ozone (regulated as volatile organic compounds (VOC) and oxides of nitrogen (NOx)). 

For purposes of this PSD permit and analysis, EPA will refer to NOx, which is 

functionally equivalent to NO2, for both pollutants. The Facility’s surrounding area is 

classified as Class II. The nearest Class I area is the Mesa Verde National Park, which is 

located approximately 75 kilometers (km) north of the site. The Grand Canyon National 

Park is located approximately 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 generation capacity of 1,500 MW (gross). Each 

of the two units will be 750 MW (gross) and 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 wastes 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 finalized, will allow Sithe to construct two supercritical 

pulverized coal fired boilers designed 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 supercritical cycle, each 

boiler will produce steam at 3,626 psi and 1,112F at a rate of 4,636,000 lb/hour. The 

boilers will feed the high-pressure steam through a steam turbine generator to produce 

electricity and then to a direct contact jet condenser. 

The proposed PSD permit’s BACT air pollution controls for Sithe’s supercritical 

pulverized coal-fired boilers consist of the following: 

Low-NOx burners and selective catalytic reduction (SCR) to reduce NOx 

emissions; 

Low sulfur coal, hydrated lime injection before a fabric filter, and wet limestone 

flue gas desulfurisation to reduce SO2 emissions; 

Hydrated lime injection before a fabric filter, and wet limestone flue gas 

desulfurisation to reduce acid gas emissions 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 finalized, will also allow Sithe to construct and operate 

three auxiliary steam generators to provide auxiliary steam during startup and shutdown 

of the main steam generator. Sithe will use auxiliary steam generators that are firetube/smoke-tube type (package boilers, shell type). 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% sulfur) 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 maximum annual fuel use in the 

three boilers of 142,560 MMBTU/year 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 operated 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 preparation 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 bunkers 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 prevent emissions and spontaneous 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 operate dust suppression, 

enclosures, or baghouses to reduce emissions from material transfer points and the coal 

bunkers. 

Cooling Towers 

The PSD permit, if finalized, will require Sithe to install and operate a direct contact jet 

condenser with a Heller dry cooling 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 cooling 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 condensate pumps. The major part of the flow is returned to 

the cooling tower for recooling. The cooling duty is performed by the cooling deltas, 

divided into parallel sectors, where cooling air flow is induced by a natural draft dry 

cooling tower. Sithe has applied to use, and the PSD permit is proposing to require, the 

Heller-type hybrid cooling tower to minimize water consumption. When the ambient 

temperature is below 80F, the cooling tower will operate like a natural draft dry cooling 

tower. When the temperature exceeds 80F, 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 particulate matter or other 

pollutants. 

Ash Handling 

Sithe will reduce emissions of fly ash by collecting 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 finalized, 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 generated 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 vendors’ data, Sithe’s design criteria, EPA emission factors 

from AP-42, and established emission calculation procedures. The estimated maximum 

annual potential emissions include emissions from the two supercritical pulverized coal 

boilers, the three auxiliary boilers, the emergency generators, the fire pumps, and 

materials handling. The estimated maximum annual potential emissions assume a 95% 

annual capacity factor at full load and include emissions from an anticipated 60 startups 

per year, with an average of 30 startups per 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 normal continuous operation. EPA has determined that Sithe’s 

95% capacity factor assumption and estimate of 60 startups per year is conservative, 

which means these assumptions are likely to lead to estimating higher potential emissions 

than the Facility will actually emit. 

VV. APPLICABILITY OF THE PREVENTION OF SIGNIFICANT .

DETERIORATION (PSD) REGULATIONS 

The PSD regulations define a "major stationary source" as any source type belonging to a 

list of 28 source categories which emits or has the "potential to emit" 100 tons per year 

(tpy) or more of any pollutant regulated under the Clean Air Act, 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 heat input. It is, therefore, one of the 28 

source categories specified in EPA regulations and the 100 tpy threshold applies for 

purposes of PSD applicability. The proposed Facility 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 emissions 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 thresholds 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 

SO2 3,315 3.61 0.068 0.012 n/a 3,319 

PM 553 1.02 0.083 0.015 16.1 570 

PM10 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 

H2SO4 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 particulate matter as measured by EPA Method 5. 

3. 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. EPA is treating PM10 as a surrogate for PM2.5. 

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 (NAAQS) have not been exceeded (attainment 

areas), or areas where the status of the area is uncertain (unclassified). The proposed 

Facility will be located in an area in the New Mexico Air Quality 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 

SO2 40 3,315 

TSP/PM 25 570 

PM10 15 1,120 

Ozone (VOC) 40 166 

Lead 0.6 11.1 

Fluorides 3 13.3 

Sulfuric Acid Mist (H2SO4) 7 221 

The estimated maximum annual potential emissions profile in Table 2 shows that the 

Facility is a major stationary source because its potential to emit exceeds 100 tpy for 

NOx, CO, SO2, PM, PM10 and VOC. Table 2 also shows that the Facility’s potential to 

emit lead, fluorides and sulfuric acid mist exceeds the significance thresholds. Therefore, 

all of these pollutants are subject to PSD review and must satisfy the following 

requirements: 

1. Application of Best Available 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 technology" means an emission limitation based 

on the maximum degree of reduction of each pollutant subject to regulation under 

the Clean Air Act emitted from or which results from any major emitting facility. 

6 
The permitting authority, on a case-by-case basis, taking into account energy, 

environmental, and economic impacts and other costs, makes a BACT 

determination through application of processes and available methods, systems, 

and techniques, including fuel cleaning 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 standard established pursuant to section 7411 

(NSPS) or 7412 (NESHAP) of the Clean Air Act. 

For attainment pollutants being regulated in a PSD permit, EPA evaluates emissions 

control requirements through a “top-down” BACT determination, which is described in 

EPA’s New Source Review Workshop Manual, Draft October 1990 (“PSD Manual”), 

page B-6. The top-down approach to the BACT review process involves identifying all 

demonstrated and potentially applicable control technology alternatives. PSD Manual, 

page B.11. EPA would typically review information in EPA’s BACT/LAER (Lowest 

Achievable Emission Rate) Clearinghouse, federal/state/local new source review permits, 

technical journals and other such sources. PSD Manual, page B.11. After broadly 

identifying potential control technology alternatives, EPA can eliminate 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 the top control option in the listing for selection 

as BACT, or provides clear justification why 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) control 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 technology 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 regulated pollutant under evaluation; 

2. Eliminate technically infeasible technology options; 

3. Rank remaining control technologies 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, PM10, SO2, 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. The rate of formation of thermal NOx is 

a function of residence time and free oxygen, and is exponential with peak flame 

temperature. Fuel NOx is generated when nitrogen 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 reburn, or flue gas treatment including 

selective non-catalytic reduction (SNCR) or selective catalytic reduction (SCR). . 

