Certification of Massachusetts State Implementation Plan Adequacy Regarding Clean Air Act Sections 

110(a)(1) and (2) for the 2006 PM2.5 National Ambient Air Quality Standard 

September 21, 2009 

Summary 

This document provides the U.S . Environmental Protection Agency (EPA) with certification that the existing Massachusetts State 

Implementation Plan (SIP) adequately meets the basic (or "infrastructure") requirements of 7401 U.S .C. §2110(a)(1) and (2) (Sections 

110(a)(1) and (2) of the Clean Air Act (CAA)) with respect to the 24-hour National Ambient Air Quality Standard (NAAQS) for fine 

particulate matter (PM2.5) promulgated by EPA on September 21, 2006 (the 2006 PM 2.5 NAAQS). The 2006 PM2.5 NAAQS 

lowered the 24-hour PM2.5 standard from 65 micrograms per cubic meter to 35 ug/m3 and left the annual PM2.5 standard of 15ug/m3 

unchanged. 

Background 

Under the CAA, all states are required to submit SIPs meeting the requirements of CAA Sections 110(a)(1) and (2) within 3 years after 

promulgation of a new or revised standard . Section 110(a)(1) provides the procedural and timing requirements for SIPS . Section 

110(a)(2) lists the basic elements that all SIPs must contain; these include emissions inventories, ambient air quality monitoring and 

data systems, programs for enforcement of control measures, and adequate resources to implement the plan. For the 2006 PM2.5 

NAAQS, states must certify to EPA by September 21, 2009, that the state SIP contains the basic (or "infrastructure") elements that 

will allow the state to adequately provide for the implementation, maintenance and enforcement of the revised 24-hour PM NAAQS. 

The Massachusetts Department of Environmental Protection (MassDEP) certifies that the existing Massachusetts SIP already 

addresses the basic SIP elements required under the CAA and adequately provides for the implementation, maintenance and 

enforcement of the 2006 PM2.5 NAAQS. 

Previous Infrastructure Certifications 

For the 1997 ozone NAAQS, on December 14, 2007, MassDEP submitted to EPA a Certification of State Implementation Plan 

Adequacy Regarding Clean Air Act Sections 110(a)(1) and (2) (the Ozone Certification), certifying that it met the CAA Section 

MA 2006 PM2 .5 NAAQS Certification - September, 2009 

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110(a)(1) and (2) requirements. On March 27, 2008 (73 Federal Register 16205), EPA issued a finding that, for the 1997 ozone 

NAAQS, the Massachusetts SIP is complete, with the exception of the PSD program. (See discussion regarding PSD below.) 

For the 1997 PM2.5 NAAQS, on April 4, 2008, MassDEP submitted to EPA a Certification of State Implementation Plan Adequacy 

Regarding Clean Air Act Sections 110(a)(1) and (2) for PM2.5. On October 28, 2008 (73 Fed. Register 62902), EPA issued a finding 

that, for the 1997 PM2.5 NAAQS, the Massachusetts SIP is complete, with the exception of the PSD program. In both findings, EPA 

stated the following concerning PSD: "The State of Massachusetts has failed to submit a SIP addressing section 110(a)(2)(C) and (J) 

pertaining to the Part C PSD permit program. However, this requirement has already been addressed by a FIP that remains in place, 

and therefore, this action will not trigger any additional FIP obligations." MassDEP anticipates that EPA will make a similar finding 

for PSD for the 2006 PM2.5 NAAQS. As noted in Table 1, MassDEP anticipates adopting a State PSD regulation in 2010. 

For the 1997 ozone and PM2.5 NAAQS, in an October 2, 2007 memo from William Harnett, Director of EPA's Air Quality Policy 

Division, EPA issued Guidance on SIP Elements Required Under Sections 110(a)(1) and (2) for the 1997 8-Hour Ozone and PM2.5 

NAAQS. Massachusetts' previous certifications followed that guidance. EPA has not issued updated guidance related to the 2006 PM 

2.5 NAAQS. Therefore, MassDEP has developed this certification to meet CAA requirements and to be consistent with the 1997 EPA 

guidance. 

