Phyllis Fox

Ph.D, PE, BCEE, QEP

Environmental Management

745 White Pine Ave.

Rockledge, FL 32955

321-626-6885

PhyllisFox@gmail.com

Dr. Fox has over 35 years of experience in the field of environmental engineering, including air 

pollution control, air quality management, water quality and water supply investigations, 

hazardous waste investigations, environmental permitting, nuisance investigations, 

environmental impact reports, CEQA/NEPA documentation, risk assessments, and litigation 

support. 

EDUCATION 

Ph.D. Environmental/Civil Engineering, University of California, Berkeley, 1980.

M.S. Environmental/Civil Engineering, University of California, Berkeley, 1975.

B.S. Physics (with high honors), University of Florida, Gainesville, 1971.

REGISTRATION

Registered Professional Engineer: Arizona (2001-present: #36701), California (2002-present; CH 

6058), Florida (2001-present; #57886), Georgia (2002-present; #PE027643), Washington (2002-

present; #38692), Wisconsin (2005-present; #37595-006)

Board Certified Environmental Engineer, American Academy of Environmental Engineers, 

Certified in Air Pollution Control (DEE #01-20014), 2002-present

Qualified Environmental Professional (QEP), Institute of Professional Environmental 

Practice (QEP #02-010007), 2001-present

PROFESSIONAL HISTORY

Environmental Management, Principal, 1981-present

Lawrence Berkeley Laboratory, Principal Investigator, 1977-1981

University of California, Berkeley, Program Manager, 1976-1977

Bechtel, Inc., Engineer, 1971-1976, 1964-1966

PROFESSIONAL AFFILIATIONS

American Chemical Society (1981-present)

Phi Beta Kappa (1970-present)

Sigma Pi Sigma (1970-present)
PHYLLIS FOX, PH.D., PAGE 2

Who's Who Environmental Registry, PH Publishing, Fort Collins, CO, 1992.

Who's Who in the World, Marquis Who's Who, Inc., Chicago, IL, 11th Ed., p. 371, 1993-present.

Who's Who of American Women, Marquis Who's Who, Inc., Chicago, IL, 13th Ed., p. 264, 1984-

present.

Who's Who in Science and Engineering, Marquis Who's Who, Inc., New Providence, NJ, 5th Ed., 

p. 414, 1999-present.

Who’s Who in America, Marquis Who’s Who, Inc., 59th Ed., 2005.

Guide to Specialists on Toxic Substances, World Environment Center, New York, NY, p. 80, 

1980.

National Research Council Committee on Irrigation-Induced Water Quality Problems 

(Selenium), Subcommittee on Quality Control/Quality Assurance (1985-1990).

National Research Council Committee on Surface Mining and Reclamation, Subcommittee on 

Oil Shale (1978-80)

REPRESENTATIVE EXPERIENCE

Performed environmental and engineering investigations, as outlined below, for a wide range of 

industrial and commercial facilities including petroleum refineries and upgrades thereto; 

reformulated fuels projects; petroleum distribution terminals; shale oil plants; coal gasification & 

liquefaction plants; conventional and thermally enhanced oil production; underground storage 

tanks; pipelines; gasoline stations; landfills; railyards; hazardous waste treatment facilities;

nuclear, hydroelectric, geothermal, wood, waste, gas, oil, coke and coal-fired power plants;

transmission lines; airports; hydrogen plants; petroleum coke calcining plants; coke plants;

activated carbon manufacturing facilities; asphalt plants; cement plants; incinerators; flares;

manufacturing facilities (e.g., semiconductors, electronic assembly, aerospace components, 

printed circuit boards, amusement park rides); lanthanide processing plants; ammonia plants; 

nitric acid plants; urea plants; food processing plants; almond hulling facilities; composting 

facilities; grain processing facilities; grain elevators; ethanol production facilities; soy bean oil 

extraction plants; biodiesel plants; paint formulation plants; wastewater treatment plants; marine 

terminals and ports; gas processing plants; steel mills; iron nugget production facilities; pig iron 

plant, based on blast furnace technology; direct reduced iron plant; acid regeneration facilities; 

railcar refinishing facility; battery manufacturing plants; pesticide manufacturing and 

repackaging facilities; pulp and paper mills; selective catalytic reduction (SCR) systems; halogen 

acid furnaces; contaminated property redevelopment projects (e.g., Mission Bay, Southern 

Pacific Railyards, Moscone Center expansion, San Diego Padres Ballpark); residential 

developments; commercial office parks, campuses, and shopping centers; server farms;

transportation plans; and a wide range of mines including sand and gravel, hard rock, limestone, 

nacholite, coal, molybdenum, gold, zinc, and oil shale.
PHYLLIS FOX, PH.D., PAGE 3

EXPERT WITNESS/LITIGATION SUPPORT

 For plaintiffs, in civil action relating to alleged violations of the Clean Air Act, Prevention of 

Significant Deterioration, for historic modifications (1988 – 2000) at James De Young Units 

3, 4, and 5. Reviewed produced documents, analyzed CEMS and EIA data, and prepared 

netting and BACT analyses for NOx, SO2, and PM10. Expert report February 24, 2010 and 

affidavit February 20, 2010. Sierra Club v. City of Holland, et al., U.S. District Court, 

Western District of Michigan.

 For plaintiffs, in civil action alleging failure to obtain MACT permit, expert on potential to 

emit hydrogen chloride (HCl) from a new coal-fired boiler. Reviewed record, estimated HCl 

emissions, wrote expert report June 2010 and deposed August 2010. Wildearth Guardian et 

al. v. Lamar Utilities Board, Civil Action No. 09-cv-02974, U.S. District Court, District 

of Colorado.

 For plaintiffs, expert witness on permitting, emission calculations, and wastewater treatment 

for coal to gasoline plant. Reviewed produced documents. Assisted in preparation of 

comments on draft minor source permit. Wrote two affidavits on key issues in case. 

Presented direct and rebuttal testimony 10/27 - 10/28/10 on permit enforceability and failure 

to properly calculate potential to emit, including underestimate of flaring emissions and 

omission of VOC and CO emissions from wastewater treatment, cooling tower, tank roof 

landings, and malfunctions. Sierra Club, Ohio Valley Environmental Coalition, Coal River 

Mountain Watch, West Virginia Highlands Conservancy v. John Benedict, Director, Division 

of Air Quality, West Virginia Department of Environmental Protection and TransGas 

Development System, LLC, Appeal No. 10-01-AQB.

 For plaintiffs, expert on BACT emission limits for gas-fired combined cycle power plant. 

Prepared declaration in support of CBE's Opposition to the United States' Motion for Entry

of Proposed Amended Consent Decree. Assisted in settlement discussions. U.S. EPA, 

Plaintiff, Communities for a Better Environment, Intervenor Plaintiff, v. Pacific Gas &

Electric Company, et al., U.S. District Court, Northern District of California, San Francisco 

Division, Case No. C-09-4503 SI.

 Technical expert in confidential settlement discussions with large coal-fired utility on BACT 

control technology and emission limits for NOx, SO2, PM, PM2.5, and CO for new natural 

gas fired combined cycle and simple cycle turbines with oil backup. (July 2010). Case 

settled.

 For plaintiffs, expert witness in remedy phase of civil action relating to alleged violations of 

the Clean Air Act, Prevention of Significant Deterioration, for historic modifications (1998-

99) at Gallagher Units 1 and 3. Reviewed produced documents, prepared expert and rebuttal 

reports on historic and current-day BACT for SO2, control costs, and excess emissions of 
PHYLLIS FOX, PH.D., PAGE 4

SO2. Deposed 11/18/09. United States et al. v. Cinergy, et al., In U.S. District Court for the 

Southern District of Indiana, Indianapolis Division, Civil Action No. IP99-1693 C-M/S. 

Settled 12/22/09.

 For plaintiffs, expert witness on MACT, BACT for NOx, and enforceability in an 

administrative appeal of draft state air permit issued for four 300-MW pet-coke-fired CFBs. 

Reviewed produced documents and prepared prefiled testimony. Deposed 10/8/09 and 

11/9/09. Testified 11/10/09. Application of Las Brisas Energy Center, LLC for State Air 

Quality Permit; before the State Office of Administrative Hearings, Texas. Permit remanded 

3/29/10 as LBEC failed to meet burden of proof on a number of issues including MACT.

 For defense, expert witness in unlawful detainer case involving a gasoline station, minimart, 

and residential property with contamination from leaking underground storage tanks. 

Reviewed agency files and inspected site. Presented expert testimony on July 6, 2009, on 

causes of, nature and extent of subsurface contamination. A. Singh v. S. Assaedi, in Contra 

Costa County Superior Court, CA. Settled August 2009.

 For plaintiffs, expert witness on netting and enforceability for refinery being upgraded to 

process tar sands crude. Reviewed produced documents. Prepared expert and rebuttal 

reports addressing use of emission factors for baseline, omitted sources including coker, 

flares, tank landings and cleaning, and enforceability. Deposed. In the Matter of Objection to 

the Issuance of Significant Source Modification Permit No. 089-25484-00453 to BP 

Products North America Inc., Whiting Business Unit, Save the Dunes Council, Inc., Sierra 

Club., Inc., Hoosier Environmental Council et al., Petitioners, B. P. Products North 

American, Respondents/Permittee, before the Indiana Office of Environmental Adjudication.

 For plaintiffs, expert witness on BACT, MACT, and enforceability in appeal of Title V 

permit issued to 600 MW coal-fired power plant burning Powder River Basin coal. Prepared 

technical comments on draft air permit. Reviewed record on appeal, drafted BACT, MACT, 

and enforceability pre-filed testimony. Drafted MACT and enforceability pre-filed rebuttal 

testimony. Deposed March 24, 2009. Testified June 10, 2009. In Re: Southwestern Electric 

Power Company, Arkansas Pollution Control and Ecology Commission, Consolidated 

Docket No. 08-006-P. Recommended Decision issued December 9, 2009 upholding issued 

permit. Commission adopted Recommended Decision January 22, 2010.

 For plaintiffs, expert witness in remedy phase of civil action relating to alleged violations of 

the Clean Air Act, Prevention of Significant Deterioration, for historic modifications (1989-

1992) at Wabash Units 2, 3 and 5. Reviewed produced documents, prepared expert and 

rebuttal report on historic and current-day BACT for NOx and SO2, control costs, and excess 

emissions of NOx, SO2, and mercury. Deposed 10/21/08. United States et al. v. Cinergy, et 

al., In U.S. District Court for the Southern District of Indiana, Indianapolis Division, Civil 

Action No. IP99-1693 C-M/S. Testified 2/3/09. Memorandum Opinion & Order 5-29-09 
PHYLLIS FOX, PH.D., PAGE 5

requiring shutdown of Wabash River Units 2, 3, 5 by September 30, 2009, run at baseline 

until shutdown, and permanently surrender SO2 emission allowances.

 For plaintiffs, expert witness in liability phase of civil action relating to alleged violations of 

the Clean Air Act, Prevention of Significant Deterioration, for three historic modifications 

(1997-2001) at two portland cement plants involving three cement kilns. Reviewed 

produced documents, analyzed CEMS data covering subject period, prepared netting analysis 

for NOx, SO2 and CO, and prepared expert and rebuttal reports. United States v. Cemex 

California Cement, In U.S. District Court for the Central District of California, Eastern 

Division, Case No. ED CV 07-00223-GW (JCRx), Settled 1/15/09.