In accordance with the top-down BACT process, Sithe’s PSD application first 

identified all of the potentially available control technologies for pulverized coal 

fired boilers , eliminated technically infeasible options, and then ranked the 

remaining control technologies, beginning with the technologies that will result in 

the most stringent control and the lowest emissions. EPA agrees that Sithe 

considered all of the potentially available 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 - 0.3 

Staged Combustion and LowNOx Burners 30 - 50 0.15 - 0.5 

Gas Reburn 40 - 60 0.15 - 0.3 

8 
Selective Catalytic Reduction 

SCR is a process that involves post-combustion removal of NOx from flue gas 

with a catalytic reactor. In the SCR process, 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 catalyst. The function of the catalyst is to 

effectively lower the activation energy of the NOx decomposition reaction. 

Technical factors related to this technology include the catalyst reactor design, 

optimum operating temperature, sulfur content of the fuel, 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 number of subsystems. These include the SCR 

reactor and flues, ammonia injection system 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 treated flue gas will then flow through the 

catalyst bed and exit to the air heater. 

The SCR system for a pulverized coal boiler 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 hoists 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 disadvantages in terms of operating temperature, 

reducing agent/NOx ratio, and optimum oxygen concentration. A disadvantage 

common to base metal catalysts is the narrow range of temperatures in which the 

reactions will proceed. Platinum group catalysts 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 vanadium-titanium catalyst system has been 

shown to be in the range of 550 to 800F, which is significantly higher than for 

9 
platinum catalyst systems. However, the vanadium-titanium catalyst systems 

begin to break down when continuously operating at temperatures above this 

range. Consequently, operating 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 concern for systems that employ SCR. Catalyst 

systems promote partial oxidation of sulfur dioxide to sulfur trioxide (SO3), which 

combines with water to form sulfuric acid. At typical SCR operating 

temperatures, SO3 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 PM10 entering the 

particulate collector. Fouling may eventually lead to decreased NOx reduction 

performance, increased system pressure drop over time and decreased heat 

transfer efficiencies. 

The SCR process is subject to catalyst 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 temperatures or masking of the catalyst due to 

entrainment of particulate from ambient air or internal contaminants. Chemical 

poisoning is caused by the irreversible reaction of the catalyst with a contaminant 

in the gas stream and is a permanent condition. 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 NOx reduction rates, SCR vendors suggest a higher ammonia 

injection rate than stoichiometrically required, which conversely results in 

ammonia slip. Thus an emissions trade-off between NOx and ammonia may occur 

in high NOx reduction applications. 

The potential environmental impacts associated with the use of SCR include: 

• Unreacted ammonia would be emitted to the atmosphere (ammonia slip). 

• Ammonium salts would increase loading to the particulate collection stage 

as PM10 (and PM2.5). 

• Safety issues and Risk Management Planning may be required relative to 

the transportation, handling, and storage of ammonia (aqueous or 

anhydrous). 

10 
Selective Non-Catalytic Reduction 

SNCR has been applied to a number of different types of combustion sources, 

including petroleum heaters, utility and industrial boilers fired 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 NOx in the flue gas and either injected NH3 

or urea to produce gaseous nitrogen and water vapor. SNCR systems do not 

employ a catalyst; the NOx reduction reactions are driven by the thermal 

decomposition of ammonia and the subsequent reduction of NOx. Consequently, 

the SNCR process operates at higher temperatures than the SCR process. 

Critical to the successful reduction of NOx with SNCR is the temperature of the 

flue gas at the point where the reagent is injected. For the ammonia injection 

process, the necessary temperature range is 1,700 - 1,900F; for the urea injection 

process the nominal temperature range is 1,600 - 2,100F. Also critical to 

effective application of these processes are gas mixing, residence time at 

temperature, and ammonia slip. 

Theoretically, one mole of ammonia (or one-half 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 amount of excess reagent and essentially 

achieving low NOx emissions at the expense of emissions of unreacted reagent, 

referred to as ammonia slip. These emissions represent an adverse environmental 

impact and can lead to formation of ammonium salts and may contribute to 

regional haze as a precursor to PM2.5. Thus, for a given boiler configuration, there 

is a limit on the degree of NOx reduction which can be achieved with SNCR 

while maintaining acceptable levels of ammonia slip. 

Pulverized coal-fired units have a limited furnace temperature window and poor 

lateral mixing, conditions which render SNCR less effective in these units. SNCR 

has been applied to PC boilers more often to achieve 30 – 50% reductions in 

response to Reasonably Available Control Technology (RACT) 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. 

11 
Staged Combustion 

A number of techniques have been employed to reduce the formation of NOx by 

reducing peak flame temperature and/or starving the hottest parts of the flame for 

oxygen. By staging the combustion process, a longer, cooler flame results, which 

forms less NOx. Staged combustion techniques include Low-NOx burners, flue 

gas recirculation, overfire air, burners out of service, and combinations of these. 

A collateral impact of staged combustion is an increase in emissions of products 

of incomplete combustion including 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 substantial 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 control technologies and 

therefore it is not considered further in this analysis. 

Proposed Pulverized Coal-Fired Boiler BACT for NOx 

Sithe has proposed to construct and operate the Facility 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 contained a top-down BACT analysis which EPA 

has independently evaluated. 

EPA’s independent analysis of available control technologies 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 plants, review of issued permits or 

applications for permits, discussions with EPA and State permitting staff, trade 

journals, information from industry conferences and vendor guarantees. 

EPA’s review of all available data and technologies demonstrates that Sithe’s 

proposed choice of LNB and SCR is the most stringent combination of control 

technologies available for pulverized 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 average, is lower than other NOx emissions 

12 
rates that have been proposed for or achieved by pulverized coal fired boilers 

recently. 

The National Coal Workgroup database shows that the NOx BACT emissions 

limits in recent PSD permits for pulverized coal fired boilers using LNB and SCR 

range from 0.07 lbs/MMBTU to 0.10 lbs/MMBTU, often as a 30-day average. 

Similarly, the information contained in the DOE/NETL’s database of information 

for pulverized coal fired boilers shows that 0.06 lbs/MMBTU is below the lowest 

NOx BACT emission limits for recently permitted facilities. Further examples of 

NOx BACT emissions limits for recently permitted pulverized coal boilers using 

LNB and SCR, or solely LNB for the Sand 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 Hearings and Appeals on challenges to the 

NOx BACT decisions in PSD permitting actions for pulverized coal fired boilers. 

The Nevada Department of Environmental 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 petitioner challenged whether 0.067 lbs/MMBTU 

(24 hour average) was BACT because Sithe had applied for a lower NOx BACT 

13 
limit (0.06 lbs/MMBTU as a 24 hour average) 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 determination. 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 appeal. 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 limit of 0.06 lbs/MMBTU as a 30 day 

average and 0.07 lbs/MMBTU as an annual 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 Wisconsin 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 emissions limits for NOx are 0.067 

lbs/MMBTU as a 24 hour average for Newmont 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/MMBTU 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 emission 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 year 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 concluded that BACT for NOx for these boilers 

is 0.10 lb/MMBTU using Low-NOx burners. 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, the 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 materials, EPA concurs and proposes the use of ignition 

timing retard with turbocharging and aftercooling with an emission rate of 6.5 

g/hp-hr to be BACT for NOx for the emergency generators. 

