Department of Pesticide Regulation 

Mary-Ann Warmerdam 

Director 

Arnold Schwarzenegger 

Governor 

1001 I Street • P.O. Box 4015 • Sacramento, California 95812-4015 • www.cdpr.ca.gov

A Department of the California Environmental Protection Agency 

October 26, 2006 

TO: Interested Parties 

SUBJECT: 2006 UPDATE OF VOLATILE ORGANIC COMPOUND EMISSION 

INVENTORY 

The Department of Pesticide Regulation (DPR) has completed the annual volatile organic 

compound (VOC) emission inventory based on the 2004 pesticide use data for five 

nonattainment areas in California. These areas are designated as being nonattainment for the 

federal one-hour ambient air quality standard for ozone. DPR prepared the inventory as part 

of its commitment to reduce pesticide VOC emissions under the 1994 State Implementation 

Plan (SIP) for agricultural and commercial structural pesticides. 

DPR has continued efforts to improve the accuracy of the emission inventory and the 2004 

inventory reflects these efforts. The most significant improvement was the replacement of 

pesticide product default assumptions with product specific data. In February 2005, DPR 

required the submission of thermogravimetric analysis data for several hundred pesticide 

products. Currently, thermogravimetric analysis is the most accurate method for estimating the 

VOC content of pesticide products. DPR received, evaluated, and incorporated the data for all 

applicable years of the inventory. 

As expected, the 2004 pesticide VOC emission inventory mirrors the 2004 pesticide use report 

that showed decreases for two areas and increases for the other areas compared to 2003. For the 

Sacramento Metropolitan and South Coast nonattainment areas, the 2004 pesticide VOC 

emission inventory continues to meet the targets of the 1994 SIP. The pesticide VOC emission 

inventory for the San Joaquin Valley, Ventura, and Southeast Desert nonattainment areas does 

not meet the targets. Additionally, in 2006, a court ordered DPR to achieve a 20 percent VOC 

reduction from 1991 levels in all nonattainment areas through regulation that must be adopted by 

2008. The ruling is on appeal. However, we are taking regulatory steps to achieve our 1994 SIP 

commitments and comply with the court order.

Bringing the San Joaquin Valley nonattainment area into compliance with our obligations is our 

highest priority. For several years, the pesticide VOC emission inventory trend for the San 

Joaquin Valley showed considerable and steady progress toward meeting the reduction goal, and 

was met in 2001. However, pesticide VOC emissions have increased for the last three years in 

the San Joaquin Valley and are currently above the reduction goal. For the past three years, DPR 

has begun the process of identifying regulatory measures to bring the pesticide VOC emissions 

into compliance with the goals. In 2005, DPR issued a notice to pesticide registrants of products 
Interested Parties 

October 26, 2006 

Page 2 

that contained a high amount of VOCs requiring a plan to reformulate below 20 percent. The 

notice involved over 700 pesticide products and will be completed soon. 

In May 2006, DPR launched a comprehensive initiative to improve air quality by additional 

regulation of pesticides. The Pesticide Air Initiative will involve a regulatory framework that will 

enhance DPR’s commitment to reduce VOC emissions from agricultural and commercial 

structural pesticides in nonattainment areas, as outlined in the 1994 SIP. DPR’s emphasis on 

reducing VOC emissions from pesticides will also be done in a way that reduces pesticide toxic 

risk and drift. 

Our primary focus for reducing pesticide VOC emissions will be based on a reduction in VOC 

emissions from traditional pesticide applications and a shift in pest control practices. To achieve 

these two goals, DPR will reduce emissions from fumigants (which currently account for about 

one-fourth of all pesticide pounds applied annually) and complete the reformulation reevaluation 

process for pesticide products. Regulations to reduce emissions from fumigants will be in place 

by the end of 2007. 

More information on VOCs and DPR’s Pesticide Air Initiative is available at 

<http://www.cdpr.ca.gov/docs/empm/ehap.htm>. 

