# Errata to the Redesignation Demonstration and Maintenance Plan

for the Hickory (Catawba County) and Greensboro/Winston-Salem/High Point (Davidson and Guilford Counties)

Fine Particulate Matter Nonattainment Areas

Prepared by North Carolina Department of Environment and Natural Resources Division of Air Quality

December 22, 2010(This page intentionally left blank)Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 1 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 

### INTRODUCTION

This document is intended to make minor correc tions or changes, at the request of the United States Environmental Protection Agency’s (USEPA’s ), to the December 18, 2009, Redesignation Demonstration and Maintenance Pl an for the Hickory (Catawba County) and Greensboro/Winston-Salem/High Point (Davidso n and Guilford Counties) Fine Particulate
Matter Nonattainment Areas. The correct ions and changes are described below.



### CORRECTIONS OR CHANGES

Narrative Corrections or Changes

Page 2-6, last paragraph: The USEPA requested we change the reference to the USEPA’s acid
rain database to the USEPA’s Clean Air Market s database to better reflect the data used.

Page 2-6, last paragraph: The amount of n itrogen dioxide (NOx) emissions reduced since 2002 is incorrectly listed as over 54,000 tons per year . The correct value should be over 84,000 tons

per year.

Page 3-7, under Clean Smokestacks Act: The percent reduction of annual NOx emissions by 2009 was corrected from 78% to 77%, and the pe rcent reduction of annual sulfur dioxide (SO 2 ) emissions by 2013 was corrected from 74% to 73%.

Page 3-11, Table 3-4 Point Sour ce NOx Emissions: The USEPA, Region 4 requested that the
2008 emissions for Marshall Steam Station in Catawb a County be corrected to reflect the actual emissions instead of the projected emissions. The 2008 emissions for Marshall Steam Station were updated to reflect the actual emissions. The future year NOx emissions for all units except Unit 3 were kept constant at th e 2008 emission level since their co ntrols were installed prior to 2008 and the emissions are not expe cted to change significantly from year to year. For Unit 3, selective catalytic redu ction was install during 2008, therefor e the future year emissions were adjusted to reflect this control.

Page 3-12, Table 3-5 Point Source SO 2 Emissions: The USEPA, Region 4 requested that the
2008 emissions for Marshall Steam Station in Catawb a County be corrected to reflect the actual emissions instead of the projected emissions. The 2008 emissions for Marshall Steam Station were updated to reflect the actual emissions. The future year SO 2 emissions for all units were kept constant at the 2008 emissi on level since their controls were installed prior to 2008 and the emissions are not expected to change significantly from year to year.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Page 3-12, Table 3-6 Point Source PM 2.5 Emissions: The USEPA, Region 4 requested that the
2008 emissions for Marshall Steam Station in Catawb a County be corrected to reflect the actual emissions instead of the projected emissions. The 2008 emissions for Marshall Steam Station were updated to reflect the actual emissions. The future year PM 2.5 emissions for all units were kept constant at the 2008 emissi on level since their controls were installed prior to 2008 and the emissions are not expected to change significantly from year to year.

Page 3-15, Tables 3-16 and 3-17: These tables were updated to re flect the changed point source emissions for Catawba County.

Page 3-16, Tables 3-18 and 3-19: These tables were updated to re flect the changed point source emissions for Catawba County.

Page 3-17, Table 3-21: This ta ble was updated to reflect the ch anged point source emissions for Catawba County.

Page 4-10, Table 4-6: This ta ble was updated to reflect the ch anged point source emissions for Catawba County.

Appendix C.1 Point Source Emissions Inventory Documentation Changes

Appendix C.1, page 7: The second paragraph was changed to reflect the USEPA’s request that the Marshall Steam Station 2008 emissions be update d to reflect actual emissions instead of the projected emissions.

Appendix C.1, page 7, Table 4.1: The USEPA, Region 4 requested that the 2008 emissions for Marshall Steam Station in Catawba County be correct ed to reflect the actual emissions instead of the projected emissions. The 2008 emissions for Marshall Steam Station were updated to reflect the actual emissions. The future year NOx em issions for all units ex cept Unit 3 were kept
constant at the 2008 emission level since their controls were installe d prior to 2008 and the emissions are not expected to change significan tly from year to year. For Unit 3, selective catalytic reduction was install dur ing 2008, therefore the future year emissions were adjusted to
reflect this control.

Appendix C.1, page 8, Table 4.2: The USEPA, Region 4 requested that the 2008 emissions for Marshall Steam Station in Catawba County be correct ed to reflect the actual emissions instead of the projected emissions. The 2008 emissions for Marshall Steam Station were updated to reflectHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 the actual emissions. The future year SO 2 emissions for all units were kept constant at the 2008
emission level since their controls were inst alled prior to 2008 and the emissions are not expected to change significantly from year to year.

Appendix C.1, page 8, Table 4.3: The USEPA, Region 4 requested that the 2008 emissions for Marshall Steam Station in Catawba County be correct ed to reflect the actual emissions instead of the projected emissions. The 2008 emissions for Marshall Steam Station were updated to reflect the actual emissions. The future year PM 2.5 emissions for all units were kept constant at the 2008
emission level since their controls were inst alled prior to 2008 and the emissions are not expected to change significantly from year to year.

Appendix C.1, pages 10,11,and 15, Table 5.1: The emissions for Marshall Steam Station were updated to reflect the request ed changes by the USEPA.