B. Sulfur Dioxide (SO2) 

1. Pulverized Coal-Fired Boilers 

Emissions of sulfur dioxide are generated in fossil fuel-fired sources from the 

oxidation of sulfur present in the fuel. Approximately 98% of sulfur in solid fuels 

is emitted upon combustion as gaseous sulfur oxides. Uncontrolled emissions of 

SO2 are thus affected by fuel sulfur content alone, and not by the firing 

mechanism, boiler size, or operation. Many coal-fired boilers limit emissions of 

SO2 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 SO2 emissions by approximately 70% to 90%. 

The selection of coal type and sulfur content is therefore one of the aspects that 

must be considered when making a determination of SO2 BACT and needs to be 

considered in conjunction with add-on control alternatives when performing the 

top-down analysis. 

Generally, there are two types of add-on control applicable to a coal-fired boiler: 

in-situ combustion control (sorbent injection) and post-combustion control (flue 

15 
gas desulfurisation). In-situ control is used 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 comparable to post-combustion SO2 

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 bicarbonate or magnesium oxide. 

A comparative ranking of available SO2 control technologies (see Table 4) must 

take into consideration multiple variables including coal sulfur content, % 

removal and the resulting emission rate (lb/MMBTU) in addition to collateral 

impacts on other pollutants, energy impacts, and other environmental impacts. 

Table 4 

SO2 Control Technologies for Pulverized Coal Boilers 

Pulverized Coal Control 

Technologies 

Control Efficiency Range 

(% Removal) 

Typical Emission Rate 

(lb/MMBTU) 

Wet Flue Gas Desulfurisation 90 - 98 Depends on coal sulfur content 

(lower with western coal) 

Limestone Injection 25 - 35 Depends on coal sulfur content 

(lower with western coal) 

Spray Dryer Absorber 70 - 92 Depends 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 gas 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) reacts 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 calcium 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 thickeners, 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 hydroxide in water. The slurry of calcium 

hydroxide and lime is fed to the spray tower. 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 upstream of the particulate collection system, 

typically fabric filters. The flue gas passes through a spray dryer 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 SO2 in the flue gas to form insoluble 

calcium salts. The flue gas is cooled 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 the particulate control device, 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 SO2 control must also take 

into account the level of uncontrolled SO2 to be handled, which is highly 

dependent on the sulfur content of the coal to be burned. Higher removal 

efficiencies tend to be more practical when there is a high concentration of SO2 in 

the flue gas, and vice versa. This is reflected in a comparison of the resulting 

emission rate in units of lb of SO2 per MMBTU of fuel burned (or lb of SO2 per 

kW produced). For example, a proposed project with a BACT limit of 0.16 

lb/MMBTU using an 80% removal control system 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 SO2 to BACT levels in combination 

with add-on control. 

Proposed Pulverized Coal-Fired Boiler BACT for SO2 

Sithe has proposed to construct 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 SO2 BACT emission rate of 0.06 lb/MMBTU as a 24-

hour average during operation. 

EPA’s independent analysis of available control technologies 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 plants as well as the other sources 

discussed above for NOx. 

EPA’s review of all available data and technologies demonstrates that the choice 

of low sulfur coal and wet limestone desulfurisation is the most stringent 

combination of control technologies available 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 SO2 emission rates that have been proposed for 

pulverized coal fired boilers recently. 

The PSD Permit that Nevada Department of Environmental 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 

SO2 BACT emission limit of 0.065 to 0.09 lbs/MMBTU. 

EPA is also persuaded that 0.06 lbs/MMBTU SO2 is BACT for DREF based on 

the information in the National Coal Workgroup database. The database shows 

that SO2 emission limits for recent PSD permits 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 SO2 

BACT emission limit for recently permitted facilities. 

Examples of Recently Permitted/Proposed Coal-Fired Power Plants 

Facility Size 

(MW) 

Emission 

Controls 

SO2 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 scrubber 0.09 (30-day avg.) 

0.12 (24-hr avg.) 

Longleaf 1200 Dry scrubber 0.12 (30-day avg.) 

18 
Sand Sage 660 Dry scrubber 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 capacities 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. SO2 

emissions will be controlled by only burning low sulfur distillate oil with a 

maximum sulfur content of 0.05%. No add-on SO2 controls have ever been 

applied to similar sources. The burning of low sulfur fuels such as low sulfur 

distillate oil is the only available SO2 control option and is the top level of control. 

Therefore, the applicant is proposing to only burn low sulfur distillate oil (0.05% 

sulfur maximum) and to restrict total 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 SO2 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 SO2 

controls have ever been applied to similar sources. The burning of low sulfur fuels 

such as low sulfur distillate oil is the only available SO2 control option and 

represents the top level of control. Therefore, the applicant proposes to only burn 

low sulfur distillate oil (0.05% sulfur maximum) and to restrict operation to 100 

hours per year each as BACT for the proposed emergency diesel engines. EPA 

concurs and proposes BACT for SO2 for the emergency diesel engines to be 

burning low sulfur distillate oil and limiting 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 the 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 compromise 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 turbulence. All pulverized coal-fired boilers 

identified utilize front-end methods such as good combustion control wherein CO 

formation is suppressed within the boiler. All listings in EPA’s 

RACT/BACT/LAER Clearinghouse for pulverized coal-fired boilers utilize 

combustion control techniques for CO (see Table 5). While gas-fired combustion 

turbines have been widely equipped with oxidation catalyst control technology, this 

technology has not been applied to coal-fired boilers. In addition to oxidizing CO, 

an oxidation catalyst would oxidize SO2 to produce SO3, which would exacerbate 

sulfuric acid mist emissions. The SO2 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 maintain the proper conditions to ensure 

complete combustion through one or more of the following operation design 

features: providing sufficient excess air, staged combustion to complete burn out 

of products of incomplete combustion, sufficient residence time, and good mixing. 

All of these factors also tend to reduce emissions of VOC as well as CO. 

However, this process must be optimized with the efforts to reduce NOx 

emissions, which may increase when steps to lower CO are taken. 

