VIA ELECTRONIC MAIL AND FACSIMILE

Louisiana Department of Environmental Quality

Public Participation Group
602 N. 5th St.
Baton Rouge, LA 70802
DEQ.PUBLICNOTICES@LA.GOV
Fax: (225) 219-3309

September 25, 2017

RE: Comments on Proposed Part 70 Air Operating Permit and Prevention of Significant
Deterioration Permit and the Associated Environmental Assessment Statement;
Gulf Coast Methanol Complex, IGP Methanol LLC, Myrtle Grove, Plaquemines
Parish; AI Number 204812, Permit Number PSD-LA-820 and 2240-00452-VO, and
Activity Number PER20170001 and PER20170002

Dear Public Participation Group,

On behalf of Sierra Club and its nearly 3,000 members in Louisiana, including members
who live in the project area, I respectfully submit these comments on Louisiana Department of
Environmental Quality’s (“LDEQ”) Proposed Part 70 Air Operating Permit and Prevention of
Significant Deterioration Permit and the Associated Environmental Assessment Statement for the
Gulf Coast Methanol Complex, IGP Methanol LLC, in Myrtle Grove, Plaquemines Parish, AI
Number 204812, Permit Number PSD-LA-820 and 2240-00452-VO, and Activity Number
PER20170001 and PER20170002. Additionally, Sierra Club submits and incorporates the
technical Comments of Dr. Phyllis Fox, PhD, PE regarding the proposed permit. Ex. A
[hereinafter “Fox Comments”]. Sierra Club further reserves the right to rely on all public
comments submitted, request a written response to comments, and request written notification
when any action is taken on this Draft Permit.

Sierra Club is the nation’s largest grassroots environmental organization and is dedicated
to the protection of the natural environment and public health. Sierra Club has longstanding
interest and expertise in the development and use of natural resources along the Mississippi. Our
members and supporters will be affected by the loss of wetlands in the proposed project area, as
well as degradation of downstream wetlands and the significant air pollution that will result from
the proposed methanol plant—which will be the largest in the world, if approved. For the
reasons discussed below, Sierra Club objects to the proposed permit and urges LDEQ to reject it.

1
 Introduction

LDEQ proposes to grant air permits for the construction and operation of a new methanol
plant in the heart of the Plaquemines Parish on a partial greenfield site on the bank of the
Mississippi River. At 20,000 metric tons per day (“MTPD”) of methanol, it would be four times
the size of the world’s largest methanol plant. The facility is proposed to be located in Myrtle
Grove in Plaquemines Parish, approximately 25 miles southeast of New Orleans. The
communities surrounding the proposed methanol plant are disproportionately lower income,
minority communities, which are already inundated with air and water pollution from nearby
facilities that operate pursuant to LDEQ permits. Indeed, EPA data indicates that the PM2.5, Air
Toxics Cancer Risk, and Respiratory Hazard Index for the people who live within 2 miles from
the front gate of the proposed plant are all above 90 percent for the state. Moreover, the area
immediately surrounding the proposed methanol plant is 93% minority; the nearby cities of
Ironton and Phoenix are 80% and 100% minority, respectively. Moreover, the per capita annual
income for those residents who live within this 2-mile radius is $ 16,843. As a result, an LDEQ
decision to grant the proposed permits would violate EPA environmental justice regulations
because such decision would have “the effect of subjecting [residents of Myrtle Grove, Wood
Park, Ironton, and Phoenix] to discrimination because of their race [or] color” and “the effect of
defeating or substantially impairing accomplishment of the objections of [LDEQ’s air] program
or activity with respect to individuals of a particular race.” 40 C.F.R. § 7.35(b).

Separately, the Environmental Assessment Statement (“EAS”) that IGP Methanol

submitted to support its application is woefully inadequate because it fails to provide the
information necessary for LDEQ to conduct its public trustee review. In particular,

• The EAS fails to identify the potential real and adverse environmental effects of the
proposed project. The proposed site is in the center of the Plaquemines Parish
community. Indeed, hundreds of people live directly next the proposed plant site,
plus there is an active community center located on the fenceline of the proposed
site. Yet IGP Methanol fails to acknowledge that its proposed plant will impact this
community. The EAS summarily concludes that “will be minimal and will not cause
any significant adverse impacts.” LDEQ has the responsibility as public trustee to
consider all adverse impacts on the nearby community, and must analyze the
disproportionate impact of emissions from the proposed plant on the already over-
burdened African-American community.

• The EAS also fails to provide sufficient information about any possible alternative
sites. Instead, IGP Methanol merely asserts that it shopped around and decided to
choose the present site over other undisclosed sites. But LDEQ is required to
determine that there are no alternatives that offer greater protection without unduly
curtailing the non-environmental benefits of the proposed project. LDEQ cannot
outsource this analysis to the applicant and merely accept the applicant’s bare
conclusion. A decision to grant the permits based on the EAS would therefore be
arbitrary and capricious.

2
 • Furthermore, because the EAS fails to identify adverse impacts to the community,
its cost-benefit analysis is lopsided. In fact, the cost-benefit analysis only discusses
benefits.

• The EAS fails to show that IGP Methanol taken any real steps to mitigated the
adverse impacts of its proposed plant on the neighboring community. For instance,
IGP Methanol claims that its site includes buffer areas but it fails to show where the
buffer will be located. It fails to include any site plan that shows where the
proposed plant will be constructed within its site.

• The EAS is also deficient because it fails to consider all cumulative and indirect
impacts of the proposed plant including, but limited to, impacts on climate change
due to the plant’s greenhouse gas emissions and the upstream impacts associated
with the natural gas production to feed the plant. As public trustee, LDEQ must also
analyze these impacts.

• Finally, as explained in the attached technical comments of Dr. Phyllis Fox, PhD,
PE, the Draft Permit, Briefing Sheet, Preliminary Determination Summary,
Statement of Basis, and the February 2017 Application are deficient in numerous
respects. In particular, the permit materials significantly understate emissions and
ozone impacts from the facility. Moreover, the draft permit fails to include
appropriate BACT emission limits and adequate monitoring to ensure compliance
for most emission sources

For these reasons, which are expressed in more detail below, LDEQ should deny the
proposed permits.

I. LDEQ MUST COMPLY WITH FEDERAL CIVIL RIGHTS REGULATIONS

Title VI of the Civil Rights Act of 1964 provides that “[n]o person in the United States
shall, on the ground of race, color, or national origin . . . be subjected to discrimination under
any program or activity receiving Federal financial assistance.” 42 U.S.C. § 2000d (2012).
Acceptance of federal funding and/or assistance from the EPA creates an obligation on the
recipient to comply with EPA’s implementing regulations. See 40 C.F.R. § 7.30. These EPA
regulations prohibit recipients of federal funds, such as LDEQ, from using “criteria or methods
of administering its program or activity which have the effect of subjecting individuals to
discrimination because of their race, color, [or] national origin, . . . or have the effect of
defeating or substantially impairing accomplishment of the objectives of the program or
activity with respect to individuals of a particular race, color, [or] national origin.” 40 C.F.R. §
7.35(b). Because LDEQ receives federal financial assistance from EPA, it must comply with
federal regulations in implementing its air permitting program.

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 A. Adverse impacts from the proposed plant would disproportionally impact the
communities of color.

The communities immediately surrounding the proposed IGP methanol plant are
disproportionately minority and lower income. Myrtle Grove is a rural community of
approximately 254 people, 95 percent of whom are people of color. Wood Park is directly
adjacent to the proposed facility, and has a population that is 80% minority. Phoenix, which is
directly across the Mississippi River, is a 99% African-American. The community of Ironton,
less than two miles away, is 79% minority. See EPA EJScreen Summary Reports for Myrtle
Grove, Wood Park, Ironton, and Phoenix, Ex. B. The proposed plant site borders several
residential streets, creating a fenceline community where minority populations would be forced
to live in the shadow of a chemical plant. See Google Image below. In addition, the proposed
site is less than .75 miles from Phoenix High School, the community’s only high school. Id.

EJScreen1 is EPA’s environmental justice screening and mapping tool that provides
EPA with a nationally consistent dataset and approach for combining environmental and
demographic indicators. The data shows that the community of Myrtle Grove, which is directly
adjacent to proposed facility has a population of 254 people, nearly 95 percent of whom are
African American. See Ex. B. The nearby communities of Ironton and Phoenix are both 99
percent-African American. The per capita income for residents of Ironton and Phoenix is
between $13,007 and $15,425. To put these figures into perspective, the racial makeup of
Plaquemines Parish is approximately 70 percent black, with a per capita annual income of

1
EJScreen available at https://www.epa.gov/ejscreen

4
approximately $24,837.2 The racial composition for the state is approximately 32% black and
63% white. Id. The data thus show that the proposed site for the facility is located within an
area that has a significantly higher African- American population than the parish as a whole or
the state.

EJScreen also demonstrates the relative environmental justice concerns for designated
areas in “EJ Indexes.” Due to the pollution that already inundates Myrtle Grove, Ironton,
Phoenix, and Wood Park, the community is an area of significant environmental justice
concern. For instance, the EJ Indexes for PM2.5, NATA Air Toxics Cancer Risk, and NATA
Respiratory Hazard Index, and Ozone for the people who live within 2 miles from the front gate
of the proposed plant are all above 70 percent for the state.3 The state percentile is the percent
of the state population that has less potential for exposure to PM2.5, less risk of cancer from
toxic air pollution, and less risk of respiratory illnesses. See https://www.epa.gov/ejscreen/how-
interpret-standard-report-ejscreen. The state percentile for These EJScreen Reports also give
percentiles for the EPA Region and the entire United States. See id.

There are already significant documented impacts to public health and environment of the
communities surrounding the proposed IGP plant. Indeed, it has been ranked as one of the
“dirtiest/worst counties in the US” for both NOx and VOC emissions, based on EPA emission
inventories.4 Further, as demonstrated in the attached EJScreen map, the immediately
surrounding the proposed plant is home to dozens of major sources of industrial pollution,
including ozone precursors. Indeed, facilities such as the Phillips 66 refinery, Vertex Refinery,
Enbridge Pipeline, and the adjacent coal export terminal as major sources of pollutants for the
community. As explained in the attached report of Phyllis Fox, marine vessels servicing this
terminal, including those supporting the Project, as well as associated storage tanks and vapor
combustion devices, would emit significant amounts of both NOx and VOC. These existing
facilities, coupled with the high incidence of pollution-related disease in the Parrish, suggest
background ambient ozone and NOx concentrations may be elevated.

Overall, Plaquemines Parish’s population is 23,550. More than 83% of the residents of
this Parish include individuals with higher-than-average risk for air pollution-related illness,
including children and teens (6,296); people 65 and older (2,783); people with asthma (1,835),
chronic bronchitis, or emphysema (1,272); people with cardiovascular disease or diabetes
(3,885); and people with low incomes (3,591).5 The majority of the health conditions afflicting
Parish residents are caused or aggravated by ozone pollution. Permitting yet another major

2
U.S. Census Data for Plaquemines Parish & Louisiana, available at
https://www.census.gov/quickfacts/fact/map/plaqueminesparishlouisiana/INC910215#viewtop
3
See EJScreen Report, Ex. B.
4
Scorecard, The Pollution Information Site; available at http://scorecard.goodguide.com/env-
releases/cap/county.tcl?fips_county_code=22075#ej.
5
American Lung Association, State of the Air 2015, People at Risk; available at
http://www.stateoftheair.org/2015/key-findings/people-at-risk.html and Plaquemines Parish;
available at http://www.stateoftheair.org/2015/states/louisiana/plaquemines-
parish.html?referrer=https://www.google.com/.

5
source of air pollution in the African-American communities of Myrtle Grove, Ironton, Phoenix,
and Wood Park would further exacerbate the disproportionate adverse impacts to those
communities.

B. Purported compliance with NAAQS or other standards does not constitute per
se environmental justice compliance.

LDEQ may try to claim that the emissions allowed by the proposed permit will not
violate NAAQS or other air standards and therefore its decision does not violate EPA’s
environmental justice regulations. But EPA has recognized that “[c]ompliance with
environmental laws does not constitute per se compliance with Title VI.” Draft Title VI
Guidance for EPA Assistance Recipients Administering Environmental Permitting Programs
(Draft Recipient Guidance) and Draft Revised Guidance for Investigation Title VI
Administrative Complaints Challenging Permits (Draft Revised Investigation Guidance), 65 FR
39650-01 (June 27, 2000). EPA explained that “[f]requently, discrimination results from
policies and practices that are neutral on their face, but have the effect of discriminating . . .
[T]here may be instances in which environmental laws do not regulate certain concentrations of
sources, or take into account impacts on some subpopulations which may be disproportionately
present in an affected population.” Id. at 39680.

Additionally, EPA’s most recent environmental justice guidance document eliminates

the rebuttable presumption that compliance with NAAQS shields a federally-funded permitting
authority from being found in violation of Title VI. Draft Policy Papers Environmental Health-
Based Thresholds, and Role of Complainants and Recipients in the Title VI Complaints and
Resolution Process, 78 F.R. 24739 (April 26, 2013).6 The EPA has made clear that it will
consider “the existence of hot spots, cumulative impacts, the presence of particularly sensitive
populations that were not considered in the establishment of the health-based standard,
misapplication of environmental standards, or the existence of site-specific data demonstrating
an adverse impact despite compliance with the health-based threshold.” Id.

There is no doubt that the communities and areas surrounding Myrtle Grove, Wood
Park, Ironton, and Phoenix are hot spots for harmful air emissions that result from the dense
industrial activities that LDEQ has permitted for the area. These permitted emissions have a
cumulative adverse impact that disproportionately affects African- Americans.

II. LDEQ Must Reject the Proposed Permits because the EAS Fails to
Provide the Information Necessary for the Agency to Perform its Public
Trustee Duty.

The Louisiana Environmental Quality Act mandates that “[t]he applicant for a
new permit . . . that would authorize . . . air emissions in sufficient quantity or

6
The EPA recognizes this 2013 draft guidance as its current Title VI policy. See U.S.
Environmental Protection Agency, EPA’s Title VI – Policies, Guidance, Settlements, Laws
and Regulations (Apr 20, 2016), https://www.epa.gov/ocr/epas-title-vi-policies-guidance-
settlements-laws-and-regulations (last visited Sept. 30, 2016).

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concentration to constitute a major source [such as this plant] . . . shall submit an
environmental assessment statement as a part of the permit application.” La. Rev. Stat. §
30:2018(A). The Act further provides that “[t]he environmental assessment statement . . .
shall be used [by LDEQ] to satisfy the public trustee requirements of Article IX, Section
1 of the Constitution of Louisiana.” Id. at 30:2018(B). To satisfy the public trustee
requirements, LDEQ must determine “that adverse environmental impacts have been
minimized or avoided as much as possible consistently with the public welfare” before it
can issue a final permit. Save Ourselves, Inc. v. Louisiana Envtl. Control Comm’n 452
So. 2d 1152, 1157 (interpreting La. Const. Art. IX, § 1) (emphasis added). To make this
determination, LDEQ must issue a written permit decision that satisfactorily answers
whether:

(1) the potential and real adverse environmental effects of the proposed project
have been avoided to the maximum extent possible; (2) a cost-benefit analysis of
the environmental impact costs balanced against the social and economic benefits
of the project demonstrate that the latter outweighs the former; and (3) there are
no alternative projects or alternative sites or mitigating measures which would
offer more protection to the environment than the proposed project without
unduly curtailing non-environmental benefits to the extent applicable.

In re Oil & Gas Exploration, Dev., & Prod. Facilities, Permit No. LAG260000, 2010-1640 (La.
App. 1 Cir. 6/10/11), 70 So. 3d 101, 104. Section 30:2018 specifically requires the permit
applicant to address each of these issues in the EAS that it submits to LDEQ. See La. Rev. Stat.
§ 30:2018(B).

Louisiana’s public trustee duty has been analogized to the federal National
Environmental Policy Act (“NEPA”) and requires comparable environmental review and
analysis.7 As such, IGP Methanol must also consider the indirect and cumulative impacts that
the proposed plant may cause.8 As explained below, IGP Methanol’s EAS fails to fully
address these public trustee issues in a meaningful way—as section 30:2018(B) requires—
and therefore LDEQ cannot rely on this EAS to make its decision.

7
See City Park for Everyone Coalition v. Federal Emergency Management Agency, No. 15-
918, 2015 WL 6669666 (E.D. La., Nov. 2, 2015). (“It is true that there are similarities
between NEPA environmental review and the analysis that Louisiana law requires as public
trustees.”)
8
See Medina County Environmental Action Ass'n v. Surface Transp. Bd., 602 F.3d 687, 695
(C.A.5,2010) (“[T]o comply with NEPA, an agency must consider, among other things, the
‘cumulative impacts’ of the proposed action”); see also, Gulf Restoration Network v. U.S. Dept.
of Trans., 452 F.3d 362 (5th Cir. 2006) (“[Environmental] [i]mpacts include ‘ecological …
aesthetic, historic, cultural, economic, social, or health, whether direct, indirect, or
cumulative.’(citing 40 C.F.R. § 1508.8)); see also, O’Relly v. U.S. Army Corps of Engineers, 477
F.3d 225, 234-35 (5th Cir. 2007).

7
 A. The EAS fails to identify “the potential and real adverse environmental effects of
the proposed project”

1. The EAS fails to disclose disproportionate impacts on the residents of

Plaquemines Parish.

To fulfill its public trustee duty, LDEQ must determine that “the potential and real
adverse environmental effects of the proposed project have been avoided to the maximum
extent possible.” In re Oil & Gas Exploration, 70 So. 3d at 104. But the EAS fails to identify
the potential and real adverse environmental effects of the proposed project so LDEQ cannot
rely on the EAS to provide the information necessary for it to fulfill its public trustee analysis.
In particular, IGP Methanol merely describes the area as “industrial area” and notes some
existing residential areas. EAS at 11. But as discussed in Section I.A above and as shown in
IGP Methanol’s site plan and the Google Maps image below, the proposed plant site borders a
residential community, and is only within 2 miles of the communities of Myrtle Grove, Ironton,
and Phoenix.

A comparison of the site plan and the Google Maps image shows that the proposed site
is located directly adjacent to two residential areas. See also Ex. B (providing population data
for the area). Moreover, the EAS fails to mention that the proposed site is less than one mile
from the only high school in the community, which is a gathering center. The plant would,
thus, directly impact residents who use the amenities of the community center, exposing them
to harmful air pollutants and other adverse impacts of the proposed plant. Children who play at
the park would be especially vulnerable to these exposures.

8
 The EAS fails to mention that people who live and recreate in the area will be adversely
impacted by odors, emissions, dust, heavy trucks, noise, light, and other harmful and disruptive
impacts associated with living and recreating next to a major methanol plant. The EAS fails to
mention that the plant would be constructed in the center of a lower-income African-American
community—that hundreds of lower-income African-American people will be forced to live
directly next to the plant. See Section I.A and Ex. B. The EAS fails to mention that the area is
already inundated with air pollution and ranks among the most impacted for exposure to PM2.5.
See id. The EAS also fails to mention that the area has among the highest risk of respiratory
illnesses and cancer from toxic air pollutants. See id. The EAS fails to mention that the proposed
plant will light up the area like a small city and disrupt the residential areas that are normally
dark at night and free of light pollution. The EAS similarly fails to disclose any of the noise
impacts associated with a 20,000 MTPD methanol plant, with regular barge and truck traffic.
Without mentioning any of these impacts, IGP Methanol summarily concludes that “there will be
a net social benefit to the community in and around the proposed IGPM facility.” EAS at 11.

IGP Methanol claims that “[n]umerous environmental professionals have surveyed or

will survey the site for various environmental resources (air, water, noise, threatened and
endangered species, cultural resources, wetlands, etc.),” EAS at 2, but the Company has failed to
provide any of those surveys or disclose the potential impacts. Moreover, IGP Methanol failed
to provide any information about how it plans to conduct those studies. LDEQ cannot blindly
accept the Company’s promise to conduct studies or its conclusory assertions that the impacts of
the proposed plant on air, water, noise, and light pollution will be minimal. Instead, those
studies must be made part of the record so that LDEQ and the public can review and comment on
it. Without including those documents in the record, neither the public nor LDEQ can
meaningfully evaluate the environmental impacts of the proposed plant, and it would be arbitrary
and capricious to approve the permit without those documents.

Furthermore, the EAS fails to include human health risks associated with emissions
from the proposed plant even though the plant is a major source of hazardous air pollutants and
these pollutants will travel offsite and will impact the fenceline community, which is already
inundated with air pollution. Instead, IGP Methanol merely asserts that it will comply with
National Emission Standards for Hazardous Air Pollutants. But notwithstanding any promise to
comply with these standards, the pollutants will still adversely impact the surrounding area.
The community will still suffer from exposure to these pollutants—especially in combination
with the pollutants that already impact the area.

LDEQ must consider these impacts associated with the proposed plant’s emissions. The
plant will emit the following hazardous air pollutants in tons per year:

LAC 33:III.Chapter 51 Regulated Toxic Air Pollutants (TAP)

Pollutant Emissions
Acetaldehyde 0.25
Acrolein 0.154
Benzene 0.02
Formaldehyde 2.01

9
 n-Hexane 1.46
Methanol 140.45
Toluene 0.03
Xylenes 0.01
NH3 43.48
Totals 187.854

Adverse health effects are associated with all of the pollutants the facility will emit, such
as methanol, n-hexane, and formaldehyde. See EPA Fact Sheets on Hazardous Air Pollutants
(describing harmful human health effects for acetaldehyde, benzene, dichlorobenzene,
formaldehyde, methanol, n-hexane, naphthalene, and toluene). The proposed IGP Methanol
plant is also estimated to emit significant quantities of ammonia per year.9 The health effects of
inhaling airborne ammonia at levels exceeding naturally-occurring levels include irritation and
serious burns in the mouth, lungs, and eyes, increased risk of respiratory irritation, coughing,
wheezing, and tightness in the chest, and impaired lung function.

IGP Methanol concludes that the “social and economic benefits of the proposed facility
greatly outweigh its environmental impact” EAS at 10. This conclusory assertion conclusion,
however, is flatly inconsistent with the fact that the lower-income and predominately African-
American communities surrounding the facility area already over-burdened with air pollution
and water pollution; adding to this pollution only exacerbates this burden. See Section I.A supra.
IGP Methanol’s conclusion ignores the fact that the potential adverse health impacts of the
proposed plant will have a disproportionately adverse impact on African-Americans. LDEQ
cannot ignore this fact. Indeed, the agency must examine the disparate impact of the added
pollution to this African-American community in order to fully examine the social costs of the
proposed plant. LDEQ must conduct a disparate impact analysis before it can issue a decision on
the proposed permits. LDEQ must consider less discriminating alternatives and may not issue
these permits if less discriminating alternatives exist.

LDEQ must reject the proposed permit because IGP Methanol failed to identify impacts
that the proposed plant will have on the residents of neighboring communities. LDEQ cannot
fulfill its public trustee duty by relying on this deficient EAS.

2. The proposed methanol facility is in a “Flood Plain” zoning district, and

may be prohibited under Plaquemines Parish zoning regulations.

IGP Methanol does not provide information in EAS related to zoning, and Plaquemines
Parish zoning laws may prohibit the proposed methanol facility site in Myrtle Grove if it is in the
flood plain zone. The site of IGP Methanol’s proposed coal facility may conflict with wetlands
within the Flood Plain Zoning district. For instance, Parish zoning laws provide that “no building
or land shall...be used or occupied...unless in conformity with the regulations herein specified for

9
The total ammonia emissions are unclear, as the proposed permit does not include a plant-wide
emission limit.

10
the district in which it is located.” Plaquemines Parish, La., Code of Ordinances, Zoning, app. B
§ V.1 (2012). That ordinance also limits the Flood Plain zoning district to fourteen uses, none of
which includes use as a methanol production facility, unless Plaquemines Parish Council
explicitly approves such use. Id. § L.2. There is no evidence that the Council has given this
approval to IGP Methanol. Moreover, Parish zoning ordinances require that “environmental
impact uses,” which include activities with “accompanying hazards, such as fire, explosion,
noise, vibration, dust or emission of smoke, odors or toxic gases, or other hazards,” require
“special review...and comments from the [Parish] building official and the environment review
committee.” Id. § L.2. The Company has not offered evidence that its coal facility proposal site
has been submitted to the parish building official and environmental review committee for
review and comment. Because the project conflicts with local zoning laws, this application must
be denied.
3. The proposed methanol plant is vulnerable to storm-surge flooding and
rain flood risks.

IGP Methanol’s EAS does not adequately address the risk of storm surge flooding from
the Gulf of Mexico, or provide sufficient detail for any emergency plans. This is especially
troubling in the wake of Hurricane Harvey’s impacts to Texas, as well as the fact that the nearby
United Bulk and IMT coal terminals were both inundated during Hurricane Isaac, flooding the
surrounding environment with contaminated water. A similar storm surge presents high risks for
pollution and the surrounding community because floodwater can inundate the facility and cause
methanol spills or fires due to flammable gases. Toxic gases and spills can then flow back into
the surrounding environment through the breaches, carrying harmful contaminants including
heavy metals such as arsenic, mercury, and lead into the Mississippi River and the surrounding
community.

The EAS addresses these issues in a cursory manner, and does not provide sufficient
detail outlining the Company’s emergency preparation plan. As noted, it is simply not sufficient
for IGP Methanol to note that it is “currently in discussions” to emergency response measures,
and to defer this critical emergency planning to another date. EAS at 6. Instead, the Company
must provide the public and LDEQ with a detailed hurricane preparedness and response plan
before the permit is issued. This plan must address both prevention and response strategies for
heavy rain, storm-surge flooding, and possible power outages, including a plan to capture and
treat floodwater before it is discharged from the facility.

4. The EAS does not address increased barge traffic.

The EAS does not disclose or address the significant increase in barge traffic, which
could have at least two significant impacts. First, the increased traffic increases the risk of barge
groundings and spills in the Mississippi River, which increases the likelihood of collisions and
greater potential for release of methanol or other toxic and harmful substances into the water.
Vessel strikes should also be mitigated to the maximum extent practicable by requiring
mitigation measures and best available technologies. The likelihood of vessel strikes will
increase with the increased barge traffic, and when the diversion channel is open, funneling
water at high rates of speed.

11
 Second, the EAS fails to address or disclose the air quality impacts caused by increased
vessel traffic. As noted in the attached Fox Comments, the EAS failed to include an analysis of
the air impacts caused by the construction and operation emissions from new support equipment,
including the natural gas pipeline spur (emissions from compressor, valves, connectors), the
ASU required to supply oxygen,10 or marine vessels and marine support equipment that will
export the methanol. Marine vessels are typically a major source of NOx, VOCs, and diesel
particulate matter (DPM). If foreign oils are burned in the marine vessel boilers, they can also be
major sources of lead and SO2.

Diesel exhaust, emitted by construction equipment, ships, and Port support equipment,
contains over 40 toxic substances. In 1998, the California Air Resources Board (CARB)
formally identified the particulate fraction of diesel exhaust as a toxic air contaminant and
concluded that exposure to diesel exhaust particulate matter causes cancer and acute respiratory
effects.11 The EPA followed suit in 2002 and determined that diesel exhaust is a probable human
carcinogen.12 Diesel exhaust is estimated to contribute to more than 70% of the added cancer risk
from air toxics in the United States.13 Today, numerous regulatory and public health agencies,
including CARB, EPA, and the World Health Organization14 have classified DPM as a
carcinogen.15 The air quality analysis and the EAS failed to convert DPM and other toxic air
contaminant (TAC) emissions that it identified and quantified into health risks to the impacted
community, an egregious omission. This analysis is known as a “health risk assessment” or

10
Public Notice Document, pdf 459.
11
California Air Resources Board, Initial Statement of Reasons for Rulemaking, Proposed
Identification of Diesel Exhaust as a Toxic Air Contaminant, Staff Report, June 1998; available
at https://www.arb.ca.gov/regact/diesltac/diesltac.htm.
12
U.S. EPA, Health Assessment for Diesel Engine Exhaust, Report EPA/600/8-90/057F, May
2002; available at
https://nepis.epa.gov/Exe/ZyNET.exe/300055PV.TXT?ZyActionD=ZyDocument&Client=EPA
&Index=1986+Thru+1990&Docs=&Query=&Time=&EndTime=&SearchMethod=1&TocRestri
ct=n&Toc=&TocEntry=&QField=&QFieldYear=&QFieldMonth=&QFieldDay=&IntQFieldOp
=0&ExtQFieldOp=0&XmlQuery=&File=D%3A%5Czyfiles%5CIndex%20Data%5C86thru90%
5CTxt%5C00000006%5C300055PV.txt&User=ANONYMOUS&Password=anonymous&SortM
ethod=h%7C-
&MaximumDocuments=1&FuzzyDegree=0&ImageQuality=r75g8/r75g8/x150y150g16/i425&D
isplay=hpfr&DefSeekPage=x&SearchBack=ZyActionL&Back=ZyActionS&BackDesc=Results
%20page&MaximumPages=1&ZyEntry=1&SeekPage=x&ZyPURL#.
13
Environmental Defense Fund, Cleaner Diesel Handbook, Bring Cleaner Fuel and Diesel
Retrofits into Your Neighborhood, April 2005; available at
http://www.edf.org/sites/default/files/4941_cleanerdieselhandbook.pdf.
14
International Agency for Research on Cancer, IARC: Diesel Engine Exhaust Carcinogenic,
Press Release No. 213, June 12, 2012; available at https://www.iarc.fr/en/media-
centre/pr/2012/pdfs/pr213_E.pdf.
15
Port of Long Beach, Port of Long Beach Community Impact Study, July 2016; available at
http://www.polb.com/civica/filebank/blobdload.asp?BlobID=13319.

