DRAFT 

2007 Regional SO2 Emissions and Milestone Report

December 23, 2008

Arizona

Corky Martinkovic 

Arizona Dept. of Environmental Quality 

Air Quality Division, Planning Section 

1110 West Washington Street 

Phoenix, AZ 85007 

Fax: 602-771-2366 

dam@azdeq.gov

City of Albuquerque

Dario W. Rocha 

City of Albuquerque 

Air Quality Division 

P.O. Box 1293 

Albuquerque, NM 87103 

Fax: 505-768-1977 

drocha@cabq.gov

New Mexico

Ronald Duffy 

New Mexico Environment Department 

Air Quality Bureau 

2048 Galisteo St. 

Santa Fe, NM 87505 

Phone: 505-955-8011 

Fax: 505-827-1543 

ronald.duffy@state.nm.us

Utah

Kimberly Kreykes 

Utah Department of Environmental Quality 

Division of Air Quality 

150 North 1950 West 

Salt Lake City, UT 84114-4820 

Phone: 801-536-4042 

Fax: 801-536-0085 

kkreykes@utah.gov 

Wyoming

Brian Bohlmann, P.E. 

Wyoming Department of Environmental 

Quality, Air Quality Division 

Herschler Building, 2-East 

122 West 25th Street 

Cheyenne, Wyoming 82002 

Phone: 307-777-6993 

Fax: 307-777-7682 

bbohlm@wyo.gov

 
 
December 23, 2008 

ES-1 

Based on the adjusted milestone and 

emissions data, the average of 2005, 

2006, and 2007 emissions is about 

33% below the 2007 four state 

regional milestones. 

DRAFT 

2007 Regional SO2 Emissions and Milestone Report 

Executive Summary

Under Section 309 of the federal Regional Haze Rule, nine western states and tribes 

within those states have the option of submitting plans to reduce regional haze emissions that 

impair visibility at 16 Class I national parks and wilderness areas on the Colorado Plateau. Five 

states -- Arizona, New Mexico, Oregon, Utah, and Wyoming -- initially exercised this option by 

submitting plans to EPA by December 31, 2003. Oregon elected to cease participation in the 

program in 2006. The tribes were not subject to the deadline and still can opt into the program at 

any time. Under the Section 309 plans, the four remaining participating states have tracked the 

emissions of the applicable stationary sources as part of the pre-trigger portion of the SO2 

Milestone and Backstop Trading Program. The Western Regional Air Partnership (WRAP) is 

assisting these states with the implementation and management of the regional emission 

reduction program. 

 As part of this program, the participating states must submit an annual Regional Sulfur 

Dioxide (SO2) Emissions and Milestone Report that compares emissions to milestones. A 

milestone is a maximum level of annual emissions for a given year. The first report was 

submitted in 2004 for the calendar year 2003. 

This year, the four participating states have either revised their Section 309 plans or are 

currently in the process of revising their plans. The revised plans modified the annual regional 

milestone for 2007. Because two of the four states are currently operating under revised rules, 

this transition year report compares annual emissions to 2007 milestones under both the revised 

and 2003 plans. All states are expected to have revised plans by next year's report. 

The four-state region milestone for 2007 is 422,194 tons under the original 2003 plans, 

and 420,637 tons under the revised plans. To determine whether or not the milestone was met, 

the 2005, 2006, and 2007 adjusted emissions were averaged, and this average was compared to 

the 2007 milestones. Oregon's emissions were removed from the 2005 emission totals before the 

average was calculated, to stay consistent with the 2006 and 2007 emissions total. The 

adjustments to reported emissions were required to allow the current emission estimates to be 

comparable to the emissions monitoring or calculation method used in the initial base year 

inventory (1999 for utilities and 1998 for all other sources). 

The states of Arizona, New Mexico, Utah, 

and Wyoming reported 257,234 tons of SO2

emissions for the calendar year 2007. The total 

emissions increased to 273,663 tons of SO2 after 

making adjustments to account for changes in 

monitoring and calculation methods. The 

adjustments result in an additional 16,429 tons of 

SO2 emissions, which is about 6% of the reported total emissions. Adjustments required for 
Executive Summary 

December 23, 2008 

ES-2 

changes in Part 75, Acid Rain Program, flow monitor quality assurance methods account for 

about 15,225 tons (93%) of the increase in the estimate, with the remaining 1,204 tons from 

other types of monitoring and calculation method changes. The adjusted emissions values for 

2005 and 2006 were 288,040 tons and 279,134 tons, respectively. The 2007 adjusted emissions 

total of 273,663 tons was lower than both the 2005 and 2006 adjusted annual emissions. The 

average of 2005, 2006, and 2007 adjusted emissions is 280,279 tons. 

 Based on this average adjusted annual emissions estimate, a preliminary determination 

has been made that the four states have met the 2007 regional SO2 milestone under both the 2003 

and revised plans. The plans contain provisions to adjust the milestones to reflect variations in 

smelter operations, and to account for enforcement actions (to reduce the milestones where an 

enforcement action identified that emissions in the baseline period were greater than allowable 

emissions). Based on emissions data received from the states and SIP requirements regarding 

adjustments to the milestones, the 2007 period requires a smelter adjustment under the 2003 

plans (increasing the regional milestone by 2,000 tons); no smelter adjustment is required under 

the revised plans. 

 The plans also require that the annual report identify changes in the source population 

from year to year and significant changes in a source's emissions from year to year. The 

significant emission changes from 2006 to 2007 are included in Section 7 of this report. A list of 

facilities added to or removed from the list of subject sources included in the base year 

inventories is included in Appendix B. 
Executive Summary 

December 23, 2008 

ES-3 

Table ES-1 

Overview of 2007 Regional Milestones and Emissions for Section 309 Participating States 

2007 Sulfur Dioxide Milestones

Revised SIPs 

Regional 2007 Milestone* ...................................................................................................................... 420,637 tons

 Smelter-specific Set-aside* ................................................................................................................. 0 tons

Adjusted Four-State 2007 Milestone....................................................................................................... 420,637 tons

2003 SIPs 

Regional 2007 Milestone* ...................................................................................................................... 420,194 tons

 Smelter-specific Set-aside* .......................................................................................................... 2,000 tons

Adjusted Four-State 2007 Milestone....................................................................................................... 422,194 tons

2007 Sulfur Dioxide Emissions

Reported Four-State 2007 Emissions ..................................................................................................... 257,234 tons

Adjustments** 

 Part 75 Flow RATA Procedures 15,225 ton

 Other Emission Monitoring and Calculation Methods 1,204 ton

Adjusted Four-State 2007 Emissions 273,663 ton

Average Sulfur Dioxide Emissions (2005, 2006, & 2007)

Adjusted Four-State 2007 Emissions ..................................................................................................... 273,663 tons

Adjusted Four-State 2006 Emissions ..................................................................................................... 279,134 tons

Adjusted Four-State 2005 Emissions ..................................................................................................... 288,040 tons

Average of 2005, 2006, & 2007 Adjusted Four-State Emissions ........................................................... 280,279 tons

Comparison of Emissions to Milestone

Average of 2005, 2006, & 2007 Adjusted Four-State Emissions............................................................ 280,279 tons

Adjusted Four-State 2007 Milestone Revised SIPs ................................................................................ 420,637 tons

Adjusted Four-State 2007 Milestone 2003 SIPs ..................................................................................... 422,194 tons

Difference (negative value = emissions < milestone) Revised SIPs ..................................................... -140,358 tons

Difference (negative value = emissions < milestone) 2003 SIPs .......................................................... -141,915 tons

2005 - 2007 Emissions Average as Percent of 2007 Revised SIP Milestone........................................................67%

2005 - 2007 Emissions Average as Percent of 2007 2003 SIP Milestone ............................................................66%

 * See the Regional Milestones section of each state's 309 SIP. 