Catalytic Oxidation 

Catalytic oxidation is the technology that 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 considered transferable technology for application to the 

proposed pulverized coal-fired boilers. In this alternative, a catalyst would be 

situated in the flue gas stream to lower the activation energy required to convert 

products of incomplete combustion (CO and VOC) in the presence of oxygen (O2) 

to carbon dioxide and water. The catalyst permits combination of the reactant 

species at lower gas temperatures and residence times than would 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 coal. Catalysts promote oxidation of SO2 to SO3 as 

well as CO to CO2. The amount of SO2 conversion is a function of temperature 

and catalyst design. Under optimum conditions, formation of SO3 can be 

minimized to 5% of inlet SO2. This level of conversion would result in a large 

collateral increase in H2SO4 emissions which aside from the increased ambient air 

impacts, could result in unacceptable amounts 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, variable trace element concentration in the flue 

gas and the SO2 loading before air pollution control systems, the vendor stated that 

they could not provide a catalyst system for coal-fired applications. Consequently, 

the applicant has determined that oxidation catalyst systems are considered 

technically infeasible for application 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 measure 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 also minimizing NOx, therefore represents 

BACT for the proposed boilers. BACT for CO from the proposed Facility is 0.10 

lb/MMBTU. This level is consistent with or lower than 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 average of 550 hours/year per boiler at full load. A BACT limit 

for CO emissions of 0.036 lb/MMBTU and the annual total fuel restriction of 

142,560 MMBTU/year are proposed for these boilers, which reflect the lowest 

emission limits listed in EPA’s RACT/BACT/LAER Clearinghouse. After 

reviewing the submitted materials, 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 hours/year each. The applicant proposes a 

BACT emission limit for these diesel engines 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 hours 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-fired boilers identified utilize front-end 

methods such as combustion control wherein 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 oxidation catalyst control 

technology, this technology is not easily applied to coal-fired boilers. 

A review of EPA's RACT/BACT/LAER Clearinghouse, and the applicant's review 

of recent permit decisions, indicates levels of VOC control which may be achieved 

for pulverized coal-fired boilers. 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 maintain the proper conditions to ensure 

complete combustion through one or more of the following operation design 

features: providing sufficient excess air, staged combustion to complete burn out 

of products of incomplete combustion, sufficient residence time, and good mixing. 

All of these factors also have the by-product of reducing the 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 other add-on controls are not applicable to coal-fired 

boilers as discussed in the 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 measure to control VOC emissions from coal-fired boilers 

is good combustion. Combustion control, and the resulting optimized emission 

rate to minimize formation of VOC while also minimizing NOx, 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 small distillate oil-fired auxiliary 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/year, which is equivalent to an average 

of 550 hours/year per boiler at full load. 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 proposes 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 hours/year each. The applicant proposes a 

BACT emission limit for these diesel engines 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 particulate matter emitted from coal-fired boilers 

are a function of firing configuration, boiler operation, coal properties and 

emission controls. Particulate 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 gases. Both particulate matter (PM), and 

particulate matter smaller than 10 micrometer diameter (PM10) require the 

application of BACT under the Federal PSD program. Particulate matter is total 

filterable particulate matter as determined by EPA Method 5 or 17. PM10 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/BACT/LAER Clearinghouse indicates several levels of 

particulate control that may be achieved for pulverized boilers. Emission levels 

and control technologies have been identified 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 matter that are less than or equal to 0.02 

lb/MMBTU. All but one of these listings report that a fabric filter is utilized (the 

AES Puerto Rico facility is the only exception). The control of PM using fabric 

filtration is clearly demonstrated for coal-fired boilers. Wet control techniques 

(venturi or other high-energy scrubbers), on the other hand, do not represent a 

recently applied or demonstrated control technique for coal-fired boilers and do not 

offer more stringent levels of control of particulate matter 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 determined No applications for recent 

coal-fired boilers 

Note: Emission levels represent steady-state values at base load, for front-half (filterable) 

only. 

Fabric Filter 

Fabric filters are widely used for particulate 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 through a tightly woven or felted fabric, 

causing PM in the flue gas to be collected on the fabric by sieving and other 

mechanisms. Fabric filters may be in the form of sheets, cartridges, or bags, with a 

number of the individual fabric 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 usually 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. Groups 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 fabric filters include: 

1) High collection efficiency for a broad range of particle sizes; 

25 
2) Flexibility in design (various methods of cleaning methods and filter 

media); 

3) Wide range of volumetric capacities; 

4) Reasonable pressure drops and power requirements; and 

5) Handles a wide range of solid materials. 

Some disadvantages of fabric 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 filter cloth if the waste gases are at a 

temperature close to their dew point. 

Proposed Pulverized Coal-fired Boiler BACT for Particulate Matter 

Fabric filters and electrostatic precipitators (ESP’s) represent technically feasible 

options for the control of particulate matter from coal-fired boilers. Wet control 

techniques (scrubbers), on the other hand, do not represent a demonstrated control 

technique and do not offer more stringent levels of control of particulate matter 

than fabric filters or ESP’s. ESP’s are generally less effective at controlling fine 

particulate, and are generally 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 filters, 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 PM10 (including condensable PM10) emissions to 0.02 

lb/MMBTU. Very little data are available on condensable PM10 emissions from 

coal-fired boilers burn western coal, and for that reason Sithe has proposed a 

condensable PM10 limit of 0.02 lb/MMBTU as BACT for total PM10, 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 lowest emission level for a 

new coal fired boiler (Wygen 2 in Wyoming) listed in EPA’s RACT/BACT/LAER 

Clearinghouse or the other reference materials discussed in the BACT analysis for 

NOx and SO2. 

EPA’s independent review of the materials supports Sithe’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 addition, EPA is proposing BACT for total 

26 
PM10 emissions to be a fabric filter with an emission limit of 0.02 lb/MMBTU. 

However, EPA does not believe that a three year trial period of the 0.02 

lb/MMBTU emission limit is warranted. EPA believes that the feasibility of the 

0.02 lbMMBtu emission limit can be determined during the first 18 months of 

operation and will propose an 18 month trial period commencing upon initial 

startup. 

2. Auxiliary Boilers 

The project includes three small distillate oil-fired auxiliary 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/year, which is equivalent to an average 

of 550 hours/year per boiler at full load. The applicant is proposing BACT limits 

for PM and PM10 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 Clearinghouse. 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 PM10, BACT includes an emission limit of 0.024 lb/MMBTU 

based on adding the condensable PM10 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 limitation of 142,560 MMBTU/year. For PM10, 

EPA is proposing BACT to be an emission limit of 0.024 lb/MMBTU, the use of 

0.05% sulfur distillate oil, and an annual 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 PM10, respectively, based on 

EPA emission factors in AP-42. After reviewing the submitted materials, EPA 

concurs and proposes BACT for PM and PM10 from the emergency diesel engines 

to be emission limits of 0.19 g/hp-hr and 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 will be controlled by dust 

suppression systems, enclosures and/or fabric filters. For example, conveyors will 

be constructed of enclosed design in order 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 enclosed design and will be evacuated (when 

operating) through fabric filter units, sometimes referred to as “bin vent filters”. 