### REVISED SECTIONS

Attached are the revised sections to the Redesi gnation Demonstration an d Maintenance Plan for the Hickory and Greensboro/Wins ton-Salem/High Point Fine Part iculate Matter Nonattainment Areas. To appropriately revise the original package, replace the pages as outlined below:

Narrative Replacements

Replace December 18, 2009 page 2-6 with the att ached December 22, 2010 page 2-6. (Note that December 18, 2009 page 2-5 has been included for ease of substitution.)

Replace December 18, 2009 page 3-7 with the att ached December 22, 2010 page 3-7. (Note that December 18, 2009 page 3-6 has been included for ease of substitution.)

Replace December 18, 2009 pages 3-11 through 3-12 with the attached December 22, 2010 pages 3-11 through 3-12. (Note that Decem ber 18, 2009 pages 3-10 and 3-13 have been included for ease of substitution.)

Replace December 18, 2009 pages 3-15 through 3-17 with the attached December 22, 2010 pages 3-15 through 3-17. (Note that December 1 8, 2009 page 3-14 has been included for ease of substitution.)Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Replace December 18, 2009 page 4-10 with the attached December 22, 2010 pages 4-10. (Note that December 18, 2009 page 4-11 has been included for ease of substitution.)

Appendix C.1 Replacements

Replace December 18, 2009 Appendix C.1 “Point Source Emission Inventory Documentation” pages 7 and 8 with the attached Dece mber 22, 2010 Appendix C.1 pages 7 and 8.

Replace December 18, 2009 Appendix C.1 page 10 with the attached December 22, 2010 Appendix C.1 page 10. (Note that December 18, 2009 Appendix C.1 page 9 has been included for ease of substitution.)

Replace December 18, 2009 Appendix C.1 page 11 with the attached December 22, 2010 Appendix C.1 page 11. (Note that December 18, 2009 Appendix C.1 page 12 has been included for ease of substitution.)

Replace December 18, 2009 Appendix C.1 page 15 with the attached December 22, 2010 Appendix C.1 page 15. (Note that December 18, 2009 Appendix C.1 page 16 has been included for ease of substitution.)Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2-5 Redesignation Demonstration and Ma intenance Plan December 18, 2009 • program is expected to achieve a 90% reduc tion in particulate matter (PM) emissions. These emission reductions are federally enforceable.

• Nonroad spark-ignition engines and recreati onal engines standards: Tier 1 of this standard was implemented in 2004 and Ti er 2 started in 2007, and will reduce particulate matter emissions. These emissi on reductions are federally enforceable.

• Large nonroad diesel engine standards: Promulgated in 2004, this rule is being phased in between 2008 and 2014. This rule will also reduce sulfur content in nonroad diesel fuel. When fully implemented, this rule will reduce NO x and direct
PM 2.5 emissions by over 90%. These emission reductions are federally enforceable.

The state measures that have been implemented include:

• Clean Air Bill: This State legislation expanded the inspection and maintenance (I/M) program from 9 counties to 48. It was phased-in in the Hickory and Triad nonattainment areas from July 1, 2002 through July 1, 2003. This program will
reduce NO x and Volatile Organic Compound (VOC s), and Carbon Monoxide (CO).
These emission reductions are state enforceable.

• Open burning: This regulation prohibits the burning of man-made materials throughout the State. Additionally, this re gulation prohibits open burning of yard waste in areas that the NCDAQ forecasts an air quality action da y. The open burning regulation will reduce fine particulate matter emissions, as well as NO x , VOCs and
CO emissions. These emission re ductions are state enforceable.

• Heavy duty diesel engine gap filling rule: Th is rule requires engine manufacturers to perform the supplemental testing requirem ents for heavy duty diesel engines for model years 2005 and 2006 due to delays in the USEPA’s rule and will reduce PM
emissions. These emission reductions are state enforceable.

• Clean Smokestack Act: This rule requires coal-fired power plan ts to reduce annual
NO x emissions by 77% by 2009 and to reduce annual sulfur dioxide emissions by 49% by 2009 and 73% by 2013. This legislation sets a cap on NO x and SO 2 emissions, which the public utilities cannot meet by purch asing emission credits.
These emission reductions are state enforceable.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2-6 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 • NO x State Implementation Plan (SIP) Call ru le: This rule was predicted to reduce
summertime NO x emissions from power plants and other industries by 68%. These
emission reductions are state a nd federally enforceable.

• Diesel Retrofits: As part of the Nort h Carolina Mobile Source Emission Reduction Grants program, a number of cities, counties and school dist ricts have installed Diesel Oxidation Catalysts (DOCs) or Diesel Pa rticulate Filters (DPFs) on their diesel equipment. The vehicles that have been retrofitted include schools buses, as well as county fleet trucks for solid waste pickup. These types of filters are designed to remove particulate matter, and when used with ultra low sulfur diesel fuel, NO x and
VOC emissions are also reduced. Even though these emission reductions are voluntary and not enforceable, they are st ill considered permanent reductions.

• Diesel Emissions Reduction Act (DERA): DERA provides new diesel emissions reduction grant authority for the USEPA. Th is funding is used to achieve significant
reductions in diesel emissions that improve air quality a nd protect public health. The DERA funds that the NCDAQ have received have been used to retrofit, repower, or replace existing diesel engines from on-road and nonroad mobile source vehicles/equipment. This program will reduce PM, NOx, and VOC emissions. Even though these emission reductions are voluntary and not enfo rceable, they are still considered permanent reductions.