12
HRA.16 The EAS does not contain a HRA for diesel exhaust or any other TAP(s). Thus, the
analysis has significantly underestimated air quality impacts.

5. The methanol plant abuts the planned diversion and the proposed facility
includes ship and barge docks on the Mississippi River, it is subject to the
Guidelines for Shoreline Modification.

Under La. Admin. Code. tit. 43, pt I Section 709, shoreline modification structures should
be designed and built using best practicable techniques to minimize adverse environmental
impacts; docks specifically should be designed and built using best practical techniques to avoid
obstruction of water circulation; and structures should be designed and constructed to avoid to
the maximum extent practicable downstream land loss and erosion. The diversion project will
result in changes to water circulation and the ship and barge docks will interfere with erosion by
blocking sediment transfers to the Barataria Bay estuary. IGP Methanol’s EAS does not
disclose, let alone meaningfully address, the shoreline modifications associated with the
construction of this plant along with the associated infrastructure.

In assessing the proposed permit, LDEQ must evaluate whether the application is being
made is consistent with the state’s master plan for integrated coastal protection. See, e.g., LA
R.S. 49:214.30 (A)(2). Furthermore, LDEQ must also conduct an appropriate balancing of
social, environmental and economic factors in deciding whether to grant the permit. La. R.S.
49:214.30 (C)(3). The balancing of social, environmental, and economic factors clearly do not
weigh in favor of environmental considerations. The proposed coal facility will be located in
nearly the same location as the placement for the diversion project. The CPRA considers the
diversion project to be a solution to the following problems affecting coastal Louisiana:

1. Decreased fresh water, sediment and nutrient inputs;

2. Hydrologic modifications;
3. Saltwater intrusion;
4. Wetland loss;
5. Bank erosion;
6. Altered circulation and water quality.

The diversion’s long-term goals are to restore and enhance nearly 20,000 acres of
wetlands that have been eroding over the years. The state’s Comprehensive Plan notes these
wetlands are essential to contributing to a sustainable ecosystem and reliable flood protection.

In addition, Louisiana Governor Bobby Jindal issued Executive Order No. NJ 2008-7 in
conjunction with the state’s approved Master Plan. (See http://www.gov.state.law.us/assets/docs/
OfficialDocuments2008E07SustainableCoast.pdf.) This Executive Order requires that all state
agencies:

16
Rajiv Bhatia, Health Impact Assessment, A Guide for Practice, 2011; available at
http://www.pewtrusts.org/~/media/assets/2011/.../bhatia_2011_hia_guide_for_practice.pdf.

13
 “Administer their regulatory practices, programs, contracts, grants, and all other
functions vested in them in a manner consistent with the Master Plan and public
interest to the maximum extent practicable.”

The Master Plan emphasizes the importance of wetlands as a fundamental part of the
hurricane protection system and states that wetlands within the hurricane protection system
“need to remain intact and undeveloped.” Further, the Master Plan also requires minimization of
impediments to water flow. The construction in the path of this diversion project will result in
adverse consequences to the effectiveness of the diversion project. The objects and structures
permanent fixture at this point in the river will serve an impediment to the water diversion’s flow
and circulation.

IGP Methanol provided no information analyzing the proposed methanol plant’s potential
impacts on the Mississippi River, the surrounding wetlands, and the proposed Myrtle Grove
diversion project, particularly analyzing how its operations will affect the intended sediment
transport. The EAS must assess the extent to which the facility will impede or disrupt the water
flow in the Mississippi River and the diversion project and avoid these impacts to the maximum
extent practicable.

B. The EAS fails to consider cumulative and indirect environmental effects of the
proposed plant

1. The EAS fails to consider the environmental costs associated with

greenhouse gas emissions.

According to IGP Methanol, it expects its proposed plant to emit 2,533,377 tons per year
of GHG CO2e. Air Permit Briefing Sheet at 1 May 2, 2017). Though this is a significant
amount of GHG emissions that will have environmental costs, IGP Methanol failed to discuss
these costs in its EAS.

In particular, the EAS fails to discuss the fact that the GHG emissions associated with the
plant would contribute to human-caused climate warming. Scientists have studied climate
records and have determined that “natural causes do not explain most observed warming,
especially warming since the mid-20th century.”17 “Since the Industrial Revolution began around
1750, human activities have contributed substantially to climate change by adding CO2 and other
heat-trapping gases to the atmosphere. These greenhouse gas emissions have increased the
greenhouse effect and caused Earth’s surface temperature to rise.” Id. But despite the known
effect of GHG emissions on climate warming, the EAS fails to address the impact of the GHG
emissions of the proposed plant on the climate and the resulting adverse impacts caused by

17
U.S. EPA, Causes of Climate Change, available at https://www.epa.gov/climate-change-
science/causes- climate-change#ref2 (citing IPCC (2013). Climate Change 2013: The Physical
Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the
Intergovernmental Panel on Climate Change [Stocker, T.F., D. Qin, G.-K. Plattner, M. Tignor,
S.K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. Cambridge
University Press, Cambridge, United Kingdom and New York, NY, USA).

14
warming temperatures, such as sea level rise and associated human displacement, extreme
weather events, increased ambient temperatures, altered precipitation patterns, ocean
acidification, and loss of habitat and species.18

GHG impacts on climate change are particularly relevant to Louisiana. “Between 1932
and 2010, Louisiana’s coast lost more than 1,800 square miles of land. From 2004 through 2008
alone, more than 300 square miles of marshland were lost to Hurricanes Katrina, Rita, Gustav,
and Ike.” Louisiana’s Comprehensive Master Plan for a Sustainable Coast (“Master Plan”),
2017, ES-2.19 Indeed, the State’s Master Plan blames this land loss on “the effects of climate
change” among other reasons. See id. Furthermore, according to a team of scientists from the
National Oceanic & Atmospheric Administration and scientists with World Weather Attribution,
“[h]uman-caused climate warming increased the chances of the torrential rains that unleashed
devastating floods in south Louisiana in mid August [2016] by at least 40 percent. 20 Other
significant impacts of climate change in Louisiana that the EAS fails to consider include, among
others, the intensification of tropical storms and hurricanes, threats to the sustainability of current
agricultural and fishery practices, and the negative economic impacts of such impacts (such as
inducing individuals moving away from the state and increased flood insurance rates).21

LDEQ must consider the social costs of the proposed plant’s GHG emissions in its “IT
Analysis” as part of its public trust duty. Indeed, there are several sources concluding that
carbon has a high social cost. A recent study found that the social cost of carbon ranges from $28
up to $893 per ton of CO2.22 EPA recently revised its estimated social cost of carbon to $40 in
2015 and increasing up to $76 by 2050.23

18
See http://nca2014.globalchange.gov/highlights/overview/overview;
http://www.ucsusa.org/our- work/global-warming/science-and-impacts/global-warming-
impacts#.WBOP5_krKM8; http://climate.nasa.gov/causes/;
http://climate.nasa.gov/effects/.

19
http://coastal.la.gov/wp-content/uploads/2016/08/2017-MP-Book_2-page-
spread_Combined_01.05.2017.pdf
20
NOAA News & Features, Sept. 7, 2016, http://www.noaa.gov/media-release/climate-change-
increased- chances-of-record-rains-in-louisiana-by-at-least-40-percent.
21
See https://www.epa.gov/sites/production/files/2016-09/documents/climate-change-la.pdf
(discussing the impacts of climate change on Louisiana).
22
Ackerman, Climate Risks and Carbon Prices: Revising the Social Cost of Carbon, p. 2.
Available at: http://www.sei-international.org/mediamanager/documents/Publications/Climate-
mitigation- adaptation/Economics_of_climate_policy/sei-climate-risks-carbon-prices-2011-
full.pdf.
23
Assuming a 3% discount rate. See
http://www.epa.gov/climatechange/EPAactivities/economics/scc.html. The social cost of carbon
is a simple tool that is easy for LDEQ to use and easy for the public to understand. Putting a
dollar figure on each ton of CO2 emitted as a result of a state project places climate impacts in a
context that both decision makers and the public can readily comprehend. It is backed by years

15
 Additionally, given the similarities between LDEQ’s public trustee obligation and the
federal NEPA analysis, NEPA regulations are instructive of the kind of analysis LDEQ should
be conducting. In particular, NEPA regulations mandate that federal agencies, “shall discuss any
inconsistency of a proposed action with any approved State or local plan and laws (whether or
not federally sanctioned),” 40 C.F.R. § 1506.2(d), and require agencies to address “possible
conflicts between the proposed action and the objectives of Federal, regional, State, and local
(and in the case of a reservation, Indian tribe) land use plans, policies and controls for the area
concerned.” 40 C.F.R. § 1502.16(c). This requires agencies to “discuss relevant approved
federal, regional, state, tribal, or local plans, policies, or laws for GHG emission reductions or
climate adaptation to make clear whether a proposed project’s GHG emissions are consistent
with such plans or laws.” See, e.g., CEQ Climate Guidance at 28-29.

In order to take the hard look at this issue as the public trustee obligation requires, LDEQ
must acknowledge and address the extent to which the proposed permit conflicts with national or
local emissions reduction goals and international climate commitments. The U.S. has set
ambitious climate reduction targets and established itself as an international leader on protecting
the climate. For example, in December 2015 the international climate summit in Paris produced
an historic agreement establishing the ambitious goal of limiting warming to 1.5 to 2 degrees
Celsius above pre-industrial times, a target that will require ambitious emission reductions
beyond those currently identified.24 The nearby City of New Orleans has adopted a similarly
ambitious climate plan.25 LDEQ must evaluate the GHG impacts of the proposed project to
make an informed and reasoned decision, as required by the public trustee obligation.

2. The EAS fails to consider the environmental effects associated with the
production of natural gas for the operation of the plant.

Additionally, the production of natural gas for supplying the proposed plant would
result in significant environmental impacts that IGP Methanol failed to discuss as real or
potential environmental costs in the EAS. Natural gas production—particularly from sources
such as the shale gas formations that would likely provide the majority of the supply here—is a
significant air pollution source. A subcommittee of the DOE’s Secretary of Energy’s Advisory
Board highlighted “a real risk of serious environmental consequences” resulting from

of peer reviewed scientific and economic research, it is designed to be updated to reflect the most
up-to-date information, and it has already been used by federal agencies in both rulemaking
decisions and project-level reviews under NEPA. Therefore, LDEQ must use the social cost of
carbon to disclose the impacts of the proposed methanol plant pursuant to its public trustee duty.
24
White House, U.S. Leadership and the Historic Paris Agreement to Combat Climate Change
(Dec. 12, 2015), formerly available at https://www.whitehouse.gov/the-press-
office/2015/12/12/us-leadership-and-historic-paris-agreement-combat-climate-change.
25
https://www.nola.gov/nola/media/Climate-Action/Climate-Action-for-a-Resilient-New-
Orleans.pdf.

16
continued expansion of shale gas production.26 In 2014, the National Energy Technology
Laboratory (“NETL”) released several reports detailing the adverse environmental impacts of
natural gas production in general, and of modern hydraulic fracturing in particular.27

Natural gas production is a major source of methane and other greenhouse gases.28
Emissions of methane are particularly concerning because methane from fossil sources is a
greenhouse gas that is 87 times more potent than carbon dioxide on a 20-year timeframe, and
36 times more potent on the 100-year timeframe.29 In addition, gas production is a major source
of non-greenhouse gas air pollution, such as VOCs and HAPs.30 Exposure to such pollutants
can cause eye, nose, and throat irritation, respiratory illnesses, central nervous system damage,
birth defects, cancer, or premature death.31 Additionally, activities related to the production of
natural gas pose a significant threat of contaminating water supply sources.32 These risks to
26
DOE, Secretary of Energy’s Advisory Board, Shale Gas Production Subcommittee Second 90-
Day Report 10 (Nov. 18, 2011); see also DOE, Shale Gas Production Subcommittee, First 90-
Day Report (Aug. 18, 2011).
27
NETL, Environmental Impacts of Unconventional Natural Gas Development and Production,
DOE/NETL-2014/1651 (May 29, 2014), available at
https://www.netl.doe.gov/File%20Library/Research/Oil-
Gas/publications/NG_Literature_Review3_Post.pdf; National Energy Technology Laboratory,
Life Cycle Analysis of Natural Gas Extraction and Power Generation, DOE/NETL- 2014/1646
(May 29, 2014), available at
http://www.netl.doe.gov/File%20Library/Research/Energy%20Analysis/Life%20Cycle%20Anal
ysis/NET L-NG-Power-LCA-29May2014.pdf.
28
See EPA, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 – 2014 (Apr. 15,
2016), https://www3.epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-
2016-Main-Text.pdf.
29
IPCC, Climate Change 2013: Physical Science Basis, Anthropogenic and Natural Radiative
Forcing, 714.
30
See also, US EPA, Natural Gas Extraction - Hydraulic Fracturing,
http://www2.epa.gov/hydraulicfracturing#air.
31
John L. Adgate et al., “Potential Public Health Hazards, Exposures and Health Effects from
Unconventional Natural Gas Development,” Environmental Science and Technology (2014),
available at http://pubs.acs.org/doi/abs/10.1021/es404621d; see, e.g. Lisa M. McKenzie et al.,
“Birth Outcomes and Maternal Residential Proximity to Natural Gas Development in Rural
Colorado,” Environmental Health Perspectives, (2014) at 12, available at
http://ehp.niehs.nih.gov/1306722/.
32
NETL, Environmental Impacts of Unconventional Natural Gas Development and
Production, DOE/NETL-2014/1651 (May 29, 2014), at PDF 83-93 available at
https://www.netl.doe.gov/File%20Library/Research/Oil-
Gas/publications/NG_Literature_Review3_Post.pdf; Tom Myers, Potential Contaminant
Pathways from Hydraulically Fractured Shale to Aquifers (Apr. 17, 2012) available at
https://yosemite.epa.gov/oa/eabwebdocket.n sf/fi lings%20 bv %20a ppea l %1 0number/7cfc6
0bdd71 9e52085257cd 300673d 3a/$ file/attachment%20J7%20contaminant...I.17.pdf

17
water quality result from various impacts accompanying natural gas production, including
the erosion from ground disturbances, spills and releases of chemical and other fluids, and
underground migration of gasses and chemicals. Such activities pose a direct risk of
contamination for both surface and underground water supplies.

LDEQ must analyze these environmental costs as part of its public trustee analysis of the
potential indirect and cumulative adverse impacts associated with the production of natural gas
to feed the proposed plant.

C. The EAS fails to provide any information as to whether there are alternatives sites
that would offer greater environmental protections.

IGP Methanol must also provide information in its EAS that would allow LDEQ to
determine that “there are no alternative projects or alternative sites or mitigating measures
which would offer more protection to the environment than the proposed project without
unduly curtailing non-environmental benefits to the extent applicable.” In re Oil & Gas
Exploration, 809 So. 2d at 238. But the EAS fails to make this showing. Instead, IGP Methanol
summarily concludes that there are no alternative sites without providing any evidence or facts
about the potential alternatives sites.

IGP Methanol asserts that it evaluated a handful of sites in three states (one in Texas,
three in Mississippi, and three in Louisiana) based site screening criteria (some of which it lists
but without specificity). Ultimately, IGP Methanol selected the Myrtle Grove site based on
several factors, including existing infrastructure and proximity to shipping channels. But an
alternatives analysis must detail all search criteria and provide a description of the sites
evaluated. The information must be in the record for public comment. The information must
provide the characteristics of each potential alternative site so that LDEQ can evaluate whether
IGP Methanol has made a showing that are no alternative sites that would offer greater
environmental protections.

Here, IGP Methanol included only a sparse discussion (in some cases, a sentence) of
the alternatives considered. There is no meaningful discussion, for example, of the attributes
of alternative sites in Mexico or elsewhere in the Gulf Region. Because IGP Methanol failed
to provide information about the other sites that it considered and “graded,” LDEQ must reject
the proposed permits. LDEQ cannot blindly accept IGP Methanol’s conclusions. LDEQ’s
“role as the representative of the public interest does not permit it to act as an umpire passively
calling balls and strikes…the rights of the public must receive active and affirmative
protection.” Save Ourselves, Inc. v. Louisiana Envtl. Control Comm'n, 452 So. 2d 1152, 1157
(La. 1984) (interpreting La. Const. Art. IX, § 1) (emphasis added). Indeed, any decision that
LDEQ would make based on this EAS would violate its public trustee duty.

18
 D. The EAS fails to show that IGP Methanol has mitigated the impacts of the
emissions from the proposed plant on the community.

Before it can grant the permit, LDEQ must conclude that “there are no . . . mitigating
measures which would offer more protection to the environmental that the proposed project
without unduly curtailing non-environmental benefits to the extent possible.” In re Oil & Gas
Exploration, 70 So. 3d at 104. But the EAS fails to show that IGP Methanol has mitigated the
impacts of its proposed plant on the neighboring community.

Despite its location amidst a community, IGP Methanol fails entirely to demonstrate
how it will lessen the burden of its air emissions, noise, and light on area residents. The
Company only states that “[c]ompensatory mitigation for wetland and coastal resource impacts
will be mitigated using an approved mitigation bank or an approved permittee responsible
mitigation plan,” EAS at 3, but it wholly fails to provide any details about such a plan. There is
no information in the record, for example, about how many acres of wetland forest will be lost,
how many will be mitigated, or where. LDEQ cannot simply accept IGP Methanol’s good
intentions. IGP Methanol’s promise to conduct wetlands mitigation is meaningless without a
site plan that shows the location of the lost wetlands and the mitigation. LDEQ must reject the
draft permits and require IGP Methanol to submit a revised EAS with a site plan that details the
location of its plant, the lost wetlands, and the mitigation areas. LDEQ and the public must be
given a chance to review and comment on this new information.

The remainder of IGP Methanol’s mitigation analysis is similarly inadequate. The

Company asserts without any support in the record that “[th]ere are no mitigating measures
which would offer more protection to the environment than the facility as proposed without
unduly curtailing non-environmental benefits.” EAS at 12. IGP Methanol then provides a
laundry list of pullet points purporting to demonstrate that no other mitigation exists. Again,
this is a bare conclusion without any support.

It is simply not possible for LDEQ or the public to determine whether IGP Methanol has
taken appropriate measures to minimize air, water, light, and noise pollution from the proposed
plant because the Company failed to address the possibility of mitigation for any of those issues.
Indeed, the EAS fails to mention anything about measures to mitigate the light or noise pollution,
and simply suggests that there will be surveys conducted to address those issues. But IGP
Methanol cannot wait until it has already received a permit to address mitigation; there must be
an enforceable commitment to take such measures now to ensure that there are no significant
impacts.

In fact, IGP Methanol all but concedes that it has not conducted a full analysis of
potential mitigation measures. The Company notes that it will “hold a series of neighborhood
meetings throughout Plaquemines Parish in order to address any concerns that residents may
have regarding the construction and operation of the facility.” EAS at 11. This promise to hold
meetings after the permit has already been issued cannot substitute for a meaningful
environmental assessment. LDEQ cannot defer or abdicate its public trust duties by allowing IGP
Methanol to kick the can down the road to some undefined time at which the Company will
listen to concerns of the surrounding community. And it would be arbitrary and capricious for

19
LDEQ to approve a permit for the largest methanol plant in the world without an understanding
of the environmental impacts of the project.

Finally, in accordance with the Louisiana Coastal Restoration Plan and in light of the
significant greenhouse gas and wetlands impacts from the proposed methanol project, LDEQ
must require IGP Methanol to evaluate structure and nonstructural climate adaptation measures
as part of its contingency planning. As noted, in fulfilling its public trustee obligation, LDEQ
must administer its “regulatory practices, programs, contracts, grants, and all other functions
vested in them in a manner consistent with the Master Plan and public interest to the maximum
extent practicable.”33 The Master Plan emphasizes the importance of wetlands as a fundamental
part of the hurricane protection system and states that wetlands within the hurricane protection
system “need to remain intact and undeveloped.” Further, the Master Plan also emphasizes the
importance of structural and nonstructural planning to reduce storm-surge and flood-based risk
across coastal Louisiana. Nonstructural projects are distinct from structural projects in that they
reduce risk to the existing building inventory through means of floodproofing, elevating, or
acquiring structures. The program focuses on conducting a refined coastal flood risk
vulnerability analysis, defining nonstructural project areas, prioritizing projects, and facilitating
the implementation of projects. The program also encourages flood risk awareness and supports
state and local policies that promote greater resilience across the coast. IGP Methanol’s EAS is
devoid of any discussion of such climate adaptation and resilience planning. Given the flood and
climate vulnerability of the community surrounding the proposed plant, LDEQ cannot approve
the proposed permit.

E. The lopsided cost-benefits analysis fails to include environmental costs.

LDEQ’s analysis “requires a balancing process in which environmental costs and

benefits must be given full and careful consideration along with economic, social and other
factors.” Save Ourselves, Inc. v. Louisiana Envtl. Control Comm'n, 452 So. 2d 1152, 1157 (La.
1984). But IGP Methanol’s cost-benefit analysis only discusses alleged economic and other
benefits without detailing environmental costs. The EAS summarily concludes that “there are
no long-term adverse impacts anticipated.” EAS at 10. The Company arrived at these
conclusions without considering adverse impacts. LDEQ must therefore reject the permit
because IGP Methanol failed to provide the information that would allow the agency to fully
consider and articulate the real and potential environmental costs of the proposed plant and
balance such costs against the alleged economic and social benefits.

It is true that “[h]arm to the environment cannot always be quantified as easily as the
economic benefits derived from taxes and salaries.” In re Dravo Basic Materials Co., Inc., 604
So.2d 630,636 (La. App. 1 Cir., 1992). But a cost-benefit analysis that circumvents a discussion
of the costs because they are difficult to ascertain is one that is facially inadequate. IGP
Methanol must fully consider and articulate the real and potential environmental costs such that
they can be reasonably balanced with the economic and social benefits by LDEQ in its
“analysis.” Mitigative measures do not erase the adverse effects of the proposed plant on the
community.

33
See http://www.gov.state.law.us/assets/docs/ OfficialDocuments2008E07SustainableCoast.pdf.

20
 IGP Methanol concludes that the “social and economic benefits of the proposed facility
greatly outweigh its environmental impact.” EAS at 10. This conclusion, however, ignores the
fact that the potential adverse health impacts of the proposed plant will have a disproportionately
adverse impact on African-Americans—a fact that LDEQ cannot simply ignore. Contrary to IGP
Methanol’s conclusory assertions, the agency has an independent obligation to examine the
disparate impact of the added pollution to this African-American community in order to fully
examine the social costs of the proposed plant.

Conclusion

For these reasons, and for the reasons discussed more fully in the Comments of Dr. Fox,
Sierra Club respectfully requests that LDEQ reject the modified permit.

Sincerely,

Joshua Smith
Staff Attorney
Sierra Club
2101 Webster St., Suite 1300
Oakland, CA 94612
(415)977-5560
joshua.smith@sierraclub.org

21
22
 Comments

on

Draft Permit PSD-LA-820

for the

Gulf Coast Methanol Complex

Plaquemines Parish
Louisiana

September 26, 2017

Phyllis Fox, PhD, PE

745 White Pine Ave.
Rockledge, FL 32955
 IGP Methanol LLC (IGP or the Applicant) requested a Part 70 Air Operating
Permit and a Prevention of Significant Deterioration (PSD) permit to construct and
operate the Gulf Coast Methanol Complex (the Project or Facility), near Myrtle Grove,
in Plaquemines Parish, Louisiana to produce methanol to export by marine vessels,
reportedly large Panamax vessels1. The Project consists of four identical 5,000 metric
ton per day methanol production units located on a 100-acre parcel within the Kinder
Morgan Inc., International Marine Terminal (IMT). The Facility will produce methanol
from natural gas, water, and oxygen feedstocks using the autothermal reforming (ATR)
process. The pure methanol is sent to tanks and transferred to the Kinder Morgan
vessel loading facilities for shipment.2

The Facility is a major source of criteria pollutants and was reviewed under the
Louisiana Department of Environmental Quality (LDEQ) PSD regulations at LAC
33:III.509.B. The facility is also a major source of Toxic Air Pollutants (TAPs) pursuant
to LAC 333:III, Chapter 51.3 The LDEQ has proposed Permit PSD-LA-820 (Permit).4

My review of the materials included in the Public Notice Document, including

the Draft Permit, Briefing Sheet, Preliminary Determination Summary, Statement of
Basis, and the 2/17 Application, indicate significant errors and omissions that must be
corrected before the draft permit is issued. These include:

 VOC emissions from the tanks were significantly underestimated.

Corrected emissions result in significant ozone impacts.
 The draft permit fails to include BACT emission limits and adequate
monitoring to ensure compliance for most emission sources.
 BACT is not required for greenhouse gas emissions (GHGs) from heaters
and boilers, VOC emissions from the tank scrubbers, and VOC emissions
from fugitive components.

1 Public Notice Document, pdf 470.

2 Public Notice Document, pdf 282: CK Associates, Title V/PSD Initial Air Permit Application,
Gulf Coast Methanol Complex, Plaquemines Parish, Louisiana, IGP Methanol, LLC, February 2017 (2/17
Application).
3 2/17 Application, p. 1.
4Public Notice, Louisiana Department of Environmental Quality (LDEQ) IGP Methanol LLC—
Gulf Coast Methanol Complex, Public Hearing and Request for Public Comment on Proposed Part 70 Air
Operating Permit and Prevention of Significant Deterioration (PSD) Permit & the Associated
Environmental Assessment Statement (EAS), Scheduled Publication Date: August 15, 2017 (Public Notice
Document).

1
  Emission calculations and air quality analyses are inadequately
supported.
 The ambient air quality analysis omitted emissions of VOC, NOx, CO,
SO2, and particulate matter from construction, marine vessels, and
support facilities, including a new natural pipeline and an air separation
unit (ASU), thus underestimating air quality impacts.
 The Project should not be permitted until an air quality monitoring station
is installed and sufficient background air quality data are collected to
inform the air quality analysis.
 The EAS is inadequate because the adverse environmental effects of the
project have not been avoided to the maximum extent possible.
 The EAS is inadequate because it does not include a cost-benefit analysis
or an alternatives analysis.
 The permit cannot be issued as the Applicant’s analysis demonstrates that
the Project will cause or contribute to a significant air quality impact.5

My resume is included in Exhibit 1 to these Comments. I have over 40 years of

experience in the field of environmental engineering. I have M.S. and Ph.D. degrees in
environmental engineering from the University of California at Berkeley. I am a
licensed professional engineer (chemical) in California. I have prepared and reviewed
hundreds of air permit applications, including for methanol plants in Louisiana, Texas,
and Washington.

1. AIR QUALITY IMPACTS ARE SIGNIFICANT

1.1. The Air Quality Analysis Cannot Be Reviewed as Presented in Publicly

Available Files

The Air Quality Analysis6 information included in publicly disclosed files is a

summary of an air quality analysis, not the analysis itself. The Air Quality Analysis
does not contain sufficient information to allow a subject matter expert, such as myself,
to evaluate whether the analysis is accurate and was performed correctly. The

5 Public Notice Document, pdf 6 (1-hr NOx modeled at 258 ug/m3, compared to the NAAQS of
188.7 ug/m3).
6 CK Associates, Air Quality Analysis in Support of PSD Permit No. PSD-LA-820 and Part 70
Permit No. 2240-00452-V0, IGP Methanol LLC, Plaquemines Parish, Louisiana, May 2017 (5/17 Air
Quality Analysis), pdf 609-692.

2
AERMOD modeling files are required to evaluate the analysis; but these files are
missing from the information provided for public review.

Numerous inputs and assumptions are required to run AERMOD, the model
used to estimate the air quality impacts of the Project. These include background
ambient air quality data; meteorological data, including wind velocity, wind direction,
ambient temperatures, atmospheric stability and mixing height; source characteristics,
including emission rates, stack heights, exit velocities, exit temperatures, and stack
diameters; terrain data; surface characteristics; grid spacing; building and stack
locations and dimensions; urban/rural dispersion coefficient determination; and the
handling of variable wind speeds and calm hours, which are often the controlling
meteorological conditions for National Ambient Air Quality Standards (NAAQSs)
based on 1-hour concentrations. The processing of the meteorological data is critically
important and cannot be assessed without access to the raw meteorological data files.
The missing files are cited as being present in Appendix C to the Air Quality Analysis7
but were not provided for public review.

The maximum modeled concentration, for example, is added to the background

ambient concentration. As there is no air quality monitoring station in Plaquemines
Parish, it is critically important to disclose how the background concentrations were
calculated, supported by the actual monitoring data used in the calculations. The
method used to determine background concentrations and the data used in the
background determination, must be known to assess the accuracy of the maximum
modeled concentration.

For NO2, for example, the background design value could be the overall highest
hourly background concentration, which is the most conservative, or the 98th percentile
of the annual distribution of daily maximum 1-hour values averaged across the most
recent three years of monitored data.8 The Air Quality Analysis is silent on how—and
even if—background was calculated and added to modeled concentrations.

If the above noted information is not provided, the reviewer has to be

sophisticated enough to recreate the information from scratch, which is impossible for

7 Public Notice Document, pdf 688.

8
Memorandum from Tyler Fox to Regional Air Division Directors: Re: Additional Clarification
Regarding Application of Appendix W Modeling Guidance for the 1-hour NO2 National Ambient Air
Quality Standard, March 1, 2011, p. 17; available at https://www.epa.gov/sites/production/files/2015-
07/documents/appwno2_2.pdf.