Enclosed design of materials handling system 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 will be subject to NSPS Subpart OOO. A review of 

the EPA RACT/BACT/LAER Clearinghouse gives a range of control efficiencies 

from baghouses. Although the most recent permits for coal fired power plants, 

Bull Mountain and Roundup Power Projects, determined that BACT was 0.01 

gr/dscf for all sources, the Mid America permit identified 0.005 gr/dscf for 

baghouses associated with coal sources and 0.01 gr/dscf for other material handling 

activities. The applicant proposes to also specify these filterable PM/PM10 

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 chemical crusting agents to prevent both 

weathering of the coal and fugitive dust emissions. When coal is added to or 

reclaimed from the inactive pile, which is expected to be very infrequently, the coal 

will be wetted and/or treated with chemical agents to minimize any emissions of 

fugitive dust. The Applicant believes that these operational measures, and those of 

the NSPS for coal handling operations (Subpart Y), represent BACT for inactive 

storage and associated coal handling operations. After reviewing the submitted 

materials, EPA concurs and proposes as BACT for PM/PM10 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 materials. 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 chemical agents to minimize fugitive dust 

emissions. 

F. Sulfuric Acid Mist (H2SO4) 

1. Pulverized Coal-Fired Boilers 

Emissions of sulfuric acid mist are generated in fossil fuel-fired sources from the 

oxidation of sulfur present in the fuel. The amounts of sulfur or SO2 that are 

oxidized to sulfuric acid mist may be affected by trace metal catalysis. 

In addition to applying BACT, the applicant recognizes that sulfuric acid mist is a 

28 
precursor to the formation of regional haze, 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 additional stage of acid gas removal using hydrated lime (a 

proprietary technology) has been included upstream of the fabric filter to remove 

sulfuric acid mist before it enters the wet scrubber. The application of this 

technology will result in emission levels 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 injection 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 acid mist from industrial boilers or emergency 

diesel generators. BACT for sulfuric acid 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 auxiliary 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 generated 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 hydrated lime before the fabric filter, with 

additional removal expected from the wet limestone 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% control) as BACT. This 

emission rate is consistent with or lower than all recent BACT decisions. 

No appreciable HF is emitted from distillate oil-fired industrial auxiliary boilers or 

emergency diesel engines, and the use of low fluorine bearing fuel (very low sulfur 

distillate oil) represents BACT for HF for these emission sources. After reviewing the 

submitted materials, EPA concurs and proposes BACT for emissions 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 generated 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 PM10 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 determined to represent BACT for PM10. 

For distillate oil-fired industrial 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 evaluation 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 

SO2 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 

PM10 0.02, 6-hour average Baghouse 

H2SO4 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 the emission limits in the permit for H2SO4, 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 

SO2 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 

PM10 0.024, 3-hour average Low sulfur distillate fuel oil and 

good combustion practices 

H2SO4 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 particulate 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 retard, turbo-charging and aftercooling 

SO2 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/PM10 0.24 g/hp-hr Low sulfur distillate fuel oil and good 

combustion 

H2SO4 0.006 g/hp-hr Low sulfur distillate fuel (0.05%) 

31 
Table 11 

Summary of Proposed BACT Emission Limits for the Materials Handling System 

Pollutant Emission Limit 

(lb/MMBTU) 

Control Technology 

PM/PM10 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 determination process for each unit at the 

facility that emits the regulated pollutant (see Section VI above). However, EPA is 

comparing the emissions from Circulating Fluidized Bed Technology (CFB) separately 

because an applicant must choose either a pulverized coal boiler or CFB for all pollutants. 

Therefore, EPA in this permitting evaluation is comparing the two technologies separately. 

Table 12 

Range of Emissions Control from Coal Combustion Technologies 

Coal Technology Efficiency (%) % NOx Controlled % SO2 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 air 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 maintained at less than 2,000 degrees F, while contact with 

fluidized solids can increase combustion reaction rate and heat 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 inherent pollutant emissions. In a CFB, NOx 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 

SO2 within the CFB boiler process itself. Efficiencies for standard atmospheric circulating 

fluidized bed combustion units range from 36 to 38%. 

The most recent atmospheric CFB plants 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 SO2 limits) 

 JEA Northside (an earlier generation Foster Wheeler unit) 

The majority of support systems for fluidized bed boilers are very similar to pulverized coal 

operations; however, CFB technology has inherent advantages in flexibility to utilize low 

grade fuels and, as a result, may have lower fuel costs relative to other coal technologies 

because they are able to burn less expensive fuels. CFBs have long been considered “Clean 

Coal” technology due to the inherent limitation of emissions of SO2 and NOx from within 

the process itself, without the need for add-on pollution control equipment. Disadvantages 

include limited unit size (about 300 MW maximum), somewhat more complex equipment 

and operations, and the generation 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 from 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 and emission rates, a CFB plant would 

generate 11% more emissions than Desert Rock. 

• On an annual ton/yr basis, all emissions from a CFB plant 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. 

SO2 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. 

SO2 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 

PM10 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. 

PM10 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 H2SO4 

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 that was recently proposed by EPA Region 8 for Deseret Power that 

contains emission rates slightly lower than the above for SO2 and NOx. 

After reviewing the submitted materials, as well as our own coal-fired 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 Combined 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 would be redefining the source. In preparing the draft permit, 

EPA did consider whether IGCC is a BACT option, but concluded it is not because it 

would fundamentally change the basic design of the proposed source. 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 pollutants emitted in significant 

quantities, the analysis must consider whether the proposed Facility will cause a violation 

of (1) the National Ambient Air Quality Standards (NAAQS), and (2) the applicable PSD 

increments. A discussion of the general approach, air quality model selection, significant 

impact levels, PSD increment consumption, and the project’s compliance with ambient air 

quality standards is presented below. 

EPA’s conclusion is that Sithe 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 any Air Quality Related 

Value (AQRV) at any Class I area. 

35 
In summary, the proposed Facility’s impact will be well below the significant impact level 

for NO2 and CO. The proposed Facility’s impact will exceed the significant impact level 

for SO2 and PM10, thereby triggering a cumulative impact analysis. The cumulative impact 

analysis Sithe submitted, however, demonstrated that the proposed Facility will not cause 

or contribute to an exceedance of the SO2 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 deposition at any Class I area, or on the acidneutralizing capacity of sensitive lakes. Sithe provided substantial additional modeling in 

response to requests from the Federal 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 Background Ambient Air Quality Data 

The ambient impact analysis required Sithe to provide representative meteorological data as 

an input into the air quality model. Recently, EPA updated its Guidance to allow applicants 

to use three years of prognostic 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 input to the chosen air quality model, CALPUFF 

(see below). Sithe originally used data from RUC2 ("Rapid Update Cycle"), a National 

Weather Service model that incorporates data from many sources, including regular 

weather stations, NEXRAD radar stations, and satellites. After consultation with and 

concurrence by the National Park Service, Sithe updated the modeling using data from the 

MM5 meteorological model at a higher spatial resolution. CALMET is a preprocessor that 

prepares the meteorological fields for input to CALPUFF by incorporating local weather 

observations, and also local terrain effects on the wind flow. Various CALMET input 

options for accomplishing this, such as radius of influence of observation stations, were 

provided by the National Park Service (NPS). These approaches meet EPA Guidance 

requirements for meteorological data. 