One of the largest components of PM 2.5 in the southeastern United States is sulfate. This is formed through various chemical reactions from the precursor SO 2 . Another component of
PM 2.5 is nitrate, which is formed from the precursor NO x . Controls installed on coal-fired power plants over the past few years have significan tly reduced these two pr ecursor pollutants. Table 2-4 presents the annual emissions for the North Carolina sources that are in the USEPA’s Clean Air Markets database. Since 2002, when the NO x controls started coming on-line to meet
the NO x SIP Call and later to meet the North Carolina Clean Smokestacks Act (NCCSA), the
NO x emissions from subject sources have decrea sed over 84,000 tons per year. To meet the SO 2 emission caps in the NCCSA, the North Caro lina public utilities started installing SO 2 controls late in 2005. Since then, the SO 2 emissions from the utilities in North Carolina have decreased nearly 274,000 tons. The decline in SO 2 emissions has coincided w ith the decline in annual
PM 2.5 concentrations across North Carolina.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-6 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Table 3-1 OBDII Phase-in Effective Dates County Date Catawba July 1, 2003 Davidson July 1, 2003 Guildford July 1, 2002

These emission reductions are state enforceable. The expected NO x benefits for the maintenance years are listed in Table 3-2 below.

Table 3-2 I/M NO x Benefits by County
NO x I/M Benefit (Tons/year) 2008 2011 2014 2017 2021
Total NO x for Catawba County 202 272 335 393 469
Total NO x for Davidson County 207 273 329 382 452
Total NO x for Guilford County 660 865 1,055 1,225 1,426

NO x SIP Call Rule/CAIR
In response to the USEPA’s NO x SIP call, North Carolina adopted rules to control the emissions
of NO x from large stationary combustion sources. These rules cover (1) fossil fuel-fired stationary boilers, combustion turbines, and comb ined cycle systems serv ing a generator with a nameplate capacity greater than 25 MW and selli ng any amount of electricity, (2) fossil fuelfired stationary boilers, combustion turbines, and combined cycle systems having a maximum design heat input greater than 250 million Britis h thermal units per hour, and (3) reciprocating stationary internal combustion en gines rated at equal to or great er than 2400 brake horsepower (3000 brake horsepower for diesel engines and 4400 brake horsepow er for dual fuel engines). As part of the NO x SIP Call, the USEPA rules established a NO x budget for sources in North
Carolina and other states. North Carolina has a Phase II budget (i.e., em ission allowance) of 165,022 tons NO x per ozone season.

Besides amending existing NO x rules and adopting new NO x rules specifically to address the
USEPA NO x SIP Call, the North Carolina rules also re quire new sources to control emissions of
NO x . The objective of this requiremen t is (1) to aid in meeting the NO x budget for North Carolina for minor sources and (2) to aid in a ttaining and maintaining the ambient air quality
standard for ozone in North Carolina. North Carolina’s NO x SIP Call rule was predicted to
reduce summertime NO x emissions from power plants a nd other industries by 68% by 2006. In October 2000, the North Carolina Environmen tal Management Commission (EMC) adopted rules requiring th e reductions.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-7 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 In 2009, the NO x SIP Call program was replaced with th e CAIR, a cap-and-trade program that
will achieve reductions of emissions of SO 2 and NO x in the eastern United States. NO x sources that were regulated under the NO x SIP Call are now regulated under the CAIR program. North Carolina adopted the CAIR rule s in 2006 (amended in 2008). North Carolina’s CAIR rules set
annual SO 2 allowances as well as bo th ozone season and annual NO x allowances for coal-fired electric generating units and ot her large combustion sources. Th ese regulations are due to a Federal program and thus are both State and Federally enforceable.

Due to the Court challenges of CAIR in 2008, the USEPA will be making changes to this program soon. However, the existing CAIR rules will remain in place until the USEPA promulgates changes to the program.

Clean Smokestacks Act

In June 2002, the North Carolina General Assemb ly enacted the NCCSA, which requires coalfired power plants in Nort h Carolina to reduce annual NO x emissions by 77% by 2009. These power plants must also reduce annual SO 2 emissions by 49% by 2009 and 73% by 2013. It is significant to note that this law sets a cap on NO x and SO 2 emissions for the State which the North Carolina public utilities cannot meet by purch asing credits from sour ces outside of North Carolina. With requiring year-round NO x controls and not allowing the purchase of NO x credits to meet the caps, the NCCSA reduces NO x emissions beyond the requirements of the NO x SIP
Call Rule. One of the first state laws of its ki nd in the nation, this legislation provides a model for other states in controlling multiple air pollutants from older coal-fired power plants. These
emissions reductions are state enforceable.

Prevention of Significant Deterioration
All new major sources of SO 2 and NO x will be evaluated under the prevention of significant deterioration program and are required to use best available control technology. These emissions
reductions are state enforceable.

Open Burning
The North Carolina open burning regulation proh ibits the burning of man-made materials statewide. In June 2004, the EMC approved re visions to the open burning regulation banning open burning of yard waste and land clearing debris on forecasted Code Orange or higher "air quality action days," for those counties that th e NCDAQ or local air programs forecast ozone or fine particulate matter. The following counties in the Hickory area are subject to this rule : Alexander , Catawba , southeastern Burke and southeastern Caldwell. The following counties inHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-10 Redesignation Demonstration and Ma intenance Plan December 18, 2009 SAFETY-LU (the Safe, Accountable, Flexible, E fficient Transportation Equity Act: A Legacy for Users) as well as any updated transporta tion legislation and th e CAA as amended.

Mobile Source Emission Reduction Grants

• Diesel Retrofits: As part of the Nort h Carolina Mobile Source Emission Reduction Grants program, a number of cities, counties and school dist ricts have installed Diesel Oxidation Catalysts (DOCs) or Diesel Pa rticulate Filters (DPFs) on their diesel equipment. The vehicles that have been retrofitted include schools buses, as well as county fleet trucks for solid waste pic kup. Although these types of filters are designed to remove fine particulate matter, when used with ultra low sulfur diesel fuel, NO x and VOC emissions are also reduced.

