2010 Regional SO2 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: 307-777-6993

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: 801-536-4248

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 87507

Phone: 505-476-4329

Fax: 505-476-4375

rhonda.payne@state.nm.us

Albuquerque-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 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 areas on the Colorado Plateau. Five states -- Arizona, New 

Mexico, Oregon, Utah, and Wyoming -- and Albuquerque-Bernalillo County initially exercised 

this option by submitting plans 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 

Section 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 SO2

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

The milestone for 2010 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 was 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 130,340

tons of SO2 emissions for the calendar year 2010. 

The total emissions increased to 131,124 tons of

SO2 after making adjustments to account for 

changes in monitoring and calculation methods. 

The adjustments result in an additional 784 tons of 

SO2 emissions. The adjusted emissions values for 

2008 and 2009 were 165,595 tons and 143,704 tons, respectively. The average of 2008, 2009, 

and 2010 adjusted emissions is 146,808 tons. 

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

emissions in 2010 are below the regional SO2 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 2009 Milestone ........................................................................................................................ 200,722 tons

2010 Sulfur Dioxide Emissions

Reported 2010 Emissions ....................................................................................................................... 130,340 tons

Adjustments***

Emission Monitoring and Calculation Methods .............................................................................. 784 tons

Adjusted 2010 Emissions (rounded number) .......................................................................................... 131,124 tons

Average Sulfur Dioxide Emissions (2008, 2009, & 2010)

Adjusted 2010 Emissions ....................................................................................................................... 131,124 tons

Adjusted 2009 Emissions ....................................................................................................................... 143,704 tons

Adjusted 2008 Emissions ....................................................................................................................... 165,595 tons

Average of 2008, 2009, & 2010 Adjusted Emissions ............................................................................ 146,808 tons

Comparison of Emissions to Milestone

Average of 2008, 2009, & 2010 Adjusted Emissions .............................................................................146,808 tons

Adjusted Three-State 2010 Milestone..................................................................................................... 200,722 tons

Difference (Negative Value = Emissions < Milestone) ..........................................................................-53,915 tons

2008 – 2010 Emissions Average as Percent of 2010 Milestone ...........................................................................73%

* Section 309 participating states means the states of New Mexico, Utah and Wyoming and AlbuquerqueBernalillo 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 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 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 SO2 Milestone and 

Backstop Trading Program by not resubmitting a Section 309 State Implementation 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 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 Section 309 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 eighth 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 2010. Based on the first eight 

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. 
2010 Milestone Report

March 22, 2012

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 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 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, Albuquerque-Bernalillo County had also submitted a Section 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 County. 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 

participating Section 309 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 greater reasonable progress 

than BART.

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 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 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 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 seventh report, 2008, 2009, and 2010 emissions 

are averaged.

How Is Compliance with the SO2 Milestone Determined?

While the WRAP assists with the preparation of this report, each Section 309 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 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 SO2 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 SO2 Emissions in 2009;

● Monitoring Methodology Emissions Adjustments;

● Three-Year Average Emissions;

● Enforcement Milestone Adjustments;

● Quality Assurance (Including Source Change Information);

● 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 2010

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 2010 reported SO2 emissions for 

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

Table 1

Reported 2010 SO2 Emissions by State

State Reported 2010 SO2 Emissions (tons/year)

New Mexico 20,112

Utah 26,317

Wyoming 83,911

TOTAL 130,340
2010 Milestone Report

March 22, 2012

5

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 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 SO2

Emissions 

(tons)

Adjusted 

2010 SO2

Emissions 

(tons)

Monitoring 

Methodology 

Adjustment

(tons) Description

NM Giant Industries/Ciniza 

Refinery (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 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 threeyears' emissions 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 SO2 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 adjustments 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 

2010. 

6.0 Quality Assurance

The states provided 2010 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.
2010 Milestone Report

March 22, 2012

7

6.1 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% 

from the previous 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 Emissions Change of > ± 20% from the Previous Year

State County 

FIPS

State 

Facility 

Identifier

Reported 

2009 SO2

Emissions 

(tons)

Reported 

2010 SO2

Emission

s (tons)

Plant Name Description/

Comments

NM 015 350150002 651 786 BP America 

Production/Empire 

Abo Plant [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 in 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 JanMar 2010 then 

operated with reduced 

plant inlet rate.