 For intervenors Clean Wisconsin and Citizens Utility Board, prepared data requests, 

reviewed discovery and expert report. Prepared prefiled direct, rebuttal and surrebuttal 

testimony on cost to extend life of existing Oak Creek Units 5-8 and cost to address future 

regulatory requirements to determine whether to control or shutdown one or more of the 

units. Oral testimony 2/5/08. Application for a Certificate of Authority to Install Wet Flue 

Gas Desulfurization and Selective Catalytic Reduction Facilities and Associated Equipment 

for Control of Sulfur Dioxide and Nitrogen Oxide Emissions at Oak Creek Power Plant Units 

5, 6, 7 and 8, WPSC Docket No. 6630-CE-299.

 For plaintiffs, expert witness on alternatives analysis and BACT for NOx, SO2, total PM10, 

and sulfuric acid mist in appeal of PSD permit issued to 1200 MW coal fired power plant 

burning Powder River Basin and/or Central Appalachian coal (Longleaf). Assisted in drafting

technical comments on NOx on draft permit. Prepared expert disclosure. Presented 8+ days 

of direct and rebuttal expert testimony. Attended all 21 days of evidentiary hearing from 

9/5/07 – 10/30/07 assisting in all aspects of hearing. Friends of the Chatahooche and Sierra 

Club v. Dr. Carol Couch, Director, Environmental Protection Division of Natural Resources 

Department, Respondent, and Longleaf Energy Associates, Intervener. ALJ Final Decision 

1/11/08 denying petition. ALJ Order vacated & remanded for further proceedings, Fulton 

County Superior Court, 6/30/08. Court of Appeals of GA remanded the case with directions 

that the ALJ's final decision be vacated to consider the evidence under the correct standard of 

review, July 9, 2009. The ALJ issued an opinion April 2, 2010 in favor of the applicant.

Final permit issued April 2010.

 For plaintiffs, expert witness on diesel exhaust in inverse condemnation case in which Port 

expanded maritime operations into residential neighborhoods, subjecting plaintiffs to noise, 

light, and diesel fumes. Measured real-time diesel particulate concentrations from marine 

vessels and tug boats on plaintiffs’ property. Reviewed documents, depositions, DVDs, and 

photographs provided by counsel. Deposed. Testified October 24, 2006. Ann Chargin, 

Richard Hackett, Carolyn Hackett, et al. v. Stockton Port District, Superior Court of 

California, County of San Joaquin, Stockton Branch, No. CV021015. Judge ruled for 

plaintiffs.
PHYLLIS FOX, PH.D., PAGE 6

 For plaintiffs, expert witness on NOx emissions and BACT in case alleging failure to obtain 

necessary permits and install controls on gas-fired combined-cycle turbines. Prepared and 

reviewed (applicant analyses) of NOx emissions, BACT analyses (water injection, SCR, ultra 

low NOx burners), and cost-effectiveness analyses based on site visit, plant operating 

records, stack tests, CEMS data, and turbine and catalyst vendor design information. 

Participated in negotiations to scope out consent order. United States v. Nevada Power. Case 

settled June 2007, resulting in installation of dry low NOx burners (5 ppm NOx averaged 

over 1 hr) on four units and a separate solar array at a local business.

 For plaintiffs, expert witness in appeal of PSD permit issued to 850 MW coal fired boiler 

burning Powder River Basin coal (Iatan Unit 2) on BACT for particulate matter, sulfuric acid 

mist and opacity and emission calculations for alleged historic violations of PSD. Assisted in

drafting technical comments, petition for review, discovery requests, and responses to 

discovery requests. Reviewed produced documents. Prepared expert report on BACT for 

particulate matter. Assisted with expert depositions. Deposed February 7, 8, 27, 28, 2007. In 

Re PSD Construction Permit Issued to Great Plains Energy, Kansas City Power & Light –

Iatan Generating Station, Sierra Club v. Missouri Department of Natural Resources, Great 

Plains Energy, and Kansas City Power & Light. Case settled March 27, 2007, providing 

offsets for over 6 million ton/yr of CO2 and lower NOx and SO2 emission limits.

 For plaintiffs, expert witness in remedy phase of civil action relating to alleged violations of 

the Clean Air Act, Prevention of Significant Deterioration, for historic modifications of coalfired boilers and associated equipment. Reviewed produced documents, prepared expert 

report on cost to retrofit 24 coal-fired power plants with scrubbers designed to remove 99% 

of the sulfur dioxide from flue gases. Prepared supplemental and expert report on cost 

estimates and BACT for SO2 for these 24 complaint units. Deposed 1/30/07 and 3/14/07. 

United States and State of New York et al. v. American Electric Power, In U.S. District Court 

for the Southern District of Ohio, Eastern Division, Consolidated Civil Action Nos. C2-99-

1182 and C2-99-1250. Settlement announced 10/9/07.

 For plaintiffs, expert witness on BACT, enforceability, and alternatives analysis in appeal of 

PSD permit issued for a 270-MW pulverized coal fired boiler burning Powder River Basin 

coal (City Utilities Springfield Unit 2). Reviewed permitting file and assisted counsel draft

petition and prepare and respond to interrogatories and document requests. Reviewed 

interrogatory responses and produced documents. Assisted with expert depositions. 

Deposed August 2005. Evidentiary hearings October 2005. In the Matter of Linda 

Chipperfield and Sierra Club v. Missouri Department of Natural Resources. Missouri 

Supreme Court denied review of adverse lower court rulings August 2007.

 For plaintiffs, expert witness in civil action relating to plume touchdowns at AEP’s Gavin 

coal-fired power plant. Assisted counsel draft interrogatories and document requests. 

Reviewed responses to interrogatories and produced documents. Prepared expert report 

“Releases of Sulfuric Acid Mist from the Gavin Power Station.” The report evaluates 
PHYLLIS FOX, PH.D., PAGE 7

sulfuric acid mist releases to determine if AEP complied with the requirements of CERCLA 

Section 103(a) and EPCRA Section 304. This report also discusses the formation, chemistry, 

release characteristics, and abatement of sulfuric acid mist in support of the claim that these 

releases present an imminent and substantial endangerment to public health under Section 

7002(a)(1)(B) of the Resource Conservation and Recovery Act (“RCRA”). Citizens Against 

Pollution v. Ohio Power Company, In the U.S. District Court for the Southern District of 

Ohio, Eastern Division, Civil Action No. 2-04-cv-371. Case settled 12-8-06.

 For petitioners, expert witness in contested case hearing on BACT, enforceability, and 

emission estimates for an air permit issued to a 500-MW supercritical Power River Basin 

coal-fired boiler (Weston Unit 4). Assisted counsel prepare comments on draft air permit 

and respond to and draft discovery. Reviewed produced file, deposed (7/05), and prepared 

expert report on BACT and enforceability. Evidentiary hearings September 2005. In the 

Matter of an Air Pollution Control Construction Permit Issued to Wisconsin Public Service 

Corporation for the Construction and Operation of a 500 MW Pulverized Coal-fired Power 

Plant Known as Weston Unit 4 in Marathon County, Wisconsin, Case No. IH-04-21. The 

Final Order, issued 2/10/06, lowered the NOx BACT limit from 0.07 lb/MMBtu to 0.06 

lb/MMBtu based on a 30-day average, added a BACT SO2 control efficiency, and required a 

0.0005% high efficiency drift eliminator as BACT for the cooling tower. The modified 

permit, including these provisions, was issued 3/28/07. Additional appeals in progress.

 For plaintiffs, adviser on technical issues related to Citizen Suit against U.S. EPA regarding 

failure to update New Source Performance Standards for petroleum refineries, 40 CFR 60, 

Subparts J, VV, and GGG. Our Children’s Earth Foundation and Sierra Club v. U.S. EPA et 

al. Case settled July 2005. CD No. C 05-00094 CW, U.S. District Court, Northern District of 

California – Oakland Division. Proposed revisions to standards of performance for 

petroleum refineries published 72 FR 27178 (5/14/07).

 For interveners, reviewed proposed Consent Decree settling Clean Air Act violations due to 

historic modifications of boilers and associated equipment at two coal-fired power plants. In 

response to stay order, reviewed the record, selected one representative activity at each of 

seven generating units, and analyzed to identify CAA violations. Identified NSPS and NSR 

violations for NOx, SO2, PM/PM10, and sulfuric acid mist. Summarized results in an expert 

report. United States of America, and Michael A. Cox, Attorney General of the State of 

Michigan, ex rel. Michigan Department of Environmental Quality, Plaintiffs, and Clean 

Wisconsin, Sierra Club, and Citizens' Utility Board, Intervenors, v. Wisconsin Electric 

Power Company, Defendant, U.S. District Court for the Eastern District of Wisconsin, Civil 

Action No. 2:03-CV-00371-CNC. Order issued 10-1-07 denying petition.

 For a coalition of Nevada labor organizations (ACE), reviewed preliminary determination to 

issue a Class I Air Quality Operating Permit to Construct and supporting files for a 250-MW 

pulverized coal-fired boiler (Newmont). Prepared about 100 pages of technical analyses and 
PHYLLIS FOX, PH.D., PAGE 8

comments on BACT, MACT, emission calculations, and enforceability. Assisted counsel 

draft petition and reply brief appealing PSD permit to U.S. EPA Environmental Appeals 

Board (EAB). Order denying review issued 12/21/05. In re Newmont Nevada Energy 

Investment, LLC, TS Power Plant, PSD Appeal No. 05-04 (EAB 2005).

 For petitioners and plaintiffs, reviewed and prepared comments on air quality and hazardous 

waste based on negative declaration for refinery ultra low sulfur diesel project located in 

SCAQMD. Reviewed responses to comments and prepared responses. Prepared declaration 

and presented oral testimony before SCAQMD Hearing Board on exempt sources (cooling 

towers) and calculation of potential to emit under NSR. Petition for writ of mandate filed 

March 2005. Case remanded by Court of Appeals to trial court to direct SCAQMD to reevaluate the potential environmental significance of NOx emissions resulting from the 

project in accordance with court’s opinion. California Court of Appeals, Second Appellate

Division, on December 18, 2007, affirmed in part (as to baseline) and denied in part. 

Communities for a Better Environment v. South Coast Air Quality Management District and 

ConocoPhillips and Carlos Valdez et al v. South Coast Air Quality Management District and 

ConocoPhillips. Certified for partial publication 1/16/08. Appellate Court opinion upheld by

CA Supreme Court 3/15/10.

 For amici seeking to amend a proposed Consent Decree to settle alleged NSR violations at 

Chevron refineries, reviewed proposed settlement, related files, subject modifications, and 

emission calculations. Prepared declaration on emission reductions, identification of NSR 

and NSPS violations, and BACT/LAER for FCCUs, heaters and boilers, flares, and sulfur 

recovery plants. U.S. et al. v. Chevron U.S.A., Northern District of California, Case No. C 

03-04650. Memorandum and Order Entering Consent Decree issued June 2005. Case No. C 

03-4650 CRB.

 For petitioners, prepared declaration on enforceability of periodic monitoring requirements, 

in response to EPA’s revised interpretation of 40 CFR 70.6(c)(1). This revision limited 

additional monitoring required in Title V permits. 69 FR 3203 (Jan. 22, 2004). 