• Diesel Emissions Reduction Act (DERA): DERA provides new diesel emissions reduction grant authority for the USEPA. Th is funding is used to achieve significant
reductions in diesel emissions that improve air quality a nd protect public health. In response to DERA, the USEPA created grant and funding programs under the National Clean Diesel Campaign to build on the success of its regulatory and voluntary efforts to reduce emissions from di esel engines. The DERA funds that the NCDAQ have received have been used to retrofit, repower, or replace existing diesel engines from on-road and nonroad m obile source vehicles/equipment.

3.3 EMISSIONS INVENTORIES AN D MAINTENANCE DEMONSTRATION

3.3.1 Theory of Approach
There are two basic approaches used to demonstr ate continued maintenance. The first is the comparison of a projected emissions inventory wi th a baseline emissions inventory. The second approach involves complex analysis using grid ded photochemical modeling. The approach used by the NCDAQ is the comparison of emissi ons inventories for the years 2008 and 2021.

For the maintenance demonstration, the base year of 2008 was chosen since it is a year that falls within the attaining design valu e period of 2006-2008 and some emi ssions inventory data was in the process of being developed for this year . The maintenance demonstration is made by comparing the 2008 baseline emissions inventory to the 2021 projected emissions inventory. The baseline emissions inventory represents an emission level for a period when the ambient air quality standard was not violated, 2006-2008. If th e projected emissions remain at or below the baseline emissions, continued maintenance is dem onstrated and it then follows, if the projected
emissions remain at or below the baseline emissi ons, then the ambient ai r quality standard shoulHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-11 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 not be violated in the future. In addition to comp aring the final year of th e plan, all of the interim years are compared to the 2008 baseline to demons trate that these years are also expected to
show continued maintenance of the a nnual fine particulate matter standard.

The emissions inventories are comprised of four major types of sources: point, area, on-road mobile and nonroad mobile. The projected emi ssions inventories have been estimated using projected rates of growth in population, traffic, economic activity, expected control programs, and other parameters. Naturally occurring, or biogenic, emissions are not included in the emissions inventory comparison, as these emission s are outside the State’s span of control.

3.3.2 Emission Inventories

There are four different man-made emission inventory source classi fications: (1) st ationary point, (2) area, (3) on-road mobile and (4) nonroad mobile sources.

Point sources are those stationary sources that require an Air Permit to operate. In general, these sources have a potential to emit more than 5 tons per year of CO, NO x , PM, SO 2 and/or VOC from a single facility. The source emissions are tabulated from data coll ected by direct on-site
measurements of emissions or mass balance cal culations utilizing emission factors from the USEPA’s AP-42. There are usually several emissi on sources for each facility. Emission data is collected for each point source at a facility and the data is entered into an in-house database system. For the projected year's inventory, point sources are adjusted by growth factors based on
Standard Industrial Classification codes. The growth factors are gene rated using the USEPA’s Economic Growth Analysis System version 5.0 (E -GAS 5.0) program or using growth patterns obtained from County Business Patterns. For detailed discussion on how the point sources emission inventory was developed, see Appendix C .1. A summary of the point source emissions are presented in Tables 3-4 to 3-6.

Table 3-4. Point Source NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 13,310 10,549 10,548 10,548 10,548

Davidson 841 865 892 920 961 Guilford 231 231 232 233 237
Triad Total 1,072 1,096 1,124 1,153 1,198Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-12 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-5 Point Source SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 6,189 6,187 6,186 6,184 6,183

Davidson 286 289 292 295 299 Guilford 449 451 453 455 458
Triad Total 735 740 745 750 757

Table 3-6. Point Source PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 6,976 6,975 6,975 6,973 6,971

Davidson 179 178 177 176 175 Guilford 62 62 62 63 63
Triad Total 241 240 239 239 238

Area sources are those stationary sources whose emissions are relatively small but due to the large number of these sources, the collective emi ssions could be significan t (i.e., dry cleaners, service stations, etc.). For area sources, emissions are estimated by multiplying an emission factor by some known indicator of collective activity such as production, number of employees, or population. These types of em issions are estimated on the count y level. For the projected year's inventory, area source emissions are changed by population growth, projected production growth, or when applicable, by E-GAS 5.0 growth factors. For detailed discussion on how the area source emission inventory wa s developed, see Appendix C.2. A summary of the area source emissions are presented in Tables 3-7 to 3-9.

Table 3-7. Area Source NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 662 614 566 520 454

Davidson 583 551 516 486 438 Guilford 1,243 1,210 1,177 1,146 1,099
Triad Total 1,826 1,816 1,693 1,632 1,537Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-13 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Table 3-8. Area Source SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 2,263 2,037 1,808 1,580 1,277

Davidson 983 838 692 548 353 Guilford 4,129 3,905 3,683 3,460 3,164
Triad Total 5,112 4,743 4,375 4,008 3,517

Table 3-9. Area Source PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 682 658 629 606 559

Davidson 1,071 1,028 979 937 857 Guilford 697 663 623 590 524
Triad Total 1,768 1,691 1,602 1,527 1,381

For mobile sources, the USEPA’s MOBILE6.2 mob ile model is run to generate the twelve functional road class (i.e. urban in terstate, rural interstate, rural local, etc.) emission factors. The emissions are calculated by multiplying the road cl ass vehicle miles traveled (VMT) by the road class emission factor and summed to the county leve l. For the projected y ears’ inventories, the
on-road mobile sources emissions are calcula ted by running the MOBILE6.2 mobile model for the future year to generate emission factors that take into consideration expected Federal tailpipe standards, fleet turnover and new fuels. The new emission factors are multiplied by the projected VMT. For detailed discussion on how the on-road mobile emission inventory was developed, see Appendix C.3. A summary of the on-road mobile source emissions are presented
in Tables 3-10 to 3-12.