Sincerely, 

Paul H. Gosselin 

Chief Deputy Director 

(916) 445-4000 
Department of Pesticide Regulation 

Mary-Ann Warmerdam 

Director M E M O R A N D U M Arnold Schwarzenegger 

Governor 

1001 I Street • P.O. Box 4015 • Sacramento, California 95812-4015 • www.cdpr.ca.gov

A Department of the California Environmental Protection Agency 

TO: John S. Sanders 

 Branch Chief 

 Environmental Monitoring Branch 

FROM: Tamara L. Roush, Ph.D Original signed by Tamara Roush

 Environmental Research Scientist 

 (916) 324-4279 

DATE: October 24, 2006 

SUBJECT: 2006 UPDATE TO THE PESTICIDE VOC INVENTORY: 

 ESTIMATED EMISSIONS 1990-2004 

I. OVERVIEW 

This memorandum summarizes the Department of Pesticide Regulation’s (DPR’s) 2006 update 

of estimated pesticide volatile organic compound (VOC) emission data, with particular attention 

to May-October “ozone season” emissions in California’s five non-attainment areas (NAAs). An 

electronic file containing detailed statewide 1990-2004 data is available by download from 

DPR’s Web page at <http://www.cdpr.ca.gov/docs/pur/vocproj/vocmenu.htm> along with a 

variety of VOC documentation. 

The 1990–2004 annual VOC inventories were recalculated and included three revisions to the 

procedures used in 2005 (Li and Spurlock 2005). The revisions were 1) adding 11 application 

sites previously excluded from the VOC inventory and excluding three sites previously included, 

2) updating criteria used to identify and exclude consumer products, and 3) re-calculating the 

default emission potential for products containing sodium tetrathiocarbonate. These revisions are 

explained in greater detail in Spurlock (2006). Future changes that were not incorporated in this 

year’s calculations involve updates to default emission potentials based on formulation codes and 

improved estimations of emission potentials based on data from field studies. 

Additionally, the 1990 – 2004 VOC inventories incorporate new emission potential data for 

several hundred products. In February 2005, DPR requested thermogravimetric analysis data for 

several hundred pesticide products. Thermogravimetric analysis is currently the most accurate 

method for estimating the VOC content of pesticide products. DPR requested the data for most 

liquid products included in the inventory that had not been tested previously. The VOC 

emissions described here incorporate the thermogravimetric analysis data submitted, reviewed, 

and approved as of August 2006. The delay in publishing this annual report is due to time 

required to evaluate and incorporate the new data. 

The 2004 VOC emissions reported are based on DPR’s 2004 pesticide use data, released in 

January 2006 (DPR, 2006). The NAA attainment goals discussed are those originally described 
John S. Sanders 

October 24, 2006 

Page 2 

in the January 8, 1997, Federal Register, page 1170, Emission Reductions (Federal Register, 

1997), as well as those described in the relief order issued April, 26, 2006, following the decision 

in El Comité Para Bienstar de Earlimart v. Helliker, 416 F. Supp. 2d 912, (E.D. Cal. 2006). 

Previously, the 1990 baseline was used to calculate the reduction goals of 12% in the 

San Joaquin Valley NAA and 20% in each of the other NAAs. Under the court order, the 1991 

base year is used, and the goal in each is 20%. (Table 1). For simplicity and ease of comparison 

with previous reports, most of this document refers to the original goals that use 1990 as the base 

year and a 12% reduction for San Joaquin Valley. 

TABLE 1: 1990 and 1991 May–October (ozone season) pesticide VOC emissions and goal 

emission rates in NAAs 1–5 reported as tons of total organic gases per day (tpd). 

 Original Court Order 

NAA 

1990 

emissions 

(tpd) 

Goal 

emissions 

(tpd) 

Goal 

Year 

1991 

emissions 

(tpd) 

Goal 

emissions 

(tpd) 

1 - Sacramento Metropolitan 2.876 2.301 2005 3.134 2.507 

2 - San Joaquin Valley 22.604 19.892 1999 22.258 17.806 

3 - Southeast Desert 1.241 0.993 2007 0.838 0.670 

4 - Ventura 4.524 3.619 2005 3.946 3.157 

5 - South Coast 10.898 8.718 2010 5.210 4.168 

II. 2004 VOC INVENTORY RESULTS BY NON-ATTAINMENT AREA (NAA) 

The 2004 VOC emissions were calculated for each non-attainment area and summed 

according to primary active ingredient, application site, and emission category as defined by 

the Air Resources Board (ARB). The primary active ingredient is defined as the pesticidal 

active ingredient present at the highest percentage in a product. If a pesticide product 

contains 20 percent of active ingredient “A” and 10 percent of active ingredient “B”, all 

estimated emissions from that product are assigned to the primary active ingredient “A”. 