 ** See the Annual Emissions Report section of each state's 309 SIP. 

 
Executive Summary 

December 23, 2008 

ES-4 

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December 23, 2008 

1 

2007 Regional SO2 Emissions and Milestone Report 

1.0 Introduction 

1.1 Background 

 Under Section 309 of the federal Regional Haze Rule (40 CFR Part 51), nine western 

states and the tribes within those states have the option of submitting plans to reduce regional 

haze emissions that impair visibility at 16 Class I national parks and wilderness areas on the 

Colorado Plateau. Five states -- Arizona, New Mexico, Oregon, Utah, and Wyoming -- and the 

city of Albuquerque, New Mexico exercised this option by submitting plans to EPA by 

December 1, 2003. Oregon has since elected to cease participation in the SO2 Milestone and 

Backstop Trading Program by not resubmitting a Section 309 SIP. The tribes were not subject to 

this deadline and still can opt into the program at any time. 

Under the Section 309 State Implementation Plans (SIPs), these four states have been 

tracking emissions under the pre-trigger requirements of the SO2 Milestone and Backstop 

Trading Program since 2003. The Western Regional Air Partnership (WRAP) is assisting these 

states with the implementation and management of this regional emission reduction program. 

Under the milestone phase of the program, the states have established annual SO2 

emissions targets (from 2003 to 2018). These voluntary emissions reduction targets represent 

reasonable progress in reducing the emissions that contribute to regional haze. If the 

participating sources fail to meet the milestones through this voluntary program, then the states 

will trigger the backstop trading program and implement a regulatory emissions cap for the 

states, allocate emissions allowances (or credits) to the affected sources based on the emissions 

cap, and require the sources to hold sufficient allowances to cover their emissions each year. 

 This report is the fifth annual report for the milestone phase of this program. The report 

provides background on regional haze and the Section 309 program, the milestones established 

under the program, and the emissions reported for 2007. Based on the first five years, the 

voluntary milestone phase of the program is working, and emissions are well below the target 

levels. 

What is Regional Haze? 

Regional haze is air pollution that is transported long distances and reduces visibility in 

national parks and wilderness areas across the country. Over the years, this haze has reduced the 

visual range from 145 kilometers (90 miles) to 24-50 kilometers (15-31 miles) in the East, and 

from 225 kilometers (140 miles) to 56-145 kilometers (35-90 miles) in the West. The pollutants 

that create this haze are sulfates, nitrates, organic carbon, elemental carbon, and soil dust. 

Human-caused haze sources include industry, motor vehicles, agricultural and forestry burning, 

and windblown dust from roads and farming practices. 
Draft Report 

December 23, 2008 

2 

What U.S. EPA Requirements Apply? 

In 1999, the Environmental Protection Agency (EPA) issued regulations to address 

regional haze in 156 national parks and wilderness areas across the country. These regulations 

were published in the Federal Register on July 1, 1999 (64 FR 35714). The goal of the Regional 

Haze Rule (RHR) is to eliminate human-caused visibility impairment in national parks and 

wilderness areas across the country. It contains strategies to improve visibility over the next 60 

years, and requires states to adopt implementation plans. 

EPA's RHR provides two paths to address regional haze. One is 40 CFR 51.308 (Section 

308), and requires most states to develop long-term strategies out to the year 2064. These 

strategies must be shown to make "reasonable progress" in improving visibility in Class I areas 

inside the state and in neighboring jurisdictions. The other is 40 CFR 51.309 (Section 309), and 

is an option for nine states -- Arizona, California, Colorado, Idaho, Nevada, New Mexico, 

Oregon, Utah, and Wyoming -- and the 211 tribes located within these states to adopt regional 

haze strategies for the period from 2003 to 2018. These strategies are based on 

recommendations from the Grand Canyon Visibility Transport Commission (GCVTC) for 

protecting the 16 Class I areas on the Colorado Plateau. Adopting these strategies constitutes 

reasonable progress until 2018. These same strategies can also be used by the nine western 

states and tribes to protect the other Class I areas within their own jurisdictions. 

 EPA revised the RHR on July 6, 2005 (70 FR 39104), and again on October 13, 2006 (71 

FR 60612) in response to two legal challenges. The October 13, 2006 revisions modified 

Section 309 to provide a methodology consistent with the Court's decision for regional 

alternatives like the strategy based on the GCVTC recommendations. 

How Have the WRAP States Responded to EPA Requirements? 

 Of the nine states (and tribes within those states) that have the option under Section 309 

of participating in a regional strategy to reduce SO2 emissions, five states had originally 

submitted Section 309 SIPs to EPA. These states were Arizona, New Mexico, Oregon, Utah, 

and Wyoming. In addition, the City of Albuquerque had also submitted a Section 309 SIP. 

EPA, however, never approved these SIPs due to the legal challenges. 

 

 Oregon has opted out of submitting a revised Section 309 SIP under the modified RHR, 

which leaves four participating states. Utah and Wyoming have already submitted revised SIPs 

to EPA, and Arizona and New Mexico are in the process of revising their SIPs. To date, no 

tribes have opted to participate under Section 309, and the other four states of the original nine 

opted to submit SIPs under Section 308 of the RHR. 

 The following summarizes a few key elements of the Section 309 process for the four 

states: 

1. Section 309(d)(4)(i) requires SO2 milestones in the SIP, and includes provisions for 

making adjustments to these milestones if necessary. The milestones must provide for 

steady and continuing emission reductions through 2018, and provide for greater 

reasonable progress than the provisions of Section 308. 
Draft Report 

December 23, 2008 

3 

2. Section 309(d)(4)(iii) requires monitoring and reporting of stationary source SO2 

emissions in order to ensure the SO2 milestones are met. The SIP must commit to 

reporting to the WRAP as well as to EPA. 

3. Section 309(d)(4)(iv) requires that a SIP contain criteria and procedures for activating the 

trading program within 5 years if an annual milestone is exceeded. A Section 309 SIP 

also must provide assessments in 2013 and 2018. 

This report responds to Item 2, above, and provides the annual report that compares the 

2007 emissions against the milestones for the states that have submitted Section 309 SIPs to 

EPA. 

What Elements Must the Regional SO2 Emissions and Milestone Report Contain? 

 To facilitate compliance with the Section 309 SIPs, the WRAP has committed to 

compiling a regional report on emissions for each year. In accordance with the SIPs, the WRAP 

will compile the individual state emission reports into a summary report that includes: 

1. Reported regional SO2 emissions (tons/year). 

2. Adjustments to account for: 

● Changes in flow rate measurement methods; 

● Changes in emissions monitoring or calculation methods; or 

● Enforcement actions or settlement agreements as a result of enforcement actions. 

3. As applicable, average adjusted emissions for the last three years (which are compared to 

the regional milestone). Since this is the fifth report, 2005, 2006, and 2007 emissions are 

averaged. 

4. Regional milestone adjustments to account for production increases at certain smelters. 

How Is Compliance with the SO2 Milestone Determined? 

 While the WRAP assists with the preparation of this report, each state reviews the 

information in the report, and proposes a draft determination that the regional SO2 milestone has 

either been met or exceeded. The draft determination is then submitted for public review and 

comment during the first part of 2009, culminating in a final report sent to EPA by March 31, 

2009. 