3
anyone in the 30-day review period and well beyond the reach of the lay reviewer,
regardless of the review time.

1.2. Emissions Are Unsupported

The air quality analysis depends on the magnitude of emissions during Project
operation. The 2/17 Application includes spreadsheets in Appendix A9 that calculate
operational emissions. This appendix contains 30 pages of detailed emission calculation
spreadsheets. This information is contained in pdf versions of formerly live Excel
spreadsheets, which were used to calculate emissions. The Public Notice Document fails
to include the unlocked Excel spreadsheets, thus preventing any meaningful review of
the pdf versions without trial and error re-creation, which is not feasible within the very
short review period.

An unlocked Excel spreadsheet allows a reviewer to click on any cell and inspect
the calculations that were made to yield the result in the cell. Unlocked Excel
spreadsheets are required to review emissions calculations. The pdf versions included
in the 2/17 Application, Appendix A, on the other hand, do not allow inspection of
underlying formulas. Compounding the problem, the pdf spreadsheets are often not
annotated with footnotes that divulge sources and equations used to make the
calculations in the emission tables. Without the unlocked Excel spreadsheets, it is
impossible for anyone, including a subject-matter expert such as myself, to review and
verify the emission calculations without manually replicating the calculations by trial
and error, a tedious process that would take longer than the 30 days allotted to review
the Public Notice Document.

1.3. Ozone Impacts Are Significant

The Project will emit significant amounts of NOx (258.95 ton/yr) and VOCs
(248.51 ton/yr), which in the presence of sunlight in the atmosphere are converted into
ozone. Ozone at ground level is a harmful air pollutant because of its adverse effects on
people and the environment. The public health impacts include:

 making it more difficult to breathe deeply and vigorously;

 causing shortness of breath, and pain when taking a deep breath;
 causing coughing and sore or scratchy throat;
 inflaming and damaging the airways;

9 Public Notice Document, pdf 481.

4
  aggravating lung diseases such as asthma, emphysema, and chronic
bronchitis;
 increasing the frequency of asthma attacks;
 making the lungs more susceptible to infection;
 continuing to damage the lungs even when the symptoms have
disappeared; and
 causing chronic obstructive pulmonary disease (COPD).10
Further, a major new study found evidence that people with lung cancer faced
greater risk from ozone and other outdoor air pollutants. The 2016 study tracked the air
pollution levels from 1988 to 2011 experienced by more than 350,000 cancer patients in
California. The researchers found that the ozone and other air pollutants shortened
their survival.11 In addition, some evidence suggests that other groups, including
women, people who suffer from obesity and people with low incomes, may also face
higher risk from ozone.12 Numerous studies have documented the serious public health
impacts of ozone.

Ozone also affects sensitive vegetation and ecosystems, including forests, parks,
wildlife refuges and wilderness areas. Ozone also can cause significant damage to
vegetation during the growing season.13

Thus, it is critical that the huge increase in ozone precursors that will result from
this Project and its support facilities, which have been significantly underestimated as
explained below, be fully mitigated.

The existing ambient ozone concentrations in the vicinity of the Project site are
unknown as there are no air quality monitoring stations in Plaquemines Parish for any
pollutant, including ozone. Further, the EPA has not determined the ozone attainment
status of Plaquemines Parish for any criteria pollutant, including ozone and its
precursor NOx, as there is no monitor in the Parish.14

10
U.S. EPA, Health Effects of Ozone Pollution; available at https://www.epa.gov/ozone-
pollution/health-effects-ozone-pollution.
11 S. P. Eckel and others, Air Pollution Affects Lung Cancer Survival, Thorax, v. 71, 2016, pp. 891-
898.
12 ALA 2017, p. 33.
13
Ibid.
14 40 CFR 81.319 – Louisiana. See also https://www.gpo.gov/fdsys/pkg/CFR-2013-title40-

vol18/xml/CFR-2013-title40-vol18-sec81-319.xml.

5
 However, others have ranked it as one of the “dirtiest/worst counties in the US”
for both NOx and VOC emissions, based on EPA emission inventories.15 Further, the
immediately surrounding area contains several major sources of ozone precursors,
including a Phillips 66 refinery and the adjacent coal export terminal. Marine vessels
servicing this terminal, including those supporting the Project, as well as associated
storage tanks and vapor combustion devices, would emit significant amounts of both
NOx and VOC. These existing facilities, coupled with the high incidence of pollution-
related disease in the Parrish, suggest background ambient ozone and NOx
concentrations may be elevated.

Plaquemines Parish’s population is 23,550. Over 83% of the residents of this

Parish include individuals with higher-than-average risk for air pollution-related
illness, including children and teens (6,296); people 65 and older (2,783); people with
asthma (1,835), chronic bronchitis, or emphysema (1,272); people with cardiovascular
disease or diabetes (3,885); and people with low incomes (3,591).16 The majority of the
health conditions afflicting Parish residents are caused or aggravated by ozone
pollution. Thus, it is very important to assure that the ozone impacts from the Project
are fully analyzed and disclosed.

The Application includes an air quality impact analysis, which requires

information on background air quality data. As there are no monitoring sites in
Plaquemines Parish, this analysis used background concentrations from other sites, as
follows:17

15 Scorecard, The Pollution Information Site; available at http://scorecard.goodguide.com/env-

releases/cap/county.tcl?fips_county_code=22075#ej.
16 American Lung Association, State of the Air 2015, People at Risk; available at
http://www.stateoftheair.org/2015/key-findings/people-at-risk.html and Plaquemines Parish; available
at http://www.stateoftheair.org/2015/states/louisiana/plaquemines-
parish.html?referrer=https://www.google.com/.
17 Public Notice Document, pdf 577.

6
Background ozone concentrations were based on a monitor at Hahnville, LA.18

Air quality impacts are estimated by adding the increase in each pollutant due to
Project emissions to the background concentration. As there are no monitors in the
Parish, and thus no background data, the first obvious air quality issue is the absence of
an air quality monitoring station in the Parish. With the high incidence of air quality-
related disease and nearby concentration of industry, this Project should not go forward
until a monitoring station is installed and sufficient background air quality data are
collected to inform the air quality analysis.

1.4. VOC Emissions from the Tanks Are Underestimated

The Applicant estimated that the Project would emit 248.51 ton/yr of VOC19 and
the LDEQ did not question this estimate. As demonstrated below, VOC emissions were
significantly underestimated—which, when corrected, results in a significant ozone air
quality impact.

The emission calculations in the 2/17 Application indicate that the tanks emit
75.38 ton/yr of VOCs,20 or 30% of the total VOC. This is a significant underestimate,
based on real-time monitoring of tanks. Many studies have demonstrated that the
method used in the 2/17 Application to estimate tank emissions, the TANKS 4.09d
model based on AP-42 algorithms,21 significantly underestimates them.

Actual measurements of tank emissions using differential absorption lidar

(DIAL)22 compared to those calculated using AP-42 algorithms indicate that AP-42

18 Public Notice Document, pdf 578.

19 Public Notice Document, pdf 1, 4, 70, 73, 80, 81, 88, 92, 95, 106,203, 287, 634.
20 Public Notice Document, pdf 482-483: (4 x 17.36 + 5.18 + 0.76 = 75.38).
21U.S. EPA, Compilation of Air Pollutant Emission Factors (“AP-42”), Chapter 7; available at:
https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-compilation-air-emission-
factors#5thed.
22 LIDAR is a surveying technology that measures distance by illuminating a target with a laser
light. Differential absorption lidar (DIAL) measurements utilize two or more closely spaced (<1 nm)
wavelengths to factor out surface reflectivity as well as other transmission losses, since these factors are
relatively insensitive to wavelength. When tuned to the appropriate absorption lines of a particular gas,
DIAL measurements can be used to determine the concentration (mixing ratio) of that particular gas in
the atmosphere. See Wikipedia, Lidar; available at
https://en.wikipedia.org/wiki/Lidar#Meteorology_and_atmospheric_environment.

7
substantially underestimates VOC and HAP emissions.23 This study demonstrates an
underestimate of VOC emissions by the AP-42 algorithms used in the TANKS program
by a factor of 33.24 Another similar study demonstrated underestimates by factors of 5
to 15, as summarized in Table 1.25

Table 1: Comparison of DIAL Results and

Tank Emissions Estimated Using AP-42

Others have similarly concluded that “[c]rude oil and heated oil tank emissions
measured by DIAL were 5–10 times higher than estimated by TANKS.”26

A recent study commissioned by the South Coast Air Quality Management

District (SCAQMD) using real-time monitoring to measure the emissions of VOCs and
other pollutants at six refineries and a tank farm confirmed these results.27 Mobile

Allan K. Chambers, Melvin Strosher, Tony Wootton, Jan Moncrieff, and Philip McCready,
23

Direct Measurement of Fugitive Emissions of Hydrocarbons from a Refinery, Journal of the Air and Waste
Management Association, v. 58, August 2008, pp. 1047–1056. Abstract available at
https://www.ncbi.nlm.nih.gov/pubmed/18720654.
24 Ibid., Tables 7 and 8.
25 U.S. EPA, Critical Review of DIAL Emission Test Data for BP Petroleum Refinery in Texas
City, Texas, November 2010, Table 2; available at
https://www3.epa.gov/airtoxics/bp_dial_review_report_12-3-10.pdf.
26Rod Robinson, The Application of Differential Absorption Lidar (DIAL) for Pollutant
Emissions Monitoring, January 2015, pdf 46; available at https://www.h-gac.com/board-of-
directors/advisory-committees/regional-air-quality-planning-advisory-
committee/documents/2015/Jan%2015/DIAL%20%202015%20Houston%20Meeting%20January%20(sen
t%20version).pdf.
27FluxSense Inc., Emission Measurements of VOCs, NO2 and SO2 from Refineries in the South
Coast Air Basin Using Solar Occultation Flux and Other Remote Sensing Methods, Final Report, April 11,
2017 (FluxSense Report); available at https://www.courthousenews.com/wp-
content/uploads/2017/06/FluxSense-Study.pdf.

8
optical measurements were made at the tank farm for eight days between September 28
and October 7, 2015, to estimate tank VOC and other emissions. The results of these
measurements were compared with emissions reported to the SCAQMD in emission
inventories, as required by their operating permits. The methods used to calculate VOC
emissions from the tanks are the same as those used in the 2/17 Application. Tank
emissions, for example, were calculated using the EPA model TANKS 4.09d.28

The FluxSense comparison demonstrated that VOC emissions were

underestimated by an average factor of 6.2, ranging from 2.7 to 12 for the six facilities,
compared to emissions reported to the SCAQMD. A factor of 6.2 means that the
emission inventories underestimated VOC emissions by a factor of 6.2 compared to
measured VOC emissions. This is consistent with results reported elsewhere for other
facilities that also estimate their emissions using AP-42 and other similar methods.
Johansson et al. (2014), for example, reported that, “Despite some significant variations
from year to year and from area to area, there is a clear pattern of measured VOC
emissions (alkanes, ethane, and propene) exceeding reported emissions with almost an
order of magnitude on average...”29 The majority of the VOC emissions originate from
the tanks.

The LDEQ concluded that:30

However, this conclusion is not valid if VOC emissions are higher than disclosed.
If the lower end of the FluxSense VOC range (an average factor of 2.7 underestimate) is
used to correct VOC emissions reported for the tanks in the 2/17 Application, VOC

28 Public Notice Document, pdf 510, 511, 512-581.

29 Johansson et al. Emission measurements of alkenes, alkanes, SO2, and NO2 from stationary
sources in Southeast Texas over a 5  year period using SOF and mobile DOAS. Journal of Geophysical
Research: Atmospheres, 2014, p. 1983; available at
http://onlinelibrary.wiley.com/doi/10.1002/2013JD020485/pdf
30 Public Notice Document, pdf 80.

9
emissions would increase from 248.51 ton/yr to 345.85 ton/yr.31 Using this revised
value in the Applicant’s ozone impact analysis yields a MERP32 of 1.05%,33 which
indicates a significant ozone impact. If an average VOC underestimate of 6.2 were
used, the total VOC emissions increase to 546.26 ton/yr34 and the MERP would rise to
1.26%,35 which indicates a significant ozone impact. Thus, ozone impacts are
significant, requiring mitigation, such as a more efficient tank scrubber system and the
use of geodesic domes on the internal floating roof storage tanks.

1.5. VOC, NOx, and Particulate Matter Emissions from Construction and
Marine Vessels Were Omitted from the Ambient Air Quality Analyses

The ambient air quality impact analysis required to satisfy the PSD requirement
must include all sources of emissions relative to the pre-project conditions. The NSR
Manual describes the required analysis thus:36

The air quality analysis supplied by the Applicant did not include any
construction emissions. It also did not include construction and operation emissions

31 FluxSense Report, Table 43 and Table 1 (adjusted to exclude the VOC emissions from non-tank
sources): (248.51 - 57.26 + 2.7 x 57.26) = 345.85 ton/yr.
32 Memorandum from Richard A. Wayland, Air Quality Assessment Director, to Regional Air

Division Directors, Guidance on the Development of Modeled Emission Rates for Precursors (MERPs) as
a Tier 1 Demonstration Tool for Ozone and PM2.5 under the PSD Permitting Program, December 2, 2016.
33 Revised MERP assumes a tank VOC underestimate of 2.7: (258.59 ton/yr NOx/375.9 ton/yr

MERP) + (345.85 ton/yr VOC/948 ton/yr MERP) = 1.05%.

34 FluxSense Report, Table 43 and Table 1 (adjusted to exclude the VOC emissions from non-tank
sources): (248.51 - 57.26 + 6.2 x 57.26) = 546.26 ton/yr.
35Revised MERP assuming a tank VOC underestimate of 6.2: (258.59 ton/yr NOx/375.9 ton/yr
MERP) + (546.26 ton/yr VOC/948 ton/yr MERP) = 1.26%
36 NSR Manual, p. D.4.

10
from new support equipment, including the natural gas pipeline spur (emissions from
compressor, valves, connectors), the ASU required to supply oxygen,37 or marine
vessels and marine support equipment that will export the methanol. Marine vessels
are typically a major source of NOx, VOCs, and diesel particulate matter (DPM). If
foreign oils are burned in the marine vessel boilers, they can also be major sources of
lead and SO2. Thus, the analysis has significantly underestimated air quality impacts.

Diesel exhaust, emitted by construction equipment, ships, and Port support

equipment, contains over 40 toxic substances. In 1998, the California Air Resources
Board (CARB) formally identified the particulate fraction of diesel exhaust as a toxic air
contaminant and concluded that exposure to diesel exhaust particulate matter causes
cancer and acute respiratory effects.38 The EPA followed suit in 2002 and determined
that diesel exhaust is a probable human carcinogen.39 Diesel exhaust is estimated to
contribute to more than 70% of the added cancer risk from air toxics in the United
States.40 Today, numerous regulatory and public health agencies, including CARB,
EPA, and the World Health Organization41 have classified DPM as a carcinogen.42 The
air quality analysis and the EAS failed to convert DPM and other toxic air contaminant
(TAC) emissions that it identified and quantified into health risks to the impacted
community, an egregious omission. This analysis is known as a “health risk

37 Public Notice Document, pdf 459.

38
California Air Resources Board, Initial Statement of Reasons for Rulemaking, Proposed
Identification of Diesel Exhaust as a Toxic Air Contaminant, Staff Report, June 1998; available at
https://www.arb.ca.gov/regact/diesltac/diesltac.htm.
39
U.S. EPA, Health Assessment for Diesel Engine Exhaust, Report EPA/600/8-90/057F, May
2002; available at
https://nepis.epa.gov/Exe/ZyNET.exe/300055PV.TXT?ZyActionD=ZyDocument&Client=EPA&Index=
1986+Thru+1990&Docs=&Query=&Time=&EndTime=&SearchMethod=1&TocRestrict=n&Toc=&TocEntr
y=&QField=&QFieldYear=&QFieldMonth=&QFieldDay=&IntQFieldOp=0&ExtQFieldOp=0&XmlQuery
=&File=D%3A%5Czyfiles%5CIndex%20Data%5C86thru90%5CTxt%5C00000006%5C300055PV.txt&User=
ANONYMOUS&Password=anonymous&SortMethod=h%7C-
&MaximumDocuments=1&FuzzyDegree=0&ImageQuality=r75g8/r75g8/x150y150g16/i425&Display=h
pfr&DefSeekPage=x&SearchBack=ZyActionL&Back=ZyActionS&BackDesc=Results%20page&Maximum
Pages=1&ZyEntry=1&SeekPage=x&ZyPURL#.
40
Environmental Defense Fund, Cleaner Diesel Handbook, Bring Cleaner Fuel and Diesel
Retrofits into Your Neighborhood, April 2005; available at
http://www.edf.org/sites/default/files/4941_cleanerdieselhandbook.pdf.
International Agency for Research on Cancer, IARC: Diesel Engine Exhaust Carcinogenic, Press
41

Release No. 213, June 12, 2012; available at https://www.iarc.fr/en/media-

centre/pr/2012/pdfs/pr213_E.pdf.
Port of Long Beach, Port of Long Beach Community Impact Study, July 2016; available at
42

http://www.polb.com/civica/filebank/blobdload.asp?BlobID=13319.

11
assessment” or HRA.43 The EAS does not contain a HRA for diesel exhaust or any other
TAP(s).

2. PERMIT CONDITIONS ARE NOT ENFORCEABLE

The draft Permit will be approved under LAC 33:III.501 on an expedited basis in
accordance with LAC 33:I, Chapter 18. The transmittal letter contains this unusual
statement: “The submittal was approved on the basis of the emissions reported and the
approval in no way guarantees the design scheme presented will be capable of
controlling the emissions as to the types and quantities stated.”44 However, that is
precisely the purpose of a permit, to assure the design scheme achieves the emission
rates the permit is based on. My review of the Permit indicates that it does not assure
the Permit will achieve the Applicant’s estimated emissions.

The New Source Review Manual, upheld in numerous Environmental Appeals

Board (EAB) cases, requires that BACT emission limits must be met on a continual basis
at all levels of operation. The Manual states:45

My review of the proposed draft Permit indicates that the vast majority of the
conditions fail to assure that the proposed BACT limits are met on a continual basis at

Rajiv Bhatia, Health Impact Assessment, A Guide for Practice, 2011; available at
43

http://www.pewtrusts.org/~/media/assets/2011/.../bhatia_2011_hia_guide_for_practice.pdf.
44 Public Notice Documents, pdf 3, Letter from Elliott B. Vega, Assistant Secretary, LDEQ, to

Randall Harris, IGP Methanol LLC, Re: Part 70 Operating Permit, Gulf Coast Methanol Complex, IGP
Methanol LLC, Myrtle Grove, Plaquemines Parish, Louisiana, Agency Interest No. 204812, Activity No:
PER20170001.
45 U.S. EPA, New Source Review Workshop Manual: Prevention of Significant Deterioration and

Nonattainment Area Permitting, Draft, October 1990, p. B.56.

12
all levels of operation. This outcome is preordained because the draft Permit fails to
require adequate monitoring—or any monitoring at all—for the vast majority of the
emission units and pollutants. Further, the files posted on LDEQ’s website indicate that
LDEQ did not perform an independent review of the Applicant’s submittals, but simply
accepted them. Thus, it is critically important that all emission limits are enforceable.

The Facility includes 32 separate emission sources with emissions as outlined in

“Emission Rates for Criteria Pollutants and CO2e”46, as follows:47

46 Public Notice Document, pdf 22-29.

47 Public Notice Document, pdf 9-10.

13
 Table 2: Emission Units

However, as discussed below, the proposed permit conditions fail to include any
monitoring for the vast majority of these emission rates; and for those that are included,
the monitoring is inadequate to demonstrate compliance with BACT limits and facility

14
design. Thus, the Permit is wholly unacceptable and should be withdrawn and
redrafted.

The air quality analysis and BACT analyses are based on the facility emitting
specific amounts of each criteria pollutant: nitrogen oxides (NOx), sulfur dioxide (SO2),
carbon monoxide (CO), volatile organic compounds (VOC), particulate matter less than
2.5 microns (PM2.5); particulate matter less than 10 microns (PM10); and carbon dioxide
equivalent (CO2e), also known as greenhouse gas emissions (GHG).48

Table 3: Annual Emissions (ton/yr)

The draft Permit contains 436 conditions. However, these conditions fail to
include establish emission limits and require monitoring to assure that BACT is
achieved in practice for pollutants that exceed the PSD significance threshold (VOC,
NOx, CO, PM10, PM2.5) for the majority of the emission sources. Further, where
specific emission limits are established, the Permit fails to include either any monitoring
at all, or includes inadequate monitoring. The draft Permit also does not contain any
emission limits for SO2. While BACT was not triggered for SO2, this does not excuse
LDEQ from establishing emission limits to assure that SO2 emissions remain below the
BACT SO2 significance threshold.

The proposed permit establishes BACT and other emission limits for some
pollutants as direct emissions or surrogates, but fails to require any compliance
monitoring at all. These omissions include monitoring for:

 In-Line Boilers: PM10/PM2.5, CO, VOC49

 Flares: Opacity50
 Engines: PM10/PM2.5, VOC, CO, NOx51

48 Public Notice Document, pdf 70-71.

49 Condition 42.
50 Condition 117.
51 Conditions 123.

15
  Induced Draft Cooling Units: VOC, Opacity, Drift Rate52

The proposed Permit fails to establish any emission limits to assure that
emissions remain below the BACT threshold for SO2, which did not trigger BACT. The
proposed permit also does not require any monitoring for the following:

 Flares53
 Storage Tanks: HAPs, VOCs54
 Scrubbers: VOCs55
 Heaters: total suspended particulate56
 Reactors: TOC57
 Marine Vessel Loading: VOC, % reduction58
 Marine Vessel Loading Scrubber: VOC, % reduction59
 Methanol Complex: GHGe60

The proposed Permit fails to establish adequate monitoring for:

 Scrubbers: HAPs (monitored once)61

 Heaters: stack test every five years for PM10/PM2.5, NOx, CO, VOC62

The heater common stack requirement in Condition 176 requires a

performance/emissions test on startup and every five years thereafter. There are two
major problems with this stack test condition.

52 Conditions 139-144.
53 Flares: Conditions 66-122.
54 Tanks: Conditions 145-158.
55 Scrubbers: Conditions 163-173.
56 Condition 175.
57 Condition 184.
58Condition 335-336. Condition 341 requires submittal of test results, but there is no condition
requiring testing.
59Conditions 370-371. Condition 376 requires submittal of test results, but there is no condition
requiring testing.
60 Condition 414 (0.38 ton/ton MeOH).
61 Scrubbers: Condition 170.
62 Condition 65.

16
 First, the pollutants that would be measured are ambiguous. The subsequent
condition, 177, suggests stack tests would only be conducted for NOx and CO while the
prior condition, 175, sets forth a limit on total suspended particulate matter (TSP),
implying that Condition 176 may apply to total suspended particulate matter, as no
monitoring for TSP is included elsewhere in the Permit. Condition 176 should be
modified to identify the pollutant(s) that will be monitored in the stack test.

Second, if compliance with the NOx and CO BACT limits is intended, a stack test
every five years is not adequate. CEMS are available for both NOx and CO and are
routinely used to determine compliance with NOx and CO limits on heaters.

Third, a stack test every five years, regardless of the pollutant(s), is not adequate
to determine compliance with a BACT or any other emission limit. A stack test
typically lasts three hours and is conducted under ideal operating conditions, generally
after the source is tuned up, which minimizes emissions compared to routine operation.
Further, fired sources in methanol plants do not operate at a uniform rate, but rather
vary depending on the status of the catalyst used in the methanol synthesis process. A
three-hour optimal snapshot every five years is not adequate to assure the emissions of
any pollutant meet the BACT emission rates or that emissions of SO2 and lead (Pb)
remain below the BACT significance thresholds.

In order to assure that emissions meet the BACT emission limits continuously, as
required, they must be measured continuously from each source. Fired sources in
methanol plants do not operate at a steady rate. Steady-state operation allows short-
term sampling, such as periodic stack tests, to determine annual emissions by
multiplying pounds per unit of fuel combusted as measured in a periodic stack test by
total fuel use (or firing rate). However, for a non-steady-state source, a 3-hour sample
collected once every five years cannot yield a representative estimate of annual
emissions from a boiler or any other source that does not operate at steady state.

In order to assure that emissions meet the BACT limits, emissions must be
continuously measured for each source. Fired sources such as boilers typically operate
at a steady rate, except during periods of startup, shutdown, and malfunction, which
can be separately measured and/or estimated. Steady-state operation allows short-
term sampling, such as periodic stack tests, to determine annual emissions by
multiplying pounds per unit of fuel combusted as measured in a periodic stack test by
total fuel use (or firing rate). However, for a non-steady-state source, such as those at
the proposed Facility, a 3-hour sample collected once every five years cannot yield a

17
representative estimate of annual emissions from a boiler, heater or any other source
that does not operate at steady state.

In rejecting an air permit for the Yuhuang methanol plant in Louisiana, the EPA
concluded that a 5-year stack testing frequency for the auxiliary boiler is inadequate to
ensure compliance with the auxiliary boiler CO emission limit and the permit record
lacked any justification for the frequency of this stack testing condition.63 The record in
this case lacks any justification for 5-year stack testing. The EPA also found that “a
single stack test, repeated every five years” was not sufficient for purposes of
demonstrating compliance with the permit’s VOC limits.64

For the boilers, the proposed Permit establishes specific emission limits for NOx
and requires compliance using continuous emission monitoring systems (CMS) for the
boilers.65 However, the draft Permit fails to require any testing at all for NOx emissions
from other emission units.66 It also establishes emission limits for PM10/PM2.5, CO,
and VOC, but does not require any testing to determine if these limits are met.67 No
emission limits or testing are established for other emission units and pollutants,
including the auxiliary boiler68 and emissions of all pollutant except NOx from the
heaters.69

The failure to specify any emission limits or monitoring for the tanks is
particularly egregious, as studies have demonstrated that the methods used to estimate
tank emissions significantly underestimate VOC emissions. See Comment 1.4.

3. BACT NOT REQUIRED FOR GHG EMISSIONS

The major sources of GHGe emissions are the in-line boilers and heaters, which
emit 98% of the GHGe.70 The LDEQ’s and Applicant’s GHG BACT analyses are

63
Yuhaung Chemical Inc., EPA Order on Petition No. Vl-2015-03, p.14 (2016) (Yuhuang Order),
p.18.
64 Yuhuang Order, p.21.
65 Boilers, Conditions 1-9.
66 Heaters, Conditions 44-65.
In-Line Boilers, Condition 42; Cooling Tower Drift, Condition 144; Cooling Tower Opacity,
67

Condition 142; Heaters, Condition 65.

68 Condition 43.
69 Heaters, Conditions 44-65.
70 Public Notice Document, pdf 883: (110,271 + 508,700)*4/2,533,377 = 0.98.

18
seriously outdated and fail to recognize the progress in controlling GHGs over the past
decade, thus failing to identify BACT for GHGs.

The Applicant’s BACT analysis identifies carbon capture and sequestration

(CCS) as an “emerging” technology to control GHGe. This technology captures CO2
from combustion stacks, purifies it, compresses it, and ships it offsite for storage or use.
The Applicant’s and LDEQ’s BACT analyses argue that this technology is not
economically or technically feasible for the IGP Methanol Plant.71 These analyses are
outdated, superficial, and incorrect. BACT for GHGe from the ICP Methanol Plant is
CCS for GHGe emissions from the heaters and boilers with either nearby storage or
export and use for enhanced oil recovery (EOR).

First, the BACT analyses assert commercial scale CCS systems have only been
demonstrated on high CO2 concentration streams and not from combustion exhaust gas
streams on anything other than slip streams at coal-fired power plants.72 This is not
correct. See Exhibit 2. The BACT analyses admit that “[a] number of post-combustion
carbon capture projects have taken place on slipstreams at coal-fired power plants.
Although these projects have demonstrated the technical feasibility of small-scale CO2
capture on a slipstream of power plant’s emissions using various solvent-based
scrubbing processes,” the Applicant argues they are not “available” for purposes of
BACT on a full-scale plant. The BACT analyses also point to a number of Department
of Energy (DOE) demonstration projects that were canceled.73 However, the LDEQ and
the Applicant fail to disclose all of the successes on similar facilities, thus presenting a
biased and incorrect GHG BACT analysis.

Many similar facilities are in operation, construction, or development around the

world. These are compiled in Exhibit 2 to these comments and shown in Figure 1. In
fact, CCS is a proven technology that has been in use for over 40 years. CCS was
developed not as BACT for GHGe emissions from industrial facilities, but to provide an
economic source of CO2 for use in enhanced oil recovery and other industrial purposes,
such as in the beverage industry.74 Further, there has been considerable progress in
CCS development especially in 2017, in the United States, China, Japan, the Middle East

71 Public Notice Document, pdf 77-79 and 274-279.

72 Public Notice Document, pdf 78 and 275.
73 Public Notice Document, pdf 78 and 275.
74 See 80 Fed. Reg. at 64,555 (October 23, 2015).

19
and Europe, which is not recognized in the BACT analysis.75 The CCS BACT analyses
fail to acknowledge this recent experience.