Table 3-10. On-road Mobile Source NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 3,546 2,830 2,128 1,617 1,193

Davidson 3,954 3,060 2,243 1,679 1,216 Guilford 10,462 7,957 5,885 4,410 3,268
Triad Total 14,416 11,017 8,128 6,089 4,484Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-14 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Table 3-11. On-road Mobile Source SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 23 20 22 23 25

Davidson 24 20 21 22 24 Guilford 74 64 69 75 80
Triad Total 98 84 90 97 104

Table 3-12. On-road Mobile Source PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 59 51 43 39 37

Davidson 64 53 43 38 36 Guilford 170 142 125 117 117
Triad Total 234 195 168 155 153

Nonroad mobile sources are equipment that can move but do not use the roadways, i.e., lawn mowers, construction equipment, railroad locomotiv es, aircraft, etc. The emissions from this category are calculated using the USEPA’s N ONROAD2008a nonroad mobile model, with the exception of the railroad locomotives and aircraft engine. The railroad locomotive and aircraft engine emissions are estimated by taking activit y data, such as landi ngs and takeoffs, and multiply by an emission factor. These emissions ar e also estimated at the county level. For the projected years’ inventories, the emissions are estimated using the USEPA’s NONROAD2008a nonroad mobile model, E-GAS 5.0 growth factor s or projected landing and takeoff data for
aircraft. For detailed discussion on how the nonroad mobile emission inventory was developed, see Appendix C.4. A summary of the nonroad mobile source emissions are presented in
Tables 3-13 to 3-15.

Table 3-13. Nonroad Mobile Source NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 1,173 922 700 551 453

Davidson 1,831 1,632 1,467 1,275 1,115 Guilford 3,864 3,371 2,816 2,350 1,980
Triad Total 5,695 5,003 4,283 3,625 3,095Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-15 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-14. Nonroad Mobile Source SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 18 6 4 3 4

Davidson 25 17 2 2 2 Guilford 96 51 42 42 43
Triad Total 121 68 44 44 45

Table 3-15. Nonroad Mobile Source PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 70 67 57 46 38

Davidson 71 67 58 46 40 Guilford 264 252 220 186 157
Triad Total 335 319 278 232 197

3.3.3 Summary of Emissions

The sum total of these man-made emissions for the PM 2.5 nonattainment areas is tabulated in Tables 3-16 though 3-18.

Table 3-16. Total Man-Made NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 18,691 14,915 13,942 13,236 12,648

Davidson 7,209 6,108 5,118 4,360 3,730 Guilford 15,800 12,769 10,110 8,139 6,584
Triad Total 23,009 18,877 15,228 12,499 10,314

Table 3-17. Total Man-Made SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 8,493 8,250 8,020 7,790 7,489

Davidson 1,318 1,164 1,007 867 678 Guilford 4,748 4,471 4,247 4,032 3,745
Triad Total 6,066 5,635 5,254 4,899 4,423Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-16 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-18. Total Man-Made PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 7,787 7,751 7,704 7,664 7,605

Davidson 1,385 1,326 1,257 1,197 1,108 Guilford 1,193 1,119 1,030 956 861
Triad Total 2,578 2,445 2,287 2,153 1,969

3.3.4 Maintenance Demonstration

As discussed above, maintenance is demonstrat ed when the future years total man-made
emissions are less than the 2008 baseline emissi ons. The following tables summarized the SO 2 , NO x , and primary PM 2.5 emissions for both the Hickory a nd Triad nonattainment areas. The difference between the base year and the final ye ar of the plan illustrates that the continued maintenance of the annual fine par ticulate matter NAAQS is expected.

Table 3-19 Maintenance Demonstration for Hickory PM 2.5 Nonattainment Area

Year NO x (tons per year) SO 2 (tons per year) PM 2.5 (tons per year) 2008 18,691 8,493 7,787 2011 14,915 8,250 7,751 2014 13,942 8,020 7,704 2017 13,236 7,790 7,664 2021 12,648 7,489 7,605
Difference from 2008 to 2021 -6,043 -1,004 -182

Table 3-20 Maintenance Demonstration for Triad PM 2.5 Nonattainment Area

Year NO x (tons per year) SO 2 (tons per year) PM 2.5 (tons per year) 2008 23,009 6,066 2,578 2011 18,877 5,635 2,445 2014 15,228 5,254 2,287 2017 12,499 4,899 2,153 2021 10,314 4,423 1,969
Difference from 2008 to 2021 -12,695 -1,643 -609Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-17 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 The difference between the attainment level of emissions (2008) from all man-made sources and the projected level of emissions from all ma n-made sources in the nonattainment areas are considered the “safety margin”. The safety marg in for each projected year is listed below in
Table 3-21 and 3-22.

Table 3-21 Safety Margin for Hickory PM 2.5 Nonattainment Area

Year NO x (tons per year) SO 2 (tons per year) PM 2.5 (tons per year) 2011 -3,776 -243 -36 2014 -4,749 -473 -83 2017 -5,455 -703 -123 2021 -6,043 -1,004 -182

Table 3-22 Safety Margin for Triad PM 2.5 Nonattainment Area

Year NO x (tons per year) SO 2 (tons per year) PM 2.5 (tons per year) 2011 -4,132 -431 -133 2014 -7,781 -812 -291 2017 -10,510 -1,167 -425 2021 -12,695 -1,643 -609

For both nonattainment areas, th ere are significant safety margins from 2011 to 2021. In addition to the above safety margins within the PM 2.5 nonattainment areas, SO 2 emissions from nearby coal-fired power plants will be significantly reduced due to the NCCSA. This effectively gives the PM 2.5 nonattainment areas an even larger safety margin for SO 2 . Table 2-5 shows the
SO 2 reductions at nearby coal-fir ed power plants. These reduc tions will benefit both the Triad and Hickory nonattainment areas and will provide large safety margins through 2021.