 SIP Transition Period and Milestones

 The revised SIPs modified the annual regional milestone for 2007. Because only two of 

the four states are operating under revised rules, this report includes comparisons to milestones 

under both the revised and the 2003 SIPs. All states are expected to have revised SIPs by next 

year's report. 
Draft Report 

December 23, 2008 

4 

1.2 Report Organization 

 This report presents the regional SO2 emissions and milestone information required by 

the 309 SIPs for the four states. The report is divided into the following sections, including two 

appendices: 

● Reported SO2 Emissions in 2007; 

● Monitoring Methodology Emissions Adjustments; 

● Three-year Average Emissions; 

● Enforcement Milestone Adjustments; 

● Smelter Milestone Adjustments; 

● Quality Assurance (including Source Change information); 

● Preliminary Milestone Determination; 

● Appendix A - Facility Emissions and Emissions Adjustments; and 

● Appendix B - Changes to SO2 Emissions and Milestone Source Inventory. 

2.0 Reported SO2 Emissions in 2007 

 All stationary sources with reported emissions of 100 tons or more per year in 2000 or 

any subsequent year are required to report annual SO2 emissions. Table 1 summarizes the annual 

reported emissions from applicable sources in each state. The 2007 reported SO2 emissions for 

each applicable source are in Appendix A, Table A-1. 

Table 1 

Reported 2007 SO2 Emissions by State 

State Reported 2007 SO2 Emissions (tons/year) 

Arizona 85,922 

New Mexico 30,786 

Utah 30,733 

Wyoming 109,793 

TOTAL 257,234 

3.0 Monitoring Methodology Emissions Adjustments 

 The annual emissions reports for each state include proposed emissions adjustments to 

ensure consistent comparison of emissions to the milestones. The adjustments account for any 

differences in emissions that result from changes in the monitoring or calculation methodology 

used in 2007 as compared to the methodology used to calculate baseline year emissions (1998 

and 1999). The following sections detail what adjustments apply for 2007. Note that the revised 

Section 309 SIPs establish new milestones for 2008-2018 using an updated baseline of 2006. 
Draft Report 

December 23, 2008 

5 

Therefore, the adjustments described in the following sections will not be performed in 

subsequent reports under the revised SIPs. 

3.1 Changes in Part 75 Flow Rate Methodology 

 The Section 309 SIPs spell out three specific methods for adjusting Part 75 Acid Rain 

Program electric generating unit emissions due to changes in quality assurance procedures for 

the flow monitor component of SO2 continuous emission monitoring systems. These changes 

involve the use of new flow reference methods in the Relative Accuracy Test Audit (RATA), 

which were not available in the 1999 baseline year. The use of these new methods (reference 

methods 2F, 2G, 2H, and 2J) are expected to result in a decrease in the SO2 emissions 

measurement. 

 The three methods in the SIPs for adjusting for flow RATA reference method changes are 

outlined below: 

1. Directly determine the difference in flow rate through a side-by-side comparison of data 

collected with the new and old flow reference methods during a RATA test. 

2. Compare the annual average heat rate using Acid Rain heat input data (mmBtu) and total 

generation (MWhrs) as reported to the federal Energy Information Administration (EIA). 

Under this approach, the flow adjustment factor shall be calculated using the following 

ratio: 

Heat input/MW for first full year of data using new flow rate method

Heat input/MW for last full year of data using old flow rate method

3. Compare the standard CFM per MW before and after the new flow reference method 

based on CEM data submitted in the Acid Rain Program, as follows: 

SCF/Unit of Generation for first full year of data using new flow rate method

SCF/Unit of Generation for last full year of data using old flow rate method 

New Mexico, Utah, Arizona, and Wyoming provided adjusted emissions for changes in 

the Part 75 flow RATA reference method for several plants: the Public Service Corp of New 

Mexico San Juan plant and the Tri-State Escalante plant in New Mexico; the PacifiCorp Carbon, 

Hunter, and Huntington plants and the Intermountain Power Service Corporation plant in Utah; 

the AEPCO Apache Station and Pinnacle West - Cholla Generating Station in Arizona; and the 

Pacificorp Dave Johnston, Jim Bridger, Naughton, and Wyodak plants in Wyoming. Changes in 

the RATA flow reference method result in an upward adjustment for the 2007 SO2 emissions of 

15,225 tons. 

 The adjustment for each of these plants is listed below in Table 2. The Appendix table 

A-1 provides additional information on the flow RATA reference method changes, and which 

adjustment method was used for each plant. 
Draft Report 

December 23, 2008 

6 

Table 2 

Adjustments for Changes in Part 75 Flow RATA 

State Source 

Reported 2007 

SO2 Emissions 

(tons) 

Flow RATA 

Adjustment 

(tons) 

Adjusted 2007 

SO2 Emissions 

(tons) 

AZ AEPCO - Apache Station 2,662 2,675 13 

AZ Pinnacle West - Cholla Generating 

Station 

23,522 23,650 128 

NM Public Service Co. of New 

Mexico/San Juan Generating 

Station 

15,305 17,683 2,378 

NM Tri-State Gen & 

Transmission/Escalante Station 

1,124 1,591 467 

UT Intermountain Power Service 

Corporation - Intermountain 

Generation Station 

4,764 4,788 24 

UT PacifiCorp - Carbon Power Plant 6,511 7,537 1,026 

UT PacifiCorp - Hunter Power Plant 6,672 7,658 986 

UT PacifiCorp - Huntington Power 

Plant 

4,351 4,931 580 

WY PacifiCorp - Dave Johnston 21,356 25,791 4,435 

WY PacifiCorp - Jim Bridger 19,053 20,486 1,433 

WY PacifiCorp - Naughton 21,588 24,873 3,285 

WY PacifiCorp - Wyodak 7,835 8,305 470 

3.2 Changes in Emissions Monitoring and Calculation Methodology 

 In addition to the specific flow reference method related requirement for Part 75 program 

sources, there is also a general requirement to account for any changes in emissions monitoring 

or calculation methods. The reported emissions are adjusted so that the adjusted emissions levels 

are comparable to the levels that would result if the state used the same emissions monitoring or 

calculation method that was used in the base year inventory (1999 for utilities and 1998 for all 

other sources). The net impact throughout the region as a result of these adjustments is an 

increase of 1,204 tons from the reported 2007 emissions. Table 3 summarizes these results, and 

Appendix A provides additional source information. Some key aspects of the adjustments 

include: 

● Utah adjusted their emissions upward by 338 tons. 

● Wyoming adjusted their emissions downward by 284 tons. 
Draft Report 

December 23, 2008 

7 

● Arizona did not report any emissions adjustments. 

● The city of Albuquerque, New Mexico reported that plant baseline emissions were 

incorrect for two facilities, which should not have been included in milestone 

calculations. In each case, the 1998 baseline emissions were based on the facility 

potential to emit, and not on reported emissions, which were less than 100 tons per year 

in 1998 and in each year since then. Thus, their emissions would not typically be 

included in this report, but until the milestones can be revised in the next SIP revision to 

correct the baseline error, these sources will be included and adjusted up to their potential 

to emit so that "paper decreases" in emissions are not counted towards meeting the 

milestones. The adjustment increased emissions by 1,150 tons. 