Sithe was also required to provide representative background air quality data. For the 

NAAQS compliance analysis, Sithe added background concentration to modeled 

concentrations, and compared the total to the NAAQS. To determine the background 

concentration, Sithe used the closest monitors to the site of the proposed Facility which are 

22-24 km away in Farmington, New Mexico for SO2, NOx, PM10, and O3 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 would expect closer the 

DREF site because Farmington and Rio Rancho have much greater residential and 

commercial activity than the project site on the Navajo Nation. We have 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 tends to mix throughout the basin over several days. The 

background data recorded by the Farmington and 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 Federal 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 AERMOD would be inadequate. 

In CALPUFF, the individual puffs composing a plume may follow independent paths, 

which is a much more realistic simulation than the single straight line plume assumed in 

ISCST3 and AERMOD. As shown by Sithe, the area surrounding the site for the proposed 

Facility is subject to complex winds. The varying 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 exacerbated by the complex terrain in the area and its 

non-uniform slopes. Multi-day stagnation 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 meteorological inputs discussed above, an air quality model needs inputs 

characterizing emissions sources. Sithe modeled the proposed Facility’s emissions at their 

proposed maximum allowable emission 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 SO2 NAAQS, Sithe modeled the main stack at 50% 

higher than the proposed PSD permit’s allowable 24-hour average maximum, i.e. Sithe 

modeled the SO2 emissions at 0.09 lb/MMBtu although the proposed PSD permit will only 

allow the Facility to emit SO2 at 0.06 lbs/MMBtu). Sithe chose to model the proposed 

Facility’s emissions conservatively to account for short-term variability that might occur 

during any 24-hour period. Sithe also used inputs for the proposed Facility’s stack height, 

temperature, and exit velocity, 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 screening, which is an estimate of impacts under 

different load conditions, with the SCREEN3 model, 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 cause 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 determined 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 analyses, but Sithe also included additional sets 

of receptors that are progressively more closely 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 impaction can occur. Other sets of receptors are prescribed by the 

FLMs for each Class I area; all 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, Wilderness Areas, and National Monuments; while these are not 

Class I areas, they are of special concern to the FLMs. 

The proposed Facility’s modeled impacts are shown in Table 15 and 16 below. The PSD 

regulations do not allow a project to make a "significant" contribution 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 NO2 and CO, which demonstrates the proposed Facility’s compliance with the NAAQS 

and PSD increment for those pollutants. 

The proposed Facility’s modeled impacts from PM10 and SO2 exceeded the SIL, triggering 

the requirement for a cumulative analysis for those two pollutants. Sithe’s cumulative 

analysis demonstrated that the proposed Facility 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 the surrounding 15 Class I areas. The FLMs requested 

Sithe to perform additional modeling. Sithe performed several rounds of additional 

modeling to evaluate if the Facility's emissions would have an adverse impact on Class I 

area visibility. On April 25, 2006, the United States Forest Service (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 the 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 with 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 mechanisms other than the PSD permit to memorialize Sithe's 

commitment to perform the mitigation strategy. Accordingly, EPA has concluded it is 

appropriate to propose approval of the PSD permit while Sithe and the FLMs continue to 

discuss memorializing Sithe's commitment to perform the agreed upon mitigation strategy. 

38 
Table 15 

Maximum Predicted Air Quality Impacts from the Proposed Project 

Pollutant Averaging 

Period 

Modeled 

Impact 

SIL 

(ug/m3

) 

PSD Class II 

Increment 

(ug/m3

) 

NAAQS 

(ug/m3

) 

NOx Annual 0.56 1 25 100 

SO2 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 SO2 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 SO2 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 predicted values above the proposed Class I Significant Impact 

Levels. 

C. NAAQS Compliance 

As discussed above in general, to show NAAQS compliance, Sithe performed cumulative 

analyses for PM10 and SO2 by including the emissions of nearby sources. Sithe used data 

on source allowable emissions from State emission inventories where available, and Sithe 

supplemented this data by using EPA's National 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 SO2, 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 suggested by NPS and is based on past modeling 

work and experience showing that the impact of such small and distant sources to be 

negligible. A 40 tpy source would be omitted only if it were 50 km or more away, which 

illustrates the conservativeness 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 concentration, are less than half the NAAQS in every 

case. Sithe has thus demonstrated compliance with all the NAAQS. 

40 
Table 17 

Predicted Cumulative Air Quality Impacts on the NAAQS 

Pollutant Averaging 

Period 

Modeled 

Impact 

(ug/m3

) 

Background 

Concentrations 

(ug/m3) 

Total Impact 

(ug/m3) 

NAAQS 

(ug/m3) 

SO2 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 generally above, is more 

complicated than the analysis for the NAAQS, because not all emissions "count" toward, or 

consume, increment. EPA’s regulations provide that the only emissions changes that 

consume increment are those emissions that have occurred since the "baseline date". The 

reason for this provision is that 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 State 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 procedure assumed that all of the emissions at major 

sources, with two exceptions discussed below, consumed increment, regardless of when the 

emissions began to occur relative to the baseline date. PSD increment consumption is 

based on changes in actual emissions (not maximum allowable emissions), of which 

records are kept. Continuous Emissions Monitors (CEMs) in the stack of each major source 

are required under various regulatory programs, such as the Acid Rain Program. EPA, 

therefore, provided Sithe with nearby sources' maximum actual emission rates that were 

representative of their 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 omitted or undercounted in 

State databases. That potential problem is not present for this permitting action because the 

area surrounding the site of the proposed Facility is sparsely populated, and has relatively 

little commercial or industrial activity 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 general knowledge of the areas, minor source 

permitting programs, and previous studies of the status of the increment, State regulators 

concluded that minor source growth 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 PSD increment analysis is that the "baseline 

date" may be different for different areas, because 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 increment depending on which Class 

I area was being evaluated; in the worst case this would require different combinations of 

emissions estimates and different 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 consume 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 Facility are the Four Corners Power Plant (FCPP), 

and the San Juan Generating Station (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 available. Although some of the emissions reductions from FCPP 

and SJGS were required by EPA to remedy SO2 NAAQS violations monitored in the 1970s, 

the actual reductions were far greater than required to cure the 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 SO2 NAAQS. Sithe then modeled only 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 concentration, are well below the Class I and 

Class II increments where they are respectively applicable. Sithe has 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/m3

) 

Increment 

(ug/m3) 

SO2 3-hour 67.3 512 

24-hour 10.75 91 

PM10 24-hour 8.47 30 

Annual 1.82 17 

Table 19 

Predicted Cumulative Impacts on the Class I SO2 Increments 

Class I Area 

SO2 impacts, μg/m3 

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 numbers indicate increment expansion, due to 

emission reductions at FCPP and SJGS. 

