1. SUBCHAPTER 19 APPENDICES C AND G

2. SC 19 Study Where do the numbers come from?Where do the numbers come from? Re-evaluate the basis of the numbers.Re-evaluate the basis of the numbers. How would you come up with the numbers today?How would you come up with the numbers today?

3. APPENDICES C AND G CHRONOLOGICAL HISTORY 1970 – 1970 FEDERAL CAA: SEC. 111 NSPS AND SEC. 112 NESHAP o 1970 – 1970 FEDERAL CAA: SEC. 111 NSPS AND SEC. 112 NESHAP o 1970 – APPENDIX C AND G ADOPTED IN ORIGINAL SIP AS FIGURE 1 AND TABLE 1 RESPECTIVELY o 1971 – NSPS FIRST PROPOSED, INCLUDING STANDARDS FOR STEAM GENERATING UNITS (0.2 LB/MMBTU)

4. o1975 – NSPS FINAL 1. Documentation includes a stack test protocol (1974) and a letter (1976). 2. The sole living developer of the Subchapter 19 appendices has stated that the standards contained in the appendices included both filterable and condensable PM when originally adopted. 3. EPA has confirmed that if the 1970 Oklahoma SIP had excluded back-half, it would not have been approved.

5. APPENDIX C COMPARISON TO OTHER STATES oArkansasNo state standard oColoradoW/O condensables: allowables are about 1/3 of Appendix C oIowa1. Outside any standard metropolitan area = 0.8 Lb/MMBTU 2. Inside a standard metropolitan area = 0.6 Lb/MMBTU

6. 3. New fossil fuel fired steam generating unit: A. (150–250 MMBTUHr = 0.2 Lb/MMbtu B. Less than 150 MMBTUHr = 0.6 Lb/MMBTU 4. Separate allowables for asphalt batch plants, cement kilns, cupolas for metallurgical melting, electric furnaces for mm, sand handling, grain handling, lime kilns, meat smokehouses, phosphate plants, Portland cement batch plants, incinerators and paint and surface coating.

7. oKansasSame as Appendix C oLouisianaW/condensables: 0.6 Lb/MMBTU oMinnesotaTables not available on line oMissouriW/condensables: same as Appendix C oNebraska1. 10 MMBTUHr or less - same as Appendix C 2. Greater than 10 MMBTUHr and less than 10,000 MMBTUHr - slightly higher than Appendix C 3. 10,000 MMBTUHr or more = 0.12 Lb/MMBTU oNew MexicoW/condensables: same as Appendix C

8. o TexasW/condensables: Up to 0.3 Lb/MMBTU for EGUS rated at 2500 MMBTUHr or more (solid fuel fired - 2 hr average) and 0.1Lb/MMBTU for oil or gas fired EGUs

9. APPENDIX G COMPARISON TO OTHER STATES o ArkansasNo state standard o Bay AreaSame as Appendix G o ColoradoW/O condensables: about 73% of Appendix G o IowaSame as Appendix G o Kansas1. Same as Appendix G for feed rates of 60,000 Lb/Hr or less 2. 73% of Appendix G for feed rates greater than 60,000 Lb/Hr

10. o Knox Co., Tenn.1. Existing sources same as Appendix G 2. New sources same as Minnesota o LouisianaSame as Appendix G o Minnesota1. Slightly less than Appendix G up to 60,000 Lb/Hr feed rate 2. Less than Appendix G for 60,000 Lb/Hr feed rate or more o MissouriSame as Appendix G o NebraskaSame as Appendix G

11. oNew MexicoSpecific allowables for each industry. pumice, mica, perlite, non-ferrous smelters, oil-burning equipment, potash, salt, sodium nitrite, lime mfg plants. o South DakotaSame as Appendix G o TexasW/condensables: 1. Less than Appendix G for 5000 Lb/Hr feed rate or less 2. Greater than Appendix G for greater than 5000 Lb/Hr feed rate

14. October AQC Meeting How would you come up with the numbers today?How would you come up with the numbers today? Summary of studySummary of study Recommendation of optionsRecommendation of options