## 2010 Regional SO 2 

## Emissions and Milestone Report

March 22 , 2012

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: 30 7

- 777

- 6993

Fax: 307

- 777

- 7682 brian.bohlmann@wyo.gov Utah

Colleen Delaney Utah Department of Environmental Quality Division of Air Quality

195 North 1950 West Salt Lake City, UT 84114

- 4820

Phone: 801

- 536

- 4 24 8

Fax: 801

- 536

- 0085 cdelaney@utah.gov

New Mexico

Rhonda Payne New Mexico Environment Department Air Quality Bureau 1301 Siler Rd., Bldg. B Santa Fe, NM 8750 7

Phone: 505

- 476

- 4329

Fax: 505

- 476

- 4375 rhonda.payne@state.nm.us A lbuquerque

- Bernalillo County

Neal Butt City of Albuquerque Environmental Health/Air Quality Division

P.O. Box 1293 Albuquerque, NM 87103

Phone: 505

- 768

- 2660

Fax: 505

- 768

- 1977 Nbutt@cabq.gov

### Executive Summary March 22, 2012

ES

- 1 Based on the adjusted milestone and emissions data, the average of 2008, 2009, and 2010 emissions is about 27 %

below the 2010 three

- state regional

milestone. 

## 2010 Regional SO 2 

## 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 p lans to reduce regional haze emissions that impair visibility at 16 Class I areas on the Colorado Plateau. Five states

-- Arizona, New Mexico, Oregon, Utah, and Wyoming

-- and Albuquerque

- Bernalillo County initially exercised this option by submitting pla ns to EPA by December 31, 2003. Oregon elected to cease participation in the program in 2006 and Arizona elected to cease participation in 2010 . The tribes were not subject to the deadline and still can opt into the program at any time. Under the

Sectio n 309 plans, the three participating states and Albuquerque

- Bernalillo County have tracked the emissions of the applicable stationary sources as part of the pre

- trigger portion of the SO 2 

### Milestone and Backstop Trading Program. The Western Regional Air Pa rtnership (WRAP) is assisting these states and city with the implementation and management of the regional emission reduction program. As used in this document, Section 309 states means the states of New Mexico, Utah and Wyoming and Albuquerque

- Bernalillo County

.

As part of this program, the Section 309 states must submit an annual Regional Sulfur Dioxide (SO 2 

### ) Emissions and Milestone Report that compares emissions to milestones. A milestone is a maximum level of annual emissions for a given year. The f irst report was submitted in 2004 for the calendar year 2003.

The milestone for 20 10 is 200,722 . To determine whether or not the milestone was met,

the 2008

, 2009 , and 2010 adjusted emissions from the Section 309 states were averaged, and this

average wa s compared to the 2010 milestone. The adjustments to reported emissions were required to allow the basis of current emission estimates to be comparable to the emissions monitoring or calculation method used in the most recent base year inventory (2006).

The Section 309 states reported 130,3 40

tons of SO 2 

### emissions for the calendar year 2010

. The total emissions increased to 131,124 tons of

SO 2 

### after making adjustments to account for changes in monitoring and calculation methods. The adjustments resul t in an additional 784 tons of

SO 2 

### emissions. The adjusted emissions values for

200 8 and 200 9 were 165,595 tons and 143,704 tons, respectively. Th e average of 200 8

, 200 9

, and 20 10 adjusted emissions is 146,808 tons

.

Based on this average annual emiss ions estimate, the Section 309 states determined that

emissions in 2010 are below the regional SO 2 

### milestone for 2010 . The plans contain provisions to adjust the milestones to account for enforcement actions (to reduce the milestones where an

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

### Executive Summary March 22, 2012

ES

- 2 emissions). Based on emissions data received from the states and plan requirements regarding adjustments to the milestones, no enforcement action adjustment is required.

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 2009 to 2010 are included in Section 6 of this report. A list of facilities added to or removed from the list of subject sources included in the original base year inventories is included in Appendix B.

Table ES

- 1

Overview of 2010 Regional Milestones and Emissions for Section 309 Participating States *

2010 Sulfur Dioxide Milestones

Regional 2010 Milestone* *

................................ ................................ ................................ .................... 200,722 tons Adjusted 200 9 Milestone

................................ ................................ ................................ ........................ 200,722 tons



### 2010 Sulfur Dioxide Emissions

Reported 2010 Emissions

................................ ................................ ................................ ....................... 130,3 40 tons Adjustments** * Emission Monitoring and Calculation Methods

................................ ................................ .............. 784 to ns Adjusted 2010 Emissions (rounded number)

................................ ................................ .......................... 131,124 tons



### Average Sulfur Dioxide Emissions ( 2008

, 2009 , & 2010 )

Adjusted 2010 Emissions

................................ ................................ ................................ ....................... 131,124 tons Adjusted 200 9 Emissions

................................ ................................ ................................ ....................... 143,704 tons Adjusted 200 8 Emissions

................................ ................................ ................................ ....................... 165,595 tons Average of 200 8

, 200 9 , & 20 10 Adjusted Emissions

................................ ................................ ............ 146,808 tons



### Comparison of Emissions to Milestone

Average of 200 8

, 200 9 , & 20 10 Adjusted Emissions

................................ ................................ ............. 146,808 tons Adjusted Three

- State 20 10 Milestone

................................ ................................ ................................ ..... 200,722 tons Difference (Negative Value = Emissions < Milestone)

................................ ................................ .......... - 53,915 tons
200 8