VIII. ADDITIONAL IMPACT ANALYSIS 

In addition to assessing the ambient air quality impacts expected from a proposed new 

source or modification, the PSD regulations require that certain other impacts be 

considered. These include impacts on visibility, soils and vegetation, and growth. 

43 
A. Visibility 

Sithe modeled the proposed Facility’s potential impact on visibility and other AQRVs, 

which are defined by the FLM for each Class I area. As mentioned above, Sithe conducted 

several rounds of additional modeling, after extensive consultations 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 assessing impacts on Class I areas. Sithe followed the FLM’s 

recommended procedures for using CALPUFF along with the post-processing program 

CALPOST, for assessing acid deposition 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 hectare). 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 visibility. For visibility, see page 38 for a discussion of the 

USFS letter dated April 25, 2006. 

At the request of the USFS, Sithe also performed 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 methodology, which is based on the 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 particulate matter are multiplied by the light extinction 

capacity of each, then the daily averages of the resulting total extinction increase above 

natural background is compared to the 5% level. 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 procedure 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 naturally 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% level, so that its visibility impacts are 

acceptable. 

Sithe also performed a supplemental analysis to assess the 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 visibility at Class I areas using the same metric that is used under 

the Regional Haze Rulemaking (extinction improvement in the 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 analysis 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 additional mitigation that will more than offset any potential 

contribution to visibility impairment. 

EPA has concluded that construction and operation of the proposed Facility is consistent 

with the requirements for visibility improvement under the Regional Haze Rule. 

B. Soils and Vegetation 

The PSD regulations require analysis 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 screening levels are equivalent to or less stringent than the 

NAAQS and/or PSD increments, therefore satisfaction of NAAQS and PSD increments 

assures that sensitive vegetation will not be negatively affected. 

C. Growth 

Growth impacts due to the proposed 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 emissions associated with the workforce will be primarily the 

result of motor vehicle exhaust emissions associated with the commute of workers to and 

from the plant site. 

IX ENDANGERED SPECIES 

Pursuant to Section 7 of the Endangered Species 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 species or result in the destruction or adverse 

modification of such species’ designated critical habitat. EPA has determined 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 endangered 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 fulfilled through a lead agency pursuant to 50 CFR § 402.07. Since 

the land, electrical transmission lines, and access roads required for the proposed project 

are located on the Navajo Indian Reservation and lands under the jurisdiction of the Bureau 

of Indian Affairs (BIA), the BIA will act as the lead Federal agency for purposes of 

fulfilling the responsibilities under Section 7 of the ESA for the project. 

EPA may proceed with the final permit issuance upon conclusion of consultation, review of 

FWS’s Biological Opinion, and our determination that issuance of the permit will be 

consistent with the ESA requirements. 

X. NATIONAL HISTORIC PRESERVATION ACT (NHPA) 

Section 106 of the NHPA requires responsible Federal officials to take into account the 

effects of their decisions on historic properties eligible for the National Register of Historic 

Places, and consult with appropriate State or Tribal Historic Preservation Officers and other 

interested parties to avoid, reduce, or mitigate any identified adverse effects. The applicant 

has retained a consultant to conduct cultural resource studies to support Section 106 

consultations. On 17 February 2004, the consultant contacted the Navajo Nation Tribal 

Historic Preservation Officer (THPO) to provide initial notification about the proposed 

Facility, inform him of the purpose of the project, and briefly describe the elements of the 

project. As a follow up to the initial 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 parties who should be involved in the consultations, 

and developing an appropriate strategy to inventory and evaluate cultural resources that 

could be affected. 

XI. TITLE IV (ACID RAIN PERMIT) 

The applicant must apply for and obtain an acid rain permit. The applicant will apply for 

this permit prior to facility operation. 

XII. ENVIRONMENTAL JUSTICE 

On February 11, 1994, Executive Order 12898, “Federal Actions to Address Environmental 

Justice in Minority Populations and Low-Income 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 environmental laws, regulations, and policies. EPA 

has this goal for all communities and persons across this Nation. In addition, EPA 

published guidance entitled, “Final Guidance For Incorporating Environmental Justice 

Concerns in EPA's NEPA Compliance 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 Report 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 disproportionately 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 listed 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 translations of fact sheets in Dine. The applicant has also 

prepared a data presentation to better characterize 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 analyses contained in the 

permit application, and our independent evaluation of the information contained in our 

Administrative Record, it is our determination that the proposed Facility will employ 

BACT and will not cause or contribute to a violation 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 herein. 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

NOx, SO2, sulfuric acid mist, PM2.5, mercury, and particulate is

here. There is also the potential need to lower CO2 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 CO2. Emission control technologies for

eastern bituminous high sulfur fuels that can achieve 0.016 lb/

MBtu NOx, 0.04 lb/MBtu SO2, and 0.006 lb/MBtu particulate

(including acid mist) are examined. For PRB coal, emission levels down to 0.008 lb/MBtu NOx, 0.04 lb/MBtu SO2, and 0.006

lb/MBtu particulate with a high level of mercury capture can be

achieved. This level of NOx 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 integrated

gasification 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 versus

steam 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 CO2 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 (NOx, SOx, 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 advanced

cycles 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 CO2 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 CO2 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 NOx 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. Again

the 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 through

the 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

CO2 emissions.

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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 NOx emissions.

Figure 4 shows the same comparison for SO2. A typical removal in a wet scrubber is 90% with some today as high as 95% to

98%. Again, as the SO2 removal rate in the scrubber increases, the

effect of cycle heat rate improvement on further SO2 removal decreases.
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In 1971, the New Source Performance Standards for new

coal-fired power plants in the U.S. were 0.7 lb NOx/MBtu, 1.2

lb SO2/MBtu, and 0.1 lb particulate /MBtu. These regulations

were tightened in 1979. For NOx, the regulation was 0.5 or 0.6

lb NOx/MBtu depending on the type of coal. The regulation for

SO2 was a sliding scale from 1.2 down to 0.3 lb SO2/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.

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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 NOx burners, an advanced high removal efficiency

selective catalytic NOx 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.

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The plant configuration for low sulfur western coal consists

of low NOx 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.

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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 NOx.

However, the synergistic effects of each unit operation or system in the train on all the pollutants must now be recognized.

Some of these 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

SO2 to SO3, which becomes sulfuric acid, H2SO4. 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.

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NOx is controlled by advanced low NOx burners and an advanced selective catalytic NOx reduction system. Figure 8 shows

the NOx 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 NOx emissions performance in several different equivalent measurements and how it compares to a state-ofthe-art natural gas combined cycle plant using dry low NOx combustion and with a nominal emissions rate of 9 ppm @ 15% O2.