● New Mexico did not have information on the baseline year emissions calculation and 

monitoring methodologies, and thus did not make any adjustments for facilities under the 

state's jurisdiction. The 1998 baseline year corresponded to a period when New Mexico's 

inventory relied on the sources to calculate and report emissions. Also, during that 

period, New Mexico prepared an emissions inventory every other odd year (1997 and 

1999). 
Draft Report 

December 23, 2008 

8 

Table 3 

Adjustments for Changes in Monitoring Methodology 

(Albuquerque, New Mexico, Utah, and Wyoming) 

State Source 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Monitoring 

Methodology 

Adjustment 

(tons) Comment 

NM GCC Rio Grande 

Cement 

16 1,103 1,087 Facility potential to emit 

was used for the baseline 

year calculation. 

Adjustment is equal to the 

difference between 

reported and potential 

emissions. 

NM Southside Water 

Reclamation Plant 

57 120 63 Facility potential to emit 

was used for the baseline 

year calculation. 

Adjustment is equal to the 

difference between 

reported and potential 

emissions. 

UT Chevron Products Co. - 

Salt Lake Refinery 

1,104 1,085 -19 AP42 emission factor 

changed. In calculating 

flares, method changed 

from AP42 to engineering 

data. 

UT Graymont Western US 

Inc. - Cricket Mountain 

Plant 

31 415 384 AP42 emission factors 

changed. Method of 

calculating kiln emissions 

changed from permit limit 

to stack test. 

UT Tesoro West Coast - 

Salt Lake City Refinery 

909 878 -31 Reported emissions 

include SO3. SO3 was not 

included in 1998. 

UT Holly Ref. - Phillips 

Refinery 

579 582 3 Changed in the estimation 

method from AP42 in 

1998 to CEM. 

WY Burlington Resources - 

Lost Cabin Gas Plant 

2,461 2,459 -2 Change in the calculation 

method for emissions from 

the Train 3 sulfur pit. 

WY Solvay Chemicals - 

Soda Ash Plant (Green 

River Facility) 

56 104 48 Change in calculation 

method from base year. 

WY Sinclair Oil Company - 

Sinclair Refinery 

1,035 705 -330 FCC unit used stack test 

and hours of operation in 

1998; went to CEM in 

2004. 
Draft Report 

December 23, 2008 

9 

4.0 Three-Year Average Emissions (2005, 2006, and 2007) 

The SIPs require multi-year averaging of emissions from 2004 to 2017 for the milestone 

comparison. From 2005 to 2017, a three-year average (which includes the reporting year and the 

two previous years) will be calculated to compare with the milestone. The average of the three 

years' emissions from 2005 to 2007 is 280,279 tons. Table 4 shows the adjusted emissions for 

each year and three year average emissions. The following report sections describe the adjusted 

milestone determination. 

Table 4 

Average Sulfur Dioxide Emissions (2005, 2006, & 2007) 

Year Adjusted SO2 Emissions (tons/year) 

2005 288,040 

2006 279,134 

2007 273,663 

Three Year Average (2005, 2006, 2007) 280,279 

5.0 Enforcement Milestone Adjustments 

 The SIPs require that each state report on proposed milestone adjustments that are due to 

enforcement actions, which affect baseline year emissions. The purpose of this adjustment is to 

remove emissions that occurred above the allowable level in the baseline year from the baseline 

and the annual milestones. The enforcement milestone adjustments require an approved SIP 

revision before taking effect. 

 Enforcement Milestone Adjustment

 There were no proposed enforcement action related milestone adjustments reported for 

2007. 

6.0 Smelter-Specific Set-Aside Milestone Adjustments 

Smelter Adjustment Scenarios

 Each state or tribe determines the amount of facility specific set-aside, if any, that will be 

added to the milestone to account for operational increases at the remaining smelters in the 

region. This set-aside is only available for use if the annual sulfur input and emissions from the 

copper smelter is above the baseline levels listed in the applicable SIP. The increase to the 

milestone is based on a smelter's proportional increase above its baseline sulfur input. 

 
Draft Report 

December 23, 2008 

10 

 The revised Section 309 SIPs establish new updated milestones for the years 2008 - 2018. 

This update revised the baseline year, and also changed the smelter-specific set-aside table. For 

purposes of this milestone report, both the old and new baseline year and smelter specific setasides were used to calculate 2007 milestones consistent with both SIP methodologies. 

 

2007 Smelter Adjustment - 2003 SIPs

 A comparison of smelter 2007 emissions to baseline levels in the milestone section of the 

2003 SIPs is provided in Table 5, and shows that the Phelps Dodge Miami smelter in Arizona is 

the only operating smelter with reported 2007 SO2 emissions above the baseline emissions. 

Table 5 

Smelter 2007 SO2 Emissions and Baseline SO2 Emissions 

State Source 

Reported 2007 SO2

Emissions (tons) 

SO2 Baseline Emissions 

(tons) 

AZ BHP San Manuel 0 16,000 

AZ Asarco Hayden 20,339 23,000 

AZ Phelps Dodge Miami 9,111 8,000 

NM Phelps Dodge Hurley 0 16,000 

NM Phelps Dodge Hidalgo 0 22,000 

UT Kennecott Salt Lake 975 1,000 

 The sulfur throughput for the Phelps Dodge Miami smelter in 2007 was also greater than 

the baseline throughput, triggering the smelter adjustment. The emissions and throughput 

comparisons, and the smelter adjustment calculation for Phelps Dodge Miami are shown in Table 

6. The adjustment based on a comparison of 2007 sulfur throughput to baseline sulfur 

throughput is 2,480 tons. This is greater than the available set-aside of 2,000 tons, and thus only 

an amount up to the 2,000 tons set-aside is allowable per the Arizona SIP. 
Draft Report 

December 23, 2008 

11 

Table 6 

Phelps Dodge Miami - Smelter Adjustment 

SO2 Emission Comparison

2007 Reported Emissions............................................................................................................................ 9,111 tons

Baseline Emissions...................................................................................................................................... 8,000 tons

Reported 2007 emissions are 1,111 tons greater than baseline emissions.

Sulfur Throughput Comparison

2007 Sulfur Throughput.......................................................................................................................... 274,150 tons

Baseline Sulfur Throughput* .................................................................................................................. 208,700 tons

2007 Throughput Increase .........................................................................................................................65,450 tons

2007 Throughput Increase as a Percent of Baseline Throughput..........................................................................31%

Smelter Adjustment

2007 Calculated Adjustment (Baseline Emissions x Percent Throughput Increase)** .............................. 2,480 tons

Smelter Set-Aside* ..................................................................................................................................... 2,000 tons

2007 Adjustment (The lesser of the Calculated Adjustment or Set-Aside)** ............................................ 2,000 tons

 * See the Arizona SIP, Table 8-3 (Table 3 in the 2003 Model SIP) 

 ** See Arizona SIP, Section 8.1.3(4)(e) 

2007 Smelter Adjustment - Revised SIPs

 The smelter baseline has decreased, from 86,000 tons SO2 in the 2003 SIPs to 24,000 

tons SO2 in the revised SIPs, due to the permanent closure of the BHP San Manuel, Phelps 

Dodge Chino, and Phelps Dodge Hidalgo smelters. The revised set-aside is only available if 

sulfur input and emissions from an individual copper smelter is above the baseline level listed in 

Table 7 in any particular year as a result of increased capacity. The Phelps Dodge Miami smelter 

is not included in Table 7 because the smelter is currently operating at its permitted limit, and 

therefore does not have a smelter-specific set-aside. 