– 20 10 Emissions Average as Percent of 20 10 Milestone

................................ ................................ ........... 73 %

* Section 309 participating states means the states of New Mexico, Utah and Wyoming and Albuquerque

Bernalillo County

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

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

### 2010 Milestone Report March 22, 2012

1 

## 2010 Regional SO 2 

## 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 wi thin those states have the option of submitting plans to reduce regional haze emissions that impair visibility at 16 Class I areas on the Colorado Plateau. Five states

-- Arizona, New Mexico, Oregon, Utah, and Wyoming

-- and Albuquerque

- Bernalillo County exercised this option by submitting plans to EPA by December 1, 2003. In October 2006, when EPA modified Section 309, Oregon elected to cease participation in the SO 2 

### Milestone and Backstop Trading Program by not resubmitting a Section 309 State Implement ation Plan ( SIP). In 2010, Arizona elected to cease participation in the Program. The tribes were not subject to this deadline and still can opt into the program at any time.

Under the Section 309 SIPs, these three states and one city have been tracking emissions under the pre

- trigger requirements of the SO 2 

### 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 pr ogram.

Under the milestone phase of the program, the Section 309 states have established annual

SO 2 

### 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 (o r 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 eighth annual report for the milestone phase of this program. The report provide s background on regional haze and the Section 309 program, the milestones established under the program, and the emissions reported for 2010 . Based on the first eight years, the voluntary milestone phase of the program is working and emissions are well be low 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 ca rbon, and soil

dust. Human

- caused haze sources include industry, motor vehicles, agricultural and forestry burning, and windblown dust from roads and farming practices.

### 2010 Milestone Report March 22, 2012

2 What U.S. EPA Requirements Apply ?

In 1999, the Environmental Protection Agency (E PA) 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 eliminat e 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 addres s 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 reg ional 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 con stitutes 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 Oc tober 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 evaluating the equivalence of alternatives to Best Available Retrofit Technology (BART), such as the alternative Section 309 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 p articipating in a regional strategy to reduce SO 2 

### emissions, five states had originally submitted Section 309 SIPs to EPA. These states were Arizona, New Mexico, Oregon, Utah, and Wyoming. In addition, Albuquerque

- Bernalillo County had also submitted a S ection 309 SIP. EPA, however, never approved these SIPs due to the legal challenges.

Oregon and Arizona have opted out of submitting a revised Section 309 SIP under the modified RHR, which leaves three participating states and Albuquerque

- Bernalillo Co unty . 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.

### 2010 Milestone Report March 22, 2012

3 The following summarizes a few key elements of the Section 309 process for the partic ipating Section 309 states:

1. Section 309(d)(4)(i) requires SO 2 

### 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 greater reasonable progress

than BART.

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

### emissions in order to ensure the SO 2 

### 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 five 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

2010 emissions against the milestones for the states and city that have submitted Section 309

SIPs to EPA.

What Elements Must the Regional SO 2 

### 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 SO 2 

### emissions (tons/year).

2. Adjustments to account for:

● Changes in emissions monitoring or calculation methods; or

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

3. As applicable, avera ge adjusted emissions for the last three years (which are compared to the regional milestone). Since this is the seventh report, 2008

, 2009 , and 2010 emissions are averaged.

How Is Compliance with the SO 2 

### Milestone Determined ?

While the WRAP assists w ith the preparation of this report, each Section 309 state reviews the information in the report, and proposes a draft determination that the regional SO 2 

### milestone has either been met or exceeded. The draft determination is then submitted for public

revi ew and comment during the first part of 2012 , culminating in a final report sent to EPA by March 31, 2012

.

### 2010 Milestone Report March 22, 2012

4 1.2 Report Organization

This report presents the regional SO 2 

### emissions and milestone information required by

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

● Reported SO 2 

### Emissions in 200 9 ;

● Monitoring Methodology Emissions Adjustments;

● Three

- Year Average Emissions;

● Enforcement Milestone Adjustments;

● Quality Assurance (Including Source Change Information);

● Milestone Determination;

● Appendix A

-- Fa cility Emissions and Emissions Adjustments; and

● Appendix B

-- Changes to SO 2 

### Emissions and Milestone Source Inventory.

2.0 Reported SO 2 

### Emissions in 2010

All stationary sources with reported emissions of 100 tons or more per year in 2000 or any subs equent year are required to report annual SO 2 

### emissions. Table 1 summarizes the annual reported emissions from applicable sources in each state. The 2010 reported SO 2 

### emissions for each applicable source are in Appendix A, Table A

- 1.

Table 1 Reported 2 010 SO 2 

### Emissions by State

State Reported 2010 SO 2 

### Emissions (tons/year)

New Mexico 20, 112

Utah 26,31 7

Wyoming 83,911

TOTAL 130,3 40

### 2010 Milestone Report March 22, 2012

5 3.0 Monitoring Methodology Emissions Adjustments

The annual emissions reports for each state include proposed em issions adjustments to ensure consistent comparison of emissions to the milestone. 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 (2006). The net impact throughout the region as a result of these adjustments is an

increase of 784 tons from the reported 2010 emissions. Table 2 summarizes the emissions adjustments made for a total of three facilities.

Table 2 Adjustments for Changes in Monitoring Methodology

State Source Reported

2010 SO 2 

### Emissions (tons) Adjusted

2010 SO 2 

### Emissions (tons) Monitoring

Methodology Adjustment (tons) Description

NM Giant Industries/Ciniza

Re finery (Gallup) [Old

name: GIANT REFINING/CINIZA] 430 859 429 Facility changed emissions calculation methodology from annual usage factors

to CEMS

UT Holcim

- Devil's Slide Plant 237 306 69 Facility changed emissions calculation methodology

from stack test to CEMS.