Environmental Integrity Project et al. v. EPA (U.S. Court of Appeals for the District of 

Columbia). Court ruled the Act requires all Title V permits to contain monitoring 

requirements to assure compliance. Sierra Club v. EPA, 536 F.3d 673 (D.C. Cir. 2008).

 For interveners in application for authority to construct a 500 MW supercritical coal-fired 

generating unit before the Wisconsin Public Service Commission, prepared pre-filed written 

direct and rebuttal testimony with oral cross examination and rebuttal on BACT and MACT

(Weston 4). Prepared written comments on BACT, MACT, and enforceability on draft air 

permit for same facility.

 For property owners in Nevada, evaluated the environmental impacts of a 1,450-MW coalfired power plant proposed in a rural area adjacent to the Black Rock Desert and Granite 

Range, including emission calculations, air quality modeling, comments on proposed use 
PHYLLIS FOX, PH.D., PAGE 9

permit to collect preconstruction monitoring data, and coordination with agencies and other 

interested parties. Project cancelled.

 For environmental organizations, reviewed draft PSD permit for a 600-MW coal-fired power 

plant in West Virginia (Longview). Prepared comments on permit enforceability; coal 

washing; BACT for SO2 and PM10; Hg MACT; and MACT for HCl, HF, non-Hg metallic 

HAPs, and enforceability. Assist plaintiffs draft petition appealing air permit. Retained as 

expert to develop testimony on MACT, BACT, offsets, enforceability. Participate in 

settlement discussions. Case settled July 2004.

 For petitioners, reviewed record produced in discovery and prepared affidavit on emissions 

of carbon monoxide and volatile organic compounds during startup of GE 7FA combustion 

turbines to successfully establish plaintiff standing. Sierra Club et al. v. Georgia Power 

Company (Northern District of Georgia). 

 For building trades, reviewed air quality permitting action for 1500-MW coal-fired power 

plant before the Kentucky Department for Environmental Protection (Thoroughbred). 

 For petitioners, expert witness in administrative appeal of the PSD/Title V permit issued to a 

1500-MW coal-fired power plant. Reviewed over 60,000 pages of produced documents, 

prepared discovery index, identified and assembled plaintiff exhibits. Deposed. Assisted 

counsel in drafting discovery requests, with over 30 depositions, witness cross examination, 

and brief drafting. Presented over 20 days of direct testimony, rebuttal and sur-rebuttal, with 

cross examination on BACT for NOx, SO2, and PM/PM10; MACT for Hg and non-Hg 

metallic HAPs; emission estimates for purposes of Class I and II air modeling; risk 

assessment; and enforceability of permit limits. Evidentiary hearings from November 2003 to 

June 2004. Sierra Club et al. v. Natural Resources & Environmental Protection Cabinet, 

Division of Air Quality and Thoroughbred Generating Company et al. Hearing Officer 

Decision issued August 9, 2005 finding in favor of plaintiffs on counts as to risk, BACT 

(IGCC/CFB, NOx, SO2, Hg, Be), single source, enforceability, and errors and omissions. 

Assist counsel draft exceptions. Cabinet Secretary issued Order April 11, 2006 denying

Hearing Offer’s report, except as to NOx BACT, Hg, 99% SO2 control and certain errors and 

omissions.

 For citizens group in Massachusetts, reviewed, commented on, and participated in permitting 

of pollution control retrofits of coal-fired power plant (Salem Harbor).

 Assisted citizens group and labor union challenge issuance of conditional use permit for a

317,000 ft2discount store in Honolulu without any environmental review. In support of a motion 

for preliminary injunction, prepared 7-page declaration addressing public health impacts of 

diesel exhaust from vehicles serving the Project. In preparation for trial, prepared 20-page 

preliminary expert report summarizing results of diesel exhaust and noise measurements at two 

big box retail stores in Honolulu, estimated diesel PM10 concentrations for Project using ISCST, 

prepared a cancer health risk assessment based on these analyses, and evaluated noise impacts. 
PHYLLIS FOX, PH.D., PAGE 10

 Assisted environmental organizations to challenge the DOE Finding of No Significant Impact 

(FONSI) for the Baja California Power and Sempra Energy Resources Cross-Border 

Transmissions Lines in the U.S. and four associated power plants located in Mexico (DOE EA1391). Prepared 20-page declaration in support of motion for summary judgment addressing 

emissions, including CO2 and NH3, offsets, BACT, cumulative air quality impacts, alternative 

cooling systems, and water use and water quality impacts. Plaintiff’s motion for summary 

judgment granted in part. U.S. District Court, Southern District decision concluded that the 

Environmental Assessment and FONSI violated NEPA and the APA due to their inadequate 

analysis of the potential controversy surrounding the project, water impacts, impacts from NH3

and CO2, alternatives, and cumulative impacts. Border Power Plant Working Group v. 

Department of Energy and Bureau of Land Management, Case No. 02-CV-513-IEG (POR) (May 

2, 2003).

 For Sacramento school, reviewed draft air permit issued for diesel generator located across from 

playfield. Prepared comments on emission estimates, enforceability, BACT, and health impacts 

of diesel exhaust. Case settled. BUG trap installed on the diesel generator.

 Assisted unions in appeal of Title V permit issued by BAAQMD to carbon plant that 

manufactured coke. Reviewed District files, identified historic modifications that should 

have triggered PSD review, and prepared technical comments on Title V permit. Reviewed 

responses to comments and assisted counsel draft appeal to BAAQMD hearing board, 

opening brief, motion to strike, and rebuttal brief. Case settled.

 Assisted California Central Coast city obtain controls on a proposed new city that would 

straddle the Ventura-Los Angeles County boundary. Reviewed several environmental 

impact reports, prepared an air quality analysis, a diesel exhaust health risk assessment, and 

detailed review comments. Governor intervened and State dedicated the land for 

conservation purposes April 2004.

 Assisted Central California city to obtain controls on large alluvial sand quarry and asphalt 

plant proposing a modernization. Prepared comments on Negative Declaration on air 

quality, public health, noise, and traffic. Evaluated process flow diagrams and engineering 

reports to determine whether proposed changes increased plant capacity or substantially

modified plant operations. Prepared comments on application for categorical exemption 

from CEQA. Presented testimony to County Board of Supervisors. Developed controls to 

mitigate impacts. Assisted counsel draft Petition for Writ. Case settled June 2002. 

Substantial improvements in plant operations were obtained including cap on throughput, 

dust control measures, asphalt plant loadout enclosure, and restrictions on truck routes.

 Assisted oil companies on the California Central Coast in defending class action citizen’s

lawsuit alleging health effects due to emissions from gas processing plant and leaking 

underground storage tanks. Reviewed regulatory and other files and advised counsel on 

merits of case. Case settled November 2001.
PHYLLIS FOX, PH.D., PAGE 11

 Assisted oil company on the California Central Coast in defending property damage claims 

arising out of a historic oil spill. Reviewed site investigation reports, pump tests, leachability

studies, and health risk assessments, participated in design of additional site characterization 

studies to assess health impacts, and advised counsel on merits of case. Prepare health risk 

assessment.

 Assisted unions in appeal of Initial Study/Negative Declaration ("IS/ND") for an MTBE 

phaseout project at a Bay Area refinery. Reviewed IS/ND and supporting agency permitting 

files and prepared technical comments on air quality, groundwater, and public health 

impacts. Reviewed responses to comments and final IS/ND and ATC permits and assisted 

counsel to draft petitions and briefs appealing decision to Air District Hearing Board. 

Presented sworn direct and rebuttal testimony with cross examination on groundwater 

impacts of ethanol spills on hydrocarbon contamination at refinery. Hearing Board ruled 5 to 

0 in favor of appellants, remanding ATC to district to prepare an EIR.

 Assisted Florida cities in challenging the use of diesel and proposed BACT determinations in 

prevention of significant deterioration (PSD) permits issued to two 510-MW simple cycle 

peaking electric generating facilities and one 1,080-MW simple cycle/combined cycle 

facility. Reviewed permit applications, draft permits, and FDEP engineering evaluations, 

assisted counsel in drafting petitions and responding to discovery. Participated in settlement 

discussions. Cases settled or applications withdrawn.

 Assisted large California city in federal lawsuit alleging peaker power plant was violating its 

federal permit. Reviewed permit file and applicant's engineering and cost feasibility study to 

reduce emissions through retrofit controls. Advised counsel on feasible and cost-effective 

NOx, SOx, and PM10 controls for several 1960s diesel-fired Pratt and Whitney peaker 

turbines. Case settled.

 Assisted coalition of Georgia environmental groups in evaluating BACT determinations and 

permit conditions in PSD permits issued to several large natural gas-fired simple cycle and 

combined-cycle power plants. Prepared technical comments on draft PSD permits on BACT,

enforceability of limits, and toxic emissions. Reviewed responses to comments, advised

counsel on merits of cases, participated in settlement discussions, presented oral and written 

testimony in adjudicatory hearings, and provided technical assistance as required. Cases 

settled or won at trial.

 Assisted construction unions in review of air quality permitting actions before the Indiana 

Department of Environmental Management ("IDEM") for several natural gas-fired simple 

cycle peaker and combined cycle power plants.

 Assisted coalition of towns and environmental groups in challenging air permits issued to 

523 MW dual fuel (natural gas and distillate) combined-cycle power plant in Connecticut. 

Prepared technical comments on draft permits and 60 pages of written testimony addressing 

emission estimates, startup/shutdown issues, BACT/LAER analyses, and toxic air emissions. 
PHYLLIS FOX, PH.D., PAGE 12

Presented testimony in adjudicatory administrative hearings before the Connecticut 

Department of Environmental Protection in June 2001 and December 2001.

 Assisted various coalitions of unions, citizens groups, cities, public agencies, and developers 

in licensing and permitting of over 110 coal, gas, oil, biomass, and pet coke-fired power 

plants generating over 75,000 MW of electricity. These included base-load, combined cycle, 

simple cycle, and peaker power plants in Alaska, Arizona, Arkansas, California, Colorado, 

Georgia, Florida, Illinois, Indiana, Kentucky, Michigan, Missouri, Ohio, Oklahoma, Oregon, 

Texas, West Virginia, Wisconsin, and elsewhere. Prepared analyses of and comments on 

applications for certification, preliminary and final staff assessments, and various air, water, 

wastewater, and solid waste permits issued by local agencies. Presented written and oral 

testimony before various administrative bodies on hazards of ammonia use and 

transportation, health effects of air emissions, contaminated property issues, BACT/LAER 

issues related to SCR and SCONOx, criteria and toxic pollutant emission estimates, MACT 

analyses, air quality modeling, water supply and water quality issues, and methods to reduce 

water use, including dry cooling, parallel dry-wet cooling, hybrid cooling, and zero liquid 

discharge systems.

 Assisted unions, cities, and neighborhood associations in challenging an EIR issued for the 

proposed expansion of the Oakland Airport. Reviewed two draft EIRs and prepared a health 

risk assessment and extensive technical comments on air quality and public health impacts. 

The California Court of Appeals, First Appellate District, ruled in favor of appellants and 

plaintiffs, concluding that the EIR "2) erred in using outdated information in assessing the 

emission of toxic air contaminants (TACs) from jet aircraft; 3) failed to support its decision 

not to evaluate the health risks associated with the emission of TACs with meaningful 

analysis," thus accepting my technical arguments and requiring the Port to prepare a new 

EIR. See Berkeley Keep Jets Over the Bay Committee, City of San Leandro, and City of 

Alameda et al. v. Board of Port Commissioners (August 30, 2001) 111 Cal.Rptr.2d 598.