Figure 1: CCS Facilities in Operation (17), Construction (4),

and Development (16)

The Petra Nova Carbon Capture facility at Unit 8 of the coal-fired W. A. Parish
power plant near Houston, for example, was retrofitted with a 1.4 Mt CO2 (90%
capture) post-combustion CO2 capture facility that has been in operation since January
2017. This facility captures 1.4 Mt of CO2 annually from a 240 MW slipstream from the
610 MW unit and sends it 82 miles by pipeline for on-shore EOR in Hilcorp’s West
Ranch Oil Field in Jackson County, Texas. The facility uses the KM-CDR process,
developed by Mitsubishi Heavy Industries and the Kansai Electric Power Company,
specifically designed for low cost and low energy-consuming CO2 absorption and
desorption.76 The CO2 concentration in the gas stream from a coal-fired boiler is similar
to the CO2 concentration in gas streams from the Project’s heaters and boilers.

Second, the Applicant’s GHGe BACT analysis admits that an advantage of using
CCS for the Project is the location of a nearby CO2 transport pipeline operated by
Denbury that could transport recovered CO2 to Texas oilfields. The LDEQ, on the other

75 Global CCG Institute, Major Strides in 2017 for CCS; available at

https://www.globalccsinstitute.com/insights/authors/GlobalCCS%20Institute/2017/05/08/major-
strides-2017-ccs?author=NjA3.
76 Petra Nova Carbon Capture; available at http://www.globalccsinstitute.com/projects/petra-

nova-carbon-capture-project.

20
hand, fails to consider off-site use, looking only at on-site storage and incorrectly
concluding there is none.77

Pipeline transport was eliminated by the Applicant, because it chose not to rely
on Denbury as it would not be subject to the IGPM operating permit. The Applicant
argued that “Denbury could require economic compensation that IGPM must meet in
order to comply with federally-enforceable operating permit conditions.”78 However,
the Applicant could sell the captured CO2 to Denbury to reduce or eliminate these
costs, an option not considered. As EPA noted:79

Compensation for pipeline use is not unreasonable and is a cost that would
ordinarily be included in a cost-effectiveness analysis. It is not a valid justification for
eliminating a feasible technology. Further, IGP, a company with the resources to build
the largest methanol plant in the world, could certainly negotiate acceptable conditions
for the use of a nearby pipeline, a tiny fraction of Project cost. CCS plants in the United
States that transport CO2 by pipelines owned by others have succeeded in negotiating
pipeline agreements; see, for example, Petra Nova.80

Third, CCS technology is technically and economically feasible at the IGP Facility.
The EPA recently determined that CCS technology is a feasible, economic, and

77 Public Notice Document, pdf 78 (“Moreover, LDEQ finds CO2 storage at or near the site to be

technically infeasible.”)
78 Public Notice Document, pdf 275-276.
79 80 Fed. Reg. at 64,566 (October 23, 2015).
80 Petra Nova Carbon Capture; available at http://www.globalccsinstitute.com/projects/petra-

nova-carbon-capture-project.

21
appropriate control technology for many steam boilers, similar to IGP’s process boilers
and heaters.81 EPA determined that the cost of CCS is reasonable, assuming CO2
storage in deep saline formations.82 Further, EPA reported the cost, expressed as the
levelized cost of electricity (LCOE) in $/MWh for new natural gas combined cycle
plants at the low end of the cost range (60–105 $/MWh).83 Others estimated the LCOE
for new natural gas combined cycle plants at $33 to $87/MWh,84 contradicting LDEQ’s
assertion that CCS on natural gas sources would be much higher than other sources due
to the lower concentrations of GHGs in the exhaust gases. EPA also found that plants
in most parts of the country would have access to CO2 storage in deep saline
formations.85 There is nothing in this record to distinguish the IGP Facility gas stream
from heaters and boilers with those where EPA has concluded that CCS is economically
and technically feasible. The EPA concluded:86

The LDEQ, on the other hand, relied on an outdated 2010 report to conclude that
CCS was not cost effective, stating that EPA estimates the cost per ton of CO2 avoided
to be $103 ($114/tonne) for natural-gas-fired combined cycle power plants, where CO2
concentrations are in the range of 3% to 4%,87 comparable to levels in new natural gas
combined cycle plants discussed above. However, the LDEQ does not present any basis

81 See 80 Fed. Reg. at 64,510 and 64,565 (October 23, 2015).

82 See id. at 64,563, 64,566, and 64,572.
83 See id. At 64,568, Table 10.
84 80 Fed. Reg. at 64,565 (October 23, 2015).
85 See id. at 64,577, Figure 1.
86 80 Fed. Reg. at 64,565 (October 23, 2015).
87 Public Notice Document, pdf 79.

22
for concluding that $103/ton is not cost effective, nor discloses the CO2 concentration in
the Project’s exhaust gases. Further, the LDEQ did not explain that the cost per tonne
“captured,” the relevant metric for BACT, ranges from $49/ton for IGCC to $95/ton for
a new natural gas combustion plant, nor did it disclose that the report concluded that
“[i]mprovements to currently available CO2 capture and compression processes are
important in reducing the costs incurred for CO2 capture.”88 Those improvements have
been developed and employed, as demonstrated by the active CCS projects
summarized in Exhibit 2.

Elsewhere, the LDEQ erroneously concludes that CO2 storage “at or near the site
to be technically infeasible. Dedicated sequestration was rejected by LDEQ due to the
lack of suitable geologic reservoir (e.g., basalt formations, organic rich shale basins, un-
mineable coal areas, and saline formations) or opportunities for enhanced oil recovery
in the immediate vicinity of the facility.”89 In reaching this conclusion, the LDEQ cites
the third edition of the Carbon Sequestration Atlas.90 However, this Atlas is outdated.
The 2015 edition shows many suitable storage formations in and around Plaquemines
Parish, as illustrated in Figure 2.91 This atlas shows Plaquemines Parish (including
adjacent offshore areas) overlies or is near sedimentary basins, oil reservoirs, natural
gas reservoirs, unmineable coal deposits, organic-rich shale basins, and off-shore CO2
storage potential in Louisiana.92 These formations have substantial CO2 sequestration
potential.93

88 CCSTF, Report of the Interagency Task Force on Carbon Capture and Storage, August 2010, p.
34; available at https://energy.gov/fe/downloads/ccstf-final-report.
89 Public Notice Document, pdf 78.
90U.S. DOE, Carbon Sequestration Atlas of the United States and Canada, 3 rd Edition, 2010, pp.
27-31; available at https://www.netl.doe.gov/KMD/CDs/atlasIII/2010atlasIII.pdf .
91 National Energy Technology Laboratory, Carbon Storage Atlas, 5 th Edition, August 20, 2015,
pp. 24-31; available at https://www.netl.doe.gov/research/coal/carbon-storage/atlasv.
92 See National Energy Technology Laboratory, Carbon Storage Atlas, 5th Edition, pp.24-31 (2015);
available at https://www.netl.doe.gov/File%20Library/Research/Coal/carbon-storage/atlasv/ATLAS-
V-2015.pdf.
93 Id. at p.110 (2015).

23
Figure 2: Areas with CO2 Storage Potential Near Plaquemines Parish

Plaquemines Parish:

Sedimentary Basins

Oil Reservoirs

Natural Gas Reservoirs

Unmineable Coal

Saline Formations

Organic-Rich Shale Basins

Offshore CO2 Storage Potential

24
 Fourth, the Applicant’s BACT analysis includes a cost-effectiveness analysis for
amine treatment and CO2 transport that estimated the cost of capture and sequestration
of CO2 from heaters and boilers as $39.18/ton.94 This BACT analysis eliminated CCS as
not cost effective, compared to a range of $5 to $23 per short ton CO2 removed.95
However, no citation is provided for this range. Further, it apparently fails to include
cost data for the 17 operating facilities tabulated in Exhibit 2. Finally, the cost analysis
grossly overestimates costs.

The Applicant’s BACT analysis argues CCS works best for “high-purity CO2
streams, asserting additional equipment, such as amine treaters, are required to purify
the combustion gases,” which it asserts have not been demonstrated on a commercial
scale.96 The LDEQ’s analysis also assumes impurities such as NOx that can degrade the
CO2 capture materials.97 However, this is not correct on both counts. First, the amine
treatment systems have been in use for decades and are demonstrated on many similar
facilities. Second, this equipment, if required, would be based on a much smaller
system than costed in Table 3-6 because the heaters and boilers that generate GHGe at
the Facility will be equipped with controls to remove the pollutants—catalytic oxidation
will remove over 90% of CO and VOCs and selective catalytic reduction (SCR) will
remove over 90% of the NOx,98 pollutants the amine system would be designed to
remove. Thus, the resulting gas streams will be relatively clean compared to sources in
the cited cost range and would not require purification to the extent assumed in the cost
analysis. This avoids the majority of the assumed cleanup cost required before carbon
capture can be implemented. The BACT analysis failed to take this into consideration
and thus is fundamentally flawed.

Further, the assumptions used to calculate the capital recovery factor are not
realistic. Given the current interest rate environment, an interest rate of 7% is
unrealistic; 3% to 4% is more reasonable. Further, a 20-year life is too short for
equipment that has a 40-year demonstration period; 30 years is more typically assumed
and is more reasonable for equipment with a long operating history. The revised
capital recovery factor, assuming an interest rate of 4% and a 30-year equipment life, is

94 Public Notice Document, pdf 278, Table 3-6.

95 Public Notice Document, pdf 277.
96 Public Notice Document, pdf. 274-275.
97 Public Notice Document, pdf 78.
98 Public Notice Document, pdf 71.

25
0.058,99 which reduces the cost effectiveness of capture and sequestration from
$39.18/ton to $24.1/ton, which is within the range cited in the Applicant’s BACT
analysis.

Fifth, the BACT analysis should have explored the possibility of obtaining some
or all of the power required to operate the GHG control system on-site from renewables
such as wind and solar. Fuel mix for a facility, especially in the context of GHGe
emissions, is an appropriate consideration in the BACT analysis.

In sum, carbon capture is feasible and cost effective for the GHGe emissions from
the Project’s heaters and boilers and must be required as BACT. Further, commenters
encourage the LDEQ to look at the projected monetary investment in carbon capture
and sequestration technology not as an economic cost but as a potential economic
benefit. Like construction of other aspects of the proposed facility, construction of the
carbon capture and sequestration technology would mean a significant increase in IGP’s
investment in Plaquemines Parish. This type of investment will lead to more
construction and process jobs, increase the tax base, and increase foreign direct
investment in Plaquemines Parish and Louisiana; important benefits to consider when
weighing the cost of a control.

4. BACT IS NOT REQUIRED FOR VOC EMISSIONS FROM METHANOL

TANK SCRUBBERS

The Project includes two fixed roof buffer tanks in each methanol unit and
several internal floating roof product tanks.100 The Applicant concluded that BACT for
VOC emissions from the fixed roof tanks is the use of a wet scrubber to recover
methanol product with an efficiency of 95%, and from the internal floating roof tank, a
wet scrubber with an efficiency of 98%.101 However, LDEQ concluded that BACT for all
of these tanks is a wet scrubber with an efficiency of 95%. The draft permit likewise
only requires a scrubber control efficiency of 95% for all the methanol storage tanks.102

The Application fails to provide any information on the ventilation system that
would route methanol vapors to the scrubber or on the scrubber itself—such as the
vendor, type, design flow rate, ventilation system control efficiency, etc. Similar

99 CRF = [i(1+i)n/[(1+i)n - 1] = [0.04(1 + 0.04)30]/[(1+ 0.04)30-1] = 0.058.

100 Public Notice Document, pdf 271.
101 Public Notice Document, pdf 271, 273.
102 Public Notice Document, pdf 42 (Condition 158), 43 (Condition 173).

26
facilities have proposed more efficient scrubbers. There are three major problems with
this determination.

First, the five-step, top-down BACT analysis was not performed. Rather, a
control efficiency was plucked out of thin air with no support whatsoever.

Second, BACT is an emission limit, not a control efficiency, which is an

intermediate step in establishing an emission limit. The BACT analysis failed to
establish a BACT VOC emission limit for the scrubbers, which is required to satisfy Step
3 of the BACT analysis.

Third, the Application asserts the 95% control efficiency with no support. The
NSR Manual requires the use of the most recent regulatory decisions and performance
data for identifying the emissions performance level(s) to be evaluated in all cases.103
Further, other information to be considered in determining the performance level
representing achievable limits includes manufacturer’s data, engineering estimates, and
the experience of other sources. The Applicant and agency must survey the RBLC and
other sources, both domestic and foreign, including other agencies’ determinations and
(draft) permits, permit applications for other proposed plants, technology vendors,
performance test reports, consultants, technical journal articles, etc. None of these
sources were consulted in determining BACT for the methanol tank scrubbers. A
review of recent methanol plants indicates 95% VOC control is not BACT in this
application.

The similar Kalama facility, proposed in Washington State, includes crude and
product methanol tanks, vented to a wet scrubber. The Kalama application
concluded:104

The Kalama control efficiency is based on manufacturer’s information, which

specifies a minimum capture efficiency of 99% for methanol vapors. The Southwest

103 NSR Manual, p. B.23.

104 Kalama Application, pdf 191.

27
Clean Air Agency (SWCAA) agreed and established BACT CO permit limits of 0.72
ton/yr and 0.16 lb/hr, and VOC limits of 2.50 ton/yr and 0.57 lb/hr. 105 A final permit
has been issued with these limits.106

The similar Yuhuang methanol plant, located in St. James, Louisiana, includes
three fixed roof, raw methanol tanks equipped with a closed vent system routed to a
scrubber with a 98% control efficiency.107

In sum, VOC BACT for the methanol product tanks scrubbers should be VOC
emissions based on 99% control.

5. BACT NOT REQUIRED FOR FUGITIVE EMISSIONS

Fugitive emissions are leaks from valves, pressure relief devices (PRDs),
connectors, pumps, and compressors. The LDEQ’s and Applicant’s BACT analyses
concluded that BACT for VOC emissions from fugitive components is a leak detection
and repair (LDAR) program that meets the requirements of 40 CFR 63 Subpart H,
without conducting a top-down BACT analysis.108 Complying with regulations that the
Applicant must meet regardless of BACT does not satisfy BACT.

The Applicant evaluated three technologies to control fugitive emissions: (1)

“zero leak” components”; (2) infrared camera monitoring; and (3) LDAR compliance
programs. The Applicant’s analysis of each is superficial and unsupported and thus
fails to identify BACT.

First, the Applicant eliminated leakless components by arguing that their use
“may be limited by materials of construction and process operating conditions, such as
high temperatures.” The Applicant also argued they “are not considered technically
feasible on a facility-wide basis to replace standard pumps and valves.”109 However,

105 Southwest Clean Air Agency, Technical Support Document, Air Discharge Permit ADP 16-

3204, Draft, November 21, 2016, p. 16-17 (manufacturer specifications); available at

http://www.swcleanair.org/docs/permits/prelim/16-3204TSD.PDF.
106Southwest Clean Air Agency, Air Discharge Permit 16-3204, June 7, 2017, Condition 11, p. 6;
available at swcleanair.org/docs/permits/Final/16-3204ADP.PDF.
Ramboll Environ, Application for a Minor Modification to Title V Permit No. 2560-00295-V0
107

Pdf 15, Yuhuang Chemical, Inc. Methanol Plant, June 2016 pdf 14-16, 116, Table 1-3 of EDMS Doc. No.
10239485 (Attachment F), available at
http://edms.deq.louisiana.gov/app/doc/view.aspx?doc=10239485&ob=yes&child=yes.
108 Public Notice Document, pdf 77.
109 Public Notice Document, pdf 268.

28
the Applicant failed to supply any specific example or evidence from a vendor
confirming their infeasibility.

Regardless, these arguments leave open the possibility of using leakless

components in areas without process constraints, such as on piping connecting storage
tanks. Compressors, for example, can be designed with a closed-vent system to capture
and transport leakage from the compressor drive shaft seal back to a process or a fuel
gas system or to a control device. The BACT analysis must evaluate these feasible
options.

Second, there are many different versions of LDAR programs. The Applicant
selected the version required by 40 CFR 63 Subpart H without considering any other
LDAR option. A regulatory requirement that the Applicant must follow regardless of
BACT, does not necessarily satisfy BACT. It is merely the status quo.

The most basic elements of an LDAR program are the definition of a leak
(expressed as parts per million of the leaked substance), the frequency of monitoring,
and the timeline in which leaks are repaired once discovered. The Bay Area Air Quality
Management District (BAAQMD) has demonstrated that stricter regulation is feasible
than contemplated in 40 CFR 63 Subpart H, required as BACT in the Draft Permit.

The BAAQMD supervises LDAR programs at five refineries with over 200,000
regulated components, as well as chemical plants, bulk plants, and bulk terminals
under Regulation 8, Rule 18 (Reg 8-18). This regulation, first adopted in 1998, sets lower
leak limits, more frequent inspections, and shorter repair schedules than required as
BACT as summarized in Table 4, below.

29
 Table 4: Comparison of Draft Permit LDAR Program
with BAAQMD Rule 8-18
40 CFR 63 BAAQMD
Subpart H Rule 8-18
Leak definition – valves in
500 ppm 100 ppm
gas/vapor/light liquid services
Leak definition –
1,000 ppm/500
pumps/compressors in light 500 ppm
ppm
liquid service
Connectors in gas/vapor/light
500 ppm 100 ppm
liquid services
Inspection frequency Monthly/annual+ Quarterly/annual110
Repair schedule 15 days 7 days111

Another key aspect of an LDAR program is the scope of any exemptions

recognized by the program. The LDAR program evaluated in the BACT analysis
exempts leaks that are “unsafe” or “difficult” to monitor. The BAAQMD rule does not
recognize such an exemption, as it is not consistent with BACT, given the BAAQMD’s
experience. The BACT analysis must include all feasible LDAR programs, including
one as effective as is currently in use within the BAAQMD.

In particular, in order to avoid the need to monitor such unsafe equipment leaks,
the facility should be designed to minimize or eliminate them to the extent feasible.
Any remaining components that qualify as difficult or unsafe to monitor or repair
should be required to use leakless designs. This should be cost effective as (1) the cost
of monitoring, repairing and re-monitoring devices that are difficult to monitor is
substantially higher than components in more convenient locations; and (2) the
potential emissions from leaking “inaccessible” components is greater as a leak is less
likely to be observed visually or by sense of smell, and instrumented monitoring only
occurs annually.

The BACT analysis also did not consider requiring that “repeat offenders” be
replaced. The South Coast Air Quality Management District and the Ventura County

110Pumps are subject to daily visual inspection. If a valve has not been found to be leaking
during five quarterly inspections, the inspection frequency is reduced to once per year.
If the leak is detected by BAAQMD personnel during an inspection it must be repaired within
111

24 hours. The BAAQMD rules also require that leaks detected by the source be minimized within 24
hours.

30
Air Pollution Control District each have rules under which components that have been
subject to repair more than, for example, five times within a year be replaced with
BACT/BARCT or be vented to an approved air pollution control device.112

Finally, the LDEQ must ensure the integrity of any LDAR program. As U.S.
EPA’s history of enforcement actions demonstrates, this integrity cannot be taken for
granted.113 The U.S. EPA has encountered significant fraud in the conduct of LDAR
inspections and in the reporting of results.114 To avoid this, LDEQ must include
safeguards in the Permit, including requiring a licensed professional engineer to sign
off on all LDAR reports. LDEQ must also explore requiring periodic independent audits
of the LDAR program, at least for the largest emitters.

Third, the BACT analysis rejected the use of infrared camera monitoring due to
alleged absence of methods to interpret and retain video records and detection limits
higher than leak limits.115 However, these claims are false. There are several
recommended technologies and practices116 that are applicable to equipment leaks and
which have been widely used in the field and required in EPA consent decrees and

112See SCAQMD Rule 1173(g)(3) and Ventura County APCD Rule 74.7. Under the Ventura
County rule, for example, if a valve is found to have suffered five major leaks in a year it shall be replaced
by a valve with a bellows seal, or with graphite, PTE or PTFE stack chevron seal rings, or with BACT
technology level components.
For a more recent example, see U.S. EPA’s recent refinery settlements. See, e.g.,
113

http://www.epa.gov/compliance/resources/cases/civil/caa/oil/index.html.
114 In the late 1990s, EPA discovered flagrant, industry-wide violations of several CAA
requirements at the nation’s refineries. Among the most significant were LDAR rules violations where
refiners, and independent contractors hired by refiners, routinely underreported by up to a factor of 10
the number of leaking valves, leading to significant excess emissions. The ensuing enforcement actions
led to 29 settlements with operators of over 90% of the refining capacity in the country. These settlements
required improved LDAR practices, $82 million in fines, and $75 million in Supplemental Environmental
Projects. This experience demonstrates a need for detailed independent oversight of LDAR activities, as
does the recent Pelican refinery criminal prosecution.
115 Public Notice Document, pdf 268.
See, e.g., ENVIRON International Corporation, Literature Assessment of Remote Sensing
116

Technologies for Detecting and Estimating Emissions for Flares and Fugitives, Prepared for Texas
Commission on Environmental Quality, May 2008; available at
https://webcache.googleusercontent.com/search?q=cache:kUUf1hnOhNQJ:https://www.tceq.texas.gov
/assets/public/implementation/air/am/contracts/reports/oth/5820784005FY0809-20080530-environ-
remote_sensing_flares_fugitives.pdf+&cd=4&hl=en&ct=clnk&gl=us; M-F Benassay and others, Optical
Methods for Remote Measurement of Diffuse VOCs: Their Role in Quantification of Annual Refinery
Emissions, June 2008; available a: https://www.concawe.eu/wp-content/uploads/2017/01/rpt_08-6-
2008-02481-01-e.pdf.

31
information collection to quantify emissions from fugitive and other sources.117
Handheld infrared cameras have been used to identify, in real time, process
components that are leaking.118 Additional imaging technologies, including the use of
DIAL (Differential Absorption Light Detection and Ranging), can also be used to
identify fugitive sources of VOCs.119 The existing LDAR program could be expanded to
process units not currently covered (e.g., cooling towers).120 These options must be
evaluated as a part of a complete BACT analysis for fugitive VOC emissions from
flanges. A recent study in California used remote sensing to identify leaks that would
not be detected by a conventional LDAR program—a malfunctioning vent on an
external roof of a tank and a leak in a buried pipe.121

Optical scanning programs can be a part of an overall improved LDAR program.

Use of optical cameras involves some modest level of investment; however, once
purchased, these devices can provide an extremely low-cost means of filling the gaps in
the LDAR program. Daily or weekly scans can identify plant areas containing gross
emitters (including “unsafe to monitor” or “difficult to monitor” components) for
targeted LDAR inspections. Such inspections could replace scheduled inspections and
save operators money by detecting leaks early, while improving the environmental
performance of the facility. Use of optical scanning devices, pressure relief valves,
monitoring devices and other technical advances can complement existing programs.
However, the suite of existing options has not demonstrated the ability to provide the
level of emission reductions as can be obtained from well-designed and implemented

Steven Ramsey, Shagun Bhat, and Ram Hashmonay, Optical Remote Sensing of Fugitive
117

Emissions, Presentation at 2009 LA A&WMA Environmental Conference, October 28, 2009; available at
la-awma.org/files/2009_3-4.pdf.
118 See, e.g., Technology Transfer: Optical Leak Imaging for the Hydrocarbon Industry, ICF

Consulting; available at http://www.icfi.com/Markets/Environment/doc_files/optical-leak-

imaging.pdf.
See, e.g., Refinery Demonstration of Optical Technologies for Measurement of Fugitive
119

Emissions and for Leak Detection, Alberta Research Council, November 2006, available at
http://www.arc.ab.ca/areas-of-focus/carbon-conversion-capture-and-storage/cccs-publications-and-
resources/dial-emission-reports/; see also Fugitive VOC-emissions measured at Oil Refineries in the
Province of Västra Götaland in South West Sweden, 2003, available at
http://www.spectrasyne.ltd.uk/ROSEVOCreport.pdf.
120 CARB, Reducing Greenhouse Gas Emissions from California Refineries, April 2008; available

at http://www.capcoa.org/climatechange/upload/documents/Presentation-04-11-2008-
WorkshopPresentationRefineries4-11.pdf. See also Texas Environmental Research Consortium, Project
H7-A: Compilation of Information on Cooling Towers, Equipment Fugitive Leaks and Flares, November
30, 2003.
121 FluxSense Report, pp. 91-92.

32
LDAR programs. For this reason these options must be considered in addition to and
not in lieu of existing programs.

6. ENVIRONMENTAL ASSESSMENT STATEMENT (EAS) IS

FUNDAMENTALLY FLAWED

The Louisiana Environmental Quality Act (Act) requires that an applicant for a
new permit for a major source “shall submit an environmental assessment statement as
part of the permit application.” The Act further provides that “[t]he environmental
assessment statement…shall be used by LDEQ to satisfy the public trustee requirements
of Article IX, Section 1 of the Constitution of Louisiana.”122 And for the LDEQ to satisfy
the public trustee requirements, it must determine “that adverse environmental impacts
have been minimized or avoided as much as possible consistent with the public
welfare” before it can issue a final permit.123 To make this determination, LDEQ must
issue a written permit decision that satisfactorily answers whether:124

Thus, the EAS must include:

(1) The potential and real adverse environmental effects of the proposed
permit activities.

(2) A cost-benefit analysis of the environmental impact costs of the

proposed activity balanced against the social and economic benefits of the
activity which demonstrates that the latter outweighs the former.

La Rev. Stat. §30:2018; available at

122

http://law.justia.com/codes/louisiana/2006/15/87053.html.
123Save Ourselves, Inc. v. Louisiana Envtl. Control Comm’n, 452 So. 2d 1152, 1157 (interpreting La.
Const. Art. IX, §1).
124 In re Oil & Gas Exploration, Dev., & Prod. Facilities, Permit No. LAG260000, 2010-1640 (La. App.

1 Cir. 6/10/11).

33
 (3) The alternatives to the proposed activity which would offer more
protection to the environment without unduly curtailing non-
environmental benefits.

The EAS submitted with the 2/17 Application does not disclose all potential and
real adverse environmental effects of the Project, it does not contain a cost-benefit
analysis, and it does not contain an alternatives analysis.

6.1. All Environmental Effects Have Not Been Identified

The EAS asserts that impacts from air emissions “will be minimal and will not
cause any significant adverse impacts.” However, it failed to conduct an analysis to
estimate the impacts of all components of the Project, as discussed in Comment 1. The
air quality analysis narrowly focused on the operation of the methanol plant itself and
excluded all emissions from construction and all operational emissions from support
facilities; including a new natural gas pipeline, a new cryogenic ASU, and all emissions
from marine vessel and terminal support equipment, required to export the methanol.
The record also does not include a health risk assessment, which is required to evaluate
the impact of the Project on nearby sensitive receptors. The specific impacts must be
identified so that mitigation measures can be identified. The tanks and fugitive
components, for example, would emit significant amounts of methanol, a toxic air
pollutant. Further, as discussed in Comment 1.3, when errors in emission calculations
are corrected, the increase in VOC emissions is sufficient to result in significant ozone
impacts.

6.2. The Adverse Environmental Effects of the Project Have Not Been
Avoided to the Maximum Extent Possible

The EAS asserts that “[t]here are no mitigating measures which would offer
more protection to the environment than the facility as proposed without unduly
curtailing non-environmental benefits.”125 However, this is not correct. Comments 3 to
5 identify more effective controls for GHGe emissions and VOC emissions from
methanol storage tanks, the major source of VOC emissions and ambient ozone
impacts, and fugitive sources.

The EAS regulations require that adverse environmental effects be avoided to the
maximum extent possible. The emissions of VOCs and TAP have the potential to cause
significant environmental impacts that were not analyzed, including air quality and

125 Public Notice Document, pdf 471.

34
public health impacts. The following impacts and additional controls are feasible and
would significantly reduce criteria and HAP pollutants and risks of accidents at the
facility.

6.2.1. VOC and Methanol Emissions from Storage Tanks Can and Should Be
Reduced

As discussed in Comment 1.4, VOC emissions from the methanol internal

floating roof storage tanks are substantially higher than disclosed in the Application.
These emissions are 100% methanol, which is a toxic air pollutant that would be present
in high enough concentrations to cause significant health impacts in the surrounding
community. These emissions could be substantially reduced by covering the tanks with
geodesic domes.