UT Holly Refining and Marketing Co.

-- Phillips Refinery 231 517 286 Facility changed emissions calculation methodology

from stack test to CEMS.

### 2010 Milestone Report March 22, 2012

6 4.0 Three

- Year Average Emissions ( 2008

, 2009 , and 2010 )

The SIPs require multi

- year avera ging 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' emi ssions from 2008 to 2010 is 146,808 tons . Table 3 shows the adjusted emissions for each year and three

- year average emissions. The following report sections describe the adjusted

milestone determination.

Table 3

Average Sulfur Dioxide Emissions ( 2008

, 2009 , & 2010 )

Year Adjusted SO 2 

### Emissions (tons/year)

2008 165,595

2009 143,704

2010 131,124

Three

- Year Average ( 2008

, 2009

, 2010 ) 146,808



### 5.0 Enforcement Milestone Adjustments

The SIPs require that each state report on proposed milestone adjust ments 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 milest one adjustments require an approved SIP revision before taking effect.

Enforcement Milestone Adjustment

There were no proposed enforcement action related milestone adjustments reported for

2010

.

6 .0 Quality Assurance

The states provided 2010 em issions 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

sourc e change report, and second, the states compared their inventory data for utility sources against 40 CFR Part 75 Acid Rain Program monitoring data.

### 2010 Milestone Report March 22, 2012

7 6 .1 Source Change Report

The SIPs require that this annual SO 2 

### 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 s ources 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% from the previ ous year.

Table 4 provides explanations for the emissions variations from 2009

– 2010 that are greater than 20%. Plants with variations greater than 20%, but reported emissions of less than 20

tons in both 2009 and 2010 , are not included in Table 5. Information on these plants is provided in Appendix A

.

Appendix B provides a list of all sources added or removed from the program inventory in previous reporting years. One source was added since the 2008 report.

### 2010 Milestone Report March 22, 2012

8 Table 4

Sources with an Emissi ons Change of > 

### ± 20% from the Previous Year

State County

FIPS State

Facility

Identifier Reported

2009 SO 2 

### Emissions (tons) Reported

2010 SO 2 

### Emission s (tons) Plant Name Description/

Comments

NM 015 350150002 651 786 BP America Production/Empire

Abo Plan t [Old name: Arco Permian/Empire Abo Plant] Slight increase due to increase in field gas

H2S concentration

NM 015 350150011 0 12 DCP Midstream/Artesia

Gas Plant Maintenance activites

occurred on Unit 12

that did not occur in

2009.

NM 025 350250035 479 1 ,336 DCP

Midstream/Linam Ranch Gas Plant [Old

name: GPM

GAS/LINAM

RANCH GAS PLANT] Fewer release events

in 2009 than in 2010.

NM 025 350250060 1,290 875 Targa Midstream

Services LP/Eunice Gas Plant [Old name:

WARREN

PETROLEUM/EUNI CE GAS PLANT] Decrease i n volume of acid gas flared from the acid gas flare.

NM 025 350250004 2,605 3,511 Frontier Field Services/Maljamar Gas

Plant In 2010 there was an increase in field gas

H2S concentration.

NM 031 350310008 244 430 Giant

Industries/Ciniza Refinery (Gallup) [Old

name: GIANT REFINING/CINIZA] Increase in throughput

NM 015 350150008 244 501 Marathon Oil/Indian

Basin Gas Plant SRU was offline Jan

Mar 2010 then operated with reduced plant inlet rate.

NM 015 350150010 60 39 Navajo Refining Co/Artesia Refinery E xcess emissions events

in 2010 from the two

sources SRU1&2 TGI (H

- 0473) and the FCC Unit (FCC) Flare (FL

402) resulted in less SO2

emission than in 2009.

NM 045 350450902 5,537 4,312 Public Service Co of

New Mexico/San Juan Generating Station Due to sched uled and unscheduled outages,

the Units did not run

as much in 2010 as they did in 2009.

### 2010 Milestone Report March 22, 2012

9 Table 4

Sources with an Emissi ons Change of > 

### ± 20% from the Previous Year

State County

FIPS State

Facility

Identifier Reported

2009 SO 2 

### Emissions (tons) Reported

2010 SO 2 

### Emission s (tons) Plant Name Description/

Comments

NM 025 350250008 981 1,878 Southern Union

Gas/Jal #3 2010 Operations

returned to normal

from 2009.

UT 011 10119 842 37 Chevron Products Co.

-- Salt Lake Refinery N ew controls,

decrease in excess emissions and flaring

UT 011 10122 379 280 Flying J Refinery

– (Big West Oil) Decrease in excess emissions, flaring, and

amount of sulfur in plant gas.

UT 029 10007 301 237 Holcim

- Devil's Slide

Plant Operated shorter

hours . Last year

mobile emissions were incorrectly included.