Basic SIP Elements 

The basic SIP elements required under Section 110(a)(2) are listed in Table 1 . Table 1 also lists the Massachusetts statutes and 

regulations that are already part of the Massachusetts SIP and satisfy the Section 110(a)(2) requirement. This PM2.5 NAAQS 

Certification is based on the same documentation of legal authority and program implementation as the Ozone Certification and 

PM2.5 Certification previously submitted to EPA. Table 1 includes statutory, regulatory and program references that are current as of 

the date of this certification. Hard copies of the following documents were submitted as part of the December 2007 PM2.5 

Certification (and referenced in the April 2008 Ozone Certification): 1 

" Section II, Legal Authority, of the original 1972 Massachusetts SIP for ozone. This is a narrative description of MassDEP's 

legal authority to adopt rules and regulations to comply with the CAA. 

" Legal opinions that address similar CAA requirements related to state legal authority to implement other federally mandated 

air pollution control programs; these include: 

' This documentation is unchanged and so is incorporated by reference in this certification . Per discussion with EPA staff, additional hard copies 

do not need to be submitted with this certification . 

MA 2006 PM2.5 NAAQS Certification - September, 2009 

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o November 12, 1993 and August 2, 1995, Massachusetts Attorney General's legal opinions regarding Title V of the federal 

Clean Air Act and the Commonwealth's regulations at 310 CMR 7 .00 : Appendix C: Operating Permit Program; 

o November 18, 1998 Massachusetts Attorney General's Supplemental Legal Opinion Regarding Section 129 of the Clean 

Air Act and the Commonwealth's Regulation at 310 CMR 7.08(2), the Municipal Waste Combustor Regulations; 

o July 9, 2007 MassDEP General Counsel's legal opinion regarding the authority to adopt the Clean Air Mercury Rule State 

Plan and accompanying regulations 310 CMR 7.29 and 310 CMR 7 .02. 

Conclusion 

The statutory authority and regulations referenced in Table 1, which are currently part of the Massachusetts SIP, meet the 

requirements of CAA Sections 110(a)(1) and (2) with respect to the 2006 PM2.5 NAAQS. Therefore, MassDEP certifies that the 

existing Massachusetts SIP already addresses the SIP elements required under the CAA and provides for the implementation, 

maintenance and enforcement of the 2006 PM2.5 NAAQS. 

MA 2006 PM2.5 NAAQS Certification - September, 2009 

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Table 1 

Massachusetts' Statutory Authority and Regulations Meeting Clean Air Act 

Section 110(a)(1) and (2) SIP requirements for 2006 PM2.5 NAAQS* 

Clean Air Act 

(CAA) Section 

SIP requirement (Each such plan shall. . .) Massachusetts Program 

110(a)(2)(A) . . . "include enforceable emission limitations M.G.L. c 21A, s. 8. Organization of departments; powers, duties and 

Emission limits and other control measures, means, or functions. 

and other techniques (including economic incentives 

control such as fees, marketable permits, and M.G.L. c.lll, s.142 A-N. These statutes, collectively referred to 

measures auctions of emissions rights), as well as Massachusetts Pollution Control Laws, provide MassDEP* * with broad 

schedules and timetables for compliance. . ." authority to prevent pollution or contamination of the atmosphere and to 

prescribe and establish regulations to prevent pollution or undue 

contamination of the atmosphere . 

M.G.L. c. 21A, s. 18. MassDEP's fee statute. 

MassDEP Regulations : 

In accordance with the above-referenced authority, MassDEP adopted 310 

CMR 6.00, Ambient Air Quality Standards for the Commonwealth of 

Massachusetts. This regulation sets a state 1-hour ozone standard and a PM 

standard, but it has not been updated to include an 8-hour ozone standard and 

a PM2.5 standard . MassDEP intends to revise 310 CMR 6 .00 to adopt the 

'CFR refers to the U.S . Code of Federal Regulations; CMR refers to the Code of Massachusetts Regulations 

**MassDEP was formerly known as the Department of Environmental Quality Engineering or DEQE, and prior to that Bureau of Air Quality Control in 

the Massachusetts Department of Public Health. 

MA 2006 PM2 .5 NAAQS Certification - September, 2009 

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Clean Air Act 

(CAA) Section 

SIP requirement (Each such plan shall. . .) Massachusetts Program ' 

current 24-hour and annual NAAQS for PM2.5 (and the current NAAQS for 

ozone) as Massachusetts ambient air quality standards. On June 26, 2009, 

MassDEP issued for public review, a proposed revision to 310 CMR 6.00 , 

adopting the current NAAQS for PM2.5 and ozone as Massachusetts ambient 

air quality standards. A public hearing on the proposed revision was held on 

August 4. 2009. MassDEP anticipates finalizing the revisions in early 2010. 