 Assisted lessor of former gas station with leaking underground storage tanks and TCE 

contamination from adjacent property. Lessor held option to purchase, which was forfeited 

based on misrepresentation by remediation contractor as to nature and extent of 

contamination. Remediation contractor purchased property. Reviewed regulatory agency

files and advised counsel on merits of case. Case not filed.

 Advised counsel on merits of several pending actions, including a Proposition 65 case 

involving groundwater contamination at an explosives manufacturing firm and two former 

gas stations with leaking underground storage tanks.

 Assisted defendant foundry in Oakland in a lawsuit brought by neighbors alleging property

contamination, nuisance, trespass, smoke, and health effects from foundry operation. 

Inspected and sampled plaintiff's property. Advised counsel on merits of case. Case settled.
PHYLLIS FOX, PH.D., PAGE 13

 Assisted business owner facing eminent domain eviction. Prepared technical comments on a 

negative declaration for soil contamination and public health risks from air emissions from a 

proposed redevelopment project in San Francisco in support of a CEQA lawsuit. Case 

settled.

 Assisted neighborhood association representing residents living downwind of a Berkeley

asphalt plant in separate nuisance and CEQA lawsuits. Prepared technical comments on air 

quality, odor, and noise impacts, presented testimony at commission and council meetings, 

participated in community workshops, and participated in settlement discussions. Cases 

settled. Asphalt plant was upgraded to include air emission and noise controls, including 

vapor collection system at truck loading station, enclosures for noisy equipment, and 

improved housekeeping.

 Assisted a Fortune 500 residential home builder in claims alleging health effects from faulty

installation of gas appliances. Conducted indoor air quality study, advised counsel on merits 

of case, and participated in discussions with plaintiffs. Case settled.

 Assisted property owners in Silicon Valley in lawsuit to recover remediation costs from 

insurer for large TCE plume originating from a manufacturing facility. Conducted 

investigations to demonstrate sudden and accidental release of TCE, including groundwater 

modeling, development of method to date spill, preparation of chemical inventory, 

investigation of historical waste disposal practices and standards, and on-site sewer and 

storm drainage inspections and sampling. Prepared declaration in opposition to motion for 

summary judgment. Case settled.

 Assisted residents in east Oakland downwind of a former battery plant in class action lawsuit 

alleging property contamination from lead emissions. Conducted historical research and dry

deposition modeling that substantiated claim. Participated in mediation at JAMS. Case 

settled.

 Assisted property owners in West Oakland who purchased a former gas station that had 

leaking underground storage tanks and groundwater contamination. Reviewed agency files 

and advised counsel on merits of case. Prepared declaration in opposition to summary

judgment. Prepared cost estimate to remediate site. Participated in settlement discussions. 

Case settled.

 Consultant to counsel representing plaintiffs in two Clean Water Act lawsuits involving 

selenium discharges into San Francisco Bay from refineries. Reviewed files and advised 

counsel on merits of case. Prepared interrogatory and discovery questions, assisted in 

deposing opposing experts, and reviewed and interpreted treatability and other technical 

studies. Judge ruled in favor of plaintiffs.

 Assisted oil company in a complaint filed by a resident of a small California beach 

community alleging that discharges of tank farm rinse water into the sanitary sewer system 

caused hydrogen sulfide gas to infiltrate residence, sending occupants to hospital. Inspected 
PHYLLIS FOX, PH.D., PAGE 14

accident site, interviewed parties to the event, and reviewed extensive agency files related to 

incident. Used chemical analysis, field simulations, mass balance calculations, sewer 

hydraulic simulations with SWMM44, atmospheric dispersion modeling with SCREEN3, 

odor analyses, and risk assessment calculations to demonstrate that the incident was caused 

by a faulty drain trap and inadequate slope of sewer lateral on resident's property. Prepared a 

detailed technical report summarizing these studies. Case settled.

 Assisted large West Coast city in suit alleging that leaking underground storage tanks on city

property had damaged the waterproofing on downgradient building, causing leaks in an 

underground parking structure. Reviewed subsurface hydrogeologic investigations and 

evaluated studies conducted by others documenting leakage from underground diesel and 

gasoline tanks. Inspected, tested, and evaluated waterproofing on subsurface parking 

structure. Waterproofing was substandard. Case settled.

 Assisted residents downwind of gravel mine and asphalt plant in Siskiyou County, 

California, in suit to obtain CEQA review of air permitting action. Prepared two declarations 

analyzing air quality and public health impacts. Judge ruled in favor of plaintiffs, closing 

mine and asphalt plant.

 Assisted defendant oil company on the California Central Coast in class action lawsuit 

alleging property damage and health effects from subsurface petroleum contamination. 

Reviewed documents, prepared risk calculations, and advised counsel on merits of case. 

Participated in settlement discussions. Case settled.

 Assisted defendant oil company in class action lawsuit alleging health impacts from 

remediation of petroleum contaminated site on California Central Coast. Reviewed 

documents, designed and conducted monitoring program, and participated in settlement 

discussions. Case settled.

 Consultant to attorneys representing irrigation districts and municipal water districts to 

evaluate a potential challenge of USFWS actions under CVPIA section 3406(b)(2). 

Reviewed agency files and collected and analyzed hydrology, water quality, and fishery data. 

Advised counsel on merits of case. Case not filed.

 Assisted residents downwind of a Carson refinery in class action lawsuit involving soil and 

groundwater contamination, nuisance, property damage, and health effects from air 

emissions. Reviewed files and provided advise on contaminated soil and groundwater, toxic 

emissions, and health risks. Prepared declaration on refinery fugitive emissions. Prepared 

deposition questions and reviewed deposition transcripts on air quality, soil contamination, 

odors, and health impacts. Case settled.

 Assisted residents downwind of a Contra Costa refinery who were affected by an accidental 

release of naphtha. Characterized spilled naphtha, estimated emissions, and modeled 

ambient concentrations of hydrocarbons and sulfur compounds. Deposed. Presented 

testimony in binding arbitration at JAMS. Judge found in favor of plaintiffs.
PHYLLIS FOX, PH.D., PAGE 15

 Assisted residents downwind of Contra Costa County refinery in class action lawsuit alleging 

property damage, nuisance, and health effects from several large accidents as well as routine 

operations. Reviewed files and prepared analyses of environmental impacts. Prepared 

declarations, deposed, and presented testimony before jury in one trial and judge in second. 

Case settled.

 Assisted business owner claiming damages from dust, noise, and vibration during a sewer 

construction project in San Francisco. Reviewed agency files and PM10 monitoring data and 

advised counsel on merits of case. Case settled.

 Assisted residents downwind of Contra Costa County refinery in class action lawsuit alleging 

property damage, nuisance, and health effects. Prepared declaration in opposition to 

summary judgment, deposed, and presented expert testimony on accidental releases, odor, 

and nuisance before jury. Case thrown out by judge, but reversed on appeal and not retried.

 Presented testimony in small claims court on behalf of residents claiming health effects from 

hydrogen sulfide from flaring emissions triggered by a power outage at a Contra Costa 

County refinery. Analyzed meteorological and air quality data and evaluated potential health 

risks of exposure to low concentrations of hydrogen sulfide. Judge awarded damages to 

plaintiffs.

 Assisted construction unions in challenging PSD permit for an Indiana steel mill. Prepared 

technical comments on draft PSD permit, drafted 70-page appeal of agency permit action to 

the Environmental Appeals Board challenging permit based on faulty BACT analysis for 

electric arc furnace and reheat furnace and faulty permit conditions, among others, and 

drafted briefs responding to four parties. EPA Region V and the EPA General Counsel 

intervened as amici, supporting petitioners. EAB ruled in favor of petitioners, remanding 

permit to IDEM on three key issues, including BACT for the reheat furnace and lead 

emissions from the EAF. Drafted motion to reconsider three issues. Prepared 69 pages of 

technical comments on revised draft PSD permit. Drafted second EAB appeal addressing 

lead emissions from the EAF and BACT for reheat furnace based on European experience 

with SCR/SNCR. Case settled. Permit was substantially improved. See In re: Steel 

Dynamics, Inc., PSD Appeal Nos. 99-4 & 99-5 (EAB June 22, 2000).

 Assisted defendant urea manufacturer in Alaska in negotiations with USEPA to seek relief 

from penalties for alleged violations of the Clean Air Act. Reviewed and evaluated 

regulatory files and monitoring data, prepared technical analysis demonstrating that permit 

limits were not violated, and participated in negotiations with EPA to dismiss action. Fines 

were substantially reduced and case closed.

 Assisted construction unions in challenging PSD permitting action for an Indiana grain mill. 

Prepared technical comments on draft PSD permit and assisted counsel draft appeal of 

agency permit action to the Environmental Appeals Board challenging permit based on faulty
PHYLLIS FOX, PH.D., PAGE 16

BACT analyses for heaters and boilers and faulty permit conditions, among others. Case 

settled.

 As part of a consent decree settling a CEQA lawsuit, assisted neighbors of a large west coast 

port in negotiations with port authority to secure mitigation for air quality impacts. Prepared 

technical comments on mobile source air quality impacts and mitigation and negotiated a $9 

million CEQA mitigation package. Represented neighbors on technical advisory committee 

established by port to implement the air quality mitigation program. Program successfully 

implemented.

 Assisted construction unions in challenging permitting action for a California hazardous 

waste incinerator. Prepared technical comments on draft permit, assisted counsel prepare 

appeal of EPA permit to the Environmental Appeals Board. Participated in settlement 

discussions on technical issues with applicant and EPA Region 9. Case settled.

 Assisted environmental group in challenging DTSC Negative Declaration on a hazardous 

waste treatment facility. Prepared technical comments on risk of upset, water, and health 

risks. Writ of mandamus issued.

 Assisted several neighborhood associations and cities impacted by quarries, asphalt plants, 

and cement plants in Alameda, Shasta, Sonoma, and Mendocino counties in obtaining 

mitigations for dust, air quality, public health, traffic, and noise impacts from facility

operations and proposed expansions.

 For over 100 industrial facilities, commercial/campus, and redevelopment projects, 

developed the record in preparation for CEQA and NEPA lawsuits. Prepared technical 

comments on hazardous materials, solid wastes, public utilities, noise, worker safety, air 

quality, public health, water resources, water quality, traffic, and risk of upset sections of 

EIRs, EISs, FONSIs, initial studies, and negative declarations. Assisted counsel in drafting 

petitions and briefs and prepared declarations.

 For several large commercial development projects and airports, assisted applicant and 

counsel prepare defensible CEQA documents, respond to comments, and identify and 

evaluate "all feasible" mitigation to avoid CEQA challenges. This work included developing 

mitigation programs to reduce traffic-related air quality impacts based on energy

conservation programs, solar, low-emission vehicles, alternative fuels, exhaust treatments, 

and transportation management associations.

SITE INVESTIGATION/REMEDIATION/CLOSURE

 Technical manager and principal engineer for characterization, remediation, and closure of 

waste management units at former Colorado oil shale plant. Constituents of concern 

included BTEX, As, 1,1,1-TCA, and TPH. Completed groundwater monitoring programs, 
PHYLLIS FOX, PH.D., PAGE 17

site assessments, work plans, and closure plans for seven process water holding ponds, a 

refinery sewer system, and processed shale disposal area. Managed design and construction 

of groundwater treatment system and removal actions and obtained clean closure.