UT 011 10123 461 231 Holly Refining

– Phillips Refinery Reduction in excess

emissions

UT 007 10081 5,494 7,462 PacifiCorp

-- Carbon

Power Plant Burned 24,481 more

tons of coal

UT 037 10034 147 82 Patara Midstream LLC (was EnCana Oil & Gas (USA) Incorporated and Tom Brown Incorporated)

- Lisbon Natural Gas Processing Plant) The incinerator was not operated in 2010. New control process is being used at the plant

UT 043 10676 104 60 Utelite Corporat ion

– Shale Processing Throughput of coal and operation hours

decreased

WY 045 0005 2,692 1,525 Black Hills Corporation

-- Osage SO2 emissions

decreased due to inactivity

WY 041 0012 25 0 BP America Production Company

-

- Whitney Facility SO2 emissions d ue to decreased upset flaring from the emergency

flare

WY 013 971 0 Burlington Resources

-- Big Horn Wells SO2 emissions decreased by more

than 20% due to decreased field flaring.

### 2010 Milestone Report March 22, 2012

10 Table 4

Sources with an Emissi ons Change of > 

### ± 20% from the Previous Year

State County

FIPS State

Facility

Identifier Reported

2009 SO 2 

### Emissions (tons) Reported

2010 SO 2 

### Emission s (tons) Plant Name Description/

Comments

WY 013 0028 1,683 2,386 Burlington Resources

-- Lost Cabin Gas

Plant SO2 emissions increased by more

than 20% due to

increases in the

emissions from the

Train 3 Tail Gas

Incinerator and the

Train 3 Flare. These

increases were primarily caused by problems with reaction furnace shutdowns, H2S Compressor shutdowns, and power

outa ges from the local electricity supplier.

WY 041 0009 185 74 Chevron USA

-- Carter Creek Gas Plant SO2 emissions decreased by more

than 20% due to the

CY 2009 emissions

included those from a major plant shutdown

and turnaround event

which was conducted

for maintenance

purposes.
WY 037 0014 37 82 Chevron USA

-- Table

Rock Gas Plant (Formerly Anadarko E&P Co LP) SO2 emissions increased by more

than 20% due to the plant being shut down

for most of CY 2009 and being fully operational in CY

2010.

WY 041 0008 1 169 Chevron USA

-- Whitney Canyon/Carter Creek

Wellfield SO2 emissions increased by more

than 20% due to the testing of Well #1

- 17M, authorized by

waivers wv

- 10364 and

wv

- 11071 to conduct 2

flow tests on this well.

WY 013 0008 54 96 Devon Gas Services,

L.P.

-- Beaver Creek

Gas Plant SO2 emissions

increased due to changes in the

calculation methods and increased flaring

in 2010

### 2010 Milestone Report March 22, 2012

11 Table 4

Sources with an Emissi ons Change of > 

### ± 20% from the Previous Year

State County

FIPS State

Facility

Identifier Reported

2009 SO 2 

### Emissions (tons) Reported

2010 SO 2 

### Emission s (tons) Plant Name Description/

Comments

WY 029 0012 1,343 1,029 Encore Operating LP

-

- Elk Basin Gas Plant SO2 emissions

decreased due to the sulfur reactors being

cha nged out in 2009; emissions dropped 50

- 100 lb/hr

WY 023 0001 217 14 Exxon Mobil Corporation

-- LaBarge Black Canyon Dehydration Facility No plant shutdown in

2010 for maintenance items and project tie

ins; had a shutdown in 2009 (requires full plant depre ssurization); increasing reliability and understanding of Acid Gas Injection System

WY 023 0013 1,101 587 Exxon Mobil Corporation

-- Shute

Creek No plant shutdown in

2010 for maintenance items and project tie

ins; had a shutdown in 2009 (requires full pla nt depressurization)

WY 037 0047 58 0 FMC Wyoming Corporation

-- Granger Soda Ash

Plant SO2 emissions

decreased due to the temporary production

curtailment of the FMC Granger facility for inventory control purposes; Zero hours of operation for the

coal

- f ired boilers

WY 021 0001 230 134 Frontier Oil & Refining Company

-- Cheyenne Refinery SO2 emissions decreased by more

than 20% due to the Desox catalyst additive usage in the catalytic cracker.

WY 043 3 86 40 Hiland Partners, LLC

-

- Hiland Gas Plant SO2 emissions

decreased due to decreased flaring in

2010.

WY 029 0010 226 125 Marathon Oil Co

-- Oregon Basin

Wellfield SO2 emissions

decreased due to more use of underground injetion of gas that reduces the potential

to flare.

### 2010 Milestone Report March 22, 2012

12 Table 4

Sources with an Emissi ons Change of > 

### ± 20% from the Previous Year

State County

FIPS State

Facility

Identifier Reported

2009 SO 2 

### Emissions (tons) Reported

2010 SO 2 

### Emission s (tons) Plant Name Description/

Comments

WY 037 8 126 52 Merit Energy Company

-- Brady

Gas Plant SO2 emissions decreased by more

than 20% due to reduced operating

hours of the Ucarsol Regenerator Heater (H

- 100A). Also, the

Benfield Thermal Oxidizer (TO=1) did not operate in 2010.

WY 9 1 17,778 13,322 Pacificorp

– Dave

John ston Plant SO2 emissions

decreased due to both a new dry scrubber in

Unit 3 and reduced operating hours for

Unit 4.

WY 37 1002 17,309 13,654 Pacificorp

– Jim Bridger Plant SO2 emissions

decreased due to the

installation of Flue

Gas Desulfurization

sytem u pgrades per Air Quality permit

MD

- 1552 on Unit 1.

WY 007 0001 1,999 204 Sinclair Wyoming Refining Company

-- Sinclair Refinery SO2 emissions decreased by more

than 20% due to decreased flaring from

CY 2009 to CY 2010

in the vertical flare. Also, there was a significant reduction

of SO2 emissions in the FCC regenerator per the consent decree.