In the meantime, however, all MassDEP regulations that require compliance 

with an ambient air quality standard require compliance with the NAAQS. 

Therefore, the out-of-date state ambient air quality standards in 310 CMR 6.00 

do not have a regulatory impact. 

MassDEP also adopted regulations to control air pollution at 310 CMR 7.00 . 

Air Pollution Control. With a few exceptions (for regulations that EPA did 

not require be part of the federally-enforceable SIN), these regulations have 

been submitted to EPA and incorporated into the Massachusetts SIP, as 

detailed in the numerous MassDEP SIP revisions submitted since the original 

1971 PM SIP and 1972 Ozone SIP and approved by EPA as part of the SIP in 

40 CFR Part 52, Subpart W. 

Other MassDEP regulations that have been adopted and incorporated in the 

SIP include: 

310 CMR 60.00. Air Pollution Control for Mobile Sources. 

310 CMR 4.00. Timely Action & Fee Schedule Regulations . 110(a)(2)(B) . . . "provide for establishment and operation M.G.L. c. 111, s. 142B-D. These statutes give MassDEP the authority to Ambient Air of appropriate devices, methods, systems, maintain and operate air sampling stations and devices, and to require, for the quality and procedures necessary to (i) monitor, purpose of conducting a continuing inventory of air pollution sources of monitoring/data compile, and analyze data on ambient air emissions, any person to register with MassDEP and provide emissions system quality, and (ii) upon request, make such information. 

data available to the Administrator." 

MassDEP regulations relating to this authority include: 

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Clean Air Act 

CAA Section 

SIP requirement (Each such plan shall. . .) Massachusetts Program 

310 CMR 7.12. Source Registration. 

310 CMR 7.13. Stack Testing. 

310 CMR 7.14. Monitoring Devices and Reports. 

310 CMR 7.00 : Appendix C. Operating Permit Program. 

310 CMR 7.00: Appendix A. Emissions Offsets and Nonattainment Review. 

I 

I MassDEP collects and reports ambient air quality data for 03, S02, N02, Pb, 

CO, PM1o and PM2.5 . These data are reviewed and validated before being sent 

to the EPA air quality system (AQS), no later than 90 days after the end of a 

calendar quarter. 

On January 28, 1980, MassDEQE submitted to EPA pursuant to 40 CFR § 

52.370 (13), a comprehensive air quality monitoring plan to meet requirements 

of 40 CFR part 58 . 

On August 24, 2009, MassDEP submitted to EPA the most recent annual air 

monitoring network plan. 

110(a)(2)(C) . . . "include a program to provide for the M.G.L. c 111, s.2C. Pollution violations; orders of department of 

Program for enforcement of the measures described in environmental protection. This statute authorizes MassDEP to issue orders 

enforcement of subparagraph (A), and regulation of the enforcing air pollution control regulations. 

control 

measures 

modification and construction of any 

stationary source within the areas covered by M.G.L. c. 111, s 142A-N. Massachusetts Pollution Control Laws authorize 

the plan as necessary to assure that national MassDEP to adopt regulations to control pollution or contamination of 

ambient air quality standards are achieved, atmosphere, and enforce such regulations and issue penalties. 

including a permit program as required in 

parts C and D;" M.G.L. c.21A, s .16. Administrative Penalties Act. 

I 

MassDEP regulations adopted pursuant to these authorities include: 

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Clean Air Act 

(CAA) Section 

SIP requirement (Each such plan shall. . .) Massachusetts Program 

310 CMR 5.00. Administrative Penalties. 

310 CMR 7.02 . Plan Approval and Emission Limitations List . 

310 CMR 7.52. Enforcement Provisions . 

310 CMR 7.00 : Appendix C. Operating Permit and Compliance Program. 

With respect to the permit program requirement, MassDEP submitted a NSR 

Equivalency Determination to EPA-Region 1 on December 30, 2005 . 