Table 7 

Revised SIP - Smelter Baselines and Set-Aside 

State Source 

Baseline Sulfur 

Input 

(tons S) 

Baseline 

Allocation 

(tons SO2) 

Smelter Specific 

Set-Aside 

(tons SO2) 

AZ Asarco Hayden 235,000 23,000 3,000 

UT Kennecott Salt Lake 340,269 1,000 100 

Total 575,269 24,000 3,100 
Draft Report 

December 23, 2008 

12 

 A smelter set-aside is not available for 2007 under the revised SIPs. The 2007 emissions 

from the Asarco Hayden and Kennecott smelters (see Table 6) are below the baseline allocations 

in Table 7. 

7.0 Quality Assurance 

 The states provided 2007 emissions data based on their state emissions inventories. For 

this report, additional quality assurance (QA) procedures were used to supplement the normal 

QA procedures the states follow for their emissions inventories. First, each state submitted a 

source change report, and second, the states compared their inventory data for utility sources 

against 40 CFR Part 75 Acid Rain Program monitoring data. 

7.1 Source Change Report 

 The SIPs require that this annual SO2 emissions and milestone report include a 

description of source changes or exceptions report to identify: 

● Any new sources that were not contained in the previous calendar year's emissions report, 

and an explanation of why the sources are now included in the program; 

● Identification of any sources that were included in the previous year's report and are no 

longer included in the program, and an explanation of why this change has occurred; and 

● An explanation for emissions variations at any applicable source that exceeds ± 20 

percent from the previous year. 

 No sources were added to the program inventory in 2007. Phelps Dodge Hidalgo smelter 

and Phelps Dodge Hurley smelter/concentrator were both closed in 2006, but are being included 

in the inventory for the smelter adjustment. Appendix B provides a list of all sources added or 

removed from the program inventory in previous reporting years. Table 8 provides explanations 

for the emissions variations from 2006 - 2007 that are greater than 20 percent. Plants with 

variations greater than 20 percent, but reported emissions of less than 20 tons, are not included in 

Table 8. Information on these plants is provided in Appendix A. 

 
13 

Table 8 

Sources with an Emissions Change of > ± 20% from the Previous Year 

State 

County 

FIPS 

Code 

State 

Facility ID 

Reported 2006 

SO2 Emissions 

(tons) 

Reported 2007 

SO2 Emissions 

(tons) Facility Name Reas

AZ 017 1807 1,895 1,504 Abitibi - Snowflake Pulp Mill Used low sulfuAZ 019 2869 7 48 Arizona Portland Cement Emissions base

performance te

AZ 007 2435 16,088 20,339 Asarco - Hayden Smelter Increase in ope

in capacity. 

AZ 015 5992 1,047 1,979 CLC - Nelson Lime Plant Increase in ope

in capacity. 

AZ 007 5992 6,383 9,111 Phelps Dodge - Miami Smelter Increase in ope

in capacity. 

AZ 001 4477 13,520 16,882 SRP - Coronado Generating 

Station 

Scrubber downefficiency. 

NM 015 350150024 263 65 Agave Energy/Agave Dagger 

Draw Gas Plant 

Plant burned onfield explosion

NM 015 350150011 162 68 DCP Midstream/Artesia Gas 

Plant 

Acid Gas Injec2006 has signifemissions. 

NM 025 350250035 1,558 253 DCP Midstream/Linam Ranch 

Gas Plant [Old name: GPM GAS/LINAM RANCH GAS PLANT] 

 Plant did not himplemented re

NM 031 350310008 840 1,278 Giant Industries/Ciniza Refinery 

[Old name: GIANT REFINING/CINIZA] 

Production incrand boiler utilizCEMS on flare ability to monit

NM 025 350250007 1,125 354 J L Davis Gas 

Processing/Denton Plant 

The reason for reported. 
14 

Table 8 

Sources with an Emissions Change of > ± 20% from the Previous Year (cont.) 

State 

County 

FIPS 

Code 

State 

Facility ID 

Reported 2006 

SO2 Emissions 

(tons) 

Reported 2007 

SO2 Emissions 

(tons) Facility Name Reas

NM 015 350150010 160 62 Navajo Refining Co/Artesia 

Refinery 

Changes in inlemaintenance, aupsets. 

NM 007 350070001 149 0 Raton Pub. Service/Raton 

Power Plant 

Did not operate 

NM 025 350250008 1,435 2,895 Sid Richardson Gasoline/Jal #3 SRU malfuncti

emission event

NM 025 350250063 277 335 Targa Midstream 

Services/Saunders Plant [Old names: Dynegy Midstream Services/Saunders Plant; WARREN PETROLEUM/SAUNDERS PLANT] 

SRU was shut change catalystflared during thcomposition ha2007. 

UT 011 10119 2,201 1,174 Chevron Products Co. - Salt 

Lake Refinery 

Company addeand a vacuum gto their process

UT 049 10796 118 0 Geneva Steel - Steel 

Manufacturing Facility 

Company has gthe plant equip

UT 011 10123 478 579 Holly Refining and Marketing 

Co. - Phillips Refinery 

Source test chathe heating valubreakdown em

UT 035 10346 737 976 Kennecott Utah Copper Corp. - 

Smelter & Refinery 

Increase in opeequipment, and sulfur content. 

UT 015 10238 17,402 4,351 PacifiCorp. - Huntington Power 

Plant 

FGD control inBoiler 2. Boileoperation - 1932006. 
15 

Table 8 

Sources with an Emissions Change of > ± 20% from the Previous Year (cont.) 

State 

County 

FIPS 

Code 

State 

Facility ID 

Reported 2006 

SO2 Emissions 

(tons) 

Reported 2007 

SO2 Emissions 

(tons) Facility Name Reas

UT 007 10096 858 447 Sunnyside Cogeneration 

Associates - Sunnyside Cogeneration Facility 

Source test shorate due to incrlimestone and d

WY 041 0012 2,257 1,205 BP America - Whitney Canyon 

Gas Plant 

Emissions decrinlet gas rates, of the main pla

WY 013 0028 1,715 2,461 Burlington Resources - Lost 

Cabin Gas Plant 

Increased emisproblems with furnace and the blowers. 

WY 041 219 1 Chevron - Whitney Canyon 

Carter Creek Well Field 

Emissions decrfield flaring. 

WY 041 0009 205 46 Chevron USA - Carter Creek 

Gas Plant 

There was no pa decrease in mdecrease in flar

WY 013 57 6 Devon Energy - Beaver Creek 

Field 

Emissions decrfield flaring. 

WY 023 0013 2,205 846 Exxon - Shute Creek Treating 

Facility 

Emissions decrof the tail gas i

WY 037 0010 161 249 FMC Wyoming Corp. - Granger 

Soda Ash Plant 

Increase in emisoda ash produ

WY 029 0007 447 348 Marathon Oil Co. - Oregon 

Basin Gas Plant 

Increased lengtturnaround resuacid gas incineemissions. Incdue to boiler do

WY 029 265 164 Marathon Oil Co. - Oregon 

Basin Field 

Decreased plandecreased flarin

WY 015 0001 143 202 The Western Sugar Cooperative 

- Torrington Plant 

Increase in emisulfur content o
Draft Report 

December 18, 2008 

16 

7.2 Part 75 Data 

 Federal Acid Rain Program emissions monitoring data (required by 40 CFR Part 75) 

were used to check reported power plant emissions, and whether or not a monitoring method 

adjustment was required for changes in Part 75 quality assurance procedures as described in 

section 3.1 of this report. 

 Sources in the region subject to Part 75 emitted about 67% of the region's reported 

emissions in 2007. We compared Acid Rain Program power plant emission data from EPA's 

Data and Maps website to plant totals reported by each state. The SIPs require the use of Part 75 

methods for Part 75 sources, so the reported emissions should match. 