3.4 CONTINGENCY PLAN

3.4.1 Overview

The two main elements of the North Carolina contingency plan are tracking and triggering mechanisms to determine when contingency meas ures are needed and a process of developing and adopting appropriate control measures. Ther e will be three potential triggers for the contingency plan. The primary trigger of the contingency plan will be a violation of the annual
PM 2.5 NAAQS at any of the monitors in either PM 2.5 nonattainment area. Th e secondary triggerHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-10 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 4-5 Guilford County MVEB
2011 2021

NO x Emissions (kg/year) Base Emissions 7,218,360 2,964,834 Safety Margin Allocated to MVEB 721,836 592,967

NO x Conformity MVEB 7,940,196 3,557,801

PM 2.5 Emissions (kg/year) Base Emissions 128,465 105,716 Safety Margin Allocated to MVEB 26,191 48,940

PM 2.5 Conformity MVEB 154,656 154,656

4.5 NEW SAFETY MARGINS

For the Hickory nonattainment area, a tota l of 256,756 kg/year (283 tons/year) and 216,442 kg/year (239 tons/year) of the 2011 and 2021 NO x safety margins, respectively, were added to
the NO X MVEBs.

For the Triad nonattainment area, a to tal of 999,478 kg/year (1,102 tons/year) and 813,510 kg/year (897 tons/year) of the 2011 and 2021 NO x safety margins, respectively, were
added to the Triad NO X MVEBs. For PM 2.5 , a total of 36,552 kg/year (40 tons/year) and 74,572 kg/year (82 tons/year) of the 2011 and 2021 PM 2.5 safety margins, respectively, were added to
the Triad PM 2.5 MVEBs.

Table 4-6 New Safety Margins for the Hickory PM 2.5 nonattainment area

Year NO x (tons/year) PM 2.5 (tons/year) 2011 -3,493 -36 2014 -4,749 -83 2017 -5,455 -123 2021 -5,804 -182Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-11 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Table 4-7 New Safety Margins for the Triad PM 2.5 nonattainment area

Year NO x (tons/year) PM 2.5 (tons/year) 2011 -3,030 -93 2014 -7,781 -291 2017 -10,510 -425 2021 -11,798 -527Point Source Emission Inventory Documentation 7 Hickory and Greensboro/Winston Salem/High Point Annual-PM2.5 Appendix C.1 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 

### 4.0 TOTAL POINT SOURCES EM ISSIONS FOR HICKORY AND
TRIAD NONATTAINMENT AREAS

In the following sections the emissions for the Hickory and Triad nonattainment areas are totaled, as well as, the estimated facility emissi ons for each county in the nonattainment area are identified for the base year (2008) and th e future maintenance years (2011, 2014, 2017 and 2021).

In the original maintenance plan submitted December 18, 2009, the emissions for the one large utility facility located in Catawba County, D uke Power –Marshall Steam Station, the annual emissions were estimated by using North Ca rolina’s 2009 Clean Smokestacks Act Compliance Plan. In December 2010, the USEPA requested that the estimated 2008 emissions be updated using the actual 2008 emissions. The 2008 emissi ons for Marshall Steam Station were updated to reflect the actual emissions. The future year SO 2 emissions for this facility were kept constant
since the SO 2 controls at this facility were all installed prior to 2008 and the estimated emissions are expected to be relatively constant from year to year. The emission controls at Marshall Steam Station unit 3 were upgraded from selectiv e non-catalytic reduction to selective catalytic reduction during 2008. Therefore, the future year NOx emissions for this unit were based upon the 2009 Clean Smokestacks Act Compliance Plan.

Emission summary tables for Hickory and Tr iad nonattainment counties are as follow:

Table 4.1. Hickory and Triad Point Source NOx Emissions (ton/year) County 2008 2011 2014 2017 2021 Catawba 13,310 10,549 10,548 10,548 10,548

Davidson 841 865 892 920 961

Guilford 231 231 232 233 237

Triad Total 1,072 1,096 1,124 1,153 1,198Point Source Emission Inventory Documentation 8 Hickory and Greensboro/Winston Salem/High Point Annual-PM2.5 Appendix C.1 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 4.2. Hickory and Triad Point Source SO 2 Emissions (ton/year) County 2008 2011 2014 2017 2021 Catawba 6,189 6,187 6,186 6,184 6,183

Davidson 286 289 292 295 299

Guilford 449 451 453 455 458

Triad Total 735 740 745 750 757

Table 4.3. Hickory and Triad Point Source PM 2.5 Emissions (ton/year) County 2008 2011 2014 2017 2021 Catawba 6,976 6,975 6,975 6,973 6,971

Davidson 179 178 177 176 175

Guilford 62 62 62 63 63

Triad Total 241 240 239 239 238Point Source Emission Inventory Documentation 9 Hickory and Greensboro/Winston Salem/High Point Annual-PM2.5 Appendix C.1 Redesignation Demonstration and Main tenance Plan December 18, 2009 

### DISCUSSION OF POINT SOURCE CATEGORIES

Industrial processes in the inventory are identif ied with 8-digit numbers known as the Source Classification Codes (SCC). These are grouped numerically into a number of categories for convenience. The following is the inventories re ported by SCC by county. In general, the first three digits of the SCC code descri be the process and the last five digits give more detail as to the fuel used, size of source, etc.