110(a)(2)(D) . . . "contain adequate provisions - (i) Revision to the Massachusetts State Implementation Plan - Interstate prohibiting, consistent with the provisions of The Massachusetts SIP revision addressing the Interstate Air Pollution transport this title, any source or other type of Transport Requirements of Clean Air Act Section 110(a)(2)(D)(i),relating to emissions activity within the State from the 1997 PM2.5 and ozone standards, was submitted to EPA on January 31, emitting any air pollutant in amounts which 2008. In that SIP revision, MassDEP relied upon its adoption of 310 CMR will - (I) contribute significantly to 7.32, the Massachusetts Clean Air Interstate Rule (MassCAIR), to address its nonattainment in, or interfere with contribution to downwind nonattainment areas, as required by EPA's Clean 

maintenance by, any other State with respect Air Interstate Rule. MassDEP continues to implement the MassCAIR 

to any such national primary or secondary program. 

ambient air quality standard, or (Il) interfere 

with measures required to be included in the EPA has not issued new regulations or guidance regarding how states should 

applicable implementation plan for any other address transport in connection with the 2006 PM2.5 standard . MassDEP will 

State under part C to prevent significant submit a separate transport SIP to EPA to address this issue once EPA has 

deterioration of air quality or to protect provided the necessary guidance . 

visibility, (ii) insuring compliance with the 

applicable; requirements of sections 126 and In the meantime, Massachusetts is not contributing significantly to non115 (relating to interstate and international attainment in any other state, as all areas that are downwind of Massachusetts 

pollution abatement) ;" are attaining the 2006 PM2.5 NAAQS. 

MassDEP is addressing visibility pursuant to its Regional Haze SIP, which it 

anticipates submitting to EPA in 2010. 

NSR Equivalency Determination was submitted to EPA-Region 1 on 

MA 2006 PM2.5 NAAQS Certification - September, 2009 

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Clean Air Act SIP requirement (Each such plan shall. . .) Massachusetts Program 

(CAA) Section ( 

December 30, 2005. 

Pursuant to its PSD Program Delegation Agreement, MassDEP returned 

delegation of the PSD Program to EPA on February 23, 2003. Under the 

terms of the Performance Partnership Agreement between EPA Region 1 and 

MassDEP, EPA continues to administer the PSD program with the 

cooperation and assistance of MassDEP. MassDEP anticipates that this 

arrangement will continue for purposes of implementing PSD for sources of 

PM2.5, until MassDEP adopts a state PSD regulation, which it expects to do, 

in 2010. 

For the 1997 ozone and PM2.5 NAAQS, EPA found that Massachusetts failed ' 

to submit a SIP addressing Section 110(a)(2)(C) (the Part C PSD permit 

program), but this requirement has already been addressed in a Federal 

Implementation Plan (FIP) that remains in place and that the finding will, 

therefore, not trigger any additional FIP obligation. 

110(a)(2)(E) . . . "provide (i) necessary assurances that the M.G.L. c 21A, s. 8. Organization of departments; powers, duties and 

Adequate State (or, except where the Administrator functions . This statute mandates that in no event shall the department 

resources deems inappropriate, the general purpose authorize implementation of any plan, strategy or technology less protective of 

local government or governments, or a the environment than required by any applicable federal statute. 

regional agency designated by the State or 

general purpose local governments for such M.G.L. c. 111, s. 142A-N and the accompanying regulations. These statutes 

purpose) will have adequate personnel, and regulations provide MassDEP with sufficient authority to carry out 

funding, and authority under State (and, as implementation of the plan. 

appropriate, local) law to carry out such 

implementation plan (and is not prohibited M.G.L. c. 111, s. 142E. Cooperation by, and Authority of Department over, 

by any provision of Federal or State law other Agencies, Commissioners, Authorities, or Political Subdivisions with 

from carrying out such implementation plan Respect to Air Pollution . 

or portion thereof), (ii) requirements that the 

State comply with the requirements M.G.L. c 21A, s. 8 . Organization of departments ; powers, duties and 

MA 2006 PM2.5 NAAQS Certification - September, 2009 

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Clean Air Act 

(CAA) Section 

SIP requirement (Each such plan shall. . .) Massachusetts Program 

respecting State boards under section 128, functions . 

and (iii) necessary assurances that, where the 

State has relied on a local or regional In Section X of the Massachusetts 1971 SIP for PM, the Bureau of Air Use government, agency, or instrumentality for Management provided details that it had adequate personnel and funding to the implementation of any plan provision, carry out implementation of the original SIP . This resource finding has been the State has responsibility for ensuring updated in subsequent SIP submissions related to PM and ozone. MassDEP 

adequate implementation of such plan has continued to add staff and programs since that time and currently has 

provision;" adequate personnel and funding to implement the existing SIP. 