 Principal engineer for characterization, remediation, and closure of process water ponds at a 

former lanthanide processing plant in Colorado. Designed and implemented groundwater 

monitoring program and site assessments and prepared closure plan.

 Advised the city of Sacramento on redevelopment of two former railyards. Reviewed work 

plans, site investigations, risk assessment, RAPS, RI/FSs, and CEQA documents. 

Participated in the development of mitigation strategies to protect construction and utility

workers and the public during remediation, redevelopment, and use of the site, including 

buffer zones, subslab venting, rail berm containment structure, and an environmental 

oversight plan.

 Provided technical support for the investigation of a former sanitary landfill that was 

redeveloped as single family homes. Reviewed and/or prepared portions of numerous 

documents, including health risk assessments, preliminary endangerment assessments, site 

investigation reports, work plans, and RI/FSs. Historical research to identify historic waste 

disposal practices to prepare a preliminary endangerment assessment. Acquired, reviewed, 

and analyzed the files of 18 federal, state, and local agencies, three sets of construction field 

notes, analyzed 21 aerial photographs and interviewed 14 individuals associated with 

operation of former landfill. Assisted counsel in defending lawsuit brought by residents 

alleging health impacts and diminution of property value due to residual contamination. 

Prepared summary reports.

 Technical oversight of characterization and remediation of a nitrate plume at an explosives 

manufacturing facility in Lincoln, CA. Provided interface between owners and consultants. 

Reviewed site assessments, work plans, closure plans, and RI/FSs.

 Consultant to owner of large western molybdenum mine proposed for NPL listing. 

Participated in negotiations to scope out consent order and develop scope of work. 

Participated in studies to determine premining groundwater background to evaluate 

applicability of water quality standards. Served on technical committees to develop 

alternatives to mitigate impacts and close the facility, including resloping and grading, 

various thickness and types of covers, and reclamation. This work included developing and 

evaluating methods to control surface runoff and erosion, mitigate impacts of acid rock 

drainage on surface and ground waters, and stabilize nine waste rock piles containing 328 

million tons of pyrite-rich, mixed volcanic waste rock (andesites, rhyolite, tuff). Evaluated 

stability of waste rock piles. Represented client in hearings and meetings with state and 

federal oversight agencies.
PHYLLIS FOX, PH.D., PAGE 18

REGULATORY (PARTIAL LIST)

 Identified errors in N2O emission factors in the Mandatory Greenhouse Gas Reporting Rule, 

40 CFR 98, and prepared technical analysis to support Petition for Rulemaking to Correct 

Emissions Factors in the Mandatory Greenhouse Gas Reporting Rule, filed with EPA on 

10/28/10.

 Assist interested parties develop input for and prepare comments on the Information 

Collection Request for Petroleum Refinery Sector NSPS and NESHAP Residual Risk and 

Technology Review, 75 FR 60107 (9/29/10).

 Technical reviewer of EPA's "Emission Estimation Protocol for Petroleum Refineries," 

posted for public comments on CHIEF on 12/23/09, prepared in response to the City of 

Houston's petition under the Data Quality Act. (March 2010)

 Prepared comments on SCR cost effectiveness for EPA's Advanced Notice of Proposed 

Rulemaking, Assessment of Anticipated Visibility Improvements at Surrounding Class I 

Areas and Cost Effectiveness of Best Available Retrofit Technology for Four Corners Power 

Plant and Navajo Generating Station, 74 FR 44313 (August 28, 2009).

 Prepared comments on Proposed Rule for Standards of Performance for Coal Preparation and 

Processing Plants, 74 FR 25304 (May 27, 2009).

 Reviewed and assisted interested parties prepare comments on proposed Kentucky air toxic 

regulations at 401 KAR 64:005, 64:010, 64:020, and 64:030 (June 2007).

 Prepared comments on proposed Standards of Performance for Electric Utility Steam 

Generating Units and Small Industrial-Commercial-Industrial Steam Generating Units, 70 

FR 9706 (February 28, 2005).

 Prepared comments on Louisville Air Pollution Control District proposed Strategic Toxic Air 

Reduction regulations.

 Prepared comments and analysis of BAAQMD Regulation, Rule 11, Flare Monitoring at 

Petroleum Refineries.

 Prepared comments on Proposed National Emission Standards for Hazardous Air Pollutants; 

and, in the Alternative, Proposed Standards of Performance for New and Existing Stationary

Sources: Electricity Utility Steam Generating Units (MACT standards for coal-fired power 

plants).

 Prepared Authority to Construct Permit for remediation of a large petroleum-contaminated 

site on the California Central Coast. Negotiated conditions with agencies and secured 

permits.

 Prepared Authority to Construct Permit for remediation of a former oil field on the California 

Central Coast. Participated in negotiations with agencies and secured permits.
PHYLLIS FOX, PH.D., PAGE 19

 Prepared and/or reviewed hundreds of environmental permits, including NPDES, UIC, 

Stormwater, Authority to Construct, Prevention of Significant Deterioration, Nonattainment 

New Source Review, and RCRA, among others. 

 Participated in the development of the CARB document, Guidance for Power Plant Siting 

and Best Available Control Technology, including attending public workshops and filing 

technical comments.

 Performed data analyses in support of adoption of emergency power restoration standards by 

the Public Utilities Commission for “major” power outages, where major is an outage that 

simultaneously affects 10% of the customer base.

 Drafted portions of the Good Neighbor Ordinance to grant Contra Costa County greater 

authority over safety of local industry, particularly chemical plants and refineries.

 Participated in drafting BAAQMD Regulation 8, Rule 28, Pressure Relief Devices, 

including participation in public workshops, review of staff reports, draft rules and other 

technical materials, preparation of technical comments on staff proposals, research on 

availability and costs of methods to control PRV releases, and negotiations with staff.

 Participated in amending BAAQMD Regulation 8, Rule 18, Valves and Connectors, 

including participation in public workshops, review of staff reports, proposed rules and other 

supporting technical material, preparation of technical comments on staff proposals, research 

on availability and cost of low-leak technology, and negotiations with staff.

 Participated in amending BAAQMD Regulation 8, Rule 25, Pumps and Compressors, 

including participation in public workshops, review of staff reports, proposed rules, and other 

supporting technical material, preparation of technical comments on staff proposals, research 

on availability and costs of low-leak and seal-less technology, and negotiations with staff.

 Participated in amending BAAQMD Regulation 8, Rule 5, Storage of Organic Liquids, 

including participation in public workshops, review of staff reports, proposed rules, and other 

supporting technical material, preparation of technical comments on staff proposals, research 

on availability and costs of controlling tank emissions, and presentation of testimony before 

the Board.

 Participated in amending BAAQMD Regulation 8, Rule 18, Valves and Connectors at 

Petroleum Refinery Complexes, including participation in public workshops, review of staff 

reports, proposed rules and other supporting technical material, preparation of technical 

comments on staff proposals, research on availability and costs of low-leak technology, and 

presentation of testimony before the Board.

 Participated in amending BAAQMD Regulation 8, Rule 22, Valves and Flanges at Chemical 

Plants, etc, including participation in public workshops, review of staff reports, proposed 

rules, and other supporting technical material, preparation of technical comments on staff 
PHYLLIS FOX, PH.D., PAGE 20

proposals, research on availability and costs of low-leak technology, and presentation of 

testimony before the Board.

 Participated in amending BAAQMD Regulation 8, Rule 25, Pump and Compressor Seals, 

including participation in public workshops, review of staff reports, proposed rules, and other 

supporting technical material, preparation of technical comments on staff proposals, research 

on availability of low-leak technology, and presentation of testimony before the Board.

 Participated in the development of the BAAQMD Regulation 2, Rule 5, Toxics, including 

participation in public workshops, review of staff proposals, and preparation of technical 

comments.

 Participated in the development of SCAQMD Rule 1402, Control of Toxic Air Contaminants 

from Existing Sources, and proposed amendments to Rule 1401, New Source Review of 

Toxic Air Contaminants, in 1993, including review of staff proposals and preparation of 

technical comments on same.

 Participated in the development of the Sunnyvale Ordinance to Regulate the Storage, Use 

and Handling of Toxic Gas, which was designed to provide engineering controls for gases 

that are not otherwise regulated by the Uniform Fire Code.

 Participated in the drafting of the Statewide Water Quality Control Plans for Inland Surface 

Waters and Enclosed Bays and Estuaries, including participation in workshops, review of 

draft plans, preparation of technical comments on draft plans, and presentation of testimony

before the SWRCB.

 Participated in developing Se permit effluent limitations for the five Bay Area refineries, 

including review of staff proposals, statistical analyses of Se effluent data, review of 

literature on aquatic toxicity of Se, preparation of technical comments on several staff 

proposals, and presentation of testimony before the Bay Area RWQCB.

 Represented the California Department of Water Resources in the 1991 Bay-Delta Hearings 

before the State Water Resources Control Board, presenting sworn expert testimony with 

cross examination and rebuttal on a striped bass model developed by the California 

Department of Fish and Game.

 Represented the State Water Contractors in the 1987 Bay-Delta Hearings before the State 

Water Resources Control Board, presenting sworn expert testimony with cross examination 

and rebuttal on natural flows, historical salinity trends in San Francisco Bay, Delta outflow, 

and hydrodynamics of the South Bay.

 Represented interveners in the licensing of over 20 natural-gas-fired power plants and one 

coal gasification plant at the California Energy Commission and elsewhere. Reviewed and 

prepared technical comments on applications for certification, preliminary staff assessments, 

final staff assessments, preliminary determinations of compliance, final determinations of 

compliance, and prevention of significant deterioration permits in the areas of air quality, 
PHYLLIS FOX, PH.D., PAGE 21

water supply, water quality, biology, public health, worker safety, transportation, site 

contamination, cooling systems, and hazardous materials. Presented written and oral 

testimony in evidentiary hearings with cross examination and rebuttal. Participated in 

technical workshops.

 Represented several parties in the proposed merger of San Diego Gas & Electric and 

Southern California Edison. Prepared independent technical analyses on health risks, air 

quality, and water quality. Presented written and oral testimony before the Public Utilities 

Commission administrative law judge with cross examination and rebuttal.

 Represented a PRP in negotiations with local health and other agencies to establish impact of 

subsurface contamination on overlying residential properties. Reviewed health studies 

prepared by agency consultants and worked with agencies and their consultants to evaluate 

health risks.

WATER QUALITY/RESOURCES

 Directed and participated in research on environmental impacts of energy development in the 

Colorado River Basin, including contamination of surface and subsurface waters and 

modeling of flow and chemical transport through fractured aquifers.

 Played a major role in Northern California water resource planning studies since the early

1970s. Prepared portions of the Basin Plans for the Sacramento, San Joaquin, and Delta 

basins including sections on water supply, water quality, beneficial uses, waste load 

allocation, and agricultural drainage. Developed water quality models for the Sacramento 

and San Joaquin Rivers.