 We also queried EPA's database for the Acid Rain Program to obtain the flow reference 

method used in the RATAs reported by the plants since the 1999 baseline year. This information 

was used to check if there had been a change in flow reference methods since the 1999 baseline 

year. 

8.0 Preliminary Milestone Determination 

 The 2007 milestone based on the revised SIPs is 420,637 tons. No adjustment is required 

for changes in smelter operation. 

 The 2007 milestone was also determined based on the 2003 SIPs. First, the 682,000 ton 

regional milestone is adjusted for states and tribes that have not opted to participate in the 309 

program by subtracting the amount for each state or tribe. The milestone is also adjusted to 

account for changes in smelter operations. No adjustment is required for enforcement actions. 

This results in an adjusted milestone of 422,194 tons. Table 9 shows each element of the 2007 

milestone calculation under the 2003 SIPs. 

 The average of 2005, 2006 and 2007 adjusted emissions were determined to be 280,279

tons. Therefore, the participating states have met the milestones in the revised SIPs and 2003 

SIPs (420,637 and 422,194 tons respectively). 
Draft Report 

December 18, 2008 

17 

Table 9 

Regional 2007 SO2 Emissions Milestone for the Four States - Based on 2003 SIPs 

Base Regional 2007 Milestone* ..................................................................................................... 682,000 tons

Milestone Adjustments* 

 States and Tribes not participating in the backstop program: 

 California.................................................................................................................................... -37,784 tons

 Colorado ..................................................................................................................................... -98,897 tons

 Idaho........................................................................................................................................... -18,016 tons

 Nevada........................................................................................................................................ -20,187 tons

 Oregon ........................................................................................................................................ -26,268 tons

 Shoshone-Bannock Tribe of the Fort Hall Reservation................................................................ -4,994 tons

Navajo Nation............................................................................................................................. -53,147 tons

 Ute Indian Tribe of the Uintah and Ouray Reservation................................................................ -1,129 tons

 Wind River Reservation ............................................................................................................... -1,384 tons

 Smelter Set-Aside* ....................................................................................................................... 2,000 tons

 Enforcement................................................................................................................................................ 0 tons

Adjusted Four-State 2007 Milestone 

(Arizona, New Mexico, Utah, Wyoming) ............................................................................................. 422,194 tons

 * See the Regional Milestones section of each state's 2003 Section 309 SIP. 
A-1 

Appendix A 

Table A-1 

2007 Reported and Adjusted Emissions for Sources Subject to Section 309 - Regional Haze 

State 

County 

FIPS 

State 

Facility 

Identifier ORIS Plant Name 

Plant 

SIC 

Plant 

NAICS 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Part 75 

Flow 

RATA 

Emission 

Adjustment 

(tons) 

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons) 

AZ 017 1807 Abitibi - 

Snowflake Pulp Mill 

2621 322121 1,504 1,504 Low 

AZ 003 3532 160 AEPCO - Apache 

Generating Station 

4911 221112 2,662 2,675 13 Low 

AZ 019 2869 Arizona Portland 

Cement 

3241 32731 48 48 Une

emis

AZ 007 2435 Asarco - Hayden 

Smelter 

3331 331411 20,339 20,339 Red

AZ 021 15582 BHP - San 

Manuel Smelter 

3331 331411 0 0 Faci

AZ 003 2148 CLC - Douglas 

Lime Plant 

3274 32741 963 963 Faci

AZ 015 5992 CLC - Nelson 

Lime Plant 

3274 32741 1,979 1,979 Faci

AZ 007 5129 Phelps Dodge - 

Miami Smelter 

3331 331411 9,111 9,111 Incr

dow

AZ 025 2393 Phoenix Cement 3241 32731 7 7 Old 

in op

AZ 017 447 113 Pinnacle West - 

Cholla Generating Station 

4911 221112 23,522 23,650 128 
A-2 

Table A-1 

2007 Reported and Adjusted Emissions for Sources Subject to Section 309 - Regional Haze Ru

State 

County 

FIPS 

State 

Facility 

Identifier ORIS Plant Name 

Plant 

SIC 

Plant 

NAICS 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Part 75 

Flow 

RATA 

Emission 

Adjustment 

(tons) 

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons) 

AZ 001 4477 6177 SRP - Coronado 

Generating Station 

4911 221112 16,882 16,882 

AZ 019 126 TEP - Irvington 

Generating Station 

4911 221112 2,908 2,908 

AZ 001 3222 8223 TEP - Springerville 

Generating Station 

4911 221112 5,997 5,997 New 

NM 015 350150024 Agave 

Energy/Agave Dagger Draw Gas Plant 

1311 211111 65 65 Agav

Draw Draw

NM 015 350150002 BP America 

Production/Empire Abo Plant [Old name: Arco Permian/Empire Abo Plant] 

1321 211112 300 300 

NM 015 350150011 DCP 

Midstream/Artesia Gas Plant 

1321 211112 68 68 New 

NM 025 350250044 DCP 

Midstream/Eunice Gas Plant [Old name: GPM GAS EUNICE GAS PLANT] 

1321 211112 1,063 1,063 New 

NM 025 350250035 DCP 

Midstream/Linam Ranch Gas Plant [Old name: GPM GAS/LINAM RANCH GAS PLANT] 

1321 211112 253 253 New 
A-3 

Table A-1 

2007 Reported and Adjusted Emissions for Sources Subject to Section 309 - Regional Haze Ru

State 

County 

FIPS 

State 

Facility 

Identifier ORIS Plant Name 

Plant 

SIC 

Plant 

NAICS 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Part 75 

Flow 

RATA 

Emission 

Adjustment 

(tons) 

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons) 

NM 025 350150138 Duke - 

Magnum/Pan Energy - Burton Flats 

1321 211112 0 0 No l

NM 015 350150285 Duke 

Energy/Dagger Draw Gas Plant 

1321 211112 0 0 Agav

Draw Draw

NM 025 350250060 Dynegy Midstream 

Services/Eunice Gas Plant [Old name: WARREN PETROLEUM/EUNICE GAS PLANT] 

1321 211112 2,355 2,355 

NM 025 350250004 Frontier Field 

Services/Maljamar Gas Plant 

1321 211112 2,520 2,520 

NM 001 00008 GCC Rio Grande 

Cement 

3241 327310 16 1,103 1,087 Facil

for thAdjudifferepo

NM 031 350310008 Giant 

Industries/Ciniza Refinery (Gallup) [Old name: GIANT REFINING/CINIZA] 

2911 32411 1,278 1,278 

NM 025 350250007 J L Davis Gas 

Processing/Denton Plant 

1311 211111 354 354 

NM 015 350150008 Marathon 

Oil/Indian Basin Gas Plant 

1321 211112 680 680 
A-4 

Table A-1 

2007 Reported and Adjusted Emissions for Sources Subject to Section 309 - Regional Haze Ru

State 

County 

FIPS 

State 

Facility 

Identifier ORIS Plant Name 

Plant 

SIC 

Plant 

NAICS 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Part 75 

Flow 

RATA 

Emission 

Adjustment 

(tons) 

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons) 

NM 015 350150010 Navajo Refining 

Co/Artesia Refinery 

2911 32411 62 62 

NM 023 350230003 Phelps Dodge 

Hidalgo Smelter 

3331 331411 0 0 

NM 017 350170001 Phelps Dodge 

Hurley Smelter/ Concentrator 

3331 331411 0 0 

NM 045 350450902 2451 Public Service Co. 

of New Mexico/ San Juan Generating Station 

4911 221112 15,305 17,683 2,378 

NM 007 350070001 Raton Pub. 