Geodesic domes should be required to reduce the VOC and methanol emissions
from all internal floating roof tanks. These domes are feasible, satisfy best available
control technology (BACT), and are widely used. Over 10,000 aluminum domes have
been installed on petrochemical storage tanks in the United States.126 The ExxonMobil
Torrance Refinery: “completed the process of covering all floating roof tanks with
geodesic domes to reduce volatile organic compound (VOCs) emissions from facility
storage tanks in 2008. By installing domes on our storage tanks, we’ve reduced our
VOC emissions from these tanks by 80%. These domes, installed on tanks that are used
to store gasoline and other similar petroleum-derived materials, help reduce VOC
emissions by blocking much of the wind that constantly flows across the tank roofs,
thus decreasing evaporation from these tanks.”127

A crude storage capacity project, recently proposed at the Phillips 66 Los Angeles
Carson Refinery, required external floating roof tanks with geodesic domes to store
crude oil with an RVP of 11.128 The ConocoPhillips Wilmington Refinery added a
geodesic dome to an existing oil storage tank to satisfy BACT.129 Similarly, Chevron

126 M. Doxey and M. Trinidad, Aluminum Geodesic Dome Roof for Both New and Tank Retrofit

Projects, Materials Forum, v. 30, 2006, available at

http://www.materialsaustralia.com.au/lib/pdf/Mats.%20Forum%20page%20164_169.pdf.
127 Torrance Refinery: An Overview of our Environmental and Social Programs, 2010, available at

http://www.exxonmobil.com/NA-English/Files/About_Where_Ref_TorranceReport.pdf.
See, e.g., Phillips 66 Los Angeles Refinery Carson Plant—Crude Oil Storage Capacity Project,
128

September 6, 2013, Table 1-1, Draft Negative Declaration, available at

https://www.aqmd.gov/CEQA/documents/2013/nonaqmd/Draft_ND_Phillips_66_Crude_Storage.pdf
129SCAQMD Letter to G. Rios, December 4, 2009, available at
http://yosemite.epa.gov/r9/air/epss.nsf/e0c49a10c792e06f8825657e007654a3/e97e6a905737c9bd882576

35
proposes130 to use domes on several existing tanks to mitigate VOC emission increases
at its Richmond Refinery.131 The U.S. Department of Justice CITGO Consent Decree
required a geodesic dome on a gasoline storage tank at the Lamont, Texas refinery.132
Methanol is more volatile than crude oil or gasoline, enhancing the benefits of its use for
the Project. Further, numerous vendors have provided geodesic dome tanks.133

These numerous applications of geodesic domes to control VOC emissions from

storage tanks satisfy the “achieved in practice” test for BACT. Thus, geodesic domes
should be required to reduce environmental impacts of the Project. Further, if the
emissions were properly calculated, the facility would be a major source, triggering PSD
for VOC. Geodesic domes satisfy BACT for the new and modified storage tanks.

6.2.2. VOC Emissions from Loading Should Be Reduced

The facility includes a vapor combustor to reduce VOC emissions during loading
operations. The draft permit requires that loading VOC emissions be reduced by 98%.
Similar vapor combustors are routinely designed and permitted to achieve 99% VOC
control.

6.2.3. VOC Emissions from Fugitive Components Should be Reduced

The draft permit includes a leak detection and repair program (LDAR) to control
leaks from fugitive components, such as valves, connectors, pumps, and compressors.
Leaks from these components can be completely eliminated by using leakless

cd0064b56a/$FILE/ATTTOA6X.pdf/ID%20800363%20ConocoPhillips%20Wilmington%20-
%20EPA%20Cover%20Letter%20%20-AN%20501727%20501735%20457557.pdf.
130 City
of Richmond, Chevron Refinery Modernization Project, Environmental Impact Report,
Volume 1: Draft EIR, March 2014 (Chevron DEIR), available at
http://chevronmodernization.com/project-documents/.
131 Chevron DEIR, Chapter 4.3.
CITGO Petroleum Corp. Clean Air Act Settlement, available at
132

http://www2.epa.gov/enforcement/citgo-petroleum-corporation-clean-air-act-settlement.
133See, e.g., Aluminum Geodesic Dome, available at http://tankaluminumcover.com/Aluminum-
Geodesic-Dome; Larco Storage Tank Equipments, available at
http://www.larco.fr/aluminum_domes.html; Vacono Dome, available at
http://www.easyfairs.com/uploads/tx_ef/VACONODOME_2014.pdf; Peksay Ltd., available at
http://www.thomasnet.com/productsearch/item/10039789-13068-1008-1008/united-industries-group-
inc/geodesic-aluminum-dome-roofs/; United Industries Group, Inc., available at
http://www.thomasnet.com/productsearch/item/10039789-13068-1008-1008/united-industries-group-
inc/geodesic-aluminum-dome-roofs/.

36
components or more aggressively controlled by following procedures developed by the
BAAQMD and SCAQMD, as described in Comment 5.

7. The EAS Does Not Include A Cost-Benefit Analysis

The EAS does not include an analysis of environmental costs relative to the
purported economic benefits, but rather only generally discusses the economic benefits
without addressing the risks or quantifying the costs of health risks. The cost of the
Project to the affected community depends upon health risks that result from the
emission of TAPs. The EAS does not include a health risk assessment, an essential
component of a cost-benefit analysis to determine the cost of the Project. This is an
egregious omission given the fact that the Project is a major source of toxic air
pollutants that will be built adjacent to residential areas in Plaquemines Parish. Costs
will be incurred for medical expenses to address health impacts and to retrofit homes to
minimize indoor air pollution.

Adverse health effects are associated with all of the TAPs the facility will emit, 134
including methanol, toluene, xylenes, acetaldehyde, acrolein, and benzene.135 Instead of
evaluating the health impacts of all of these TAPs combined, the EAS concludes that
because the ambient concentrations of only three TAPs—ammonia, methanol, and
formaldehyde—would not exceed the Louisiana Ambient Air Standards for those
hazardous substances, there will not be an adverse impact to air quality.136 However,
carcinogenic, chronic, and acute health impacts result from cumulative exposure to all
of the TAPs combined. Further, there is no evidence in the record that the Louisiana
standards for these three HAPs are consistent with current health research, as reflected
in exposure levels established elsewhere. In fact, the Louisiana standards are higher
than chronic reference exposure levels for both methanol (4,000 v. 6,240 ug/m3) and
ammonia (640 v. 200 ug/m3)137. The cumulative health impacts of TAPs must be
evaluated in a risk assessment, which is a scientific process of quantifying adverse

134 See, e.g., OEHHA Acute 8-hour and Chronic Reference Exposure Level Summary, June 2016;
available at https://oehha.ca.gov/air/general-info/oehha-acute-8-hour-and-chronic-reference-exposure-
level-rel-summary.
135 Public Notice Document, pdf 5.
136 Public Notice Document, pdf 6.
137 See OEHHA Acute, 8-hour and Chronic Reference Exposure Level (REL) Summary; available
at https://oehha.ca.gov/air/general-info/oehha-acute-8-hour-and-chronic-reference-exposure-level-rel-
summary.

37
effects of all TAPs combined.138 The record does not contain a health risk assessment
nor an analysis of the costs of the resulting health impacts. Further, regardless, the air
in the community will be worse because of the emission of additional pollutants—both
TAPs and criteria pollutants. The LDEQ must consider the cost of this added pollution
on residents to satisfy its obligation to demonstrate that the social and economic
benefits of the activity outweigh its economic costs.

138See, e.g., OEHHA, Air Toxics Hot Spots Program Guidance Manual for Preparation of Health
Risk Assessment, March 6, 2015; available at https://oehha.ca.gov/air/crnr/notice-adoption-air-toxics-
hot-spots-program-guidance-manual-preparation-health-risk-0.

38
 Phyllis Fox, Ph.D, PE
Environmental Management
745 White Pine Ave.
Rockledge, FL 32955
321-626-6885
PhyllisFox@gmail.com

Dr. Fox has over 40 years of experience in the field of environmental engineering, including air
pollution control (BACT, BART, MACT, LAER, RACT), greenhouse gas emissions and control,
cost effectiveness analyses, water quality and water supply investigations, hydrology, hazardous
waste investigations, environmental permitting, nuisance investigations (odor, noise),
environmental impact reports, CEQA/NEPA documentation, risk assessments, and litigation
support.

EDUCATION
Ph.D. Environmental/Civil Engineering, University of California, Berkeley, 1980.
M.S. Environmental/Civil Engineering, University of California, Berkeley, 1975.
B.S. Physics (with high honors), University of Florida, Gainesville, 1971.

REGISTRATION

Registered Professional Engineer: Arizona (2001-2014: #36701; retired), California (2002-

present; CH 6058), Florida (2001-2016; #57886; retired), Georgia (2002-2014; #PE027643;
retired), Washington (2002-2014; #38692; retired), Wisconsin (2005-2014; #37595-006; retired)
Board Certified Environmental Engineer, American Academy of Environmental Engineers,
Certified in Air Pollution Control (DEE #01-20014), 2002-2014; retired)
Qualified Environmental Professional (QEP), Institute of Professional Environmental
Practice (QEP #02-010007, 2001-2015: retired).

PROFESSIONAL HISTORY

Environmental Management, Principal, 1981-present

Lawrence Berkeley National Laboratory, Principal Investigator, 1977-1981
University of California, Berkeley, Program Manager, 1976-1977
Bechtel, Inc., Engineer, 1971-1976, 1964-1966

PROFESSIONAL AFFILIATIONS

American Chemical Society (1981-2010)

Phi Beta Kappa (1970-present)
Sigma Pi Sigma (1970-present)
Who's Who Environmental Registry, PH Publishing, Fort Collins, CO, 1992.
Who's Who in the World, Marquis Who's Who, Inc., Chicago, IL, 11th Ed., p. 371, 1993-present.
 PHYLLIS FOX, PH.D., PAGE 2

Who's Who of American Women, Marquis Who's Who, Inc., Chicago, IL, 13th Ed., p. 264, 1984-
present.
Who's Who in Science and Engineering, Marquis Who's Who, Inc., New Providence, NJ, 5th Ed.,
p. 414, 1999-present.
Who’s Who in America, Marquis Who’s Who, Inc., 59th Ed., 2005.
Guide to Specialists on Toxic Substances, World Environment Center, New York, NY, p. 80,
1980.
National Research Council Committee on Irrigation-Induced Water Quality Problems
(Selenium), Subcommittee on Quality Control/Quality Assurance (1985-1990).
National Research Council Committee on Surface Mining and Reclamation, Subcommittee on
Oil Shale (1978-80)

REPRESENTATIVE EXPERIENCE

Performed environmental and engineering investigations, as outlined below, for a wide range of
industrial and commercial facilities including: petroleum refineries and upgrades thereto;
reformulated fuels projects; refinery upgrades to process heavy sour crudes, including tar sands
and light sweet crudes from the Eagle Ford and Bakken Formations; petroleum, gasoline and
ethanol distribution terminals; coal, coke, and ore/mineral export terminals; LNG export, import,
and storage terminals; crude-by-rail projects; shale oil plants; crude oil/condensate marine and
rail terminals; coal gasification and liquefaction plants; oil and gas production, including
conventional, thermally enhanced, hydraulic fracking, and acid stimulation techniques;
underground storage tanks; pipelines; compressor stations; gasoline stations; landfills; railyards;
hazardous waste treatment facilities; nuclear, hydroelectric, geothermal, wood, biomass, waste,
tire-derived fuel, gas, oil, coke and coal-fired power plants; transmission lines; airports;
hydrogen plants; petroleum coke calcining plants; coke plants; activated carbon manufacturing
facilities; asphalt plants; cement plants; incinerators; flares; manufacturing facilities (e.g.,
semiconductors, electronic assembly, aerospace components, printed circuit boards, amusement
park rides); lanthanide processing plants; ammonia plants; nitric acid plants; urea plants; food
processing plants; wineries; almond hulling facilities; composting facilities; grain processing
facilities; grain elevators; ethanol production facilities; soy bean oil extraction plants; biodiesel
plants; paint formulation plants; wastewater treatment plants; marine terminals and ports; gas
processing plants; steel mills; iron nugget production facilities; pig iron plant, based on blast
furnace technology; direct reduced iron plant; acid regeneration facilities; railcar refinishing
facility; battery manufacturing plants; pesticide manufacturing and repackaging facilities; pulp
and paper mills; olefin plants; methanol plants; ethylene crackers; alumina plants, desalination
plants; selective catalytic reduction (SCR) systems; selective noncatalytic reduction (SNCR)
systems; halogen acid furnaces; contaminated property redevelopment projects (e.g., Mission
Bay, Southern Pacific Railyards, Moscone Center expansion, San Diego Padres Ballpark);
residential developments; commercial office parks, campuses, and shopping centers; server
 PHYLLIS FOX, PH.D., PAGE 3

farms; transportation plans; and a wide range of mines including sand and gravel, hard rock,
limestone, nacholite, coal, molybdenum, gold, zinc, and oil shale.

EXPERT WITNESS/LITIGATION SUPPORT

 For the California Attorney General, assist in determining compliance with probation terms
in the matter of People v. Chevron USA.
 For plaintiffs, assist in developing Petitioners’ proof brief for National Parks Conservation
Association et al v. U.S. EPA, Petition for Review of Final Administrative Action of the U.S.
EPA, In the U.S. Court of Appeals for the Third Circuit, Docket No. 14-3147.
 For plaintiffs, expert witness in civil action relating to alleged violations of the Clean Air
Act, Prevention of Significant Deterioration, for historic modifications (1997-2000) at the
Cemex cement plant in Lyons, Colorado. Reviewed produced documents, prepared expert
and rebuttal reports on PSD applicability based on NOx emission calculations for a
collection of changes considered both individually and collectively. Deposed August 2011.
United States v. Cemex, Inc., In U.S. District Court for the District of Colorado (Civil
Action No. 09-cv-00019-MSK-MEH). Case settled June 13, 2013.
 For plaintiffs, in civil action relating to alleged violations of the Clean Air Act, Prevention of
Significant Deterioration, for historic modifications (1988 – 2000) at James De Young Units
3, 4, and 5. Reviewed produced documents, analyzed CEMS and EIA data, and prepared
netting and BACT analyses for NOx, SO2, and PM10 (PSD case). Expert report February
24, 2010 and affidavit February 20, 2010. Sierra Club v. City of Holland, et al., U.S. District
Court, Western District of Michigan (Civil Action 1:08-cv-1183). Case settled. Consent
Decree 1/19/14.
 For plaintiffs, in civil action alleging failure to obtain MACT permit, expert on potential to
emit hydrogen chloride (HCl) from a new coal-fired boiler. Reviewed record, estimated HCl
emissions, wrote expert report June 2010 and March 2013 (Cost to Install a Scrubber at the
Lamar Repowering Project Pursuant to Case-by-Case MACT), deposed August 2010 and
March 2013. Wildearth Guardian et al. v. Lamar Utilities Board, Civil Action No. 09-cv-
02974, U.S. District Court, District of Colorado. Case settled August 2013.
 For plaintiffs, expert witness on permitting, emission calculations, and wastewater treatment
for coal-to-gasoline plant. Reviewed produced documents. Assisted in preparation of
comments on draft minor source permit. Wrote two affidavits on key issues in case.
Presented direct and rebuttal testimony 10/27 - 10/28/10 on permit enforceability and failure
to properly calculate potential to emit, including underestimate of flaring emissions and
omission of VOC and CO emissions from wastewater treatment, cooling tower, tank roof
landings, and malfunctions. Sierra Club, Ohio Valley Environmental Coalition, Coal River
Mountain Watch, West Virginia Highlands Conservancy v. John Benedict, Director, Division
 PHYLLIS FOX, PH.D., PAGE 4

of Air Quality, West Virginia Department of Environmental Protection and TransGas

Development System, LLC, Appeal No. 10-01-AQB. Virginia Air Quality Board remanded
the permit on March 28, 2011 ordering reconsideration of potential to emit calculations,
including: (1) support for assumed flare efficiency; (2) inclusion of startup, shutdown and
malfunction emissions; and (3) inclusion of wastewater treatment emissions in potential to
emit calculations.
 For plaintiffs, expert on BACT emission limits for gas-fired combined cycle power plant.
Prepared declaration in support of CBE's Opposition to the United States' Motion for Entry
of Proposed Amended Consent Decree. Assisted in settlement discussions. U.S. EPA,
Plaintiff, Communities for a Better Environment, Intervenor Plaintiff, v. Pacific Gas &
Electric Company, et al., U.S. District Court, Northern District of California, San Francisco
Division, Case No. C-09-4503 SI.
 Technical expert in confidential settlement discussions with large coal-fired utility on BACT
control technology and emission limits for NOx, SO2, PM, PM2.5, and CO for new natural
gas fired combined cycle and simple cycle turbines with oil backup. (July 2010). Case
settled.
 For plaintiffs, expert witness in remedy phase of civil action relating to alleged violations of
the Clean Air Act, Prevention of Significant Deterioration, for historic modifications (1998-
99) at Gallagher Units 1 and 3. Reviewed produced documents, prepared expert and rebuttal
reports on historic and current-day BACT for SO2, control costs, and excess emissions of
SO2. Deposed 11/18/09. United States et al. v. Cinergy, et al., In U.S. District Court for the
Southern District of Indiana, Indianapolis Division, Civil Action No. IP99-1693 C-M/S.
Settled 12/22/09.
 For plaintiffs, expert witness on MACT, BACT for NOx, and enforceability in an
administrative appeal of draft state air permit issued for four 300-MW pet-coke-fired CFBs.
Reviewed produced documents and prepared prefiled testimony. Deposed 10/8/09 and
11/9/09. Testified 11/10/09. Application of Las Brisas Energy Center, LLC for State Air
Quality Permit; before the State Office of Administrative Hearings, Texas. Permit remanded
3/29/10 as LBEC failed to meet burden of proof on a number of issues including MACT.
Texas Court of Appeals dismissed an appeal to reinstate the permit. The Texas Commission
on Environmental Quality and Las Brisas Energy Center, LLC sought to overturn the Court
of Appeals decision but moved to have their appeal dismissed in August 2013.
 For defense, expert witness in unlawful detainer case involving a gasoline station, minimart,
and residential property with contamination from leaking underground storage tanks.
Reviewed agency files and inspected site. Presented expert testimony on July 6, 2009, on
causes of, nature and extent of subsurface contamination. A. Singh v. S. Assaedi, in Contra
Costa County Superior Court, CA. Settled August 2009.
 PHYLLIS FOX, PH.D., PAGE 5

 For plaintiffs, expert witness on netting and enforceability for refinery being upgraded to
process tar sands crude. Reviewed produced documents. Prepared expert and rebuttal
reports addressing use of emission factors for baseline, omitted sources including coker,
flares, tank landings and cleaning, and enforceability. Deposed. In the Matter of Objection to
the Issuance of Significant Source Modification Permit No. 089-25484-00453 to BP
Products North America Inc., Whiting Business Unit, Save the Dunes Council, Inc., Sierra
Club., Inc., Hoosier Environmental Council et al., Petitioners, B. P. Products North
American, Respondents/Permittee, before the Indiana Office of Environmental Adjudication.
Case settled.
 For plaintiffs, expert witness on BACT, MACT, and enforceability in appeal of Title V
permit issued to 600 MW coal-fired power plant burning Powder River Basin coal. Prepared
technical comments on draft air permit. Reviewed record on appeal, drafted BACT, MACT,
and enforceability pre-filed testimony. Drafted MACT and enforceability pre-filed rebuttal
testimony. Deposed March 24, 2009. Testified June 10, 2009. In Re: Southwestern Electric
Power Company, Arkansas Pollution Control and Ecology Commission, Consolidated
Docket No. 08-006-P. Recommended Decision issued December 9, 2009 upholding issued
permit. Commission adopted Recommended Decision January 22, 2010.
 For plaintiffs, expert witness in remedy phase of civil action relating to alleged violations of
the Clean Air Act, Prevention of Significant Deterioration, for historic modifications (1989-
1992) at Wabash Units 2, 3 and 5. Reviewed produced documents, prepared expert and
rebuttal report on historic and current-day BACT for NOx and SO2, control costs, and excess
emissions of NOx, SO2, and mercury. Deposed 10/21/08. United States et al. v. Cinergy, et
al., In U.S. District Court for the Southern District of Indiana, Indianapolis Division, Civil
Action No. IP99-1693 C-M/S. Testified 2/3/09. Memorandum Opinion & Order 5-29-09
requiring shutdown of Wabash River Units 2, 3, 5 by September 30, 2009, run at baseline
until shutdown, and permanently surrender SO2 emission allowances.
 For plaintiffs, expert witness in liability phase of civil action relating to alleged violations of
the Clean Air Act, Prevention of Significant Deterioration, for three historic modifications
(1997-2001) at two portland cement plants involving three cement kilns. Reviewed
produced documents, analyzed CEMS data covering subject period, prepared netting analysis
for NOx, SO2 and CO, and prepared expert and rebuttal reports. United States v. Cemex
California Cement, In U.S. District Court for the Central District of California, Eastern
Division, Case No. ED CV 07-00223-GW (JCRx). Settled 1/15/09.
 For intervenors Clean Wisconsin and Citizens Utility Board, prepared data requests,
reviewed discovery and expert report. Prepared prefiled direct, rebuttal and surrebuttal
testimony on cost to extend life of existing Oak Creek Units 5-8 and cost to address future
regulatory requirements to determine whether to control or shutdown one or more of the
units. Oral testimony 2/5/08. Application for a Certificate of Authority to Install Wet Flue
Gas Desulfurization and Selective Catalytic Reduction Facilities and Associated Equipment
 PHYLLIS FOX, PH.D., PAGE 6

for Control of Sulfur Dioxide and Nitrogen Oxide Emissions at Oak Creek Power Plant Units
5, 6, 7 and 8, WPSC Docket No. 6630-CE-299.
 For plaintiffs, expert witness on alternatives analysis and BACT for NOx, SO2, total PM10,
and sulfuric acid mist in appeal of PSD permit issued to 1200 MW coal fired power plant
burning Powder River Basin and/or Central Appalachian coal (Longleaf). Assisted in drafting
technical comments on NOx on draft permit. Prepared expert disclosure. Presented 8+ days
of direct and rebuttal expert testimony. Attended all 21 days of evidentiary hearing from
9/5/07 – 10/30/07 assisting in all aspects of hearing. Friends of the Chatahooche and Sierra
Club v. Dr. Carol Couch, Director, Environmental Protection Division of Natural Resources
Department, Respondent, and Longleaf Energy Associates, Intervener. ALJ Final Decision
1/11/08 denying petition. ALJ Order vacated & remanded for further proceedings, Fulton
County Superior Court, 6/30/08. Court of Appeals of GA remanded the case with directions
that the ALJ's final decision be vacated to consider the evidence under the correct standard of
review, July 9, 2009. The ALJ issued an opinion April 2, 2010 in favor of the applicant.
Final permit issued April 2010.
 For plaintiffs, expert witness on diesel exhaust in inverse condemnation case in which Port
expanded maritime operations into residential neighborhoods, subjecting plaintiffs to noise,
light, and diesel fumes. Measured real-time diesel particulate concentrations from marine
vessels and tug boats on plaintiffs’ property. Reviewed documents, depositions, DVDs, and
photographs provided by counsel. Deposed. Testified October 24, 2006. Ann Chargin,
Richard Hackett, Carolyn Hackett, et al. v. Stockton Port District, Superior Court of
California, County of San Joaquin, Stockton Branch, No. CV021015. Judge ruled for
plaintiffs.
 For plaintiffs, expert witness on NOx emissions and BACT in case alleging failure to obtain
necessary permits and install controls on gas-fired combined-cycle turbines. Prepared and
reviewed (applicant analyses) of NOx emissions, BACT analyses (water injection, SCR, ultra
low NOx burners), and cost-effectiveness analyses based on site visit, plant operating
records, stack tests, CEMS data, and turbine and catalyst vendor design information.
Participated in negotiations to scope out consent order. United States v. Nevada Power. Case
settled June 2007, resulting in installation of dry low NOx burners (5 ppm NOx averaged
over 1 hr) on four units and a separate solar array at a local business.
 For plaintiffs, expert witness in appeal of PSD permit issued to 850 MW coal fired boiler
burning Powder River Basin coal (Iatan Unit 2) on BACT for particulate matter, sulfuric acid
mist and opacity and emission calculations for alleged historic violations of PSD. Assisted in
drafting technical comments, petition for review, discovery requests, and responses to
discovery requests. Reviewed produced documents. Prepared expert report on BACT for
particulate matter. Assisted with expert depositions. Deposed February 7, 8, 27, and 28,
2007. In Re PSD Construction Permit Issued to Great Plains Energy, Kansas City Power &
Light – Iatan Generating Station, Sierra Club v. Missouri Department of Natural Resources,
 PHYLLIS FOX, PH.D., PAGE 7

Great Plains Energy, and Kansas City Power & Light. Case settled March 27, 2007,
providing offsets for over 6 million ton/yr of CO2 and lower NOx and SO2 emission limits.
 For plaintiffs, expert witness in remedy phase of civil action relating to alleged violations of
the Clean Air Act, Prevention of Significant Deterioration, for historic modifications of coal-
fired boilers and associated equipment. Reviewed produced documents, prepared expert
report on cost to retrofit 24 coal-fired power plants with scrubbers designed to remove 99%
of the sulfur dioxide from flue gases. Prepared supplemental and expert report on cost
estimates and BACT for SO2 for these 24 complaint units. Deposed 1/30/07 and 3/14/07.
United States and State of New York et al. v. American Electric Power, In U.S. District Court
for the Southern District of Ohio, Eastern Division, Consolidated Civil Action Nos. C2-99-
1182 and C2-99-1250. Settlement announced 10/9/07.
 For plaintiffs, expert witness on BACT, enforceability, and alternatives analysis in appeal of
PSD permit issued for a 270-MW pulverized coal fired boiler burning Powder River Basin
coal (City Utilities Springfield Unit 2). Reviewed permitting file and assisted counsel draft
petition and prepare and respond to interrogatories and document requests. Reviewed
interrogatory responses and produced documents. Assisted with expert depositions.
Deposed August 2005. Evidentiary hearings October 2005. In the Matter of Linda
Chipperfield and Sierra Club v. Missouri Department of Natural Resources. Missouri
Supreme Court denied review of adverse lower court rulings August 2007.
 For plaintiffs, expert witness in civil action relating to plume touchdowns at AEP’s Gavin
coal-fired power plant. Assisted counsel draft interrogatories and document requests.
Reviewed responses to interrogatories and produced documents. Prepared expert report
“Releases of Sulfuric Acid Mist from the Gavin Power Station.” The report evaluates
sulfuric acid mist releases to determine if AEP complied with the requirements of CERCLA
Section 103(a) and EPCRA Section 304. This report also discusses the formation, chemistry,
release characteristics, and abatement of sulfuric acid mist in support of the claim that these
releases present an imminent and substantial endangerment to public health under Section
7002(a)(1)(B) of the Resource Conservation and Recovery Act (“RCRA”). Citizens Against
Pollution v. Ohio Power Company, In the U.S. District Court for the Southern District of
Ohio, Eastern Division, Civil Action No. 2-04-cv-371. Case settled 12-8-06.