 Conducted hundreds of studies over the past 30 years on Delta water supplies and the 

impacts of exports from the Delta on water quality and biological resources of the Central 

Valley, Sacramento-San Joaquin Delta, and San Francisco Bay. Typical examples include:

1. Evaluate historical trends in salinity, temperature, and flow in San Francisco Bay

and upstream rivers to determine impacts of water exports on the estuary; 

2. Evaluate the role of exports and natural factors on the food web by exploring the 

relationship between salinity and primary productivity in San Francisco Bay, 

upstream rivers, and ocean;

3. Evaluate the effects of exports, other in-Delta, and upstream factors on the 

abundance of salmon and striped bass; 

4. Review and critique agency fishery models that link water exports with the 

abundance of striped bass and salmon; 

5. Develop a model based on GLMs to estimate the relative impact of exports, 

water facility operating variables, tidal phase, salinity, temperature, and other 

variables on the survival of salmon smolts as they migrate through the Delta;
PHYLLIS FOX, PH.D., PAGE 22

6. Reconstruct the natural hydrology of the Central Valley using water balances, 

vegetation mapping, reservoir operation models to simulate flood basins, 

precipitation records, tree ring research, and historical research;

7. Evaluate the relationship between biological indicators of estuary health and 

down-estuary position of a salinity surrogate (X2); 

8. Use real-time fisheries monitoring data to quantify impact of exports on fish 

migration; 

9. Refine/develop statistical theory of autocorrelation and use to assess strength of 

relationships between biological and flow variables;

10. Collect, compile, and analyze water quality and toxicity data for surface waters in 

the Central Valley to assess the role of water quality in fishery declines; 

11. Assess mitigation measures, including habitat restoration and changes in water 

project operation, to minimize fishery impacts; 

12. Evaluate the impact of unscreened agricultural water diversions on abundance of 

larval fish; 

13. Prepare and present testimony on the impacts of water resources development on 

Bay hydrodynamics, salinity, and temperature in water rights hearings; 

14. Evaluate the impact of boat wakes on shallow water habitat, including 

interpretation of historical aerial photographs;

15. Evaluate the hydrodynamic and water quality impacts of converting Delta islands 

into reservoirs; 

16. Use a hydrodynamic model to simulate the distribution of larval fish in a tidally

influenced estuary;

17. Identify and evaluate non-export factors that may have contributed to fishery

declines, including predation, shifts in oceanic conditions, aquatic toxicity from 

pesticides and mining wastes, salinity intrusion from channel dredging, loss of 

riparian and marsh habitat, sedimentation from upstream land alternations, and 

changes in dissolved oxygen, flow, and temperature below dams.

 Developed, directed, and participated in a broad-based research program on environmental 

issues and control technology for energy industries including petroleum, oil shale, coal 

mining, and coal slurry transport. Research included evaluation of air and water pollution, 

development of novel, low-cost technology to treat and dispose of wastes, and development 

and application of geohydrologic models to evaluate subsurface contamination from in-situ 
PHYLLIS FOX, PH.D., PAGE 23

retorting. The program consisted of government and industry contracts and employed 45 

technical and administrative personnel.

 Coordinated an industry task force established to investigate the occurrence, causes, and 

solutions for corrosion/erosion and mechanical/engineering failures in the waterside systems 

(e.g., condensers, steam generation equipment) of power plants. Corrosion/erosion failures 

caused by water and steam contamination that were investigated included waterside 

corrosion caused by poor microbiological treatment of cooling water, steam-side corrosion 

caused by ammonia-oxygen attack of copper alloys, stress-corrosion cracking of copper 

alloys in the air cooling sections of condensers, tube sheet leaks, oxygen in-leakage through 

condensers, volatilization of silica in boilers and carry over and deposition on turbine blades, 

and iron corrosion on boiler tube walls. Mechanical/engineering failures investigated 

included: steam impingement attack on the steam side of condenser tubes, tube-to-tube-sheet 

joint leakage, flow-induced vibration, structural design problems, and mechanical failures 

due to stresses induced by shutdown, startup and cycling duty, among others. Worked with 

electric utility plant owners/operators, condenser and boiler vendors, and architect/engineers 

to collect data to document the occurrence of and causes for these problems, prepared reports 

summarizing the investigations, and presented the results and participated on a committee of 

industry experts tasked with identifying solutions to prevent condenser failures.

 Evaluated the cost effectiveness and technical feasibility of using dry cooling and parallel 

dry-wet cooling to reduce water demands of several large natural-gas fired power plants in 

California and Arizona.

 Designed and prepared cost estimates for several dry cooling systems (e.g., fin fan heat 

exchangers) used in chemical plants and refineries.

 Designed, evaluated, and costed several zero liquid discharge systems for power plants.

 Evaluated the impact of agricultural and mining practices on surface water quality of Central 

Valley steams. Represented municipal water agencies on several federal and state advisory

committees tasked with gathering and assessing relevant technical information, developing 

work plans, and providing oversight of technical work to investigate toxicity issues in the 

watershed.

AIR QUALITY/PUBLIC HEALTH

 Prepared or reviewed the air quality and public health sections of hundreds of EIRs and EISs 

on a wide range of industrial, commercial and residential projects.

 Prepared or reviewed hundreds of NSR and PSD permits for a wide range of industrial 

facilities.

 Designed, implemented, and directed a 2-year-long community air quality monitoring 

program to assure that residents downwind of a petroleum-contaminated site were not 
PHYLLIS FOX, PH.D., PAGE 24

impacted during remediation of petroleum-contaminated soils. The program included realtime monitoring of particulates, diesel exhaust, and BTEX and time integrated monitoring

for over 100 chemicals.

 Designed, implemented, and directed a 5-year long source, industrial hygiene, and ambient 

monitoring program to characterize air emissions, employee exposure, and downwind 

environmental impacts of a first-generation shale oil plant. The program included stack 

monitoring of heaters, boilers, incinerators, sulfur recovery units, rock crushers, API 

separator vents, and wastewater pond fugitives for arsenic, cadmium, chlorine, chromium, 

mercury, 15 organic indicators (e.g., quinoline, pyrrole, benzo(a)pyrene, thiophene, benzene),

sulfur gases, hydrogen cyanide, and ammonia. In many cases, new methods had to be 

developed or existing methods modified to accommodate the complex matrices of shale plant 

gases.

 Conducted investigations on the impact of diesel exhaust from truck traffic from a wide 

range of facilities including mines, large retail centers, light industrial uses, and sports 

facilities. Conducted traffic surveys, continuously monitored diesel exhaust using an 

aethalometer, and prepared health risk assessments using resulting data.

 Conducted indoor air quality investigations to assess exposure to natural gas leaks, 

pesticides, molds and fungi, soil gas from subsurface contamination, and outgasing of 

carpets, drapes, furniture and construction materials. Prepared health risk assessments using 

collected data.

 Prepared health risk assessments, emission inventories, air quality analyses, and assisted in 

the permitting of over 70 1 to 2 MW emergency diesel generators.

 Prepare over 100 health risk assessments, endangerment assessments, and other health-based 

studies for a wide range of industrial facilities.

 Developed methods to monitor trace elements in gas streams, including a continuous realtime monitor based on the Zeeman atomic absorption spectrometer, to continuously measure 

mercury and other elements.

 Performed nuisance investigations (odor, noise, dust, smoke, indoor air quality, soil 

contamination) for businesses, industrial facilities, and residences located proximate to and 

downwind of pollution sources.

PUBLICATIONS AND PRESENTATIONS (Partial List - Representative 

Publications)

J.P. Fox, T.P. Rose, and T.L. Sawyer, Isotope Hydrology of a Spring-fed Waterfall in Fractured 

Volcanic Rock, Submitted to Journal of Hydrology, 2007.
PHYLLIS FOX, PH.D., PAGE 25

C.E. Lambert, E.D. Winegar, and Phyllis Fox, Ambient and Human Sources of Hydrogen 

Sulfide: An Explosive Topic, Air & Waste Management Association, June 2000, Salt Lake City, 

UT.

San Luis Obispo County Air Pollution Control District and San Luis Obispo County Public 

Health Department, Community Monitoring Program, February 8, 1999.

The Bay Institute, From the Sierra to the Sea. The Ecological History of the San Francisco BayDelta Watershed, 1998.

J. Phyllis Fox, Well Interference Effects of HDPP’s Proposed Wellfield in the Victor Valley 

Water District, Prepared for the California Unions for Reliable Energy (CURE), October 12, 

1998.

J. Phyllis Fox, Air Quality Impacts of Using CPVC Pipe in Indoor Residential Potable Water 

Systems, Report Prepared for California Pipe Trades Council, California Firefighters Association, 

and other trade associations, August 29, 1998.

J. Phyllis Fox and others, Authority to Construct Avila Beach Remediation Project, Prepared for 

Unocal Corporation and submitted to San Luis Obispo Air Pollution Control District, June 1998.

J. Phyllis Fox and others, Authority to Construct Former Guadalupe Oil Field Remediation 

Project, Prepared for Unocal Corporation and submitted to San Luis Obispo Air Pollution 

Control District, May 1998.

J. Phyllis Fox and Robert Sears, Health Risk Assessment for the Metropolitan Oakland 

International Airport Proposed Airport Development Program, Prepared for Plumbers & 

Steamfitters U.A. Local 342, December 15, 1997.

Levine-Fricke-Recon (Phyllis Fox and others), Preliminary Endangerment Assessment Work 

Plan for the Study Area Operable Unit, Former Solano County Sanitary Landfill, Benicia, 

California, Prepared for Granite Management Co. for submittal to DTSC, September 26, 1997.

Phyllis Fox and Jeff Miller, "Fathead Minnow Mortality in the Sacramento River," IEP 

Newsletter, v. 9, n. 3, 1996.

Jud Monroe, Phyllis Fox, Karen Levy, Robert Nuzum, Randy Bailey, Rod Fujita, and Charles 

Hanson, Habitat Restoration in Aquatic Ecosystems. A Review of the Scientific Literature 

Related to the Principles of Habitat Restoration, Part Two, Metropolitan Water District of 

Southern California (MWD) Report, 1996.

Phyllis Fox and Elaine Archibald, Aquatic Toxicity and Pesticides in Surface Waters of the 

Central Valley, California Urban Water Agencies (CUWA) Report, September 1997.

Phyllis Fox and Alison Britton, Evaluation of the Relationship Between Biological Indicators 

and the Position of X2, CUWA Report, 1994.
PHYLLIS FOX, PH.D., PAGE 26

Phyllis Fox and Alison Britton, Predictive Ability of the Striped Bass Model, WRINT DWR-206, 

1992.

J. Phyllis Fox, An Historical Overview of Environmental Conditions at the North Canyon Area of 

the Former Solano County Sanitary Landfill, Report Prepared for Solano County Department of 

Environmental Management, 1991.

J. Phyllis Fox, An Historical Overview of Environmental Conditions at the East Canyon Area of 

the Former Solano County Sanitary Landfill, Report Prepared for Solano County Department of 

Environmental Management, 1991.

Phyllis Fox, Trip 2 Report, Environmental Monitoring Plan, Parachute Creek Shale Oil 

Program, Unocal Report, 1991.

J. P. Fox and others, "Long-Term Annual and Seasonal Trends in Surface Salinity of San 

Francisco Bay," Journal of Hydrology, v. 122, p. 93-117, 1991.

J. P. Fox and others, "Reply to Discussion by D.R. Helsel and E.D. Andrews on Trends in 

Freshwater Inflow to San Francisco Bay from the Sacramento-San Joaquin Delta," Water 

Resources Bulletin, v. 27, no. 2, 1991.