This approach prevents “double-counting” of emissions from products containing two active 

ingredients. The Air Resources Board defines four VOC emission categories: methyl 

bromide emissions from agricultural applications, non-methyl bromide emissions from 

agricultural applications, methyl bromide emissions from structural applications, and 

non-methyl bromide emissions from structural applications. Emissions were calculated for 

May – October, the ozone season, and are reported as US tons of total organic gases per day 

(tpd). 
John S. Sanders 

October 24, 2006 

Page 3 

A. NAA 1, Sacramento Metropolitan Area 

The emission rate in NAA 1 continues the decreasing trend seen since 2002 and is down 

15.3% from the 2003 rate of 1.624 tpd. The 2004 level of 1.376 tpd is well below the 2005 

goal emission rate of 2.301 tpd (Figure 1). Molinate and thiobencarb, herbicides used on rice, 

contributed substantially to NAA 1 emissions (Table 2). The insecticide chlorpyrifos was the 

second highest contributor at 7.8% of the emissions. Rice was the highest contributing 

application site with 27.5% of emissions, followed by walnuts at 13.2% (Table 3). Products 

containing the fumigants 1,3-dichloropropene and methyl bromide accounted for much of the 

emissions in NAA 1. Agricultural applications contributed to 90.6% of the total emissions, 

with 85.6% comprised of non-methyl bromide agricultural applications (Table 4). 

TABLE 2: Top ten primary active ingredients contributing to 2004 May-October ozone season 

VOC emissions in NAA 1, the Sacramento Metropolitan Area. 

Primary AI 

Total product emissions 

(tons/day) 

% of all NAA 1 May - 

Oct 2004 emissions 

MOLINATE 0.198 14.4 

CHLORPYRIFOS 0.108 7.8 

THIOBENCARB 0.100 7.3 

1,3-DICHLOROPROPENE 0.094 6.8 

METHYL BROMIDE 0.068 5.0 

CYPERMETHRIN 0.065 4.7 

COPPER ETHANOLAMINE 

COMPLEXES, MIXED 0.055 4.0 

TRIFLURALIN 0.050 3.6 

PROPYLENE OXIDE 0.049 3.5 

DIMETHOATE 0.047 3.4 
John S. Sanders 

October 24, 2006 

Page 4 

TABLE 3: Top ten pesticide application sites contributing to 2004 May-October ozone season 

VOC emissions in NAA 1. 

Application site Emissions (tons/day) 

% of all NAA 1 May - 

Oct 2004 emissions 

RICE 0.379 27.5 

WALNUT 0.182 13.2 

STRUCTURAL PEST CONTROL 0.130 9.4 

PROCESSING TOMATOES 0.126 9.2 

RIGHTS OF WAY 0.090 6.5 

COMMODITY FUMIGATION 0.081 5.9 

WINE GRAPE 0.071 5.2 

ALFALFA 0.054 3.9 

SOIL FUMIGATION / PREPLANT 0.037 2.7 

LANDSCAPE MAINTENANCE 0.029 2.1 

TABLE 4: 2004 May–October VOC emissions in NAA1 by ARB emission inventory 

classification (tons per day, tpd). 

Agricultural applications Structural applications 

methyl bromide emissions 0.068 0.000 

non-methyl bromide emissions 1.178 0.130 

B. NAA 2, San Joaquin Valley 

The 2004 ozone season NAA 2 emission rate of 25.648 tpd is slightly more than the 24.559 

tpd found in 2003, and still greater than rates in 2002 and 2001. Furthermore, this exceeded 

the 1999 goal of 19.892 tpd by 28.9% (Figure 1). Fumigants accounted for 54.2% of all 

emissions (Table 5), and carrots, almonds, and cotton were the top three application sites, 

contributing 38% to emissions (Table 6). These are the same trends as those reported for 

2002 and 2003. Almost all of 2004 NAA 2 VOC emissions (98.4%) were attributable to 

agricultural pesticide uses with the remaining 1.6% from commercial structural pesticide 

applications. Methyl bromide contributed only 10.6% to the agricultural applications and 

3.2% to non-agricultural applications (Table 7). 
John S. Sanders 

October 24, 2006 

Page 5 

TABLE 5: Top ten primary active ingredients contributing to 2004 May-October ozone season 

VOC emissions in NAA 2, the San Joaquin Valley. 