 For petitioners, expert witness in contested case hearing on BACT, enforceability, and
emission estimates for an air permit issued to a 500-MW supercritical Power River Basin
coal-fired boiler (Weston Unit 4). Assisted counsel prepare comments on draft air permit
and respond to and draft discovery. Reviewed produced file, deposed (7/05), and prepared
expert report on BACT and enforceability. Evidentiary hearings September 2005. In the
Matter of an Air Pollution Control Construction Permit Issued to Wisconsin Public Service
Corporation for the Construction and Operation of a 500 MW Pulverized Coal-fired Power
Plant Known as Weston Unit 4 in Marathon County, Wisconsin, Case No. IH-04-21. The
 PHYLLIS FOX, PH.D., PAGE 8

Final Order, issued 2/10/06, lowered the NOx BACT limit from 0.07 lb/MMBtu to 0.06
lb/MMBtu based on a 30-day average, added a BACT SO2 control efficiency, and required a
0.0005% high efficiency drift eliminator as BACT for the cooling tower. The modified
permit, including these provisions, was issued 3/28/07. Additional appeals in progress.
 For plaintiffs, adviser on technical issues related to Citizen Suit against U.S. EPA regarding
failure to update New Source Performance Standards for petroleum refineries, 40 CFR 60,
Subparts J, VV, and GGG. Our Children’s Earth Foundation and Sierra Club v. U.S. EPA et
al. Case settled July 2005. CD No. C 05-00094 CW, U.S. District Court, Northern District of
California – Oakland Division. Proposed revisions to standards of performance for
petroleum refineries published 72 FR 27178 (5/14/07).
 For interveners, reviewed proposed Consent Decree settling Clean Air Act violations due to
historic modifications of boilers and associated equipment at two coal-fired power plants. In
response to stay order, reviewed the record, selected one representative activity at each of
seven generating units, and analyzed to identify CAA violations. Identified NSPS and NSR
violations for NOx, SO2, PM/PM10, and sulfuric acid mist. Summarized results in an expert
report. United States of America, and Michael A. Cox, Attorney General of the State of
Michigan, ex rel. Michigan Department of Environmental Quality, Plaintiffs, and Clean
Wisconsin, Sierra Club, and Citizens' Utility Board, Intervenors, v. Wisconsin Electric
Power Company, Defendant, U.S. District Court for the Eastern District of Wisconsin, Civil
Action No. 2:03-CV-00371-CNC. Order issued 10-1-07 denying petition.
 For a coalition of Nevada labor organizations (ACE), reviewed preliminary determination to
issue a Class I Air Quality Operating Permit to Construct and supporting files for a 250-MW
pulverized coal-fired boiler (Newmont). Prepared about 100 pages of technical analyses and
comments on BACT, MACT, emission calculations, and enforceability. Assisted counsel
draft petition and reply brief appealing PSD permit to U.S. EPA Environmental Appeals
Board (EAB). Order denying review issued 12/21/05. In re Newmont Nevada Energy
Investment, LLC, TS Power Plant, PSD Appeal No. 05-04 (EAB 2005).
 For petitioners and plaintiffs, reviewed and prepared comments on air quality and hazardous
waste based on negative declaration for refinery ultra low sulfur diesel project located in
SCAQMD. Reviewed responses to comments and prepared responses. Prepared declaration
and presented oral testimony before SCAQMD Hearing Board on exempt sources (cooling
towers) and calculation of potential to emit under NSR. Petition for writ of mandate filed
March 2005. Case remanded by Court of Appeals to trial court to direct SCAQMD to re-
evaluate the potential environmental significance of NOx emissions resulting from the
project in accordance with court’s opinion. California Court of Appeals, Second Appellate
Division, on December 18, 2007, affirmed in part (as to baseline) and denied in part.
Communities for a Better Environment v. South Coast Air Quality Management District and
ConocoPhillips and Carlos Valdez et al v. South Coast Air Quality Management District and
 PHYLLIS FOX, PH.D., PAGE 9

ConocoPhillips. Certified for partial publication 1/16/08. Appellate Court opinion upheld by
CA Supreme Court 3/15/10. (2010) 48 Cal.4th 310.
 For amici seeking to amend a proposed Consent Decree to settle alleged NSR violations at
Chevron refineries, reviewed proposed settlement, related files, subject modifications, and
emission calculations. Prepared declaration on emission reductions, identification of NSR
and NSPS violations, and BACT/LAER for FCCUs, heaters and boilers, flares, and sulfur
recovery plants. U.S. et al. v. Chevron U.S.A., Northern District of California, Case No. C
03-04650. Memorandum and Order Entering Consent Decree issued June 2005. Case No. C
03-4650 CRB.
 For petitioners, prepared declaration on enforceability of periodic monitoring requirements,
in response to EPA’s revised interpretation of 40 CFR 70.6(c)(1). This revision limited
additional monitoring required in Title V permits. 69 FR 3203 (Jan. 22, 2004).
Environmental Integrity Project et al. v. EPA (U.S. Court of Appeals for the District of
Columbia). Court ruled the Act requires all Title V permits to contain monitoring
requirements to assure compliance. Sierra Club v. EPA, 536 F.3d 673 (D.C. Cir. 2008).
 For interveners in application for authority to construct a 500 MW supercritical coal-fired
generating unit before the Wisconsin Public Service Commission, prepared pre-filed written
direct and rebuttal testimony with oral cross examination and rebuttal on BACT and MACT
(Weston 4). Prepared written comments on BACT, MACT, and enforceability on draft air
permit for same facility.
 For property owners in Nevada, evaluated the environmental impacts of a 1,450-MW coal-
fired power plant proposed in a rural area adjacent to the Black Rock Desert and Granite
Range, including emission calculations, air quality modeling, comments on proposed use
permit to collect preconstruction monitoring data, and coordination with agencies and other
interested parties. Project cancelled.
 For environmental organizations, reviewed draft PSD permit for a 600-MW coal-fired power
plant in West Virginia (Longview). Prepared comments on permit enforceability; coal
washing; BACT for SO2 and PM10; Hg MACT; and MACT for HCl, HF, non-Hg metallic
HAPs, and enforceability. Assist plaintiffs draft petition appealing air permit. Retained as
expert to develop testimony on MACT, BACT, offsets, enforceability. Participate in
settlement discussions. Case settled July 2004.
 For petitioners, reviewed record produced in discovery and prepared affidavit on emissions
of carbon monoxide and volatile organic compounds during startup of GE 7FA combustion
turbines to successfully establish plaintiff standing. Sierra Club et al. v. Georgia Power
Company (Northern District of Georgia).
 For building trades, reviewed air quality permitting action for 1500-MW coal-fired power
plant before the Kentucky Department for Environmental Protection (Thoroughbred).
 PHYLLIS FOX, PH.D., PAGE 10

 For petitioners, expert witness in administrative appeal of the PSD/Title V permit issued to a
1500-MW coal-fired power plant. Reviewed over 60,000 pages of produced documents,
prepared discovery index, identified and assembled plaintiff exhibits. Deposed. Assisted
counsel in drafting discovery requests, with over 30 depositions, witness cross examination,
and brief drafting. Presented over 20 days of direct testimony, rebuttal and sur-rebuttal, with
cross examination on BACT for NOx, SO2, and PM/PM10; MACT for Hg and non-Hg
metallic HAPs; emission estimates for purposes of Class I and II air modeling; risk
assessment; and enforceability of permit limits. Evidentiary hearings from November 2003 to
June 2004. Sierra Club et al. v. Natural Resources & Environmental Protection Cabinet,
Division of Air Quality and Thoroughbred Generating Company et al. Hearing Officer
Decision issued August 9, 2005 finding in favor of plaintiffs on counts as to risk, BACT
(IGCC/CFB, NOx, SO2, Hg, Be), single source, enforceability, and errors and omissions.
Assist counsel draft exceptions. Cabinet Secretary issued Order April 11, 2006 denying
Hearing Offer’s report, except as to NOx BACT, Hg, 99% SO2 control and certain errors and
omissions.
 For citizens group in Massachusetts, reviewed, commented on, and participated in permitting
of pollution control retrofits of coal-fired power plant (Salem Harbor).
 Assisted citizens group and labor union challenge issuance of conditional use permit for a
317,000 ft2 discount store in Honolulu without any environmental review. In support of a motion
for preliminary injunction, prepared 7-page declaration addressing public health impacts of
diesel exhaust from vehicles serving the Project. In preparation for trial, prepared 20-page
preliminary expert report summarizing results of diesel exhaust and noise measurements at two
big box retail stores in Honolulu, estimated diesel PM10 concentrations for Project using ISCST,
prepared a cancer health risk assessment based on these analyses, and evaluated noise impacts.
 Assisted environmental organizations to challenge the DOE Finding of No Significant Impact
(FONSI) for the Baja California Power and Sempra Energy Resources Cross-Border
Transmissions Lines in the U.S. and four associated power plants located in Mexico (DOE EA-
1391). Prepared 20-page declaration in support of motion for summary judgment addressing
emissions, including CO2 and NH3, offsets, BACT, cumulative air quality impacts, alternative
cooling systems, and water use and water quality impacts. Plaintiff’s motion for summary
judgment granted in part. U.S. District Court, Southern District decision concluded that the
Environmental Assessment and FONSI violated NEPA and the APA due to their inadequate
analysis of the potential controversy surrounding the project, water impacts, impacts from NH3
and CO2, alternatives, and cumulative impacts. Border Power Plant Working Group v.
Department of Energy and Bureau of Land Management, Case No. 02-CV-513-IEG (POR) (May
2, 2003).
 For Sacramento school, reviewed draft air permit issued for diesel generator located across from
playfield. Prepared comments on emission estimates, enforceability, BACT, and health impacts
of diesel exhaust. Case settled. BUG trap installed on the diesel generator.
 PHYLLIS FOX, PH.D., PAGE 11

 Assisted unions in appeal of Title V permit issued by BAAQMD to carbon plant that
manufactured coke. Reviewed District files, identified historic modifications that should
have triggered PSD review, and prepared technical comments on Title V permit. Reviewed
responses to comments and assisted counsel draft appeal to BAAQMD hearing board,
opening brief, motion to strike, and rebuttal brief. Case settled.
 Assisted California Central Coast city obtain controls on a proposed new city that would
straddle the Ventura-Los Angeles County boundary. Reviewed several environmental
impact reports, prepared an air quality analysis, a diesel exhaust health risk assessment, and
detailed review comments. Governor intervened and State dedicated the land for
conservation purposes April 2004.
 Assisted Central California city to obtain controls on large alluvial sand quarry and asphalt
plant proposing a modernization. Prepared comments on Negative Declaration on air
quality, public health, noise, and traffic. Evaluated process flow diagrams and engineering
reports to determine whether proposed changes increased plant capacity or substantially
modified plant operations. Prepared comments on application for categorical exemption
from CEQA. Presented testimony to County Board of Supervisors. Developed controls to
mitigate impacts. Assisted counsel draft Petition for Writ. Case settled June 2002.
Substantial improvements in plant operations were obtained including cap on throughput,
dust control measures, asphalt plant loadout enclosure, and restrictions on truck routes.
 Assisted oil companies on the California Central Coast in defending class action citizen’s
lawsuit alleging health effects due to emissions from gas processing plant and leaking
underground storage tanks. Reviewed regulatory and other files and advised counsel on
merits of case. Case settled November 2001.
 Assisted oil company on the California Central Coast in defending property damage claims
arising out of a historic oil spill. Reviewed site investigation reports, pump tests, leachability
studies, and health risk assessments, participated in design of additional site characterization
studies to assess health impacts, and advised counsel on merits of case. Prepare health risk
assessment.
 Assisted unions in appeal of Initial Study/Negative Declaration ("IS/ND") for an MTBE
phaseout project at a Bay Area refinery. Reviewed IS/ND and supporting agency permitting
files and prepared technical comments on air quality, groundwater, and public health
impacts. Reviewed responses to comments and final IS/ND and ATC permits and assisted
counsel to draft petitions and briefs appealing decision to Air District Hearing Board.
Presented sworn direct and rebuttal testimony with cross examination on groundwater
impacts of ethanol spills on hydrocarbon contamination at refinery. Hearing Board ruled 5 to
0 in favor of appellants, remanding ATC to district to prepare an EIR.
 Assisted Florida cities in challenging the use of diesel and proposed BACT determinations in
prevention of significant deterioration (PSD) permits issued to two 510-MW simple cycle
 PHYLLIS FOX, PH.D., PAGE 12

peaking electric generating facilities and one 1,080-MW simple cycle/combined cycle
facility. Reviewed permit applications, draft permits, and FDEP engineering evaluations,
assisted counsel in drafting petitions and responding to discovery. Participated in settlement
discussions. Cases settled or applications withdrawn.
 Assisted large California city in federal lawsuit alleging peaker power plant was violating its
federal permit. Reviewed permit file and applicant's engineering and cost feasibility study to
reduce emissions through retrofit controls. Advised counsel on feasible and cost-effective
NOx, SOx, and PM10 controls for several 1960s diesel-fired Pratt and Whitney peaker
turbines. Case settled.
 Assisted coalition of Georgia environmental groups in evaluating BACT determinations and
permit conditions in PSD permits issued to several large natural gas-fired simple cycle and
combined-cycle power plants. Prepared technical comments on draft PSD permits on BACT,
enforceability of limits, and toxic emissions. Reviewed responses to comments, advised
counsel on merits of cases, participated in settlement discussions, presented oral and written
testimony in adjudicatory hearings, and provided technical assistance as required. Cases
settled or won at trial.
 Assisted construction unions in review of air quality permitting actions before the Indiana
Department of Environmental Management ("IDEM") for several natural gas-fired simple
cycle peaker and combined cycle power plants.
 Assisted coalition of towns and environmental groups in challenging air permits issued to
523 MW dual fuel (natural gas and distillate) combined-cycle power plant in Connecticut.
Prepared technical comments on draft permits and 60 pages of written testimony addressing
emission estimates, startup/shutdown issues, BACT/LAER analyses, and toxic air emissions.
Presented testimony in adjudicatory administrative hearings before the Connecticut
Department of Environmental Protection in June 2001 and December 2001.
 Assisted various coalitions of unions, citizens groups, cities, public agencies, and developers
in licensing and permitting of over 110 coal, gas, oil, biomass, and pet coke-fired power
plants generating over 75,000 MW of electricity. These included base-load, combined cycle,
simple cycle, and peaker power plants in Alaska, Arizona, Arkansas, California, Colorado,
Georgia, Florida, Illinois, Indiana, Kentucky, Michigan, Missouri, Ohio, Oklahoma, Oregon,
Texas, West Virginia, Wisconsin, and elsewhere. Prepared analyses of and comments on
applications for certification, preliminary and final staff assessments, and various air, water,
wastewater, and solid waste permits issued by local agencies. Presented written and oral
testimony before various administrative bodies on hazards of ammonia use and
transportation, health effects of air emissions, contaminated property issues, BACT/LAER
issues related to SCR and SCONOx, criteria and toxic pollutant emission estimates, MACT
analyses, air quality modeling, water supply and water quality issues, and methods to reduce
water use, including dry cooling, parallel dry-wet cooling, hybrid cooling, and zero liquid
discharge systems.
 PHYLLIS FOX, PH.D., PAGE 13

 Assisted unions, cities, and neighborhood associations in challenging an EIR issued for the
proposed expansion of the Oakland Airport. Reviewed two draft EIRs and prepared a health
risk assessment and extensive technical comments on air quality and public health impacts.
The California Court of Appeals, First Appellate District, ruled in favor of appellants and
plaintiffs, concluding that the EIR "2) erred in using outdated information in assessing the
emission of toxic air contaminants (TACs) from jet aircraft; 3) failed to support its decision
not to evaluate the health risks associated with the emission of TACs with meaningful
analysis," thus accepting my technical arguments and requiring the Port to prepare a new
EIR. See Berkeley Keep Jets Over the Bay Committee, City of San Leandro, and City of
Alameda et al. v. Board of Port Commissioners (August 30, 2001) 111 Cal.Rptr.2d 598.
 Assisted lessor of former gas station with leaking underground storage tanks and TCE
contamination from adjacent property. Lessor held option to purchase, which was forfeited
based on misrepresentation by remediation contractor as to nature and extent of
contamination. Remediation contractor purchased property. Reviewed regulatory agency
files and advised counsel on merits of case. Case not filed.
 Advised counsel on merits of several pending actions, including a Proposition 65 case
involving groundwater contamination at an explosives manufacturing firm and two former
gas stations with leaking underground storage tanks.
 Assisted defendant foundry in Oakland in a lawsuit brought by neighbors alleging property
contamination, nuisance, trespass, smoke, and health effects from foundry operation.
Inspected and sampled plaintiff's property. Advised counsel on merits of case. Case settled.
 Assisted business owner facing eminent domain eviction. Prepared technical comments on a
negative declaration for soil contamination and public health risks from air emissions from a
proposed redevelopment project in San Francisco in support of a CEQA lawsuit. Case
settled.
 Assisted neighborhood association representing residents living downwind of a Berkeley
asphalt plant in separate nuisance and CEQA lawsuits. Prepared technical comments on air
quality, odor, and noise impacts, presented testimony at commission and council meetings,
participated in community workshops, and participated in settlement discussions. Cases
settled. Asphalt plant was upgraded to include air emission and noise controls, including
vapor collection system at truck loading station, enclosures for noisy equipment, and
improved housekeeping.
 Assisted a Fortune 500 residential home builder in claims alleging health effects from faulty
installation of gas appliances. Conducted indoor air quality study, advised counsel on merits
of case, and participated in discussions with plaintiffs. Case settled.
 Assisted property owners in Silicon Valley in lawsuit to recover remediation costs from
insurer for large TCE plume originating from a manufacturing facility. Conducted
investigations to demonstrate sudden and accidental release of TCE, including groundwater
 PHYLLIS FOX, PH.D., PAGE 14

modeling, development of method to date spill, preparation of chemical inventory,

investigation of historical waste disposal practices and standards, and on-site sewer and
storm drainage inspections and sampling. Prepared declaration in opposition to motion for
summary judgment. Case settled.
 Assisted residents in east Oakland downwind of a former battery plant in class action lawsuit
alleging property contamination from lead emissions. Conducted historical research and dry
deposition modeling that substantiated claim. Participated in mediation at JAMS. Case
settled.
 Assisted property owners in West Oakland who purchased a former gas station that had
leaking underground storage tanks and groundwater contamination. Reviewed agency files
and advised counsel on merits of case. Prepared declaration in opposition to summary
judgment. Prepared cost estimate to remediate site. Participated in settlement discussions.
Case settled.
 Consultant to counsel representing plaintiffs in two Clean Water Act lawsuits involving
selenium discharges into San Francisco Bay from refineries. Reviewed files and advised
counsel on merits of case. Prepared interrogatory and discovery questions, assisted in
deposing opposing experts, and reviewed and interpreted treatability and other technical
studies. Judge ruled in favor of plaintiffs.
 Assisted oil company in a complaint filed by a resident of a small California beach
community alleging that discharges of tank farm rinse water into the sanitary sewer system
caused hydrogen sulfide gas to infiltrate residence, sending occupants to hospital. Inspected
accident site, interviewed parties to the event, and reviewed extensive agency files related to
incident. Used chemical analysis, field simulations, mass balance calculations, sewer
hydraulic simulations with SWMM44, atmospheric dispersion modeling with SCREEN3,
odor analyses, and risk assessment calculations to demonstrate that the incident was caused
by a faulty drain trap and inadequate slope of sewer lateral on resident's property. Prepared a
detailed technical report summarizing these studies. Case settled.
 Assisted large West Coast city in suit alleging that leaking underground storage tanks on city
property had damaged the waterproofing on downgradient building, causing leaks in an
underground parking structure. Reviewed subsurface hydrogeologic investigations and
evaluated studies conducted by others documenting leakage from underground diesel and
gasoline tanks. Inspected, tested, and evaluated waterproofing on subsurface parking
structure. Waterproofing was substandard. Case settled.
 Assisted residents downwind of gravel mine and asphalt plant in Siskiyou County,
California, in suit to obtain CEQA review of air permitting action. Prepared two declarations
analyzing air quality and public health impacts. Judge ruled in favor of plaintiffs, closing
mine and asphalt plant.
 PHYLLIS FOX, PH.D., PAGE 15

 Assisted defendant oil company on the California Central Coast in class action lawsuit
alleging property damage and health effects from subsurface petroleum contamination.
Reviewed documents, prepared risk calculations, and advised counsel on merits of case.
Participated in settlement discussions. Case settled.
 Assisted defendant oil company in class action lawsuit alleging health impacts from
remediation of petroleum contaminated site on California Central Coast. Reviewed
documents, designed and conducted monitoring program, and participated in settlement
discussions. Case settled.
 Consultant to attorneys representing irrigation districts and municipal water districts to
evaluate a potential challenge of USFWS actions under CVPIA section 3406(b)(2).
Reviewed agency files and collected and analyzed hydrology, water quality, and fishery data.
Advised counsel on merits of case. Case not filed.
 Assisted residents downwind of a Carson refinery in class action lawsuit involving soil and
groundwater contamination, nuisance, property damage, and health effects from air
emissions. Reviewed files and provided advise on contaminated soil and groundwater, toxic
emissions, and health risks. Prepared declaration on refinery fugitive emissions. Prepared
deposition questions and reviewed deposition transcripts on air quality, soil contamination,
odors, and health impacts. Case settled.
 Assisted residents downwind of a Contra Costa refinery who were affected by an accidental
release of naphtha. Characterized spilled naphtha, estimated emissions, and modeled
ambient concentrations of hydrocarbons and sulfur compounds. Deposed. Presented
testimony in binding arbitration at JAMS. Judge found in favor of plaintiffs.
 Assisted residents downwind of Contra Costa County refinery in class action lawsuit alleging
property damage, nuisance, and health effects from several large accidents as well as routine
operations. Reviewed files and prepared analyses of environmental impacts. Prepared
declarations, deposed, and presented testimony before jury in one trial and judge in second.
Case settled.
 Assisted business owner claiming damages from dust, noise, and vibration during a sewer
construction project in San Francisco. Reviewed agency files and PM10 monitoring data and
advised counsel on merits of case. Case settled.
 Assisted residents downwind of Contra Costa County refinery in class action lawsuit alleging
property damage, nuisance, and health effects. Prepared declaration in opposition to
summary judgment, deposed, and presented expert testimony on accidental releases, odor,
and nuisance before jury. Case thrown out by judge, but reversed on appeal and not retried.
 Presented testimony in small claims court on behalf of residents claiming health effects from
hydrogen sulfide from flaring emissions triggered by a power outage at a Contra Costa
County refinery. Analyzed meteorological and air quality data and evaluated potential health
 PHYLLIS FOX, PH.D., PAGE 16

risks of exposure to low concentrations of hydrogen sulfide. Judge awarded damages to

plaintiffs.
 Assisted construction unions in challenging PSD permit for an Indiana steel mill. Prepared
technical comments on draft PSD permit, drafted 70-page appeal of agency permit action to
the Environmental Appeals Board challenging permit based on faulty BACT analysis for
electric arc furnace and reheat furnace and faulty permit conditions, among others, and
drafted briefs responding to four parties. EPA Region V and the EPA General Counsel
intervened as amici, supporting petitioners. EAB ruled in favor of petitioners, remanding
permit to IDEM on three key issues, including BACT for the reheat furnace and lead
emissions from the EAF. Drafted motion to reconsider three issues. Prepared 69 pages of
technical comments on revised draft PSD permit. Drafted second EAB appeal addressing
lead emissions from the EAF and BACT for reheat furnace based on European experience
with SCR/SNCR. Case settled. Permit was substantially improved. See In re: Steel
Dynamics, Inc., PSD Appeal Nos. 99-4 & 99-5 (EAB June 22, 2000).
 Assisted defendant urea manufacturer in Alaska in negotiations with USEPA to seek relief
from penalties for alleged violations of the Clean Air Act. Reviewed and evaluated
regulatory files and monitoring data, prepared technical analysis demonstrating that permit
limits were not violated, and participated in negotiations with EPA to dismiss action. Fines
were substantially reduced and case closed.
 Assisted construction unions in challenging PSD permitting action for an Indiana grain mill.
Prepared technical comments on draft PSD permit and assisted counsel draft appeal of
agency permit action to the Environmental Appeals Board challenging permit based on faulty
BACT analyses for heaters and boilers and faulty permit conditions, among others. Case
settled.
 As part of a consent decree settling a CEQA lawsuit, assisted neighbors of a large west coast
port in negotiations with port authority to secure mitigation for air quality impacts. Prepared
technical comments on mobile source air quality impacts and mitigation and negotiated a $9
million CEQA mitigation package. Represented neighbors on technical advisory committee
established by port to implement the air quality mitigation program. Program successfully
implemented.
 Assisted construction unions in challenging permitting action for a California hazardous
waste incinerator. Prepared technical comments on draft permit, assisted counsel prepare
appeal of EPA permit to the Environmental Appeals Board. Participated in settlement
discussions on technical issues with applicant and EPA Region 9. Case settled.
 Assisted environmental group in challenging DTSC Negative Declaration on a hazardous
waste treatment facility. Prepared technical comments on risk of upset, water, and health
risks. Writ of mandamus issued.
 PHYLLIS FOX, PH.D., PAGE 17

 Assisted several neighborhood associations and cities impacted by quarries, asphalt plants,
and cement plants in Alameda, Shasta, Sonoma, and Mendocino counties in obtaining
mitigations for dust, air quality, public health, traffic, and noise impacts from facility
operations and proposed expansions.
 For over 100 industrial facilities, commercial/campus, and redevelopment projects,
developed the record in preparation for CEQA and NEPA lawsuits. Prepared technical
comments on hazardous materials, solid wastes, public utilities, noise, worker safety, air
quality, public health, water resources, water quality, traffic, and risk of upset sections of
EIRs, EISs, FONSIs, initial studies, and negative declarations. Assisted counsel in drafting
petitions and briefs and prepared declarations.
 For several large commercial development projects and airports, assisted applicant and
counsel prepare defensible CEQA documents, respond to comments, and identify and
evaluate "all feasible" mitigation to avoid CEQA challenges. This work included developing
mitigation programs to reduce traffic-related air quality impacts based on energy
conservation programs, solar, low-emission vehicles, alternative fuels, exhaust treatments,
and transportation management associations.

SITE INVESTIGATION/REMEDIATION/CLOSURE

 Technical manager and principal engineer for characterization, remediation, and closure of
waste management units at former Colorado oil shale plant. Constituents of concern
included BTEX, As, 1,1,1-TCA, and TPH. Completed groundwater monitoring programs,
site assessments, work plans, and closure plans for seven process water holding ponds, a
refinery sewer system, and processed shale disposal area. Managed design and construction
of groundwater treatment system and removal actions and obtained clean closure.
 Principal engineer for characterization, remediation, and closure of process water ponds at a
former lanthanide processing plant in Colorado. Designed and implemented groundwater
monitoring program and site assessments and prepared closure plan.
 Advised the city of Sacramento on redevelopment of two former railyards. Reviewed work
plans, site investigations, risk assessment, RAPS, RI/FSs, and CEQA documents.
Participated in the development of mitigation strategies to protect construction and utility
workers and the public during remediation, redevelopment, and use of the site, including
buffer zones, subslab venting, rail berm containment structure, and an environmental
oversight plan.
 Provided technical support for the investigation of a former sanitary landfill that was
redeveloped as single family homes. Reviewed and/or prepared portions of numerous
documents, including health risk assessments, preliminary endangerment assessments, site
investigation reports, work plans, and RI/FSs. Historical research to identify historic waste
 PHYLLIS FOX, PH.D., PAGE 18

disposal practices to prepare a preliminary endangerment assessment. Acquired, reviewed,

and analyzed the files of 18 federal, state, and local agencies, three sets of construction field
notes, analyzed 21 aerial photographs and interviewed 14 individuals associated with
operation of former landfill. Assisted counsel in defending lawsuit brought by residents
alleging health impacts and diminution of property value due to residual contamination.
Prepared summary reports.
 Technical oversight of characterization and remediation of a nitrate plume at an explosives
manufacturing facility in Lincoln, CA. Provided interface between owners and consultants.
Reviewed site assessments, work plans, closure plans, and RI/FSs.
 Consultant to owner of large western molybdenum mine proposed for NPL listing.
Participated in negotiations to scope out consent order and develop scope of work.
Participated in studies to determine premining groundwater background to evaluate
applicability of water quality standards. Served on technical committees to develop
alternatives to mitigate impacts and close the facility, including resloping and grading,
various thickness and types of covers, and reclamation. This work included developing and
evaluating methods to control surface runoff and erosion, mitigate impacts of acid rock
drainage on surface and ground waters, and stabilize nine waste rock piles containing 328
million tons of pyrite-rich, mixed volcanic waste rock (andesites, rhyolite, tuff). Evaluated
stability of waste rock piles. Represented client in hearings and meetings with state and
federal oversight agencies.