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As can be seen, the NOx levels from this plant will be significantly lower than the current state-of-the-art for natural gas

combined cycle technology using dry low NOx combustion.

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The NOx 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 sulfur

coal 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 NOx level leaving the boiler, a typical eastern bituminous coal with the best low NOx 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

NOx 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’s

Combustion 2000 program, is the product of extensive numerical modeling using B&W’s proprietary combustion modeling

technology. 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 newest

and most advanced coal burner B&W has commercially available. These burners are already in successful operation.

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The basic principle of conventional selective catalytic NOx

reduction is the reduction of NOx to N2 and H2O by the reaction

of NOx and ammonia (NH3). In the presence of the catalyst, the

following NOx reduction reactions occur:

NO Reduction:

4 NO + 4 NH3 + 02 → 4 N2 + 6 H20

NO2 Reduction:

6 NO2 + 8 NH3 → 7 N2 + 12 H20

2 NO2 + 4 NH3 + 02 → 3 N2 + 6 H20

Secondary reactions that can occur in the presence of the

catalyst are the oxidation of SO2 to SO3 according to:

SO2 + 1⁄2 O2 → SO3

and the oxidation of elemental mercury according to:

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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 NOx 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, SO2 and SO3 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 NOx removal efficiencies requires increasingly uniform

NH3/NOx molar ratio profiles entering the reactor.

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Today, it is possible to design an SCR to provide 95% NOx

control if the mixing issues are adequately addressed. The degree of maldistribution in a NH3/NOx 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 NH3 to achieve the design reduction. Values higher

than the mean will meet the reduction required but will exceed

the design NH3 slip. A coefficient of variation of 5% is the current industry standard for NH3/NOx molar ratio uniformity on

high efficiency SCR systems. The objective for the advanced

plant is to achieve 95% NOx 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 the

impacts of plant arrangement and the injection and mixing techniques on the NH3/NOx molar ratio profile.

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The high level of sulfur in typical bituminous coals presents

a challenge to minimizing the formation of sulfuric acid (H2SO4).

A small portion of SO2 is oxidized to SO3 in the boiler. Additional SO2 oxidation occurs across the SCR due to the presence

of vanadium in the catalyst. The amount of oxidation is dependent upon the catalyst formulation, catalyst volume, and operating conditions. The SO3 combines with H2O vapor to form

H2SO4, which can cause corrosion of air heaters, fabric filter

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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 SO3 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 SO3. The reagent injection

will reduce the SO3 loading to the air heater. As discussed in

the next section, considerable H2SO4 removal is also expected

in the pulse-jet fabric filter. Final polishing of the H2SO4 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.

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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 boilers

indicate 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 early

as 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 method

at the SCR inlet and outlet. On average, the percentage of oxidized mercury in the flue gas increased from 51% at the SCR

inlet to 93% at the SCR outlet, facilitating removal by downstream scrubbing.

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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 the

collected 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 SO3 removal process initiated with reagent injection upstream of the SCR continues in

the pulse-jet fabric filter. The flyash and residual unreacted reagent absorb SO3 as the reagent accumulates on the bag surface

while protecting the bags from deterioration by acid attack.

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The integrated advanced absorber tower illustrated in Figure 10 combines wet scrubbing and wet electrostatic precipita-

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tor (WESP) technologies for simultaneous SO2, sulfuric acid

mist, fine particulate and mercury control.

An advanced plant can be designed to achieve 99.5% SO2

removal with high sulfur coals. An SO2 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 flyash

and scrubber carryover (gypsum) are controlled to very low levels, the sulfuric acid emissions, which are a product of SO2 to

SO3 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 SO2 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 white

plumes 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 of

sulfuric 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.

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Conventional wet scrubbers utilize a wet limestone process

with in-situ forced oxidation to remove flue gas SO2 and produce a gypsum by-product according to the following overall

reaction:

CaCO3 + SO2 + 1/2 O2 + 2H2O → CaSO4 • 2H2O + CO2

The SO2 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, where

scrubber slurry is sprayed countercurrent to the flue gas flow, completing the SO2 removal process. The SO2 removal process includes

an in-situ forced oxidation system which converts calcium sulfite

(CaSO3 • 1⁄2H20) formed by the SO2 removal process to calcium

sulfate (CaSO4 • 2H20) or gypsum.

Limestone forced oxidation systems have achieved SO2 removal

efficiencies as high as 96 to 98% in a variety of power plants firing

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tained through the use of costly additives. It is possible, however, to meet low SO2 emission targets without additives while

minimizing additional capital and operating costs.

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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 SO2 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 SO2 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 the

partial pressure between the gas and the slurry. Due to the reduction of SO2 by the initial spray zones, the driving force for

mass transfer in the last spray zone is retarded. In order to meet

the high SO2 control target, fresh limestone feed is added to the

last spray zone header to provide additional driving force for

the SO2 reactions to occur.

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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 H2SO4 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%

H2SO4 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 the

more 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 strong

field 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 wet

ESP falls into the alkaline scrubber slurry and is neutralized.

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At least 90% mercury removal can be achieved through the

combined 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 additives

specifically 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 carbon

technologies. In addition, the mercury in the flyash and gypsum is in an insoluble form at concentrations sufficiently low

to be typically considered non-hazardous and suitable for utilization as a by-product.

The proprietary process of adding low-cost reagents to the

wet 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 the

environment 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 to

adversely 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.

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The configuration of the low sulfur western coal-fired plant

was depicted in Figure 7.

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Today’s low NOx burners, as discussed above, can achieve

0.16 lb/MBtu burning PRB fuel with moderate staging. A typical SCR removal efficiency on a PRB unit today is 60% with 2

ppm of ammonia slip. As discussed above, the issue with achieving high NOx removal efficiency is mixing of the flue gas with

the ammonia. With a 95% removal SCR, an outlet NOx level of

0.008 lb/MBtu can be achieved on PRB fuel.

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For the PRB coal-fired advanced plant, SO2 will be controlled

by the E-LIDS process or Enhanced Limestone Injection Dry

Scrubbing as shown in Figure 13.4

 SO2 removal of 98% can be

achieved with a nominal 0.8% sulfur, 8,000 Btu/lb coal.

Limestone (CaCO3) is injected in the upper part of the furnace where it is calcined into lime (CaO) and SO2 removal begins. Low sulfur PRB coal contains naturally occurring calcium

oxide in the ash that supplies much of the reagent needed for

SO2 removal. The amount of limestone that must be injected

into the furnace as a supplemental reagent is therefore low. This

mitigates 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 SO2, 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

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dry absorber tends to be of low reactivity. This is because the

CaO that is produced in the furnace receives a layer of CaSO4

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 dry

absorber 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.

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The speciation of mercury from low sulfur coal-fired units

tends to favor the elemental form, which is the most difficult

form of mercury to remove from the flue gas stream. The benefits of the SCR in converting elemental 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