NM 015 350150010 60 39 Navajo Refining 

Co/Artesia Refinery

Excess emissions events 

in 2010 from the two 

sources SRU1&2 TGI 

(H-0473) and the FCC 

Unit (FCC) Flare (FL402) 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 scheduled 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 Emissions Change of > ± 20% from the Previous Year

State County 

FIPS

State 

Facility 

Identifier

Reported 

2009 SO2

Emissions 

(tons)

Reported 

2010 SO2

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

New 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 Corporation –

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 due 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 Emissions Change of > ± 20% from the Previous Year

State County 

FIPS

State 

Facility 

Identifier

Reported 

2009 SO2

Emissions 

(tons)

Reported 

2010 SO2

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 

outages 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 Emissions Change of > ± 20% from the Previous Year

State County 

FIPS

State 

Facility 

Identifier

Reported 

2009 SO2

Emissions 

(tons)

Reported 

2010 SO2

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 

changed 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 tieins; had a shutdown in 

2009 (requires full 

plant 

depressurization); 

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 tieins; had a shutdown in 

2009 (requires full 

plant 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-fired 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 Emissions Change of > ± 20% from the Previous Year

State County 

FIPS

State 

Facility 

Identifier

Reported 

2009 SO2

Emissions 

(tons)

Reported 

2010 SO2

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 

Johnston 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 upgrades 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 

in 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 reported 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 dataa.

 

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 emissions 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 SO2, which represents the average 

regional 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 SO2. Therefore, the 

participating states have met the 200,722 tons SO2 milestone. 

8.0 Public Comments

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

2010 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 SO2

Emissions 

(tons)

Adjusted 

2010 SO2 

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 1,336 -

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

(cont.)
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 SO2

Emissions 

(tons)

Adjusted 

2010 SO2 

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 Navajo 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 Southern 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 211112 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 Plant Name

Plant 

SIC

Plant 

NAICS

Reported 

2010 SO2

Emissions 

(tons)

Adjusted 

2010 SO2 

Emissions 

(tons)

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons)

NM 045 350450023 Western Refining 

Southwest Inc./San Juan 

Refinery (Bloomfield) 

[Old name: GIANT 

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 Refinery

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 

Corp. -- 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 SO2

Emissions 

(tons)

Adjusted 

2010 SO2 

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 Midstream 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 10335 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 

-- Neil 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 SO2

Emissions 

(tons)

Adjusted 

2010 SO2 

Emissions 

(tons)

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons)

WY 045 0005 4151 Black Hills Corporation 

-- Osage 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 SO2

Emissions 

(tons)

Adjusted 

2010 SO2 

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 327999 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 Name: 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 Wellfield

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 SO2

Emissions 

(tons)

Adjusted 

2010 SO2 

Emissions 

(tons)

General 

New 

Monitoring 

Calculation 

Method 

Adjustment 

(tons)

WY 001 0002 Mountain Cement 

Company -- 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 Pacificorp -- 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 Company --

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 Wyoming 

-- 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 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 0014 Chevron USA (previously owned 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 

identified 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 III 2010
Appendix B

March 22, 2012

B-2

Table B-2 

Sources Removed from the SO2 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 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

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

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 revisions.**

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 inventory.
Appendix C

March 22, 2012

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 

(SO2) 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/Bernalillo 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 review 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 SO2 milestones and a backstop trading 

program that would be triggered if the milestones were not met in the 3-state region. The 

SO2 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 Annex 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 SO2 milestones for the years 2003, 2008, 2013, and 2018 to ensure 

that SO2 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 the 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 

trading 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 of 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 

milestone.
Appendix C

March 22, 2012

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 States have recently revised their RH SIPs to update the SO2 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 

Partnership (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, 2012

B-5

Potential Changes Between 2010 and 2018

There are a number of national measures that may further reduce SO2 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 SO2 may require reductions from the large 

source of SO2 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 review to evaluate the 

likelihood of meeting the 2018 milestone.