REGULATORY (PARTIAL LIST)

 In August 2017, review an Initial Study/Negative Declaration for a winery expansion and
write 20 pages of comments on air quality and Valley Fever.
 In August 2017, reviewed DEIR on a new residential community in eastern San Diego
County and researched and wrote 60 pages of comments on air quality, greenhouse gas
emissions, and health impacts.
 In July 2017, reviewed the FEIS for an expansion of the Port of Gulfport and researched and
wrote 10 pages of comments on air quality and public health.
 In June 2017, reviewed and prepared technical report on an Application for a synthetic
minor source construction permit for a new Refinery in North Dakota.
 In June 2017, reviewed responses to NPCA and other comments on the BP Cherry Point
Refinery modifications and assisted counsel in evaluating issues to appeal, including GHG
BACT, coker heater SCR cost effectiveness analysis, and SO2 BACT.
 PHYLLIS FOX, PH.D., PAGE 19

 In June 2017, reviewed Part 70 Operating Permit Renewal/Modification for the Noranda
Alumina LC/Gramercy Holdings I, LLC alumina processing plant, St. James, Louisiana, and
prepared comments on HAP emissions from bauxite feedstock.
 In May and June 2017, reviewed FEIR on Tesoro Integration Project and prepared responses
to comments on the DEIR.
 In May 2017, prepared comments on tank VOC and HAP emissions from Tesoro Integration
Project, based on real time monitoring at the Tesoro and other refineries in the SCAQMD.
 In April 2017, prepared comments on Negative Declaration for Delicato Winery in San
Joaquin County, California.
 In March 2017, reviewed Negative Declaration for Ellmore geothermal facility in Imperial
County, California and prepared summary of issues.
 In March 2017, prepared response to Phillips 66 Company’s Appeal of the San Luis Obispo
County Planning Commission’s Decision Denying the Rail Spur Extension Project Proposed
for the Santa Maria Refinery.
 In February 2017, prepared comments on Kalama draft Title V permit for 10,000 MT/day
methanol production and marine export facility in Kalama, Washington.
 In January 2017, researched and wrote 51 pages of comments on proposed Title V and PSD
permits for the St. James Methanol Plant, St. James Louisiana, on BACT and enforceability
of permit conditions.
 In December 2016, prepared comments on draft Title V Permit for Yuhuang Chemical Inc.
Methanol Plant, St. James, Louisiana, responding to EPA Order addressing enforceability
issues.
 In November 2016, prepared comments on Initial Study/Mitigated Negative Declaration for
the AES Battery Energy Storage Facility, Long Beach, CA.
 In November 2016, prepared comments on Campo Verde Battery Energy Storage System
Draft Environmental Impact Report.
 In October 2016, prepared comments on Title V Permit for NuStar Terminal Operations
Partnership L.P, Stockton, CA.
 In October 2016, prepared expert report, Technical Assessment of Achieving the 40 CFR
Part 423 Zero Discharge Standard for Bottom Ash Transport Water at the Belle River Power
Plant, East China, Michigan. Reported resulted in a 2 year reduction in compliance date for
elimination of bottom ash transport water. 1/30/17 DEQ Letter.
 In September 2016, prepared comments on Proposed Title V Permit and Environmental
Assessment Statement, Yuhuang Chemical Inc. Methanol Plant, St. James, Louisiana.
 PHYLLIS FOX, PH.D., PAGE 20

 In September 2016, prepared response to “Further Rebuttal in Support of Appeal of Planning

Commission Resolution No. 16-1, Denying Use Permit Application 12PLN-00063 and
Declining to Certify Final Environmental Impact Report for the Valero Benicia Crude-by-
Rail Project.
 In August 2016, reviewed and prepared comments on manuscript: Hutton et al., Freshwater
Flows to the San Francisco Bay-Delta Estuary over Nine Decades: Trends Evaluation.
 In August/September 2016, prepared comments on Mitigated Negative Declaration for the
Chevron Long Wharf Maintenance and Efficiency Project.
 In July 2016, prepared comments on the Ventura County APCD Preliminary Determination
of Compliance and the California Energy Commission Revised Preliminary Staff Assessment
for the Puente Power Project.
 In June 2016, prepared comments on an Ordinance (1) Amending the Oakland Municipal
Code to Prohibit the Storage and Handling of Coal and Coke at Bulk Material Facilities or
Terminals Throughout the City of Oakland and (2) Adopting CEQA Exemption Findings and
supporting technical reports. Council approved Ordinance on an 8 to 0 vote on June 27,
2016.
 In May 2016, prepared comments on Draft Title V Permit and Draft Environmental Impact
Report for the Tesoro Los Angeles Refinery Integration and Compliance Project.
 In March 2016, prepared comments on Valero’s Appeal of Planning Commission’s Denial of
Valero Crude-by-Rail Project
 In February 2016, prepared comments on Final Environmental Impact Report, Santa Maria
Rail Spur Project.
 In February 2016, prepared comments on Final Environmental Impact Report, Valero
Benicia Crude by Rail Project.
 In January 2016, prepared comments on Draft Programmatic Environmental Impact Report
for the Southern California Association of Government’s (SCAG) 2016-2040 Regional
Transportation Plan/Sustainable Communities Strategy.
 In November 2015, prepared comments on Final Environmental Impact Report for Revisions
to the Kern County Zoning Ordinance – 2015(C) (Focused on Oil and Gas Local Permitting),
November 2015.
 In October 2015, prepared comments on Revised Draft Environmental Report, Valero
Benicia Crude by Rail Project.
 In September 2015, prepared report, “Environmental, Health and Safety Impacts of the
Proposed Oakland Bulk and Oversized Terminal, and presented oral testimony on September
21, 2015 before Oakland City Council on behalf of the Sierra Club.
 PHYLLIS FOX, PH.D., PAGE 21

 In September 2015, prepared comments on revisions to two chapters of EPA’s Air Pollution
Control Cost Manual: Docket ID No. EPA-HQ-OAR-2015-0341.
 In June 2015, prepared comments on DEIR for the CalAm Monterey Peninsula Water Supply
Project.
 In April 2015, prepared comments on proposed Title V Operating Permit Revision and
Prevention of Significant Deterioration Permit for Arizona Public Service’s Ocotillo Power
Plant Modernization Project (5 GE LMS100 105-MW simple cycle turbines operated as
peakers), in Tempe, Arizona; Final permit appealed to EAB.
 In March 2015, prepared “Comments on Proposed Title V Air Permit, Yuhuang Chemical
Inc. Methanol Plant, St. James, Louisiana”. Client filed petition objecting to the permit.
EPA granted majority of issues. In the Matter of Yuhuang Chemical Inc. Methanol Plant, St.
James Parish, Louisiana, Permit No. 2560-00295-V0, Issued by the Louisiana Department of
Environmental Quality, Petition No. VI-2015-03, Order Responding to the Petitioners’
Request for Objection to the Issuance of a Title V Operating Permit, September 1, 2016.
 In February 2015, prepared compilation of BACT cost effectiveness values in support of
comments on draft PSD Permit for Bonanza Power Project.
 In January 2015, prepared cost effectiveness analysis for SCR for a 500-MW coal fire power
plant, to address unpermitted upgrades in 2000.
 In January 2015, prepared comments on Revised Final Environmental Impact Report for the
Phillips 66 Propane Recovery Project. Communities for a Better Environment et al. v.
Contra Costa County et al. Contra Costa County (Superior Court, Contra Costa County,
Case No. MSN15-0301, December 1, 2016).
 In December 2014, prepared “Report on Bakersfield Crude Terminal Permits to Operate.” In
response, the U.S. EPA cited the Terminal for 10 violations of the Clean Air Act. The Fifth
Appellate District Court upheld the finding in this report in CBE et al v. San Joaquin Valley
Unified Air Pollution Control District and Bakersfield Crude Terminal LLC et al, Super. Ct.
No. 284013, June 23, 2017.
 In December 2014, prepared comments on Revised Draft Environmental Impact Report for
the Phillips 66 Propane Recovery Project.
 In November 2014, prepared comments on Revised Draft Environmental Impact Report for
Phillips 66 Rail Spur Extension Project and Crude Unloading Project, Santa Maria, CA to
allow the import of tar sands crudes.
 In November 2014, prepared comments on Draft Environmental Impact Report for Phillips
66 Ultra Low Sulfur Diesel Project, responding to the California Supreme Court Decision,
Communities for a Better Environment v. South Coast Air Quality Management Dist. (2010)
48 Cal.4th 310.
 PHYLLIS FOX, PH.D., PAGE 22

 In November 2014, prepared comments on Draft Environmental Impact Report for the
Tesoro Avon Marine Oil Terminal Lease Consideration.
 In October 2014, prepared: “Report on Hydrogen Cyanide Emissions from Fluid Catalytic
Cracking Units”, pursuant to the Petroleum Refinery Sector Risk and Technology Review
and New Source Performance Standards, 79 FR 36880.
 In October 2014, prepared technical comments on Final Environmental Impact Reports for
Alon Bakersfield Crude Flexibility Project to build a rail terminal to allow the import/export
of tar sands and Bakken crude oils and to upgrade an existing refinery to allow it to process a
wide range of crudes.
 In October 2014, prepared technical comments on the Title V Permit Renewal and three De
Minimus Significant Revisions for the Tesoro Logistics Marine Terminal in the SCAQMD.
 In September 2014, prepared technical comments on the Draft Environmental Impact Report
for the Valero Crude by Rail Project.
 In August 2014, for EPA Region 6, prepared technical report on costing methods for
upgrades to existing scrubbers at coal-fired power plants.
 In July 2014, prepared technical comments on Draft Final Environmental Impact Reports for
Alon Bakersfield Crude Flexibility Project to build a rail terminal to allow the import/export
of tar sands and Bakken crude oils and to upgrade an existing refinery to allow it to process a
wide range of crudes.
 In June 2014, prepared technical report on Initial Study and Draft Negative Declaration for
the Tesoro Logistics Storage Tank Replacement and Modification Project.
 In May 2014, prepared technical comments on Intent to Approve a new refinery and
petroleum transloading operation in Utah.
 In March and April 2014, prepared declarations on air permits issued for two crude-by-rail
terminals in California, modified to switch from importing ethanol to importing Bakken
crude oils by rail and transferring to tanker cars. Permits were issued without undergoing
CEQA review. One permit was upheld by the San Francisco Superior Court as statute of
limitations had run. The Sacramento Air Quality Management District withdrew the second
one due to failure to require BACT and conduct CEQA review.
 In March 2014, prepared technical report on Negative Declaration for a proposed
modification of the air permit for a bulk petroleum and storage terminal to the allow the
import of tar sands and Bakken crude oil by rail and its export by barge, under the New York
State Environmental Quality Review Act (SEQRA).
 In February 2014, prepared technical report on proposed modification of air permit for
midwest refinery upgrade/expansion to process tar sands crudes.
 PHYLLIS FOX, PH.D., PAGE 23

 In January 2014, prepared cost estimates to capture, transport, and use CO2 in enhanced oil
recovery, from the Freeport LNG project based on both Selexol and Amine systems.
 In January 2014, prepared technical report on Draft Environmental Impact Report for
Phillips 66 Rail Spur Extension Project, Santa Maria, CA. Comments addressed project
description (piecemealing, crude slate), risk of upset analyses, mitigation measures,
alternative analyses and cumulative impacts.
 In November 2013, prepared technical report on the Phillips 66 Propane Recovery Project,
Rodeo, CA. Comments addressed project description (piecemealing, crude slate) and air
quality impacts.
 In September 2013, prepared technical report on the Draft Authority to Construct Permit for
the Casa Diablo IV Geothermal Development Project Environmental Impact Report and
Declaration in Support of Appeal and Petition for Stay, U.S. Department of the Interior,
Board of Land Appeals, Appeal of Decision Record for the Casa Diablo IV Geothermal
Development Project.
 In September 2013, prepared technical report on Effluent Limitation Guidelines for Best
Available Technology Economically Available (BAT) for Bottom Ash Transport Waters
from Coal-Fired Power Plants in the Steam Electric Power Generating Point Source
Category.
 In July 2013, prepared technical report on Initial Study/Mitigated Negative Declaration for
the Valero Crude by Rail Project, Benicia, California, Use Permit Application 12PLN-00063.
 In July 2013, prepared technical report on fugitive particulate matter emissions from coal
train staging at the proposed Coyote Island Terminal, Oregon, for draft Permit No. 25-0015-
ST-01.
 In July 2013, prepared technical comments on air quality impacts of the Finger Lakes LPG
Storage Facility as reported in various Environmental Impact Statements.
 In July 2013, prepared technical comments on proposed Greenhouse Gas PSD Permit for the
Celanese Clear Lake Plant, including cost analysis of CO2 capture, transport, and
sequestration.
 In June/July 2013, prepared technical comments on proposed Draft PSD Preconstruction
Permit for Greenhouse Gas Emission for the ExxonMobil Chemical Company Baytown
Olefins Plant, including cost analysis of CO2 capture, transport, and sequestration.
 In June 2013, prepared technical report on a Mitigated Negative Declaration for a new rail
terminal at the Valero Benicia Refinery to import increased amounts of "North American"
crudes. Comments addressed air quality impacts of refining increased amounts of tar sands
crudes.
 PHYLLIS FOX, PH.D., PAGE 24

 In June 2013, prepared technical report on Draft Environmental Impact Report for the
California Ethanol and Power Imperial Valley 1 Project.
 In May 2013, prepared comments on draft PSD permit for major expansion of midwest
refinery to process 100% tar sands crudes, including a complex netting analysis involving
debottlenecking, piecemealing, and BACT analyses.
 In April 2013, prepared technical report on the Draft Supplemental Environmental Impact
Statement (DSEIS) for the Keystone XL Pipeline on air quality impacts from refining
increased amount of tar sands crudes at Refineries in PADD 3.
 In October 2012, prepared technical report on the Environmental Review for the Coyote
Island Terminal Dock at the Port of Morrow on fugitive particulate matter emissions.
 In October 2012-October 2014, review and evaluate Flint Hills West Application for an
expansion/modification for increased (Texas, Eagle Ford Shale) crude processing and related
modification, including netting and BACT analysis. Assist in settlement discussions.
 In February 2012, prepared comments on BART analysis in PA Regional Haze SIP, 77 FR
3984 (Jan. 26, 2012). On Sept. 29, 2015, a federal appeals court overturned the U.S. EPA’s
approval of this plan, based in part on my comments, concluding “..we will vacate the 2014
Final Rule to the extent it approved Pennsylvania’s source-specific BART analysis and
remand to the EPA for further proceedings consistent with this Opinion.” Nat’l Parks
Conservation Assoc. v. EPA, 3d Cir., No. 14-3147, 9/19/15.
 Prepared cost analyses and comments on New York’s proposed BART determinations for
NOx, SO2, and PM and EPA’s proposed approval of BART determinations for Danskammer
Generating Station under New York Regional Haze State Implementation Plan and Federal
Implementation Plan, 77 FR 51915 (August 28, 2012).
 Prepared cost analyses and comments on NOx BART determinations for Regional Haze
State Implementation Plan for State of Nevada, 77 FR 23191 (April 18, 2012) and 77 FR
25660 (May 1, 2012).
 Prepared analyses of and comments on New Source Performance Standards for Greenhouse
Gas Emissions for New Stationary Sources: Electric Utility Generating Units, 77 FR 22392
(April 13, 2012).
 Prepared comments on CASPR-BART emission equivalency and NOx and PM BART
determinations in EPA proposed approval of State Implementation Plan for Pennsylvania
Regional Haze Implementation Plan, 77 FR 3984 (January 26, 2012).
 Prepared comments and statistical analyses on hazardous air pollutants (HAPs) emission
controls, monitoring, compliance methods, and the use of surrogates for acid gases, organic
HAPs, and metallic HAPs for proposed National Emission Standards for Hazardous Air
 PHYLLIS FOX, PH.D., PAGE 25

Pollutants from Coal- and Oil-Fired Electric Utility Steam Generating Units, 76 FR 24976
(May 3, 2011).
 Prepared cost analyses and comments on NOx BART determinations and emission
reductions for proposed Federal Implementation Plan for Four Corners Power Plant, 75 FR
64221 (October 19, 2010).
 Prepared cost analyses and comments on NOx BART determinations for Colstrip Units 1- 4
for Montana State Implementation Plan and Regional Haze Federal Implementation Plan, 77
FR 23988 (April 20, 2010).
 For EPA Region 8, prepared report: Revised BART Cost Effectiveness Analysis for Tail-End
Selective Catalytic Reduction at the Basin Electric Power Cooperative Leland Olds Station
Unit 2 Final Report, March 2011, in support of 76 FR 58570 (Sept. 21, 2011).
 For EPA Region 6, prepared report: Revised BART Cost-Effectiveness Analysis for
Selective Catalytic Reduction at the Public Service Company of New Mexico San Juan
Generating Station, November 2010, in support of 76 FR 52388 (Aug. 22, 2011).
 For EPA Region 6, prepared report: Revised BART Cost-Effectiveness Analysis for Flue Gas
Desulfurization at Coal-Fired Electric Generating Units in Oklahoma: Sooner Units 1 & 2,
Muskogee Units 4 & 5, Northeastern Units 3 &4, October 2010, in support of 76 FR 16168
(March 26, 2011). My work was upheld in: State of Oklahoma v. EPA, App. Case 12-9526
(10th Cri. July 19, 2013).
 Identified errors in N2O emission factors in the Mandatory Greenhouse Gas Reporting Rule,
40 CFR 98, and prepared technical analysis to support Petition for Rulemaking to Correct
Emissions Factors in the Mandatory Greenhouse Gas Reporting Rule, filed with EPA on
10/28/10.
 Assisted interested parties develop input for and prepare comments on the Information
Collection Request for Petroleum Refinery Sector NSPS and NESHAP Residual Risk and
Technology Review, 75 FR 60107 (9/29/10).
 Technical reviewer of EPA's "Emission Estimation Protocol for Petroleum Refineries,"
posted for public comments on CHIEF on 12/23/09, prepared in response to the City of
Houston's petition under the Data Quality Act (March 2010).
 Prepared comments on SCR cost effectiveness for EPA's Advanced Notice of Proposed
Rulemaking, Assessment of Anticipated Visibility Improvements at Surrounding Class I
Areas and Cost Effectiveness of Best Available Retrofit Technology for Four Corners Power
Plant and Navajo Generating Station, 74 FR 44313 (August 28, 2009).
 Prepared comments on Proposed Rule for Standards of Performance for Coal Preparation and
Processing Plants, 74 FR 25304 (May 27, 2009).
 PHYLLIS FOX, PH.D., PAGE 26

 Prepared comments on draft PSD permit for major expansion of midwest refinery to process
up to 100% tar sands crudes. Participated in development of monitoring and controls to
mitigate impacts and in negotiating a Consent Decree to settle claims in 2008.
 Reviewed and assisted interested parties prepare comments on proposed Kentucky air toxic
regulations at 401 KAR 64:005, 64:010, 64:020, and 64:030 (June 2007).
 Prepared comments on proposed Standards of Performance for Electric Utility Steam
Generating Units and Small Industrial-Commercial-Industrial Steam Generating Units, 70
FR 9706 (February 28, 2005).
 Prepared comments on Louisville Air Pollution Control District proposed Strategic Toxic Air
Reduction regulations.
 Prepared comments and analysis of BAAQMD Regulation, Rule 11, Flare Monitoring at
Petroleum Refineries.
 Prepared comments on Proposed National Emission Standards for Hazardous Air Pollutants;
and, in the Alternative, Proposed Standards of Performance for New and Existing Stationary
Sources: Electricity Utility Steam Generating Units (MACT standards for coal-fired power
plants).
 Prepared Authority to Construct Permit for remediation of a large petroleum-contaminated
site on the California Central Coast. Negotiated conditions with agencies and secured
permits.
 Prepared Authority to Construct Permit for remediation of a former oil field on the California
Central Coast. Participated in negotiations with agencies and secured permits.
 Prepared and/or reviewed hundreds of environmental permits, including NPDES, UIC,
Stormwater, Authority to Construct, Prevention of Significant Deterioration, Nonattainment
New Source Review, Title V, and RCRA, among others.
 Participated in the development of the CARB document, Guidance for Power Plant Siting
and Best Available Control Technology, including attending public workshops and filing
technical comments.
 Performed data analyses in support of adoption of emergency power restoration standards by
the California Public Utilities Commission for “major” power outages, where major is an
outage that simultaneously affects 10% of the customer base.
 Drafted portions of the Good Neighbor Ordinance to grant Contra Costa County greater
authority over safety of local industry, particularly chemical plants and refineries.
 Participated in drafting BAAQMD Regulation 8, Rule 28, Pressure Relief Devices,
including participation in public workshops, review of staff reports, draft rules and other
 PHYLLIS FOX, PH.D., PAGE 27

technical materials, preparation of technical comments on staff proposals, research on

availability and costs of methods to control PRV releases, and negotiations with staff.
 Participated in amending BAAQMD Regulation 8, Rule 18, Valves and Connectors,
including participation in public workshops, review of staff reports, proposed rules and other
supporting technical material, preparation of technical comments on staff proposals, research
on availability and cost of low-leak technology, and negotiations with staff.
 Participated in amending BAAQMD Regulation 8, Rule 25, Pumps and Compressors,
including participation in public workshops, review of staff reports, proposed rules, and other
supporting technical material, preparation of technical comments on staff proposals, research
on availability and costs of low-leak and seal-less technology, and negotiations with staff.
 Participated in amending BAAQMD Regulation 8, Rule 5, Storage of Organic Liquids,
including participation in public workshops, review of staff reports, proposed rules, and other
supporting technical material, preparation of technical comments on staff proposals, research
on availability and costs of controlling tank emissions, and presentation of testimony before
the Board.
 Participated in amending BAAQMD Regulation 8, Rule 18, Valves and Connectors at
Petroleum Refinery Complexes, including participation in public workshops, review of staff
reports, proposed rules and other supporting technical material, preparation of technical
comments on staff proposals, research on availability and costs of low-leak technology, and
presentation of testimony before the Board.
 Participated in amending BAAQMD Regulation 8, Rule 22, Valves and Flanges at Chemical
Plants, etc, including participation in public workshops, review of staff reports, proposed
rules, and other supporting technical material, preparation of technical comments on staff
proposals, research on availability and costs of low-leak technology, and presentation of
testimony before the Board.
 Participated in amending BAAQMD Regulation 8, Rule 25, Pump and Compressor Seals,
including participation in public workshops, review of staff reports, proposed rules, and other
supporting technical material, preparation of technical comments on staff proposals, research
on availability of low-leak technology, and presentation of testimony before the Board.
 Participated in the development of the BAAQMD Regulation 2, Rule 5, Toxics, including
participation in public workshops, review of staff proposals, and preparation of technical
comments.
 Participated in the development of SCAQMD Rule 1402, Control of Toxic Air Contaminants
from Existing Sources, and proposed amendments to Rule 1401, New Source Review of
Toxic Air Contaminants, in 1993, including review of staff proposals and preparation of
technical comments on same.
 PHYLLIS FOX, PH.D., PAGE 28

 Participated in the development of the Sunnyvale Ordinance to Regulate the Storage, Use
and Handling of Toxic Gas, which was designed to provide engineering controls for gases
that are not otherwise regulated by the Uniform Fire Code.
 Participated in the drafting of the Statewide Water Quality Control Plans for Inland Surface
Waters and Enclosed Bays and Estuaries, including participation in workshops, review of
draft plans, preparation of technical comments on draft plans, and presentation of testimony
before the SWRCB.
 Participated in developing Se permit effluent limitations for the five Bay Area refineries,
including review of staff proposals, statistical analyses of Se effluent data, review of
literature on aquatic toxicity of Se, preparation of technical comments on several staff
proposals, and presentation of testimony before the Bay Area RWQCB.
 Represented the California Department of Water Resources in the 1991 Bay-Delta Hearings
before the State Water Resources Control Board, presenting sworn expert testimony with
cross examination and rebuttal on a striped bass model developed by the California
Department of Fish and Game.
 Represented the State Water Contractors in the 1987 Bay-Delta Hearings before the State
Water Resources Control Board, presenting sworn expert testimony with cross examination
and rebuttal on natural flows, historical salinity trends in San Francisco Bay, Delta outflow,
and hydrodynamics of the South Bay.
 Represented interveners in the licensing of over 20 natural-gas-fired power plants and one
coal gasification plant at the California Energy Commission and elsewhere. Reviewed and
prepared technical comments on applications for certification, preliminary staff assessments,
final staff assessments, preliminary determinations of compliance, final determinations of
compliance, and prevention of significant deterioration permits in the areas of air quality,
water supply, water quality, biology, public health, worker safety, transportation, site
contamination, cooling systems, and hazardous materials. Presented written and oral
testimony in evidentiary hearings with cross examination and rebuttal. Participated in
technical workshops.
 Represented several parties in the proposed merger of San Diego Gas & Electric and
Southern California Edison. Prepared independent technical analyses on health risks, air
quality, and water quality. Presented written and oral testimony before the Public Utilities
Commission administrative law judge with cross examination and rebuttal.
 Represented a PRP in negotiations with local health and other agencies to establish impact of
subsurface contamination on overlying residential properties. Reviewed health studies
prepared by agency consultants and worked with agencies and their consultants to evaluate
health risks.
 PHYLLIS FOX, PH.D., PAGE 29

WATER QUALITY/RESOURCES
 Directed and participated in research on environmental impacts of energy development in the
Colorado River Basin, including contamination of surface and subsurface waters and
modeling of flow and chemical transport through fractured aquifers.
 Played a major role in Northern California water resource planning studies since the early
1970s. Prepared portions of the Basin Plans for the Sacramento, San Joaquin, and Delta
basins including sections on water supply, water quality, beneficial uses, waste load
allocation, and agricultural drainage. Developed water quality models for the Sacramento
and San Joaquin Rivers.
 Conducted hundreds of studies over the past 40 years on Delta water supplies and the
impacts of exports from the Delta on water quality and biological resources of the Central
Valley, Sacramento-San Joaquin Delta, and San Francisco Bay. Typical examples include:
1. Evaluate historical trends in salinity, temperature, and flow in San Francisco Bay
and upstream rivers to determine impacts of water exports on the estuary;
2. Evaluate the role of exports and natural factors on the food web by exploring the
relationship between salinity and primary productivity in San Francisco Bay,
upstream rivers, and ocean;
3. Evaluate the effects of exports, other in-Delta, and upstream factors on the
abundance of salmon and striped bass;
4. Review and critique agency fishery models that link water exports with the
abundance of striped bass and salmon;
5. Develop a model based on GLMs to estimate the relative impact of exports,
water facility operating variables, tidal phase, salinity, temperature, and other
variables on the survival of salmon smolts as they migrate through the Delta;
6. Reconstruct the natural hydrology of the Central Valley using water balances,
vegetation mapping, reservoir operation models to simulate flood basins,
precipitation records, tree ring research, and historical research;
7. Evaluate the relationship between biological indicators of estuary health and
down-estuary position of a salinity surrogate (X2);
8. Use real-time fisheries monitoring data to quantify impact of exports on fish
migration;
9. Refine/develop statistical theory of autocorrelation and use to assess strength of
relationships between biological and flow variables;
10. Collect, compile, and analyze water quality and toxicity data for surface waters in
the Central Valley to assess the role of water quality in fishery declines;
 PHYLLIS FOX, PH.D., PAGE 30

11. Assess mitigation measures, including habitat restoration and changes in water
project operation, to minimize fishery impacts;
12. Evaluate the impact of unscreened agricultural water diversions on abundance of
larval fish;
13. Prepare and present testimony on the impacts of water resources development on
Bay hydrodynamics, salinity, and temperature in water rights hearings;
14. Evaluate the impact of boat wakes on shallow water habitat, including
interpretation of historical aerial photographs;
15. Evaluate the hydrodynamic and water quality impacts of converting Delta islands
into reservoirs;
16. Use a hydrodynamic model to simulate the distribution of larval fish in a tidally
influenced estuary;
17. Identify and evaluate non-export factors that may have contributed to fishery
declines, including predation, shifts in oceanic conditions, aquatic toxicity from
pesticides and mining wastes, salinity intrusion from channel dredging, loss of
riparian and marsh habitat, sedimentation from upstream land alternations, and
changes in dissolved oxygen, flow, and temperature below dams.

 Developed, directed, and participated in a broad-based research program on environmental

issues and control technology for energy industries including petroleum, oil shale, coal
mining, and coal slurry transport. Research included evaluation of air and water pollution,
development of novel, low-cost technology to treat and dispose of wastes, and development
and application of geohydrologic models to evaluate subsurface contamination from in-situ
retorting. The program consisted of government and industry contracts and employed 45
technical and administrative personnel.
 Coordinated an industry task force established to investigate the occurrence, causes, and
solutions for corrosion/erosion and mechanical/engineering failures in the waterside systems
(e.g., condensers, steam generation equipment) of power plants. Corrosion/erosion failures
caused by water and steam contamination that were investigated included waterside
corrosion caused by poor microbiological treatment of cooling water, steam-side corrosion
caused by ammonia-oxygen attack of copper alloys, stress-corrosion cracking of copper
alloys in the air cooling sections of condensers, tube sheet leaks, oxygen in-leakage through
condensers, volatilization of silica in boilers and carry over and deposition on turbine blades,
and iron corrosion on boiler tube walls. Mechanical/engineering failures investigated
included: steam impingement attack on the steam side of condenser tubes, tube-to-tube-sheet
joint leakage, flow-induced vibration, structural design problems, and mechanical failures
due to stresses induced by shutdown, startup and cycling duty, among others. Worked with
 PHYLLIS FOX, PH.D., PAGE 31

electric utility plant owners/operators, condenser and boiler vendors, and architect/engineers
to collect data to document the occurrence of and causes for these problems, prepared reports
summarizing the investigations, and presented the results and participated on a committee of
industry experts tasked with identifying solutions to prevent condenser failures.
 Evaluated the cost effectiveness and technical feasibility of using dry cooling and parallel
dry-wet cooling to reduce water demands of several large natural-gas fired power plants in
California and Arizona.
 Designed and prepared cost estimates for several dry cooling systems (e.g., fin fan heat
exchangers) used in chemical plants and refineries.
 Designed, evaluated, and costed several zero liquid discharge systems for power plants.
 Evaluated the impact of agricultural and mining practices on surface water quality of Central
Valley steams. Represented municipal water agencies on several federal and state advisory
committees tasked with gathering and assessing relevant technical information, developing
work plans, and providing oversight of technical work to investigate toxicity issues in the
watershed.
AIR QUALITY/PUBLIC HEALTH
 Prepared or reviewed the air quality and public health sections of hundreds of EIRs and EISs
on a wide range of industrial, commercial and residential projects.
 Prepared or reviewed hundreds of NSR and PSD permits for a wide range of industrial
facilities.
 Designed, implemented, and directed a 2-year-long community air quality monitoring
program to assure that residents downwind of a petroleum-contaminated site were not
impacted during remediation of petroleum-contaminated soils. The program included real-
time monitoring of particulates, diesel exhaust, and BTEX and time integrated monitoring
for over 100 chemicals.
 Designed, implemented, and directed a 5-year long source, industrial hygiene, and ambient
monitoring program to characterize air emissions, employee exposure, and downwind
environmental impacts of a first-generation shale oil plant. The program included stack
monitoring of heaters, boilers, incinerators, sulfur recovery units, rock crushers, API
separator vents, and wastewater pond fugitives for arsenic, cadmium, chlorine, chromium,
mercury, 15 organic indicators (e.g., quinoline, pyrrole, benzo(a)pyrene, thiophene, benzene),
sulfur gases, hydrogen cyanide, and ammonia. In many cases, new methods had to be
developed or existing methods modified to accommodate the complex matrices of shale plant
gases.
 Conducted investigations on the impact of diesel exhaust from truck traffic from a wide
range of facilities including mines, large retail centers, light industrial uses, and sports
 PHYLLIS FOX, PH.D., PAGE 32

facilities. Conducted traffic surveys, continuously monitored diesel exhaust using an

aethalometer, and prepared health risk assessments using resulting data.
 Conducted indoor air quality investigations to assess exposure to natural gas leaks,
pesticides, molds and fungi, soil gas from subsurface contamination, and outgasing of
carpets, drapes, furniture and construction materials. Prepared health risk assessments using
collected data.
 Prepared health risk assessments, emission inventories, air quality analyses, and assisted in
the permitting of over 70 1 to 2 MW emergency diesel generators.
 Prepare over 100 health risk assessments, endangerment assessments, and other health-based
studies for a wide range of industrial facilities.
 Developed methods to monitor trace elements in gas streams, including a continuous real-
time monitor based on the Zeeman atomic absorption spectrometer, to continuously measure
mercury and other elements.
 Performed nuisance investigations (odor, noise, dust, smoke, indoor air quality, soil
contamination) for businesses, industrial facilities, and residences located proximate to and
downwind of pollution sources.