It should be noted that the SCC in any particul ar instance was selected by an individual entering inventory data into a computer maintained record. It may be that in some cases, other
individuals would have selected ot her codes. In some cases, there are two or three parallel codes that describe the same sort of equipment, the diffe rence being size. In othe r cases, one is able to select a general code for an overall process or use several more specifi c codes that together would be covered by the more general one. If , upon consideration, it appears that a more appropriate code could have been selected, that does not mean that the reported emissions are
inaccurate.

A listing of SCC with descriptions may be found in FIRE Version 5.0 Source Classification
Codes and Emission Factor Listi ng for Criteria Air Pollutants, EPA-454/R-95-012. Occasionally, new SCC is defined so it may be useful to search the EPA’s website for new
entries.Table 5.1. Catawba County Point Sources –Annual Emission (tons/year)Facility IDFacility NameUnitIDSCC20082011201420172021NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO23703500009 Maymead Materials, Inc. - Hickory Plant G-22 30500242 2 0 4 2 0 4 2 04 2 0 4 2 0 43703500009 Total2 0 4 2 0 4 2 04 2 0 4 2 0 43703500025Carolina Container CompanyG-1 30703099 0 3 0 0 3 0 0 30 0 3 0 0 3 0G-25 10300602 2 0 0 2 0 0 2 00 2 0 0 2 0 03703500025 Total2 3 0 2 3 0 2 30 2 3 0 2 3 03703500031Carpenter Company ConoverG-10 39000699 1 0 0 0 0 0 0 00 0 0 0 0 0 0G-11 10500113 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-13 39000699 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-2 20100202 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-8 39000699 0 0 0 0 0 0 0 00 0 0 0 0 0 0GR29 20100102 0 0 0 0 0 0 0 00 0 0 0 0 0 0GR32 40188805 0 0 0 0 0 0 0 00 0 0 0 0 0 03703500031 Total1 0 0 1 0 0 1 00 1 0 0 0 0 03703500043Century Furniture Industries, Inc., Plant #3G-15 30703099 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-51 40201901 0 1 0 0 1 0 0 10 0 1 0 0 1 0G-53 10300601 0 0 0 0 0 0 0 00 0 0 0 0 0 03703500043 Total0 1 0 0 1 0 0 10 0 1 0 0 1 03703500044Century Furniture Industries Plant #1G-44 10300903 3 2 0 2 2 0 1 10 1 1 0 1 1 0G-45 10300903 3 2 0 2 2 0 1 10 1 1 0 1 1 0G-46 30702002 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-47 40201901 0 5 0 0 5 0 0 50 0 4 0 0 4 03703500044 Total6 9 0 4 8 0 3 80 2 7 0 1 6 03703500073Duke Energy Carolinas, LLC - MarshallSteam StationG-1 10100501 2703 1511 1384 2703 1511 1384 2703 1511 1384 2703 1511 1384 2703 1511 1384G-127 20200301 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-128202003010 0 0 0 00 0 00 0 0 0 0 0 0G-129 20200301 0 0 0 0 0 0 0 00 0 0 0 0 0 0Table 5.1. Catawba County Point Sources –Annual Emission (tons/year) – ContinuedFacility IDFacility NameUnitIDSCC20082011201420172021NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO23703500073Duke Energy Carolinas, LLC - MarshallSteam StationG-130 20200301 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-131 20200301 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-133 20200102 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-137 20200401 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-138 20200401 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-6 30531009 0 1 0 0 1 0 0 10 0 1 0 0 1 0G-8 39999994 0 1 0 0 1 0 0 10 0 1 0 0 1 0G-2 10100501 2003 1111 1026 2003 1111 1026 2003 1111 1026 2003 1111 1026 2003 1111 1026G-33 20300101 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-4 10100501 4135 2034 1749 1376 2034 1749 1376 2034 1749 1376 2034 1749 1376 2034 1749G-49 20200401 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-5 10100501 4380 2287 2015 4380 2287 2015 4380 2287 2015 4380 2287 2015 4380 2287 2015G-50 20300101 0 0 0 0 0 0 0 00 0 0 0 0 0 0GR2 20300101 13 1 1 13 1 1 13 1 1 13 1 1 13 1 13703500073 Total13234 6946 6175 10475 6946 6175 10475 6946 6175 10475 6946 6175 10475 6946 61753703500102Hickory Chair CompanyG-1 10300903 9 5 0 9 5 0 10 5 0 10 5 0 11 5 0G-27 10300404 2 0 6 2 0 5 2 04 2 0 3 2 0 23703500102 Total11 5 6 11 5 5 12 5 4 12 5 3 13 5 23703500106HWS Company Inc. dba Hickory WhiteG-1 10300903 12 0 1 12 0 1 13 0 1 13 0 0 13 0 0G-3 10300602 1 0 0 1 0 0 1 00 1 0 0 1 0 0G-4 10300602 0 0 0 0 0 