WY 025 0005 280 205 Sinclair Casper Refining Company

-- Casper Refinery SO2 emissions decreased by more

than 20% due to decreased flaring from

CY 2009 to CY 2010

i n the vertical flare. Also, there was a significant reduction

of SO2 emissions in the FCC regenerator per the consent decree.

### 2010 Milestone Report March 22, 2012

13 6 .2 Part 75 Data

Federal Acid Rain Program emissions monitoring data (required by 40 CFR Part 75) were used to check repo rted power plant emissions.

Sources in the region subject to Part 75 emitted 69 % of the region's reported emissions in

2010

. 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. The reported emissions matched EPA's emission data a



### .

a The reported emissions for Pacificorp’s Naughton Plant in WY contain an extra 21 tons of SO2 emissions due to wastewater ponds that are not included in the acid rain data. The reported emi ssions for the San Juan Generating Station in NM contain 20 tons of SO2 emissions due to emission points that are not included in the acid rain data.

### 2010 Milestone Report March 22, 2012

14 7 .0 Preliminary Milestone Determination

The Section 309 state 2010 milestone is 200,722 tons SO 2 

### , which represents the average

reg ional emissions milestone for the years 2008

, 2009 , and 2010 . The average of 2008

, 2009

, and 2010 adjusted emissions was determined to be 146,808 tons SO 2 

### . Therefore, the participating states have met the 200,722 tons SO 2 

### milestone.

8 .0 Public Commen ts

New Mexico, Utah, Wyoming and Albuquerque

- Bernalillo County each published a draft of this report for public review and comment. No comments were received.

### Appendix A March 22, 2012

A

- 1 Appendix A

Table A

- 1

20 10 Reported and Adjusted Emissions for Sources Subject to

Section 309

-- Regional Haze Rule

State County

FIPS State Facility

Identifier ORIS Plant Name Plant

SIC Plant

NAICS Reported

2010 SO 2 Emissions (tons) Adjusted

2010 SO 2 Emissions (tons) General

New Monitoring

Calculation

Method Adjustment (tons)

NM 015 350150024 Agave Energy

Co. /Agave Dagger Draw

Gas Plant 1311 211111 0 0

-

NM 015 350150002 BP America Production/Empire Abo Plant [Old name: Arco Permian/Empire Abo Plant] 1321 211112 786 786

-

NM 015 350150011 DCP Midstream/Artesia

Gas Plant 1321 211112 12 12

-

NM 025 350250044 DCP Midstream/Eunice Gas Plant [Old name:

GPM GAS EUNICE GAS PLANT] 1321 211112 2

, 792 2

, 792 34

NM 025 350250035 DCP Midstream/Linam Ranch Gas Plant [Old

name: GPM

GAS/LINAM RANCH GAS PLANT] 1321 211112 1,336 1,3 36

-

NM 015 350150138 Duke

-- Magnum/Pan Energy

-- Burton Flats 1321 211112 0 0

-

NM 015 350150285 Duke Energy/Dagger

Draw Gas Plant 1321 211112 0 0

-

NM 025 350250060 Targa Midstream

Services , LP /Eunice Gas Plant [Old name:

WARREN

PETROLEUM/EUNICE GAS PLANT] 1321 211112 875 875

-

NM 025 350250004 Frontier Field Services/Maljamar Gas

Plant 1321 211112 3,511 3,511

-

NM 031 350310008 Giant Industries/Ciniza Refinery (Gallup) [Old

name: GIANT REFINING/CINIZA] 2911 32411 430 859 429

(con t.)

### Appendix A March 22, 2012

A

- 2 Table A

- 1

2010 Reported and Adjusted Emissions for Sources Subject to

Section 309

-- Regional Haze Rule (cont.)

State County

FIPS State Facility

Identifier ORIS Plant Name Plant

SIC Plant

NAICS Reported

2010 SO 2 Emissions (tons) Adjusted

2010 SO 2 Emissions (tons) General

New Monitoring

Calculation

Method Adjustment (tons)

NM 025 350250007 J L Davis Gas Processing/Denton Plant 1311 211111 577 577

-

NM 015 350150008 Marathon Oil/Indian

Basin Gas Plant 1321 211112 501 501

-

NM 015 350150010 Nava jo Refining Co/Artesia Refinery 2911 32411 39 39

-

NM 045 350450902 2451 Public Service Co of

New Mexico/San Juan Generating Station 4911 221112 4,312 4,312

-

NM 007 350070001 Raton Pub.

Service/Raton Power

Plant 4911 221112 0 0

-

NM 025 350250008 Sou thern Union Gas /Jal

#3 1321 211112 1,878 1,878

-

NM 025 350250051 Targa Midstream

Services , LP /Eunice

South Gas Plant 1321 211112 0 0

-

NM 025 350250061 Targa Midstream Services, LP/ Monument Plant [Old name:

WARREN

PETROLEUM/ MONUMENT PLANT] 1321 2111 12 667 667

-

NM 025 350250063 Targa Midstream

Services , LP /Saunders Plant [Old name:

WARREN

PETROLEUM/SAUND ERS PLANT] 1321 211112 229 229

-

NM 031 350310032 87 Tri

- State Gen &

Transmission/Escalante

Station 4911 221112 1,211 1 ,211

-

NM 045 350450247 Western Gas

Resources/San Juan

River Gas Plant 1321 211112 590 590

-

(cont.)