110(a)(2)(F) . . . "require, as may be prescribed by the M.G.L. c. 111, s. 142A-D. These statutes give MassDEP the authority to Stationary Administrator - (i) the installation, maintain and operate air sampling stations and devices and to require, for the 

source emissions maintenance, and replacement of equipment, purpose of conducting a continuing inventory of air pollution sources of monitoring and and the implementation of other necessary emissions, any person to register with MassDEP and provide emissions reporting steps, by owners or operators of stationary information. 

sources to monitor emissions from such 

sources, (ii) periodic reports on the nature MassDEP regulations relating to this authority include : 

and amounts of emissions and emissions- 310 CMR 7.12. Source Registration . 

related data from such sources, and (iii) 310 CMR 7.13. Stack Testing. 

correlation of such reports by the State 310 CMR 7.14. Monitoring Devices and Reports. 

agency with any emission limitations or 

standards established pursuant to this Act, Chapter 66: Section 1 . Public inspection and copies of records; presumption; 

which reports shall be available at exceptions . 

reasonable times for public inspection;" 

310 CMR 3.00. Public Records Access Regulations. 

110(a)(2)(G) . . . "provide for authority comparable to that M.G.L. C.111, s.2B-C. Air Pollution Emergencies. These statutes authorize Emergency in section 303 and adequate contingency the Commissioner of MassDEP to determine that a condition or impending 

power plans to implement such authority;" condition of the atmosphere in the commonwealth or in any part thereof 

constitutes a present or reasonably imminent danger to health, and may, with 

the approval of the governor, declare an air pollution emergency and cause the 

fact to be made known to the public . 

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Clean Air Act 

CAA Section 

SIP requirement (Each such plan shall . . .) Massachusetts Program i, 

MassDEP regulations relating to this authority are at 310 CMR 8.00, 

Prevention & Abatement ofAir Pollution Episodes & Emergencies. These 

regulations prevent ambient air concentrations of pollutants subject to a 

NAAQS from reaching levels that would constitute significant harm to public 

health, consistent with the significant harm levels and procedures for state 

emergency episode plans established by EPA in 40 CFR Part 51 .150. 

The requirement for a state to submit an emergency episode plan is based on a II 

priority region classification . For PM2.5, the classification scheme that EPA j 

is planning to propose would require states with a 24-hour PM2.5 'I 

concentration above 140.5 ug/m3 (using the most recent three years of data) to i 

develop an emergency episode plan. States that do not meet this threshold I 

would be classified as Priority III and would not be required to develop an j 

emergency episode plan for PM2.5 . Massachusetts is likely to be classified as I 

a Class III Priority Area based on its monitored data And, if that classification ! 

is assigned, Massachusetts would not be required to adopt an Emergency ! 

Episode Plan for PM2.5 . 

MassDEP forecasts predicts concentrations of PM2.5 statewide throughout the ~, 

year and issues alerts to the public when concentrations are expected to reach I 

unhealthy levels using the Air Quality Index and will continue to do so . , 

110(a)(2)(H) . . . "provide for revision of such plan - (i) M.G.L. c. 111, s. 142A-N. These statutes allow MassDEP to amend its air i 

Future SIP from time to time as may be necessary to pollution control regulations from time to time. I 

revisions take account of revisions of such national 

primary or secondary ambient air quality ! 

standard or the availability of improved or ' 

more expeditious methods of attaining such ' 

standard, and (ii) except as provided in 

paragraph (3)(C), whenever the 

Administrator finds on the basis of 

MA 2006 PM2 .5 NAAQS Certification - September, 2009 

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Clean Air Act SIP requirement (Each such plan shall. . .) Massachusetts Program (CAA) Section 

information available to the Administrator 

that the plan is substantially inadequate to 

attain the national ambient air quality 

standard which it implements or to otherwise 

comply with any additional requirements 

established under this Act;" 

110(a)(2)(J) . . . "meet the applicable requirements of M.G.L. c. 21A, s. 8. Organization of departments; powers, duties and Consultation section 121 (relating to consultation) functions. 

with 

government M.G.L. c. 111, s. 142E. Cooperation by, and Authority of Department over officials _ 

, 

other Agencies, Commissioners, Authorities, or Political Subdivisions with 

Respect to Air Pollution. 