0 0 00 0 0 0 0 0 03703500106 Total13 0 1 13 0 1 14 0 1 14 0 0 14 0 03703500159 Newton Wood Carving Company, Inc. G-1 30703002 0 1 0 0 1 0 0 10 0 1 0 0 1 03703500159 Total0 1 0 0 1 0 0 10 0 1 0 0 1 03703500180Progressive Furniture IncG-38 30702099 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-39 10200602 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-44 40201901 0 1 0 0 1 0 0 10 0 1 0 0 0 0Table 5.1. Catawba County Point Sources –Annual Emission (tons/year) – ContinuedFacility IDFacility NameUnitIDSCC20082011201420172021NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO23703500180Progressive Furniture IncG-45 40201901 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-7 40201901 0 0 0 0 0 0 0 00 0 0 0 0 0 0GR2 30702099 0 0 0 0 0 0 0 00 0 0 0 0 0 0GR3 30702099 0 0 0 0 0 0 0 00 0 0 0 0 0 0GR4 30702099 0 0 0 0 0 0 0 00 0 0 0 0 0 0GR5 30702099 0 0 0 0 0 0 0 00 0 0 0 0 0 03703500180 Total0 1 0 0 1 0 0 10 0 1 0 0 0 03703500184 Plastic Packaging IncG-61 39000699 0 0 0 1 0 0 1 00 1 0 0 1 0 03703500184 Total0 0 0 1 0 0 1 00 1 0 0 1 0 03703500186Quaker Furniture, Incorporated dba StudioQ FurnitureG-1 30703002 0 0 0 0 0 0 0 00 0 0 0 0 0 0GR6 10300603 1 0 0 1 0 0 1 00 1 0 0 1 0 03703500186 Total1 0 0 1 0 0 1 00 1 0 0 1 0 03703500202 Sherrill Furniture Company, Inc. G-10 10300603 1 0 0 1 0 0 1 00 1 0 0 1 0 03703500202 Total1 0 0 1 0 0 1 00 1 0 0 1 0 03703500206Shurtape Technologies - Hickory/HighlandPltG-100 10200603 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-16 10200602 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-167 40201301 1 0 0 1 0 0 0 00 0 0 0 0 0 040299999 1 0 0 1 0 0 0 00 0 0 0 0 0 0G-169 40201301 0 0 0 0 0 0 0 00 0 0 0 0 0 03703500206Shurtape Technologies - Hickory/HighlandPltG-208 40201301 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-226 20100202 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-77 10200603 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-78 10200603 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-85 40201301 0 0 0 0 0 0 0 00 0 0 0 0 0 0G-86 40201301 1 0 0 1 0 0 0 00 0 0 0 0 0 0G-87 40201301 1 0 0 1 0 0 0 00 0 0 0 0 0 0G-97 10200602 1 0 0 1 0 0 1 00 0 0 0 0 0 03703500206 Shurtape Technologies -Hickory/Highland G-98 10200602 1 0 0 0 0 0 0 00 0 0 0 0 0 0Table 5.1. Catawba County Point Sources –Annual Emission (tons/year) – ContinuedFacility IDFacility NameUnitIDSCC20082011201420172021NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO23703500533 Total0 1 1 0 1 1 0 11 0 1 1 0 1 1County Grand Total13310 6976 6189 10549 69756187 10548 6975 6186 10548 6973 6184 10548 6971 6183Table 5.2. Davidson County Point Sources –Annual Emission (tons/year)Facility ID Facility NameUnitID SCC Code20082011 20142017 2021NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO2 NOxPM25-PRI SO23705700023Stanley Furniture Company - LexingtonMfg G-36 10200906 15 0 0 15 0 0 15 0 0 15 0 015 0 010201201 0 9 1 0 9 1 0 9 10 9 1 0 9 13705700023 Total15 9 1 15 9 1 15 9 1 15 9 1 15 9 13705700048 Dimension Milling Company, Inc. G-2 10200906 7 3 0 7 3 0 7 3 07 3 0 7 3 03705700048 Total7 3 0 7 3 0 7 3 07 3 0 7 3 03705700049Linwood Furniture, Inc.G-48 10200906 2 1 0 2 1 0 2 1 02 1 0 2 1 0G-49 10200906 9 2 0 9 2 0 9 2 09 2 0 9 2 0G-67 40201901 0 1 0 0 1 0 0 1 00 1 0 0 1 0G-68 30703099 0 0 0 0 0 0 0 0 00 0 0 0 0 03705700049 Total11 4 1 11 4 1 11 4 1 11 4 1 11 4 13705700076T I IndustriesG-3 10200906 3 1 0 3 1 0 2 1 02 1 0 2 0 0G-66 30703099 0 0 0 0 0 0 0 0 00 0 0 0 0 0G-79 40201901 0 0 0 0 0 0 0 0 00 0 0 0 0 0G-88 40201901 0 0 0 0 0 0 0 0 00 0 0 0 0 03705700076 Total3 2 0 3 1 0 2 1 02 1 0 2 1 03705700096Leggett & Platt, Inc. - Metal Bed RailG-2 10300603 1 0 0 1 0 0 1 0 01 0 0 1 0 0G-3 10300603 0 0 0 0 0 0 0 0 00 0 0 0 0 0G-5 10300501 0 0 0 0 0 0 0 0 00 0 0 0 0 0GR3 10300603 1 0 0 1 0 0 1 0 01 0 0 1 0 0GR4 10300603 1 0 0 1 0 0 1 0 01 0 0 1 0 03705700096 Total3 0 0 3 0 0 3 0 03 0 0 3 0 03705700106Owens-Brockway Glass Container Plt 6G-19 31299999 0 0 0 0 0 0 0 0 00 0 0 0 0 0G-26 30501402 105 14 43 109 14 42 114 14 42 119 14 41 125 14 40G-27 30501402 231 23 47 240 23 46 251 23 45 261 23 45 276 23 44G-28 30501402 292 37 69 304 37 68 317 37 67 331 37 67 349 36 65G-29 30501410 0 4 0 0 4 0 0 4 00 4 0 0 4 0G-32 30501416 0 0 0 0 0 0 0 0 00 0 0 0 0 0