Primary AI 

Total product emissions 

(tons/day) 

% of all NAA 2 May - 

Oct 2004 emissions 

METAM-SODIUM 5.749 22.4 

1,3-DICHLOROPROPENE 4.887 19.1 

CHLORPYRIFOS 2.856 11.1 

METHYL BROMIDE 2.694 10.5 

DIMETHOATE 0.570 2.2 

OXYFLUORFEN 0.569 2.2 

POTASSIUM NMETHYLDITHIOCARBAMATE 0.565 2.2 

GIBBERELLINS 0.515 2.1 

ENDOSULFAN 0.515 2.0 

ACROLEIN 0.454 1.8 

TABLE 6: Top ten pesticide application sites contributing to 2004 May-October 

ozone season VOC emissions in NAA 2. 

Application site Emissions (tons/day) 

% of all NAA 2 May - 

Oct 2004 emissions 

CARROT 3.952 15.4 

ALMOND 3.113 12.1 

COTTON 2.690 10.5 

ORANGE 2.007 7.8 

NURSERY OUTDR CONTAINER 

-FLD GRWN PLANTS 1.779 6.9 

GRAPE 1.337 5.2 

POTATO 0.985 3.8 

WALNUT 0.838 3.3 

RIGHTS OF WAY 0.654 2.6 

PROCESSING TOMATOES 0.579 2.3 

TABLE 7: 2004 May–October VOC emissions in NAA 2 by ARB emission inventory 

classification (tons per day, tpd). 

Agricultural applications Structural applications 

methyl bromide emissions 2.681 0.013 

non-methyl bromide emissions 22.563 0.391 
John S. Sanders 

October 24, 2006 

Page 6 

C. NAA 3, Southeast Desert 

The 2004 NAA 3 ozone season VOC emissions of 1.506 have not changed much since 2003 

(1.559 tpd). Emission rates for this region have generally increased since 1998 and are now 

51.7% above the 2007 ozone season target of 0.993 tpd (Figure 1). The fumigants 

metam-sodium, methyl bromide, 1,3-dichloropropene, and chloropicrin were the top four 

contributing primary active ingredients, together comprising 82.7% of the NAA 3 emissions 

(Table 8). Uncultivated agricultural areas accounted for approximately one quarter of all 

emissions, followed by peppers, carrots, and strawberries (Table 9). Agricultural applications 

contributed to 94.1% of all emissions. Methyl bromide was more widely used in NAA 3, 

accounting for 24.8% of emissions from the agricultural applications (Table 10).

TABLE 8: Top ten primary active ingredients contributing to 2004 May-October ozone season 

VOC emissions in NAA 3, the Southeast Desert. 

Primary AI 

Total product emissions 

(tons/day) 

% of all NAA 3 May - 

Oct 2004 emissions 

METAM-SODIUM 0.835 55.5 

METHYL BROMIDE 0.352 22.4 

1,3-DICHLOROPROPENE 0.041 2.7 

CHLOROPICRIN 0.031 2.1 

PERMETHRIN 0.029 1.9 

CHLORPYRIFOS 0.018 1.2 

EPTC 0.015 1.0 

MEFENOXAM 0.014 0.9 

BENSULIDE 0.014 0.9 

PENDIMETHALIN 0.011 0.7 

TABLE 9: Top ten pesticide application sites contributing to 2004 May-October 

ozone season VOC emissions in NAA 3. 

Application site Emissions (tons/day)

% of all NAA 3 May 

- Oct 2004 emissions 

UNCULTIVATED AGRICULTURAL 

AREAS* 0.378 25.1 

PEPPERS, FRUITING 0.261 17.3 

CARROT 0.181 12.0 

STRAWBERRY 0.160 10.7 

POTATO 0.128 8.5 

STRUCTURAL PEST CONTROL 0.087 5.8 

CANTALOUPE 0.053 3.5 

TURF / SOD 0.039 2.6 

CELERY 0.034 2.2 

WATERMELON 0.028 1.8 

* Treatment of an area prior to determining which crop will be planted. 
John S. Sanders 

October 24, 2006 

Page 7 

TABLE 10: 2004 May–October VOC emissions in NAA 3 by ARB emission inventory 

classification (tons per day, tpd). 