J. P. Fox and others, "Reply to Discussion by Philip B. Williams on Trends in Freshwater Inflow 

to San Francisco Bay from the Sacramento-San Joaquin Delta," Water Resources Bulletin, v. 27, 

no. 2, 1991.

J. P. Fox and others, "Trends in Freshwater Inflow to San Francisco Bay from the SacramentoSan Joaquin Delta," Water Resources Bulletin, v. 26, no. 1, 1990.

J. P. Fox, "Water Development Increases Freshwater Flow to San Francisco Bay," SCWC 

Update, v. 4, no. 2, 1988.

J. P. Fox, Freshwater Inflow to San Francisco Bay Under Natural Conditions, State Water 

Contracts, Exhibit 262, 58 pp., 1987.

J. P. Fox, "The Distribution of Mercury During Simulated In-Situ Oil Shale Retorting," 

Environmental Science and Technology, v. 19, no. 4, pp. 316-322, 1985.

J. P. Fox, "El Mercurio en el Medio Ambiente: Aspectos Referentes al Peru," (Mercury in the 

Environment: Factors Relevant to Peru) Proceedings of Simposio Los Pesticidas y el Medio 

Ambiente," ONERN-CONCYTEC, Lima, Peru, April 25-27, 1984. (Also presented at Instituto 

Tecnologico Pesquero and Instituto del Mar del Peru.)

J. P. Fox, "Mercury, Fish, and the Peruvian Diet," Boletin de Investigacion, Instituto Tecnologico 

Pesquero, Lima, Peru, v. 2, no. 1, pp. 97-116, l984.

J. P. Fox, P. Persoff, A. Newton, and R. N. Heistand, "The Mobility of Organic Compounds in a 

Codisposal System," Proceedings of the Seventeenth Oil Shale Symposium, Colorado School of 

Mines Press, Golden, CO, 1984.
PHYLLIS FOX, PH.D., PAGE 27

P. Persoff and J. P. Fox, "Evaluation of Control Technology for Modified In-Situ Oil Shale 

Retorts," Proceedings of the Sixteenth Oil Shale Symposium, Colorado School of Mines Press, 

Golden, CO, 1983.

J. P. Fox, Leaching of Oil Shale Solid Wastes: A Critical Review, University of Colorado 

Report, 245 pp., July 1983.

J. P. Fox, Source Monitoring for Unregulated Pollutants from the White River Oil Shale Project, 

VTN Consolidated Report, June 1983.

A. S. Newton, J. P. Fox, H. Villarreal, R. Raval, and W. Walker II, Organic Compounds in Coal 

Slurry Pipeline Waters, Lawrence Berkeley Laboratory Report LBL-15121, 46 pp., Sept. 1982.

M. Goldstein et al., High Level Nuclear Waste Standards Analysis, Regulatory Framework 

Comparison, Battelle Memorial Institute Report No. BPMD/82/E515-06600/3, Sept. 1982.

J. P. Fox et al., Literature and Data Search of Water Resource Information of the Colorado, 

Utah, and Wyoming Oil Shale Basins, Vols. 1-12, Bureau of Land Management, 1982.

A. T. Hodgson, M. J. Pollard, G. J. Harris, D. C. Girvin, J. P. Fox, and N. J. Brown, Mercury 

Mass Distribution During Laboratory and Simulated In-Situ Retorting, Lawrence Berkeley

Laboratory Report LBL-12908, 39 pp., Feb. 1982.

E. J. Peterson, A. V. Henicksman, J. P. Fox, J. A. O'Rourke, and P. Wagner, Assessment and 

Control of Water Contamination Associated with Shale Oil Extraction and Processing, Los 

Alamos National Laboratory Report LA-9084-PR, 54 pp., April 1982.

P. Persoff and J. P. Fox, Control Technology for In-Situ Oil Shale Retorts, Lawrence Berkeley

Laboratory Report LBL-14468, 118 pp., Dec. 1982.

J. P. Fox, Codisposal Evaluation: Environmental Significance of Organic Compounds, 

Development Engineering Report, 104 pp., April 1982.

J. P. Fox, A Proposed Strategy for Developing an Environmental Water Monitoring Plan for the 

Paraho-Ute Project, VTN Consolidated Report, Sept. 1982.

J. P. Fox, D. C. Girvin, and A. T. Hodgson, "Trace Elements in Oil Shale Materials," Energy and 

Environmental Chemistry, Fossil Fuels, v.1, pp. 69-101, 1982.

M. Mehran, T. N. Narasimhan, and J. P. Fox, "Hydrogeologic Consequences of Modified In-situ 

Retorting Process, Piceance Creek Basin, Colorado," Proceedings of the Fourteenth Oil Shale 

Symposium, Colorado School of Mines Press, Golden, CO, 1981 (LBL-12063). 

U. S. DOE (J. P. Fox and others), Western Oil Shale Development: A Technology Assessment, v. 

1-9, Pacific Northwest Laboratory Report PNL-3830, 1981.
PHYLLIS FOX, PH.D., PAGE 28

J. P. Fox (ed), "Oil Shale Research," Chapter from the Energy and Environment Division Annual 

Report 1980, Lawrence Berkeley Laboratory Report LBL-11989, 82 pp., 1981 (author or coauthor of four articles in report).

J. P. Fox, The Partitioning of Major, Minor, and Trace Elements during In-Situ Oil Shale 

Retorting, Ph.D. Dissertation, U. of Ca., Berkeley, also Report LBL-9062, 441 pp., 1980 (Diss. 

Abst. Internat., v. 41, no. 7, 1981).

J.P. Fox, "Elemental Composition of Simulated In Situ Oil Shale Retort Water," Analysis of 

Waters Associated with Alternative Fuel Production, ASTM STP 720, L.P. Jackson and C.C. 

Wright, Eds., American Society for Testing and Materials, pp. 101-128, 1981.

J. P. Fox, P. Persoff, P. Wagner, and E. J. Peterson, "Retort Abandonment -- Issues and Research 

Needs," in Oil Shale: the Environmental Challenges, K. K. Petersen (ed.), p. 133, 1980 

(Lawrence Berkeley Laboratory Report LBL-11197). 

J. P. Fox and T. E. Phillips, "Wastewater Treatment in the Oil Shale Industry," in Oil Shale: the 

Environmental Challenges, K. K. Petersen (ed.), p. 253, 1980 (Lawrence Berkeley Laboratory 

Report LBL-11214).

R. D. Giauque, J. P. Fox, J. W. Smith, and W. A. Robb, "Geochemical Studies of Two Cores 

from the Green River Oil Shale Formation," Transactions, American Geophysical Union, v. 61, 

no. 17, 1980.

J. P. Fox, "The Elemental Composition of Shale Oils," Abstracts of Papers, 179th National 

Meeting, ISBN 0-8412-0542-6, Abstract No. FUEL 17, 1980.

J. P. Fox and P. Persoff, "Spent Shale Grouting of Abandoned In-Situ Oil Shale Retorts," 

Proceedings of Second U.S. DOE Environmental Control Symposium, CONF-800334/1, 1980 

(Lawrence Berkeley Laboratory Report LBL-10744).

P. K. Mehta, P. Persoff, and J. P. Fox, "Hydraulic Cement Preparation from Lurgi Spent Shale," 

Proceedings of the Thirteenth Oil Shale Symposium, Colorado School of Mines Press, Golden, 

CO, 1980 (Lawrence Berkeley Laboratory Report LBL-11071).

F. E. Brinckman, K. L. Jewett, R. H. Fish, and J. P. Fox, "Speciation of Inorganic and 

Organoarsenic Compounds in Oil Shale Process Waters by HPLC Coupled with Graphite 

Furnace Atomic Absorption (GFAA) Detectors," Abstracts of Papers, Div. of Geochemistry, 

Paper No. 20, Second Chemical Congress of the North American Continent, August 25-28, 1980, 

Las Vegas (1980).

J. P. Fox, D. E. Jackson, and R. H. Sakaji, "Potential Uses of Spent Shale in the Treatment of Oil 

Shale Retort Waters," Proceedings of the Thirteenth Oil Shale Symposium, Colorado School of 

Mines Press, Golden, CO, 1980 (Lawrence Berkeley Laboratory Report LBL-11072).

J. P. Fox, The Elemental Composition of Shale Oils, Lawrence Berkeley Laboratory Report LBL10745, 1980.
PHYLLIS FOX, PH.D., PAGE 29

R. H. Fish, J. P. Fox, F. E. Brinckman, and K. L. Jewett, Fingerprinting Inorganic and 

Organoarsenic Compounds in Oil Shale Process Waters Using a Liquid Chromatograph 

Coupled with an Atomic Absorption Detector, Lawrence Berkeley Laboratory Report LBL11476, 1980.

National Academy of Sciences (J. P. Fox and others), Surface Mining of Non-Coal Minerals, 

Appendix II: Mining and Processing of Oil Shale and Tar Sands, 222 pp., 1980.

J. P. Fox, "Elemental Composition of Simulated In-Situ Oil Shale Retort Water," in Analysis of 

Waters Associated with Alternative Fuel Production, ASTM STP 720, L. P. Jackson and C. C. 

Wright (eds.), American Society for Testing and Materials, pp. 101-128, 1980.

R. D. Giauque, J. P. Fox, and J. W. Smith, Characterization of Two Core Holes from the Naval 

Oil Shale Reserve Number 1, Lawrence Berkeley Laboratory Report LBL-10809, 176 pp., 

December 1980.

B. M. Jones, R. H. Sakaji, J. P. Fox, and C. G. Daughton, "Removal of Contaminative 

Constituents from Retort Water: Difficulties with Biotreatment and Potential Applicability of 

Raw and Processed Shales," EPA/DOE Oil Shale Wastewater Treatability Workshop, December 

1980 (Lawrence Berkeley Laboratory Report LBL-12124).

J. P. Fox, Water-Related Impacts of In-Situ Oil Shale Processing, Lawrence Berkeley Laboratory 

Report LBL-6300, 327 p., December 1980.

M. Mehran, T. N. Narasimhan, and J. P. Fox, An Investigation of Dewatering for the Modified 

In-Situ Retorting Process, Piceance Creek Basin, Colorado, Lawrence Berkeley Laboratory 

Report LBL-11819, 105 p., October 1980.

J. P. Fox (ed.) "Oil Shale Research," Chapter from the Energy and Environment Division Annual 

Report 1979, Lawrence Berkeley Laboratory Report LBL-10486, 1980 (author or coauthor of 

eight articles).

E. Ossio and J. P. Fox, Anaerobic Biological Treatment of In-Situ Oil Shale Retort Water, 

Lawrence Berkeley Laboratory Report LBL-10481, March 1980.

J. P. Fox, F. H. Pearson, M. J. Kland, and P. Persoff, Hydrologic and Water Quality Effects and 

Controls for Surface and Underground Coal Mining -- State of Knowledge, Issues, and Research 

Needs, Lawrence Berkeley Laboratory Report LBL-11775, 1980.

D. C. Girvin, T. Hadeishi, and J. P. Fox, "Use of Zeeman Atomic Absorption Spectroscopy for 

the Measurement of Mercury in Oil Shale Offgas," Proceedings of the Oil Shale Symposium: 

Sampling, Analysis and Quality Assurance, U.S. EPA Report EPA-600/9-80-022, March 1979 

(Lawrence Berkeley Laboratory Report LBL-8888).