M.G.L. c. 30A. Massachusetts Administrative Procedures Act. This statute 

requires MassDEP to provide notice and public comment and hearing prior to 

adoption of any regulations. 

Executive Order No. 145. This order requires MassDEP to provide notice 

to the Local Government Advisory Committee, through the Massachusetts 

Municipal Association, to solicit input on the impact on local government. 

Massachusetts SIP Steering Committee, established pursuant to the Clean 

Air Amendments of 1990, provides for consultation . 

. 

110(a)(2)(J) . . . "meet the applicable requirements of M.G.L. c. 30A requires MassDEP to provide notice and public comment and Public section 127 (relating to public notification), hearing prior to adoption of any regulations. 

notification 

110(a)(2)(J) . . . "meet the applicable requirements of part Pursuant to its PSD Program Delegation Agreement, MassDEP returned 

PSD and C (relating to prevention of significant delegation of the PSD Program to EPA on February 23, 2003 . Under the terms 

MA 2006 PM2.5 NAAQS Certification - September, 2009 

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Clean Air Act SIP requirement (Each such plan shall. . .) Massachusetts Program 

(CAA) Section 

-visibility deterioration of air quality and visibility of the Performance Partnership Agreement between EPA Region 1 and 

Protection protection);" MassDEP, EPA continues to administer the PSD program with the 

cooperation and assistance of MassDEP. MassDEP anticipates that this 

arrangement will continue for purposes of implementing PSD for sources of 

PM2.5 until MassDEP adopts a state PSD regulation, which it expects to do in 

2010. ' 

MassDEP is addressing visibility issues in its Regional Haze SIP, which will 

be submitted to EPA in 2010. 

110(a)(2)(K) . . . "provide for - (i) the performance of M.G.L. c. 111, s. 142B-D. These statutes give MassDEP the authority to 

Air quality such air quality modeling as the maintain and operate air sampling stations and devices and to require, for the 

modeling/data Administrator may prescribe for the purpose purpose of conducting a continuing inventory of air pollution sources of 

of predicting the effect on ambient air emissions, any person to register with MassDEP and provide emissions 

quality of any emissions of any air pollutant information. 

for which the Administrator has established 

a national ambient air quality standard, and 310 CMR 7.02. Plan Approval and Emission Limitations. 

(ii) the submission, upon request, of data 

related to such air quality modeling to the 

i 

Administrator;" i 

110(a)(2)(L) . . . "require the owner or operator of each M.G.L. c.21A, s.18. This statute authorizes MassDEP to promulgate 

Permitting fees major stationary source to pay to the regulations establishing fees . 

permitting authority, as a condition of any , I 

permit required under this Act, a fee 310 CMR 4.00. Timely Action & Fee Schedule Regulations. These I 

sufficient to cover - (i) the reasonable costs regulations set permit and compliance fees, including fees for Operating 

of reviewing and acting upon any Permits (Title V). 

application for such a permit, and (ii) if the 

owner or operator receives a permit for such ' 

source, the reasonable costs of implementing 

and enforcing the terms and conditions of , 

any such permit (not including any court 

MA 2006 PM2.5 NAAQS Certification - September, 2009 

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Clean Air Act SIP requirement (Each such plan shall. . .) 

(CAA) Section 

110(a)(2)(M) 

Consultation/ 

Participation by 

affected local 

entities 

costs or other costs associated with any 

enforcement action), until such fee 

requirement is superseded with respect to 

such sources by the Administrator's approval 

of a fee program under 

title V;" 

. . . "provide for consultation and 

participation by local political subdivisions 

affected by the plan." 

Massachusetts Program 

M.G.L. c. 30A. Massachusetts Administrative Procedures Act. This statute 

requires MassDEP to provide notice and public comment and hearing prior to adoption of any regulations. 

Executive Order No. 145 requires MassDEP to provide notice to the Local 

Government Advisory Committee, through the Massachusetts Municipal 

Association, to solicit input on the impact on local government. 

MA 2006 PM2.5 NAAQS Certification - September, 2009 

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