### Appendix A March 22, 2012

A

- 3 Table A

- 1

2010 Reported and Adjusted Emissions for Sources Subject to

Section 309

-- Regional Haze Rule (cont.)

State County

FIPS State Facility

Identifier ORIS Pla nt Name Plant

SIC Plant

NAICS Reported

2010 SO 2 Emissions (tons) Adjusted

2010 SO 2 Emissions (tons) General

New Monitoring

Calculation

Method Adjustment (tons)

NM 045 350450023 Western Refining

Southwest Inc./San Juan Refinery (Bloomfield) [Old name: GI ANT

INDUSTRIES/BLOOM
FIELD REF] 2911 32411 366 366

-

UT 049 10790 Brigham Young University

-- Main Campus 8221 611310 116 116

-

UT 027 10311 Brush Resources Inc.

-- Delta Mill 1099 212299 0 0

-

UT 011 10119 Chevron Products Co.

-- Salt Lake Refiner y 2911 324110 37 37

-

UT 011 10122 Flying J Refinery

-- (Big West Oil Company) 2911 324110 280 280

-

UT 027 10313 Graymont Western US

Inc.

-- Cricket Mountain

Plant 1422 212312 10 10

-

UT 029 10007 Holcim

- Devil's Slide

Plant 3241 327310 237 306 69

UT 011 10123 Holly Refining and Marketing Co.

-- Phillips Refinery 2911 324110 231 517 286

UT 027 10327 6481 Intermountain Power Service Corporation

-- Intermountain

Generation Station 4911 221112 5,000 5,000

-

UT 035 10572 Kennecott Utah Copper

Co rp.

-- Power Plant/Lab/Tailings Impoundment 1021 212234 3046 3046

-

UT 035 10346 Kennecott Utah Copper Corp.

-- Smelter & Refinery 3331 331411 795 795

-

(cont.)

### Appendix A March 22, 2012

A

- 4 Table A

- 1

2010 Reported and Adjusted Emissions for Sources Subject to

Section 309

-- Regional Haze Rule (cont.)

State County

FIPS State Facility

Identifier ORIS Plant Name Plant

SIC Plant

NAICS Reported

2010 SO 2 Emissions (tons) Adjusted

2010 SO 2 Emissions (tons) General

New Monitoring

Calculation

Method Adjustment (tons)

UT 007 10081 3644 PacifiCorp

-- Carbon

Power Plant 4911 221112 7,462 7,462

-

UT 015 10237 6165 PacifiCorp

-- Hunter

Power Plant 4911 221112 4,558 4,558

-

UT 015 10238 8069 PacifiCorp

-- Huntington

Power Plant 4911 221112 3,117 3,117

-

UT 037 10034 Patara Mid stream LLC (was EnCana Oil & Gas (USA) Incorporated and

Tom Brown Incorporated)

- Lisbon Natural Gas Processing

Plant 2911 211111 82 82

UT 007 10096 Sunnyside Cogeneration

Associates

-- Sunnyside Cogeneration Facility 4911 221112 449 449

-

UT 035 1033 5 Tesoro West Coast

-- Salt Lake City Refinery 2911 324110 837 837

UT 043 10676 Utelite Corporation

-- Shale processing 3295 212399 60 60

-

WY 011 0002 American Colloid

Mineral Co

-- East Colony 1459 212325 56 56

-

WY 011 0003 American Colloid

Mineral Co

-- West Colony 1459 212325 42 42

-

WY 031 0001 6204 Basin Electric

-- Laramie

River Station 4911 221112 9,378 9,378

-

WY 003 0012 Big Horn Gas Proc

-- Big Horn/Byron Gas

Plant 1311 22121 0 0

-

WY 005 0002 4150 Black Hills Corporation

-- Ne il Simpson I 4911 22112 956 956

-

WY 005 0063 7504 Black Hills Corporation

-- Neil Simpson II 4911 22112 559 559

-

(cont.)

### Appendix A March 22, 2012

A

- 5 Table A

- 1 2010 Reported and Adjusted Emissions for Sources Subject to

Section 309

-- Regional Haze Rule (cont.)

State County

FIPS State Facility

Identifier ORIS Plant Name Plant

SIC Plant

NAICS Reported

2010 SO 2 Emissions (tons) Adjusted

2010 SO 2 Emissions (tons) General

New Monitoring

Calculation

Method Adjustment (tons)

WY 045 0005 4151 Black Hills Corporation

-- Os age Plant 4911 22112 1,525 1,525

-

WY 005 0146 55479 Black Hills Corporation

-- Wygen I 4911 22112 539 539

-

WY 005 0225 Cheyenne Light Fuel and Power Company

– Wygen II 4911 22112 213 213

-

WY 005 0281 Black Hills Corporation

– Wygen III 4911 22112 173 173

-

WY 041 0012 BP America Production Company

-- Whitney Facility 1311 211111 0 0

-

WY 041 0002 BP America Production Company

-- Whitney Canyon WellField 1300 21111 6 6

-

WY 013 0009 Burlington Resources

-- Bighorn Wells 1300 21111 0 0

-

WY 013 0028 Burlington Resources

-- Lost Cabin Gas Plant 1311 211111 2,386 2,386

-

WY 041 0009 Chevron USA

-- Carter

Creek Gas Plant 1311 211111 74 74

-

WY 037 0177 Chevron USA

-- Table

Rock Field 1300 21111 0 0

-

WY 037 0014 Chevron USA

-- Table

Rock Gas Plant (Formerly Anadarko E&P Co LP) 1321 211111 82 82

-

WY 041 0008 Chevron USA

-- Whitney Canyon/Carter

Creek Wellfield 1300 21111 169 169

-

WY 013 0007 Devon Energy Production Co., L.P.