D. S. Farrier, J. P. Fox, and R. E. Poulson, "Interlaboratory, Multimethod Study of an In-Situ 

Produced Oil Shale Process Water," Proceedings of the Oil Shale Symposium: Sampling, 
PHYLLIS FOX, PH.D., PAGE 30

Analysis and Quality Assurance, U.S. EPA Report EPA-600/9-80-022, March 1979 (Lawrence 

Berkeley Laboratory Report LBL-9002).

J. P. Fox, J. C. Evans, J. S. Fruchter, and T. R. Wildeman, "Interlaboratory Study of Elemental 

Abundances in Raw and Spent Oil Shales," Proceedings of the Oil Shale Symposium: Sampling, 

Analysis and Quality Assurance, U.S. EPA Report EPA-600/9-80-022, March 1979 (Lawrence 

Berkeley Laboratory Report LBL-8901).

J. P. Fox, "Retort Water Particulates," Proceedings of the Oil Shale Symposium: Sampling, 

Analysis and Quality Assurance, U.S. EPA Report EPA-600/9-80-022, March 1979 (Lawrence 

Berkeley Laboratory Report LBL-8829).

P. Persoff and J. P. Fox, "Control Strategies for In-Situ Oil Shale Retorts," Proceedings of the 

Twelfth Oil Shale Symposium, Colorado School of Mines Press, Golden, CO, 1979 (Lawrence 

Berkeley Laboratory Report LBL-9040).

J. P. Fox and D. L. Jackson, "Potential Uses of Spent Shale in the Treatment of Oil Shale Retort 

Waters," Proceedings of the DOE Wastewater Workshop, Washington, D. C., June 14-15, 1979 

(Lawrence Berkeley Laboratory Report LBL-9716).

J. P. Fox, K. K. Mason, and J. J. Duvall, "Partitioning of Major, Minor, and Trace Elements 

during Simulated In-Situ Oil Shale Retorting," Proceedings of the Twelfth Oil Shale Symposium, 

Colorado School of Mines Press, Golden, CO, 1979 (Lawrence Berkeley Laboratory Report 

LBL-9030).

P. Persoff and J. P. Fox, Control Strategies for Abandoned In-Situ Oil Shale Retorts, Lawrence 

Berkeley Laboratory Report LBL-8780, 106 pp., October 1979.

D. C. Girvin and J. P. Fox, On-Line Zeeman Atomic Absorption Spectroscopy for Mercury 

Analysis in Oil Shale Gases, Environmental Protection Agency Report EPA-600/7-80-130, 95 p., 

August 1979 (Lawrence Berkeley Laboratory Report LBL-9702).

J. P. Fox, Water Quality Effects of Leachates from an In-Situ Oil Shale Industry, Lawrence 

Berkeley Laboratory Report LBL-8997, 37 pp., April 1979.

J. P. Fox (ed.), "Oil Shale Research," Chapter from the Energy and Environment Division 

Annual Report 1978, Lawrence Berkeley Laboratory Report LBL-9857 August 1979 (author or 

coauthor of seven articles).

J. P. Fox, P. Persoff, M. M. Moody, and C. J. Sisemore, "A Strategy for the Abandonment of 

Modified In-Situ Oil Shale Retorts," Proceedings of the First U.S. DOE Environmental Control 

Symposium, CONF-781109, 1978 (Lawrence Berkeley Laboratory Report LBL-6855).

E. Ossio, J. P. Fox, J. F. Thomas, and R. E. Poulson, "Anaerobic Fermentation of Simulated InSitu Oil Shale Retort Water," Division of Fuel Chemistry Preprints, v. 23, no. 2, p. 202-213, 

1978 (Lawrence Berkeley Laboratory Report LBL-6855).
PHYLLIS FOX, PH.D., PAGE 31

J. P. Fox, J. J. Duvall, R. D. McLaughlin, and R. E. Poulson, "Mercury Emissions from a 

Simulated In-Situ Oil Shale Retort," Proceedings of the Eleventh Oil Shale Symposium, 

Colorado School of Mines Press, Golden, CO, 1978 (Lawrence Berkeley Laboratory Report 

LBL-7823).

J. P. Fox, R. D. McLaughlin, J. F. Thomas, and R. E. Poulson, "The Partitioning of As, Cd, Cu, 

Hg, Pb, and Zn during Simulated In-Situ Oil Shale Retorting," Proceedings of the Tenth Oil 

Shale Symposium, Colorado School of Mines Press, Golden, CO, 1977.

Bechtel, Inc., Treatment and Disposal of Toxic Wastes, Report Prepared for Santa Ana 

Watershed Planning Agency, 1975.

Bay Valley Consultants, Water Quality Control Plan for Sacramento, Sacramento-San Joaquin 

and San Joaquin Basins, Parts I and II and Appendices A-E, 750 pp., 1974.
PHYLLIS FOX, PH.D., PAGE 32

POST GRADUATE COURSES

(Partial)

S-Plus Data Analysis, MathSoft, 6/94.

Air Pollutant Emission Calculations, UC Berkeley Extension, 6-7/94

Assessment, Control and Remediation of LNAPL Contaminated Sites, API and USEPA, 9/94

Pesticides in the TIE Process, SETAC, 6/96

Sulfate Minerals: Geochemistry, Crystallography, and Environmental Significance, 

Mineralogical Society of America/Geochemical Society, 11/00.

Design of Gas Turbine Combined Cycle and Cogeneration Systems, Thermoflow, 12/00

Air-Cooled Steam Condensers and Dry- and Hybrid-Cooling Towers, Power-Gen, 12/01

Combustion Turbine Power Augmentation with Inlet Cooling and Wet Compression, 

Power-Gen , 12/01

CEQA Update, UC Berkeley Extension, 3/02

The Health Effects of Chemicals, Drugs, and Pollutants, UC Berkeley Extension, 4-5/02

Noise Exposure Assessment: Sampling Strategy and Data Acquisition, AIHA PDC 205, 6/02

Noise Exposure Measurement Instruments and Techniques, AIHA PDC 302, 6/02

Noise Control Engineering, AIHA PDC 432, 6/02

Optimizing Generation and Air Emissions, Power-Gen, 12/02

Utility Industry Issues, Power-Gen, 12/02

Multipollutant Emission Control, Coal-Gen, 8/03

Community Noise, AIHA PDC 104, 5/04

Cutting-Edge Topics in Noise and Hearing Conservation, AIHA 5/04

Selective Catalytic Reduction: From Planning to Operation, Power-Gen, 12/05

Improving the FGD Decision Process, Power-Gen, 12/05

E-Discovery, CEB, 6/06

McIlvaine Hot Topic Hour, FGD Project Delay Factors, 8/10/06

McIlvaine Hot Topic Hour, What Mercury Technologies Are Available, 9/14/06

McIlvaine Hot Topic Hour, SCR Catalyst Choices, 10/12/06

McIlvaine Hot Topic Hour, Particulate Choices for Low Sulfur Coal, 10/19/06

McIlvaine Hot Topic Hour, Impact of PM2.5 on Power Plant Choices, 11/2/06

McIlvaine Hot Topic Hour, Dry Scrubbers, 11/9/06

Cost Estimating and Tricks of the Trade – A Practical Approach, PDH P159, 11/19/06

Process Equipment Cost Estimating by Ratio & Proportion, PDH G127 11/19/06

Power Plant Air Quality Decisions, Power-Gen 11/06

McIlvaine Hot Topic Hour, WE Energies Hg Control Update, 1/12/07

Negotiating Permit Conditions, EEUC, 1/21/07

BACT for Utilities, EEUC, 1/21/07

McIlvaine Hot Topic Hour, Chinese FGD/SCR Program & Impact on World, 2/1/07

McIlvaine Hot Topic Hour, Mercury Control Cost & Performance, 2/15/07

McIlvaine Hot Topic Hour, Mercury CEMS, 4/12/07
PHYLLIS FOX, PH.D., PAGE 33

Coal-to-Liquids – A Timely Revival, 9th Electric Power, 4/30/07

Advances in Multi-Pollutant and CO2 Control Technologies, 9th Electric Power, 4/30/07

McIlvaine Hot Topic Hour, Measurement & Control of PM2.5, 5/17/07

McIlvaine Hot Topic Hour, Co-firing and Gasifying Biomass, 5/31/07

McIlvaine Hot Topic Hour, Mercury Cost and Performance, 6/14/07

Ethanol 101: Points to Consider When Building an Ethanol Plant, BBI International, 6/26/07

Low Cost Optimization of Flue Gas Desulfurization Equipment, Fluent, Inc., 7/6/07.

McIlvaine Hot Topic Hour, CEMS for Measurement of NH3, SO3, Low NOx, 7/12/07

McIlvaine Hot Topic Hour, Mercury Removal Status & Cost, 8/9/07

McIlvaine Hot Topic Hour, Filter Media Selection for Coal-Fired Boilers, 9/13/07

McIlvaine Hot Topic Hour, Catalyst Performance on NOx, SO3, Mercury, 10/11/07

PRB Coal Users Group, PRB 101, 12/4/07

McIlvaine Hot Topic Hour, Mercury Control Update, 10/25/07

Circulating Fluidized Bed Boilers, Their Operation, Control and Optimization, Power-Gen, 

12/8/07

Renewable Energy Credits & Greenhouse Gas Offsets, Power-Gen, 12/9/07

Petroleum Engineering & Petroleum Downstream Marketing, PDH K117, 1/5/08

Estimating Greenhouse Gas Emissions from Manufacturing, PDH C191, 1/6/08

McIlvaine Hot Topic Hour, NOx Reagents, 1/17/08

McIlvaine Hot Topic Hour, Mercury Control, 1/31/08

McIlvaine Hot Topic Hour, Mercury Monitoring, 3/6/08

McIlvaine Hot Topic Hour, SCR Catalysts, 3/13/08

Argus 2008 Climate Policy Outlook, 3/26/08

Argus Pet Coke Supply and Demand 2008, 3/27/08

McIlvaine Hot Topic Hour, SO3 Issues and Answers, 3/27/08

McIlvaine Hot Topic Hour, Mercury Control, 4/24/08

McIlvaine Hot Topic Hour, Co-Firing Biomass, 5/1/08

McIlvaine Hot Topic Hour, Coal Gasification, 6/5/08

McIlvaine Hot Topic Hour, Spray Driers vs. CFBs, 7/3/08

McIlvaine Hot Topic Hour, Air Pollution Control Cost Escalation, 9/25/08

McIlvaine Hot Topic Hour, Greenhouse Gas Strategies for Coal Fired Power Plant Operators, 

10/2/08

McIlvaine Hot Topic Hour, Mercury and Toxics Monitoring, 2/5/09

McIlvaine Hot Topic Hour, Dry Precipitator Efficiency Improvements, 2/12/09

McIlvaine Hot Topic Hour, Coal Selection & Impact on Emissions, 2/26/09

McIlvaine Hot Topic Hour, 98% Limestone Scrubber Efficiency, 7/9/09

McIlvaine Hot Topic Hour, Carbon Management Strategies and Technologies, 6/24/10

McIlvaine Hot Topic Hour, Gas Turbine O&M, 7/22/10

McIlvaine Hot Topic Hour, Industrial Boiler MACT – Impact and Control Options, March 10, 

2011