Service/Raton Power Plant 

4911 221112 0 0 Did 

NM 025 350250008 Sid Richardson 

Gasoline/Jal #3 

1321 211112 2,895 2,895 

NM 001 00145 Southside Water 

Reclamation Plant 

4952 22132 57 120 63 Facil

for thAdjudifferepo

NM 025 350250051 Targa Midstream 

Services/Eunice South Gas Plant 

1321 211112 0 0 Euni

ownLLC Midsa ma

NM 025 350250061 Targa Midstream 

Services/Monument Plant [Old name: WARREN PETROLEUM/MONUMENT PLANT] 

1321 211112 1,235 1,235 New 

ProcTarg
A-5 

Table A-1 

2007 Reported and Adjusted Emissions for Sources Subject to Section 309 - Regional Haze Ru

State 

County 

FIPS 

State 

Facility 

Identifier ORIS Plant Name 

Plant 

SIC 

Plant 

NAICS 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Part 75 

Flow 

RATA 

Emission 

Adjustment 

(tons) 

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons) 

NM 025 350250063 Targa Midstream 

Services/Saunders Plant [Old name: WARREN PETROLEUM/SAUNDERS PLANT] 

1321 211112 335 335 New 

ProcTarg

NM 031 350310032 87 Tri-State Gen & 

Transmission/Escalante Station 

4911 221112 1,124 1,591 467 

NM 045 350450247 Western Gas 

Resources/San Juan River Gas Plant 

1321 211112 393 393 

NM 045 350450023 Western Refining 

Southwest Inc./San Juan Refinery (Bloomfield) [old name: GIANT INDUSTRIES/BLOOMFIELD REF] 

2911 32411 428 428 

UT 049 10790 Brigham Young 

University - Main Campus 

8221 611310 97 97 

UT 027 10311 Brush Resources 

Inc. - Delta Mill 

1099 212299 0 0 

UT 011 10119 Chevron Products 

Co. - Salt Lake Refinery 

2911 324110 1,104 1,085 -19 AP4

Chanto enflare

UT 037 10034 EnCana Oil & Gas 

(USA) Incorporated (was Tom Brown Incorporated) - Lisbon Natural Gas Processing Plant 

2911 211111 97 97 
A-6 

Table A-1 

2007 Reported and Adjusted Emissions for Sources Subject to Section 309 - Regional Haze Ru

State 

County 

FIPS 

State 

Facility 

Identifier ORIS Plant Name 

Plant 

SIC 

Plant 

NAICS 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Part 75 

Flow 

RATA 

Emission 

Adjustment 

(tons) 

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons) 

UT 011 10122 Flying J Refinery - 

(Big West Oil Company) 

2911 324110 390 390 

UT 027 10313 Graymont Western 

US Inc. - Cricket Mountain Plant 

1422 212312 31 415 384 AP4

Methemisto sta

UT 029 10007 Holcim - Devil's 

Slide Plant 

3241 327310 454 454 

UT 011 10123 Holly Refining and 

Marketing Co. - Phillips Refinery 

2911 324110 579 582 3 The 

estimbalan

UT 027 10327 6481 Intermountain 

Power Service Corporation - Intermountain Generation Station 

4911 221112 4,764 4,788 24 Wall 

0.99

UT 035 10572 Kennecott Utah 

Copper Corp. - Power Plant/Lab/Tailings Impoundment 

1021 212234 3,207 3,207 

UT 035 10346 Kennecott Utah 

Copper Corp. - Smelter & Refinery 

3331 331411 976 976 

UT 007 10081 3644 PacifiCorp. - 

Carbon Power Plant 

4911 221112 6,511 7,537 1,026 The 

methThe calcufor u
A-7 

Table A-1 

2007 Reported and Adjusted Emissions for Sources Subject to Section 309 - Regional Haze Ru

State 

County 

FIPS 

State 

Facility 

Identifier ORIS Plant Name 

Plant 

SIC 

Plant 

NAICS 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Part 75 

Flow 

RATA 

Emission 

Adjustment 

(tons) 

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons) 

UT 015 10237 6165 PacifiCorp. - Hunter 

Power Plant 

4911 221112 6,672 7,658 986 Two 

1999meththe eAdjufor ufor u

UT 015 10238 8069 PacifiCorp. - 

Huntington Power Plant 

4911 221112 4,351 4,931 580 Two 

1999meththe eAdjufor u

UT 007 10096 Sunnyside 

Cogeneration AssociatesSunnyside Cogeneration Facility 

4911 221112 447 448 1 AP4

157S 

UT 035 10335 Tesoro West CoastSalt Lake City 

Refinery 

2911 324110 909 878 -31 The 

in 20

the 1

UT 043 10676 Utelite Corporation 

- Shale Processing 

3295 144 144 Add

WY 011 0002 American Colloid 

Mineral Co. - East Colony 

1459 212325 65 65 Drye

calcu0.3465%

WY 011 0003 American Colloid 

Mineral Co. - West Colony 

1459 212325 46 46 Drye

calcu0.3465%

WY 037 0008 Anadarko E&P Co. 

LP - Brady Gas Plant 

1321 211112 90 90 Calc

Mon
A-8 

Table A-1 

2007 Reported and Adjusted Emissions for Sources Subject to Section 309 - Regional Haze Ru

State 

County 

FIPS 

State 

Facility 

Identifier ORIS Plant Name 

Plant 

SIC 

Plant 

NAICS 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Part 75 

Flow 

RATA 

Emission 

Adjustment 

(tons) 

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons) 

WY 037 Anadarko E&P Co. 

L.P. - Table Rock Gas Plant 

1321 153 153 Calc

Mon

WY 031 0001 6204 Basin Electric - 

Laramie River Station 

4911 221112 10,387 10,387 Calc

75). 

WY 003 0012 Big Horn Gas Proc. 

- Big Horn/Byron Gas Plant 

1311 22121 0 0 Swit

and cgas. 

WY 005 0002 4150 Black Hills 

Corporation - Neil Simpson I 

4911 22112 984 984 Calc

Bala

WY 005 0063 7504 Black Hills 

Corporation - Neil Simpson II 

4911 22112 613 613 Calc

75). 

WY 045 0005 4151 Black Hills 

Corporation - Osage Plant 

4911 22112 2,994 2,994 Calc

Year 

WY 005 0146 55479 Black Hills 

Corporation - Wygen 1 

4911 22112 688 688 Calc

75). 