D. NAA 4, Ventura 

Ozone season emissions of 9.506 increased 24.7% over 2003, and exceeded the 2005 target 

of 3.619 tpd by 97.4% (Figure 1). As in NAA 3 and NAA 2, fumigants contributed to the 

majority of emissions (Table 11). Strawberry applications produced approximately three 

quarters of the emissions, and soil fumigations accounted for another 10.5% (Table 12). 

Only 2.1% of NAA 4 emissions resulted from commercial structural pesticide applications, 

and methyl bromide emissions comprised over half of the emissions from agricultural 

applications (Table 13). 

TABLE 11: Top ten primary active ingredients contributing to 2004 May-October ozone season 

VOC emissions in NAA 4, Ventura. 

Primary AI 

Total product emissions 

(tons/day) 

% of all NAA 4 May - 

Oct 2004 emissions 

METHYL BROMIDE 4.855 51.1 

1,3-DICHLOROPROPENE 2.524 26.5 

CHLOROPICRIN 1.001 10.5 

METAM-SODIUM 0.457 4.8 

PIPERONYL BUTOXIDE 0.178 1.9 

CHLORPYRIFOS 0.081 0.9 

PETROLEUM OIL, 

UNCLASSIFIED 0.072 0.8 

ABAMECTIN 0.028 0.3 

POTASSIUM NMETHYLDITHIOCARBAMATE 0.028 0.3 

METALDEHYDE 0.024 0.3 

Agricultural applications Structural applications 

methyl bromide emissions 0.352 0.000 

non-methyl bromide emissions 1.066 0.088 
John S. Sanders 

October 24, 2006 

Page 8 

TABLE 12. Top ten pesticide application sites contributing to 2004 May-October ozone season 

VOC emissions in NAA 4. 

Application site Emissions (tons/day) 

% of all NAA 4 May - 

Oct 2004 emissions 

STRAWBERRY 7.060 74.3 

SOIL FUMIGATION / PREPLANT 0.997 10.5 

TOMATO 0.430 4.5 

STRUCTURAL PEST CONTROL 0.198 2.1 

LEMON 0.196 2.1 

NURSERY OUTDR GRWN CUT 

FLWRS OR GREENS 0.098 1.0 

UNCULTIVATED 

AGRICULTURAL AREAS 0.094 1.0 

TURF / SOD 0.080 0.8 

RASPBERRY 0.078 0.8 

PEPPERS, FRUITING 0.061 0.6 

TABLE 13: 2004 May–October VOC emissions in NAA 4 by ARB emission inventory 

classification (tons per day, tpd). 

Agricultural applications Structural applications 

methyl bromide emissions 5.135 0.000 

non-methyl bromide emissions 4.173 0.198 

E. NAA 5, South Coast 

At 2.615 tpd, VOC emissions in NAA 5 were slightly lower than those in 2003 (Figure 1), 

and were far below the 2010 goal emission rate of 8.718 tpd. Methyl bromide, 1,3-

dichloropropene, and chloropicrin contributed to 51.7% of emissions (Table 14). 

Consequently, application sites based heavily on fumigations also accounted for almost all 

emission production (Table 15). Approximately one third each of emissions in NAA 5 were 

attributable to methyl bromide agricultural uses, non-methyl bromide agricultural uses, and 

non-methyl bromide commercial structural uses (Table 16). 
John S. Sanders 

October 24, 2006 

Page 9 

TABLE 14: Top ten primary active ingredients contributing to 2004 May-October ozone 

season VOC emissions in NAA 5, South Coast. 

Primary AI 

Total product emissions 

(tons/day) 

% of all NAA 5 May - 

Oct 2004 emissions 

METHYL BROMIDE 0.881 33.7 

PERMETHRIN 0.338 12.9 

1,3-DICHLOROPROPENE 0.328 12.5 

N-OCTYL BICYCLOHEPTENE 

DICARBOXIMIDE 0.174 6.7 

CHLOROPICRIN 0.143 5.5 

BIFENTHRIN 0.075 2.9 

CHLORPYRIFOS 0.055 2.1 

CYPERMETHRIN 0.049 1.9 

PIPERONYL BUTOXIDE 0.046 1.8 

CYFLUTHRIN 0.038 1.4 

TABLE 15: Top ten pesticide application sites contributing to 2004 May-October 

ozone season VOC emissions in NAA 5. 