-- Beaver Creek Gas Field 1300 21111 1 1

-

(cont.)

### Appendix A March 22, 2012

A

- 6 Table A

- 1 2010 Reported and Adjusted Emissions for Sources Subject to

Section 309

-- Regional Haze Rule (cont.)

State County

FIPS State Facility

Identifier ORIS Plant Name Plant

SIC Plant

NAICS Reported

2010 SO 2 Emissions (tons) Adj usted

2010 SO 2 Emissions (tons) General

New Monitoring

Calculation

Method Adjustment (tons)

WY 013 0008 Devon Gas Services,

L.P.

-- Beaver Creek Gas

Plant 1311 211111 96 96

-

WY 029 0012 Encore Operating LP

-- Elk Basin Gas Plant 1311 211111 1,029 1, 029

-

WY 023 0001 Exxon Mobil Corporation

-- Labarge Black Canyon Facility 1300 21111 14 14

-

WY 023 0013 Exxon Mobil Corporation

-- Shute

Creek 1311 211111 587 587

-

WY 037 0048 FMC Corp

-- Green

River Sodium Products (Westvaco facility) 2812 32 7999 2,408 2,408

-

WY 037 0049 FMC Wyoming Corporation

-- Granger

Soda Ash Plant 1474 212391 0 0

-

WY 021 0001 Frontier Oil & Refining Company

-- Cheyenne Refinery 2911 32411 124 124

-

WY 037 0002 General Chemical

-- Green River Plant (Facility Na me: General Chemical) 1474 327999 5,246 5,246

-

WY 043 0003 Hiland Partners, LLC

-- Hiland Gas Plant 1321 48621 40 40

-

WY 029 0007 Marathon Oil Co

-- Oregon Basin Gas Plant 1321 211112 278 278

-

WY 029 0010 Marathon Oil Co

-- Oregon Basin Wellfi eld 1300 21111 125 125

-

WY 037 0008 Merit Energy Company

-- Brady Gas Plant (formerly Anadarko E&P Co LP) 1321 211112 52 52

-

(cont.)

### Appendix A March 22, 2012

A

- 7 Table A

- 1 2010 Reported and Adjusted Emissions for Sources Subject to

Section 309

-- Regional Haze Rule (cont.)

State County

FIPS State Facility

Identifier ORIS Plant Name Plant

SIC Plant

NAICS Reported

2010 SO 2 Emissions (tons) Adjusted

2010 SO 2 Emissions (tons) General

New Monitoring

Calculation

Method Adjustment (tons)

WY 001 0002 Mountain Cement

C ompany

-- Laramie

Plant 3241 23571 283 283

-

WY 037 0003 P4 Production, L.L.C.

-- Rock Springs Coal Calcining Plant 3312 331111 755 755

-

WY 009 0001 4158 Pacificorp

- Dave

Johnston Plant 4911 221112 13,332 13,332

-

WY 037 1002 8066 Pacificorp

-- Jim Bridger

Plant 4911 221112 13,654 13,654

-

WY 023 0004 4162 Pacificorp

-- Naughton

Plant 4911 221112 20,265 20,265 Note: 2010

emissions

include 21 tons

of SO2 from

wastewater ponds that are

not included in

the acid rain

database

WY 005 0046 6101 Pacifico rp

-- Wyodak

Plant 4911 221112 6,768 6,738

-

WY 037 0022 Simplot Phosphates LLC

-- Rock Springs Plant 2874 325312 1,499 1,499

-

WY 007 0001 Sinclair Oil Company

-- Sinclair Refinery 2911 32411 204 204

-

WY 025 0005 Sinclair Wyoming Refining Compan y

-- Casper Refinery 2911 32411 205 205

-

WY 037 0005 Solvay Chemicals

-- Soda Ash Plant (Green River Facility) 1474 325181 44 44

-

WY 015 0001 The Western Sugar Cooperative

-- Torrington Plant 2063 311313 148 148

-

WY 001 0005 University of Wyomi ng

-- Heat Plant 8221 61131 74 74

-

WY 045 0001 Wyoming Refining

-- Newcastle Refinery 2911 32411 535 535

-

### Appendix B March 22, 2012

B

- 1 Appendix B

Table B

- 1

Sources Added to the SO 2 

### 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 0014 Chevron USA (previously o wned by Anadarko E&P Company LP)

-- Table Rock Gas Plant 2003

WY 005 0146 Black Hills Corporation

-- Wygen 1 2003

WY 041 0002 BP America Production Company

-- Whitney Canyon Well Field 2003

WY 013 0009 Burlington Resources

-- Bighorn Wells 2003

WY 037 0177 Chevron USA

-- Table Rock Field 2003

WY 041 0008 Chevron USA

-- Whitney Canyon/Carter Creek Wellfield 2003

WY 013 0008 Devon Energy Corp.

-- Beaver Creek Gas Plant 2003

WY 035 0001 Exxon Mobil Corporation

-- Labarge Black Canyon Facility (also

iden tified as Black Canyon Dehy Facility) 2003

WY 013 0007 Devon Energy Corp.