WY 041 0012 BP America 

Production Company - Whitney Canyon Gas Plant 

1311 211111 1,205 1,205 Calc

Mete

WY 041 BP America 

Production Company - Whitney Canyon WellField 

1311 3 3 Mini

2007
A-9 

Table A-1 

2007 Reported and Adjusted Emissions for Sources Subject to Section 309 - Regional Haze Ru

State 

County 

FIPS 

State 

Facility 

Identifier ORIS Plant Name 

Plant 

SIC 

Plant 

NAICS 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Part 75 

Flow 

RATA 

Emission 

Adjustment 

(tons) 

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons) 

WY 013 Burlington 

Resources - Bighorn Wells 

1311 0 0 No f

WY 013 0028 Burlington 

Resources - Lost Cabin Gas Plant 

1311 211111 2,461 2,459 -2 Emis

submare sTrain houremis

WY 041 0009 Chevron USA - 

Carter Creek Gas Plant 

1311 211111 46 46 Turn

chan

WY 037 Chevron USA - 

Table Rock Field 

1311 328 328 Flari

WY 041 Chevron USA - 

Whitney Canyon/Carter Creek Wellfield 

1311 1 1 SO2 

2 pag

WY 013 Devon Energy 

Production Co., L.P. - Beaver Creek Gas Field 

 6 6 Tons 

emit

WY 013 0008 Devon Gas 

Services, L.P. - Beaver Creek Gas Plant 

1311 211111 84 84 Tons 

emit

WY 023 Exxon Mobil 

Corporation - Labarge Black Canyon Facility 

1311 133 133 Calc

actua

WY 023 0013 Exxon Mobil 

Corporation - Shute Creek 

1311 211111 846 846 Turb

theremeth
A-10 

Table A-1 

2007 Reported and Adjusted Emissions for Sources Subject to Section 309 - Regional Haze Ru

State 

County 

FIPS 

State 

Facility 

Identifier ORIS Plant Name 

Plant 

SIC 

Plant 

NAICS 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Part 75 

Flow 

RATA 

Emission 

Adjustment 

(tons) 

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons) 

WY 037 0048 FMC Corp. - Green 

River Sodium Products (Westvaco facility) 

2812 327999 4,234 4,234 SO2 

poinlb/m

WY 037 0049 FMC Wyoming 

Corporation - Granger Soda Ash Plant 

1474 212391 249 249 Boil

comb

WY 021 0001 Frontier Oil & 

Refining Company - Cheyenne Refinery 

2911 32411 1,033 1,033 Sour

comp2006 back syste

WY 037 0002 General Chemical - 

Green River Plant (Facility Name: General Chemical) 

1474 327999 5,701 5,701 SO2 

poinuse, 

WY 043 0003 Hiland Partners, 

L.L.C. - Hiland Gas Plant 

1321 48621 145 145 SO2 

procmeas

engin

WY 029 0012 Howell Petroleum 

Corp. - Elk Basin Gas Plant 

1311 211111 1,309 1,309 SO2 

poinMas

WY 029 0007 Marathon Oil Co. - 

Oregon Basin Gas Plant 

1321 211112 348 348 Usin

calcuemismass balanHowadeqconcbalan
A-11 

Table A-1 

2007 Reported and Adjusted Emissions for Sources Subject to Section 309 - Regional Haze Ru

State 

County 

FIPS 

State 

Facility 

Identifier ORIS Plant Name 

Plant 

SIC 

Plant 

NAICS 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Part 75 

Flow 

RATA 

Emission 

Adjustment 

(tons) 

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons) 

WY 029 Marathon Oil Co. - 

Oregon Basin Wellfield 

 164 164 Flari

WY 001 0002 Mountain Cement 

Company - Laramie Plant 

3241 23571 94 94 SO2 

poin

WY 037 0003 P4 Production, 

L.L.C. - Rock Springs Coal Calcining Plant 

3312 331111 653 653 New 

emisrepre

WY 009 0001 4158 Pacificorp. - Dave 

Johnston Plant 

4911 221112 21,356 25,791 4,435 SO2 

poinBW41.11

emisvalu

WY 037 1002 8066 PacifiCorp. - Jim 

Bridger Plant 

4911 221112 19,053 20,486 1,433 SO2 

poinBW71.04

Emisvalu

WY 023 0004 4162 PacifiCorp. - 

Naughton Plant 

4911 221112 21,588 24,873 3,285 SO2 

poinAdju1.29

acceTitle 

WY 005 0046 6101 PacifiCorp. - 

Wyodak Plant 

4911 221112 7,835 8,305 470 SO2 

poinFact

using Acid 
A-12 

Table A-1 

2006 Reported and Adjusted Emissions for Sources Subject to Section 309 - Regional Haze Ru

State 

County 

FIPS 

State 

Facility 

Identifier ORIS Plant Name 

Plant 

SIC 

Plant 

NAICS 

Reported 

2007 SO2

Emissions 

(tons) 

Adjusted 

2007 SO2

Emissions 

(tons) 

Part 75 

Flow 

RATA 

Emission 

Adjustment 

(tons) 

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons) 

WY 037 0022 Simplot Phosphates 

L.L.C. - Rock Springs Plant 

2874 325312 2,052 2,052 (Sou

estim

WY 007 0001 Sinclair Oil 

Company - Sinclair Refinery 

2911 32411 1,035 705 -330 FCC 

1998

WY 025 0005 Sinclair Wyoming 

Refining Company - Casper Refinery 

2911 32411 792 792 SO2 

poinsame 

WY 037 0010 Solvay Chemicals - 

Soda Ash Plant (Green River Facility) 

1474 56 104 48 SO2 

poin#89)(lb/Mtest x AQD with 

WY 015 0001 The Western Sugar 

Cooperative - Torrington Plant 

2063 311313 202 202 Coal

#5, & hour

WY 001 0005 University of 

Wyoming - Heat Plant 

8221 61131 71 71 SO2 

poindiese

WY 045 0001 Wyoming Refining 

- Newcastle Refinery 

2911 32411 690 690 Base 

baseanalycalcu
December 23, 2008 

Appendix B 

Table B-1 

Sources Added to the SO2 Emissions and Milestone Report Inventory 

State 

County FIP 

Code 

State 

Facility ID Facility Name 

Report 

Year of 

Change 

UT 043 10676 Utelite Corporation - Shale processing 2003 

WY 011 0002 American Colloid Mineral Company - East Colony 2003 

WY 011 0003 American Colloid Mineral Company - West Colony 2003 

WY 037 Anadarko E&P Company LP - Table Rock Gas 

Plant 

2003 

WY 005 0146 Black Hills Corporation - Wygen 1 2003 

WY 041 BP America Production Company - Whitney 

Canyon Well Field 

2003 

WY 013 Burlington Resources - Bighorn Wells 2003 

WY 037 Chevron USA - Table Rock Field 2003 

WY 041 Chevron USA - Whitney Canyon/Carter Creek 

Wellfield 

2003 

WY 013 0008 Devon Energy Corp. - Beaver Creek Gas Plant 2003 

WY 035 Exxon Mobil Corporation - Labarge Black Canyon 

Facility (also identified as Black Canyon Dehy 

Facility) 

2003 

AZ 019 2869 Arizona Portland Cement 2004 

WY 013 Devon Energy Corp. - Beaver Creek Gas Field 2004 
Draft Appendix B 

December 23, 2008 

B-2 

Table B-2 

Sources Removed from the SO2 Emissions and Milestone Report Inventory 

State 

County 

FIP 

Code 

State 

Facility 

ID Facility Name 

Baseline 

Emissions 

(tons/year) Reason for Change 

Report 

Year of 

Change 

WY 043 0001 Western Sugar 

Company - Worland 

154 Emissions did not meet 

100 TPY program criteria. 

2003 

WY 017 0006 KCS Mountain 

Resources - Golden 

Eagle 

942 Emissions did not meet 

100 TPY program criteria. 

2003 

WY 003 0017 KCS Mountain 

Resources - Ainsworth 

845 Closed since 2000. 2003 

WY 017 0002 Marathon Oil - Mill 

Iron 

260 Emissions did not meet 

100 TPY program criteria. 

2003 

AZ 021 15582 BHP - San Manuel 

Smelter 

10,409 Facility is permanently 

closed. 

2004 

UT 049 10796 Geneva Steel - Steel 

Manufacturing Facility 

881 Plant is shut down and 

disassembled. 

2004 

WY 023 0001 Astaris Production - 

Coking Plant 

1,454 Plant is permanently shut 

down and dismantled. 

2004