Application site Emissions (tons/day) 

% of all NAA 5 May - 

Oct 2004 emissions 

STRAWBERRY 1.099 42.0 

STRUCTURAL PEST CONTROL 0.892 34.1 

FUMIGATION, OTHER 0.176 6.7 

LANDSCAPE MAINTENANCE 0.140 5.4 

NURSERY OUTDR CONTAINER 

-FLD GRWN PLANTS 0.064 2.4 

RIGHTS OF WAY 0.056 2.2 

COMMODITY FUMIGATION 0.040 1.5 

SOIL APPLICATION/PREPLANT 0.029 1.1 

PEPPERS, FRUITING 0.022 0.8 

FOOD PROCESSING/HANDLING 

PLANT/AREA (ALL / UNSPEC) 0.017 0.6 

TABLE 16: 2004 May–October VOC emissions in NAA 5 by ARB emission inventory 

classification (tons per day, tpd). 

Agricultural applications Structural applications 

methyl bromide emissions 0.876 0.005 

non-methyl bromide emissions 0.845 0.889 
John S. Sanders 

October 24, 2006 

Page 10 

III. SUMMARY 

NAA 1 (Sacramento Metropolitan) and NAA 5 (South Coast) 2004 May-October emissions were 

the only two regions with emission rates below their respective attainment goals. Emission rates 

for NAA 1 and NAA 5 also were lower than those found in 2003. On the other hand NAA 2 

(San Joaquin Valley) and NAA 4 (Ventura) produced higher emission rates in 2004 and 

exceeded their attainment goals. Although the emission rate in NAA 3 (Southeast Desert) 

decreased slightly in 2004, this rate is still well above its attainment goal. These trends hold 

regardless if 1990 or 1991 is used as the base year, or a 12% or 20% reduction goal is used for 

San Joaquin Valley. Fumigants were the major sources of emissions in all regions except 

NAA 1; consequently unless these emissions are significantly reduced, NAA 2, NAA 3, and 

NAA 4 will continue to fail to meet their goals. 

IV. REFERENCES 

Department of Pesticide Regulation. 2006. News Release 06-01: DPR releases 2004 pesticide 

use data; more nature-friendly chemicals gain favor. available on-line: 

<http://www.cdpr.ca.gov/docs/pressrls/2006/060124.htm> , verified September 5, 2006. 

Eastern District of California. 2006. No. Civ. S-04-882 (E.D. Cal. filed April 6, 2006), enforcing

El Comité Para el Bienestar de Earlimart v. Helliker, 416 F. Supp. 2d 912. 

Federal Register, January 8, 1997. Volume 62, No. 5, p. 1170. 

Li, L. Y. and F. Spurlock. 2005. April 5, 2005, memorandum to J. Sanders: January 2005 update 

to the Pesticide Volatile Organic Compound Inventory: Estimated Emissions 1990—2003. 

Spurlock, F. 2006. July 18, 2006, memorandum to J. Sanders: 2006 Revisions to Procedures for 

Estimating Volatile Organic Compound Emissions from Pesticides. 

cc: Randy Segawa, Agriculture Program Supervisor 
John S. Sanders 

October 24, 2006 

Page 11 

Figure 1. Annual ozone season pesticide VOC emissions by NAA. For simplicity and ease of 

comparison with previous reports, these figures use 1990 as the base year and a 12% reduction for 

San Joaquin Valley. 

NAA 1 Sacramento Metropolitan 

Year

1990

1992

1994

1996

1998

2000

2002

2004

Emission rate (tpd)

1.0

1.5

2.0

2.5

3.0

3.5

4.0

VOC emissions

Goal emission

NAA 2 San Joaquin Valley

Year

1990

1992

1994

1996

1998

2000

2002

2004

Emission rate (tpd)

15

20

25

30

35

40

NAA 3 Southeast Desert

Year

1990

1992

1994

1996

1998

2000

2002

2004

Emission rate (tpd)

0.4

0.6

0.8

1.0

1.2

1.4

1.6

1.8

NAA 4 Ventura 

Year

1990

1992

1994

1996

1998

2000

2002

2004

Emission rate (tpd)

3

4

5

6

7

8

9

10

NAA 5 South Coast

Year

1990

1992

1994

1996

1998

2000

2002

2004

Emission rate (tpd)

2

4

6

8

10

12