-- Beaver Creek Gas Field 2004

WY 005 0225 Cheyenne Light, Fuel and Power (a subsidiary of Black Hills Corporation)

-- Wygen II 2008

WY 005 0281 Black Hills Corporation

– Wygen II I 2010

### Appendix B March 22, 2012

B

- 2 Table B

- 2

Sources Removed from the SO 2 

### Emissions and Milestone Report Inventory

State County

FIP

Code State Facility

ID Facility Name 1998

Baseline

Emissions (tons/year) Reason for Change Report

Year of Change

WY 043 0001 Western Sugar Compan y

-- 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. 200 3

WY 017 0002 Marathon Oil

-- Mill Iron 260 Emissions did not meet 100 TPY program criteria. 2003

UT 049 10796 Geneva Steel

-- Steel Manufacturing Facility 881 Plant is shut down and

disassembled. 2004

WY 023 0001 Astaris Production

-- Coking Plant 1,45 4 Plant is permanently shut

down and dismantled. 2004

ABQ*

NM 001 00008 GCC Rio Grande Cement 1,103 Not subject to program

after baseline revisions.* * 2008

ABQ

NM 001 00145 Southside Water

Reclamation Plant 120 Not subject to program

after baseline revis ions.* * 2008

NM 023 350230003 Phelps Dodge Hidalgo

Smelter 16,000 Facility is permanently

closed. 2008

NM 017 350170001 Phelps Dodge Hurley

Smelter/Concentrator 22,000 Facility is permanently

closed. 2008

* ABQ NM means Albuquerque

- Bernalillo County

. * * 1998 baseline emissions were based on the facilities' potential to emit (PTE), and not actual emissions. Actual annual emissions have always been below 100 tons. Once the year 2006 baseline became effective, these

facilities were removed from the inve ntory.

### Appendix C March 22, 20 12

B

- 3 

## Appendix C

Projected Emission Inventory for the Year 2018

State Implementation Plans (SIPs) for Regional Haze submitted under 40 CFR 51.309 require an assessment in 2013 of the likelihood of meeting the regional sulfur dioxide (SO 2 

### ) milestone for 2018. The first step in this assessment is the development of a projected inventory for the year 2018 using 2010 as a baseline. The projected inventory must be included in the 2010 milestone report.

The states of New Mexico, Utah, and Wyoming and Albuquerque/Bern alillo County (§309 States) have determined that the 2018 emission projection included in their most recent SIP revision adopted in 2011 is the best current projection for the year 2018. The 2018 emission projection will be used in the 2013 periodic SIP r eview to evaluate the likelihood of meeting the 2018 milestone.



## Background

The §309 States first submitted Regional Haze SIPs to the Environmental Protection Agency (EPA) in 2003. These SIPs contained SO 2 

### milestones and a backstop trading program that wo uld be triggered if the milestones were not met in the 3

- state region. The

SO 2 

### milestones were based on Voluntary Emissions Reduction Program for Major Industrial Sources of Sulfur Dioxide in Nine Western States and A Backstop Market Trading Program, An An nex to the Report of the Grand Canyon Visibility Transport

Commission , September 29, 2000 (the Annex) that was submitted to EPA as required by

40 CFR 51.309.

The Annex contained SO 2 

### milestones for the years 2003, 2008, 2013, and 2018 to ensure

that SO 2 

### emissions would decline continually through the first planning period as required by the regional haze rule, with the most significant reductions occurring between 2013 and 2018. Because the emission reductions were concentrated during the last years

of th e program, stakeholders were concerned that the 2018 milestone would not be met. To address these concerns, the Annex included a review in 2013 of the likelihood of meeting the 2018 milestone. If necessary, the §309 States could trigger the backstop

trad ing program proactively to ensure that the 2018 milestone would be met.

The §309 States have been implementing the §309 Regional Haze SIP since 2003. While the Annex anticipated that the emission reductions would occur primarily during the last 5 years o f the planning period, the opposite has occurred with most of the reductions occurring during the first 5 years of the planning period. Emissions in the 3

- state region have declined 45% between 2000 and 2010, and the region is on track to meet the 2018

mi lestone.

### Appendix C March 22, 20 12

B

- 4 The milestones in the §309 RH SIPs were revised in 2008 and 2011 to reflect the emission reductions that have already occurred, and there is no longer a significant drop

in the milestones between 2013 and 2018.



## 2011 SIP Revision

The §309 S tates have recently revised their RH SIPs to update the SO 2 

### milestones. These revisions were completed in 2011 and included a projected 2018 inventory. The projected inventory was based on the 2018 PRPb inventory developed by the Western Regional Air

Part nership (WRAP) to support Regional Haze SIPs in the region. This inventory was reviewed, and additional changes were made to include updated oil and gas projections from the WRAP Phase II oil and gas inventory as well as source

- specific updates due to

new permit limits. Shut down sources were removed from the inventory and new sources

were added to reflect the best available information.

### Appendix C March 22, 20 12

B

- 5 

## Potential Changes Between 2010 and 2018

There are a number of national measures that may further reduce SO 2 

### emissions between 2010 and 2018. EPA has recently proposed New Source Performance Standards for the oil and gas industry that may reduce emission in the 3

- state region. In addition, revised National Ambient Air Quality Standards for SO 2 

### may require reductions from the large

source of SO 2 

### that are included in the milestones. The §309 States do not currently anticipate any changes to the assumptions in the 2018 projections that would lead to higher than anticipated emissions growth between 2010 and 2018.



## Conclusion

The §309 States have determined that the 2018 emission projection included in their most recent SIP revision adopted in 2011 is the best current projection for the year 2018. The 2018 emission projection will be used in the 2013 periodic SIP re view to evaluate the likelihood of meeting the 2018 milestone.