PUBLICATIONS AND PRESENTATIONS (Partial List - Representative

Publications)

J.P. Fox, P.H. Hutton, D.J. Howes, A.J. Draper, and L. Sears, Reconstructing the Natural
Hydrology of the San Francisco Bay-Delta Watershed, Hydrology and Earth System Sciences,
Special Issue: Predictions under Change: Water, Earth, and Biota in the Anthropocene, v. 19,
pp. 4257-4274, 2015. http://www.hydrol-earth-syst-sci.net/19/4257/2015/hess-19-4257-2015.pdf. See
also: Estimates of Natural and Unimpaired Flows for the Central Valley of California: Water
Years 1922-2014 at: https://msb.water.ca.gov/documents/86728/a702a57f-ae7a-41a3-8bff-
722e144059d6.
D. Howes, P. Fox, and P. Hutton, Evapotranspiration from Natural Vegetation in the Central
Valley of California: Monthly Grass Reference Based Vegetation Coefficients and the Dual Crop
Coefficient Approach, Journal of Hydrologic Engineering, v.20, no. 10, October 2015.
Phyllis Fox and Lindsey Sears, Natural Vegetation in the Central Valley of California, June
2014, Prepared for State Water Contractors and San Luis & Delta-Mendota Water Authority, 311
pg.
J.P. Fox, T.P. Rose, and T.L. Sawyer, Isotope Hydrology of a Spring-fed Waterfall in Fractured
Volcanic Rock, 2007.
 PHYLLIS FOX, PH.D., PAGE 33

C.E. Lambert, E.D. Winegar, and Phyllis Fox, Ambient and Human Sources of Hydrogen
Sulfide: An Explosive Topic, Air & Waste Management Association, June 2000, Salt Lake City,
UT.
San Luis Obispo County Air Pollution Control District and San Luis Obispo County Public
Health Department, Community Monitoring Program, February 8, 1999.
The Bay Institute, From the Sierra to the Sea. The Ecological History of the San Francisco Bay-
Delta Watershed, 1998.
J. Phyllis Fox, Well Interference Effects of HDPP’s Proposed Wellfield in the Victor Valley
Water District, Prepared for the California Unions for Reliable Energy (CURE), October 12,
1998.
J. Phyllis Fox, Air Quality Impacts of Using CPVC Pipe in Indoor Residential Potable Water
Systems, Report Prepared for California Pipe Trades Council, California Firefighters Association,
and other trade associations, August 29, 1998.
J. Phyllis Fox and others, Authority to Construct Avila Beach Remediation Project, Prepared for
Unocal Corporation and submitted to San Luis Obispo Air Pollution Control District, June 1998.
J. Phyllis Fox and others, Authority to Construct Former Guadalupe Oil Field Remediation
Project, Prepared for Unocal Corporation and submitted to San Luis Obispo Air Pollution
Control District, May 1998.
J. Phyllis Fox and Robert Sears, Health Risk Assessment for the Metropolitan Oakland
International Airport Proposed Airport Development Program, Prepared for Plumbers &
Steamfitters U.A. Local 342, December 15, 1997.
Levine-Fricke-Recon (Phyllis Fox and others), Preliminary Endangerment Assessment Work
Plan for the Study Area Operable Unit, Former Solano County Sanitary Landfill, Benicia,
California, Prepared for Granite Management Co. for submittal to DTSC, September 26, 1997.
Phyllis Fox and Jeff Miller, "Fathead Minnow Mortality in the Sacramento River," IEP
Newsletter, v. 9, n. 3, 1996.
Jud Monroe, Phyllis Fox, Karen Levy, Robert Nuzum, Randy Bailey, Rod Fujita, and Charles
Hanson, Habitat Restoration in Aquatic Ecosystems. A Review of the Scientific Literature
Related to the Principles of Habitat Restoration, Part Two, Metropolitan Water District of
Southern California (MWD) Report, 1996.
Phyllis Fox and Elaine Archibald, Aquatic Toxicity and Pesticides in Surface Waters of the
Central Valley, California Urban Water Agencies (CUWA) Report, September 1997.
Phyllis Fox and Alison Britton, Evaluation of the Relationship Between Biological Indicators
and the Position of X2, CUWA Report, 1994.
 PHYLLIS FOX, PH.D., PAGE 34

Phyllis Fox and Alison Britton, Predictive Ability of the Striped Bass Model, WRINT DWR-206,
1992.
J. Phyllis Fox, An Historical Overview of Environmental Conditions at the North Canyon Area of
the Former Solano County Sanitary Landfill, Report Prepared for Solano County Department of
Environmental Management, 1991.
J. Phyllis Fox, An Historical Overview of Environmental Conditions at the East Canyon Area of
the Former Solano County Sanitary Landfill, Report Prepared for Solano County Department of
Environmental Management, 1991.
Phyllis Fox, Trip 2 Report, Environmental Monitoring Plan, Parachute Creek Shale Oil
Program, Unocal Report, 1991.
J. P. Fox and others, "Long-Term Annual and Seasonal Trends in Surface Salinity of San
Francisco Bay," Journal of Hydrology, v. 122, p. 93-117, 1991.
J. P. Fox and others, "Reply to Discussion by D.R. Helsel and E.D. Andrews on Trends in
Freshwater Inflow to San Francisco Bay from the Sacramento-San Joaquin Delta," Water
Resources Bulletin, v. 27, no. 2, 1991.
J. P. Fox and others, "Reply to Discussion by Philip B. Williams on Trends in Freshwater Inflow
to San Francisco Bay from the Sacramento-San Joaquin Delta," Water Resources Bulletin, v. 27,
no. 2, 1991.
J. P. Fox and others, "Trends in Freshwater Inflow to San Francisco Bay from the Sacramento-
San Joaquin Delta," Water Resources Bulletin, v. 26, no. 1, 1990.
J. P. Fox, "Water Development Increases Freshwater Flow to San Francisco Bay," SCWC
Update, v. 4, no. 2, 1988.
J. P. Fox, Freshwater Inflow to San Francisco Bay Under Natural Conditions, State Water
Contracts, Exhibit 262, 58 pp., 1987.
J. P. Fox, "The Distribution of Mercury During Simulated In-Situ Oil Shale Retorting,"
Environmental Science and Technology, v. 19, no. 4, pp. 316-322, 1985.
J. P. Fox, "El Mercurio en el Medio Ambiente: Aspectos Referentes al Peru," (Mercury in the
Environment: Factors Relevant to Peru) Proceedings of Simposio Los Pesticidas y el Medio
Ambiente," ONERN-CONCYTEC, Lima, Peru, April 25-27, 1984. (Also presented at Instituto
Tecnologico Pesquero and Instituto del Mar del Peru.)
J. P. Fox, "Mercury, Fish, and the Peruvian Diet," Boletin de Investigacion, Instituto Tecnologico
Pesquero, Lima, Peru, v. 2, no. 1, pp. 97-116, l984.
J. P. Fox, P. Persoff, A. Newton, and R. N. Heistand, "The Mobility of Organic Compounds in a
Codisposal System," Proceedings of the Seventeenth Oil Shale Symposium, Colorado School of
Mines Press, Golden, CO, 1984.
 PHYLLIS FOX, PH.D., PAGE 35

P. Persoff and J. P. Fox, "Evaluation of Control Technology for Modified In-Situ Oil Shale
Retorts," Proceedings of the Sixteenth Oil Shale Symposium, Colorado School of Mines Press,
Golden, CO, 1983.
J. P. Fox, Leaching of Oil Shale Solid Wastes: A Critical Review, University of Colorado
Report, 245 pp., July 1983.
J. P. Fox, Source Monitoring for Unregulated Pollutants from the White River Oil Shale Project,
VTN Consolidated Report, June 1983.
A. S. Newton, J. P. Fox, H. Villarreal, R. Raval, and W. Walker II, Organic Compounds in Coal
Slurry Pipeline Waters, Lawrence Berkeley Laboratory Report LBL-15121, 46 pp., Sept. 1982.
M. Goldstein et al., High Level Nuclear Waste Standards Analysis, Regulatory Framework
Comparison, Battelle Memorial Institute Report No. BPMD/82/E515-06600/3, Sept. 1982.
J. P. Fox et al., Literature and Data Search of Water Resource Information of the Colorado,
Utah, and Wyoming Oil Shale Basins, Vols. 1-12, Bureau of Land Management, 1982.
A. T. Hodgson, M. J. Pollard, G. J. Harris, D. C. Girvin, J. P. Fox, and N. J. Brown, Mercury
Mass Distribution During Laboratory and Simulated In-Situ Retorting, Lawrence Berkeley
Laboratory Report LBL-12908, 39 pp., Feb. 1982.
E. J. Peterson, A. V. Henicksman, J. P. Fox, J. A. O'Rourke, and P. Wagner, Assessment and
Control of Water Contamination Associated with Shale Oil Extraction and Processing, Los
Alamos National Laboratory Report LA-9084-PR, 54 pp., April 1982.
P. Persoff and J. P. Fox, Control Technology for In-Situ Oil Shale Retorts, Lawrence Berkeley
Laboratory Report LBL-14468, 118 pp., Dec. 1982.
J. P. Fox, Codisposal Evaluation: Environmental Significance of Organic Compounds,
Development Engineering Report, 104 pp., April 1982.
J. P. Fox, A Proposed Strategy for Developing an Environmental Water Monitoring Plan for the
Paraho-Ute Project, VTN Consolidated Report, Sept. 1982.
J. P. Fox, D. C. Girvin, and A. T. Hodgson, "Trace Elements in Oil Shale Materials," Energy and
Environmental Chemistry, Fossil Fuels, v.1, pp. 69-101, 1982.
M. Mehran, T. N. Narasimhan, and J. P. Fox, "Hydrogeologic Consequences of Modified In-situ
Retorting Process, Piceance Creek Basin, Colorado," Proceedings of the Fourteenth Oil Shale
Symposium, Colorado School of Mines Press, Golden, CO, 1981 (LBL-12063).
U. S. DOE (J. P. Fox and others), Western Oil Shale Development: A Technology Assessment, v.
1-9, Pacific Northwest Laboratory Report PNL-3830, 1981.
J. P. Fox (ed), "Oil Shale Research," Chapter from the Energy and Environment Division Annual
Report 1980, Lawrence Berkeley Laboratory Report LBL-11989, 82 pp., 1981 (author or co-
author of four articles in report).
 PHYLLIS FOX, PH.D., PAGE 36

D.C. Girvin and J.P. Fox, On-Line Zeeman Atomic Absorption Spectroscopy for Mercury
Analysis in Oil Shale Gases, U.S. EPA Report EPA-600/7-80-130, June 1980.
J. P. Fox, The Partitioning of Major, Minor, and Trace Elements during In-Situ Oil Shale
Retorting, Ph.D. Dissertation, U. of Ca., Berkeley, also Report LBL-9062, 441 pp., 1980 (Diss.
Abst. Internat., v. 41, no. 7, 1981).
J.P. Fox, "Elemental Composition of Simulated In Situ Oil Shale Retort Water," Analysis of
Waters Associated with Alternative Fuel Production, ASTM STP 720, L.P. Jackson and C.C.
Wright, Eds., American Society for Testing and Materials, pp. 101-128, 1981.
J. P. Fox, P. Persoff, P. Wagner, and E. J. Peterson, "Retort Abandonment -- Issues and Research
Needs," in Oil Shale: the Environmental Challenges, K. K. Petersen (ed.), p. 133, 1980
(Lawrence Berkeley Laboratory Report LBL-11197).
J. P. Fox and T. E. Phillips, "Wastewater Treatment in the Oil Shale Industry," in Oil Shale: the
Environmental Challenges, K. K. Petersen (ed.), p. 253, 1980 (Lawrence Berkeley Laboratory
Report LBL-11214).
R. D. Giauque, J. P. Fox, J. W. Smith, and W. A. Robb, "Geochemical Studies of Two Cores
from the Green River Oil Shale Formation," Transactions, American Geophysical Union, v. 61,
no. 17, 1980.
J. P. Fox, "The Elemental Composition of Shale Oils," Abstracts of Papers, 179th National
Meeting, ISBN 0-8412-0542-6, Abstract No. FUEL 17, 1980.
J. P. Fox and P. Persoff, "Spent Shale Grouting of Abandoned In-Situ Oil Shale Retorts,"
Proceedings of Second U.S. DOE Environmental Control Symposium, CONF-800334/1, 1980
(Lawrence Berkeley Laboratory Report LBL-10744).
P. K. Mehta, P. Persoff, and J. P. Fox, "Hydraulic Cement Preparation from Lurgi Spent Shale,"
Proceedings of the Thirteenth Oil Shale Symposium, Colorado School of Mines Press, Golden,
CO, 1980 (Lawrence Berkeley Laboratory Report LBL-11071).
F. E. Brinckman, K. L. Jewett, R. H. Fish, and J. P. Fox, "Speciation of Inorganic and
Organoarsenic Compounds in Oil Shale Process Waters by HPLC Coupled with Graphite
Furnace Atomic Absorption (GFAA) Detectors," Abstracts of Papers, Div. of Geochemistry,
Paper No. 20, Second Chemical Congress of the North American Continent, August 25-28, 1980,
Las Vegas (1980).
J. P. Fox, D. E. Jackson, and R. H. Sakaji, "Potential Uses of Spent Shale in the Treatment of Oil
Shale Retort Waters," Proceedings of the Thirteenth Oil Shale Symposium, Colorado School of
Mines Press, Golden, CO, 1980 (Lawrence Berkeley Laboratory Report LBL-11072).
J. P. Fox, The Elemental Composition of Shale Oils, Lawrence Berkeley Laboratory Report LBL-
10745, 1980.
 PHYLLIS FOX, PH.D., PAGE 37

R. H. Fish, J. P. Fox, F. E. Brinckman, and K. L. Jewett, Fingerprinting Inorganic and

Organoarsenic Compounds in Oil Shale Process Waters Using a Liquid Chromatograph
Coupled with an Atomic Absorption Detector, Lawrence Berkeley Laboratory Report LBL-
11476, 1980.
National Academy of Sciences (J. P. Fox and others), Surface Mining of Non-Coal Minerals,
Appendix II: Mining and Processing of Oil Shale and Tar Sands, 222 pp., 1980.
J. P. Fox, "Elemental Composition of Simulated In-Situ Oil Shale Retort Water," in Analysis of
Waters Associated with Alternative Fuel Production, ASTM STP 720, L. P. Jackson and C. C.
Wright (eds.), American Society for Testing and Materials, pp. 101-128, 1980.
R. D. Giauque, J. P. Fox, and J. W. Smith, Characterization of Two Core Holes from the Naval
Oil Shale Reserve Number 1, Lawrence Berkeley Laboratory Report LBL-10809, 176 pp.,
December 1980.
B. M. Jones, R. H. Sakaji, J. P. Fox, and C. G. Daughton, "Removal of Contaminative
Constituents from Retort Water: Difficulties with Biotreatment and Potential Applicability of
Raw and Processed Shales," EPA/DOE Oil Shale Wastewater Treatability Workshop, December
1980 (Lawrence Berkeley Laboratory Report LBL-12124).
J. P. Fox, Water-Related Impacts of In-Situ Oil Shale Processing, Lawrence Berkeley Laboratory
Report LBL-6300, 327 p., December 1980.
M. Mehran, T. N. Narasimhan, and J. P. Fox, An Investigation of Dewatering for the Modified
In-Situ Retorting Process, Piceance Creek Basin, Colorado, Lawrence Berkeley Laboratory
Report LBL-11819, 105 p., October 1980.
J. P. Fox (ed.) "Oil Shale Research," Chapter from the Energy and Environment Division Annual
Report 1979, Lawrence Berkeley Laboratory Report LBL-10486, 1980 (author or coauthor of
eight articles).
E. Ossio and J. P. Fox, Anaerobic Biological Treatment of In-Situ Oil Shale Retort Water,
Lawrence Berkeley Laboratory Report LBL-10481, March 1980.
J. P. Fox, F. H. Pearson, M. J. Kland, and P. Persoff, Hydrologic and Water Quality Effects and
Controls for Surface and Underground Coal Mining -- State of Knowledge, Issues, and Research
Needs, Lawrence Berkeley Laboratory Report LBL-11775, 1980.
D. C. Girvin, T. Hadeishi, and J. P. Fox, "Use of Zeeman Atomic Absorption Spectroscopy for
the Measurement of Mercury in Oil Shale Offgas," Proceedings of the Oil Shale Symposium:
Sampling, Analysis and Quality Assurance, U.S. EPA Report EPA-600/9-80-022, March 1979
(Lawrence Berkeley Laboratory Report LBL-8888).
D. S. Farrier, J. P. Fox, and R. E. Poulson, "Interlaboratory, Multimethod Study of an In-Situ
Produced Oil Shale Process Water," Proceedings of the Oil Shale Symposium: Sampling,
 PHYLLIS FOX, PH.D., PAGE 38

Analysis and Quality Assurance, U.S. EPA Report EPA-600/9-80-022, March 1979 (Lawrence
Berkeley Laboratory Report LBL-9002).
J. P. Fox, J. C. Evans, J. S. Fruchter, and T. R. Wildeman, "Interlaboratory Study of Elemental
Abundances in Raw and Spent Oil Shales," Proceedings of the Oil Shale Symposium: Sampling,
Analysis and Quality Assurance, U.S. EPA Report EPA-600/9-80-022, March 1979 (Lawrence
Berkeley Laboratory Report LBL-8901).
J. P. Fox, "Retort Water Particulates," Proceedings of the Oil Shale Symposium: Sampling,
Analysis and Quality Assurance, U.S. EPA Report EPA-600/9-80-022, March 1979 (Lawrence
Berkeley Laboratory Report LBL-8829).
P. Persoff and J. P. Fox, "Control Strategies for In-Situ Oil Shale Retorts," Proceedings of the
Twelfth Oil Shale Symposium, Colorado School of Mines Press, Golden, CO, 1979 (Lawrence
Berkeley Laboratory Report LBL-9040).
J. P. Fox and D. L. Jackson, "Potential Uses of Spent Shale in the Treatment of Oil Shale Retort
Waters," Proceedings of the DOE Wastewater Workshop, Washington, D. C., June 14-15, 1979
(Lawrence Berkeley Laboratory Report LBL-9716).
J. P. Fox, K. K. Mason, and J. J. Duvall, "Partitioning of Major, Minor, and Trace Elements
during Simulated In-Situ Oil Shale Retorting," Proceedings of the Twelfth Oil Shale Symposium,
Colorado School of Mines Press, Golden, CO, 1979 (Lawrence Berkeley Laboratory Report
LBL-9030).
P. Persoff and J. P. Fox, Control Strategies for Abandoned In-Situ Oil Shale Retorts, Lawrence
Berkeley Laboratory Report LBL-8780, 106 pp., October 1979.
D. C. Girvin and J. P. Fox, On-Line Zeeman Atomic Absorption Spectroscopy for Mercury
Analysis in Oil Shale Gases, Environmental Protection Agency Report EPA-600/7-80-130, 95 p.,
August 1979 (Lawrence Berkeley Laboratory Report LBL-9702).
J. P. Fox, Water Quality Effects of Leachates from an In-Situ Oil Shale Industry, Lawrence
Berkeley Laboratory Report LBL-8997, 37 pp., April 1979.
J. P. Fox (ed.), "Oil Shale Research," Chapter from the Energy and Environment Division
Annual Report 1978, Lawrence Berkeley Laboratory Report LBL-9857 August 1979 (author or
coauthor of seven articles).
J. P. Fox, P. Persoff, M. M. Moody, and C. J. Sisemore, "A Strategy for the Abandonment of
Modified In-Situ Oil Shale Retorts," Proceedings of the First U.S. DOE Environmental Control
Symposium, CONF-781109, 1978 (Lawrence Berkeley Laboratory Report LBL-6855).
E. Ossio, J. P. Fox, J. F. Thomas, and R. E. Poulson, "Anaerobic Fermentation of Simulated In-
Situ Oil Shale Retort Water," Division of Fuel Chemistry Preprints, v. 23, no. 2, p. 202-213,
1978 (Lawrence Berkeley Laboratory Report LBL-6855).
 PHYLLIS FOX, PH.D., PAGE 39

J. P. Fox, J. J. Duvall, R. D. McLaughlin, and R. E. Poulson, "Mercury Emissions from a

Simulated In-Situ Oil Shale Retort," Proceedings of the Eleventh Oil Shale Symposium,
Colorado School of Mines Press, Golden, CO, 1978 (Lawrence Berkeley Laboratory Report
LBL-7823).
J. P. Fox, R. D. McLaughlin, J. F. Thomas, and R. E. Poulson, "The Partitioning of As, Cd, Cu,
Hg, Pb, and Zn during Simulated In-Situ Oil Shale Retorting," Proceedings of the Tenth Oil
Shale Symposium, Colorado School of Mines Press, Golden, CO, 1977.
Bechtel, Inc., Treatment and Disposal of Toxic Wastes, Report Prepared for Santa Ana
Watershed Planning Agency, 1975.
Bay Valley Consultants, Water Quality Control Plan for Sacramento, Sacramento-San Joaquin
and San Joaquin Basins, Parts I and II and Appendices A-E, 750 pp., 1974.
 PHYLLIS FOX, PH.D., PAGE 40

POST GRADUATE COURSES

(Partial)

S-Plus Data Analysis, MathSoft, 6/94.

Air Pollutant Emission Calculations, UC Berkeley Extension, 6-7/94
Assessment, Control and Remediation of LNAPL Contaminated Sites, API and USEPA, 9/94
Pesticides in the TIE Process, SETAC, 6/96
Sulfate Minerals: Geochemistry, Crystallography, and Environmental Significance,
Mineralogical Society of America/Geochemical Society, 11/00.
Design of Gas Turbine Combined Cycle and Cogeneration Systems, Thermoflow, 12/00
Air-Cooled Steam Condensers and Dry- and Hybrid-Cooling Towers, Power-Gen, 12/01
Combustion Turbine Power Augmentation with Inlet Cooling and Wet Compression,
Power-Gen , 12/01
CEQA Update, UC Berkeley Extension, 3/02
The Health Effects of Chemicals, Drugs, and Pollutants, UC Berkeley Extension, 4-5/02
Noise Exposure Assessment: Sampling Strategy and Data Acquisition, AIHA PDC 205, 6/02
Noise Exposure Measurement Instruments and Techniques, AIHA PDC 302, 6/02
Noise Control Engineering, AIHA PDC 432, 6/02
Optimizing Generation and Air Emissions, Power-Gen, 12/02
Utility Industry Issues, Power-Gen, 12/02
Multipollutant Emission Control, Coal-Gen, 8/03
Community Noise, AIHA PDC 104, 5/04
Cutting-Edge Topics in Noise and Hearing Conservation, AIHA 5/04
Selective Catalytic Reduction: From Planning to Operation, Power-Gen, 12/05
Improving the FGD Decision Process, Power-Gen, 12/05
E-Discovery, CEB, 6/06
McIlvaine Hot Topic Hour, FGD Project Delay Factors, 8/10/06
McIlvaine Hot Topic Hour, What Mercury Technologies Are Available, 9/14/06
McIlvaine Hot Topic Hour, SCR Catalyst Choices, 10/12/06
McIlvaine Hot Topic Hour, Particulate Choices for Low Sulfur Coal, 10/19/06
McIlvaine Hot Topic Hour, Impact of PM2.5 on Power Plant Choices, 11/2/06
McIlvaine Hot Topic Hour, Dry Scrubbers, 11/9/06
Cost Estimating and Tricks of the Trade – A Practical Approach, PDH P159, 11/19/06
Process Equipment Cost Estimating by Ratio & Proportion, PDH G127 11/19/06
Power Plant Air Quality Decisions, Power-Gen 11/06
McIlvaine Hot Topic Hour, WE Energies Hg Control Update, 1/12/07
Negotiating Permit Conditions, EEUC, 1/21/07
BACT for Utilities, EEUC, 1/21/07
McIlvaine Hot Topic Hour, Chinese FGD/SCR Program & Impact on World, 2/1/07
McIlvaine Hot Topic Hour, Mercury Control Cost & Performance, 2/15/07
McIlvaine Hot Topic Hour, Mercury CEMS, 4/12/07
 PHYLLIS FOX, PH.D., PAGE 41

Coal-to-Liquids – A Timely Revival, 9th Electric Power, 4/30/07

Advances in Multi-Pollutant and CO2 Control Technologies, 9th Electric Power, 4/30/07
McIlvaine Hot Topic Hour, Measurement & Control of PM2.5, 5/17/07
McIlvaine Hot Topic Hour, Co-firing and Gasifying Biomass, 5/31/07
McIlvaine Hot Topic Hour, Mercury Cost and Performance, 6/14/07
Ethanol 101: Points to Consider When Building an Ethanol Plant, BBI International, 6/26/07
Low Cost Optimization of Flue Gas Desulfurization Equipment, Fluent, Inc., 7/6/07.
McIlvaine Hot Topic Hour, CEMS for Measurement of NH3, SO3, Low NOx, 7/12/07
McIlvaine Hot Topic Hour, Mercury Removal Status & Cost, 8/9/07
McIlvaine Hot Topic Hour, Filter Media Selection for Coal-Fired Boilers, 9/13/07
McIlvaine Hot Topic Hour, Catalyst Performance on NOx, SO3, Mercury, 10/11/07
PRB Coal Users Group, PRB 101, 12/4/07
McIlvaine Hot Topic Hour, Mercury Control Update, 10/25/07
Circulating Fluidized Bed Boilers, Their Operation, Control and Optimization, Power-Gen,
12/8/07
Renewable Energy Credits & Greenhouse Gas Offsets, Power-Gen, 12/9/07
Petroleum Engineering & Petroleum Downstream Marketing, PDH K117, 1/5/08
Estimating Greenhouse Gas Emissions from Manufacturing, PDH C191, 1/6/08
McIlvaine Hot Topic Hour, NOx Reagents, 1/17/08
McIlvaine Hot Topic Hour, Mercury Control, 1/31/08
McIlvaine Hot Topic Hour, Mercury Monitoring, 3/6/08
McIlvaine Hot Topic Hour, SCR Catalysts, 3/13/08
Argus 2008 Climate Policy Outlook, 3/26/08
Argus Pet Coke Supply and Demand 2008, 3/27/08
McIlvaine Hot Topic Hour, SO3 Issues and Answers, 3/27/08
McIlvaine Hot Topic Hour, Mercury Control, 4/24/08
McIlvaine Hot Topic Hour, Co-Firing Biomass, 5/1/08
McIlvaine Hot Topic Hour, Coal Gasification, 6/5/08
McIlvaine Hot Topic Hour, Spray Driers vs. CFBs, 7/3/08
McIlvaine Hot Topic Hour, Air Pollution Control Cost Escalation, 9/25/08
McIlvaine Hot Topic Hour, Greenhouse Gas Strategies for Coal Fired Power Plant Operators,
10/2/08
McIlvaine Hot Topic Hour, Mercury and Toxics Monitoring, 2/5/09
McIlvaine Hot Topic Hour, Dry Precipitator Efficiency Improvements, 2/12/09
McIlvaine Hot Topic Hour, Coal Selection & Impact on Emissions, 2/26/09
McIlvaine Hot Topic Hour, 98% Limestone Scrubber Efficiency, 7/9/09
McIlvaine Hot Topic Hour, Carbon Management Strategies and Technologies, 6/24/10
McIlvaine Hot Topic Hour, Gas Turbine O&M, 7/22/10
McIlvaine Hot Topic Hour, Industrial Boiler MACT – Impact and Control Options, March 10,
2011
 PHYLLIS FOX, PH.D., PAGE 42

McIlvaine Hot Topic Hour, Fuel Impacts on SCR Catalysts, June 30, 2011.
Interest Rates, PDH P204, 3/9/12
Mechanics Liens, PDHOnline, 2/24/13.
Understanding Concerns with Dry Sorbent Injection as a Coal Plant Pollution Control, Webinar
#874-567-839 by Cleanenergy.Org, March 4, 2013
Webinar: Coal-to-Gas Switching: What You Need to Know to Make the Investment, sponsored
by PennWell Power Engineering Magazine, March 14, 2013. Available at:
https://event.webcasts.com/viewer/event.jsp?ei=1013472.
 24-Aug-17

CO2 capture capacity Operation Transport length

Facility name (click on link to view) Lifecycle stage Country State / district Industry Capture type Transport type Primary storage type
(Mtpa) date (km)

Terrell Natural Gas Processing Plant (formerly Val

Operating UNITED STATES Texas 0.4-0.5 1972 Natural gas processing Industrial separation Pipeline 316 Enhanced oil recovery
Verde Natural Gas Plants)

Enid Fertilizer Operating UNITED STATES Oklahoma 0.7 1982 Fertiliser production Industrial separation Pipeline 225 Enhanced oil recovery

Multiple, maximum of
Shute Creek Gas Processing Plant Operating UNITED STATES Wyoming 7.0 1986 Natural gas processing Industrial separation Pipeline Enhanced oil recovery
460 km
No transport
Dedicated geological storage -
Sleipner CO2 Storage Operating NORWAY North Sea 1 1996 Natural gas processing Industrial separation required (direct Not applicable
offshore deep saline formations
injection)

Great Plains Synfuel Plant and Weyburn-Midale Operating CANADA Saskatchewan 3.0 2000 Synthetic natural gas Industrial separation Pipeline 329 Enhanced oil recovery

Dedicated geological storage -

Snøhvit CO2 Storage Operating NORWAY Barents Sea 0.7 2008 Natural gas processing Industrial separation Pipeline 153
offshore deep saline formations

Century Plant Operating UNITED STATES Texas 8.4 2010 Natural gas processing Industrial separation Pipeline 64 to 240 Enhanced oil recovery

Air Products Steam Methane Reformer Operating UNITED STATES Texas 1.0 2013 Hydrogen production Industrial separation Pipeline 158 Enhanced oil recovery

Coffeyville Gasification Plant Operating UNITED STATES Kansas 1.0 2013 Fertiliser production Industrial separation Pipeline 112 Enhanced oil recovery

[verify] Operating UNITED STATES Wyoming 0.9 2013 Natural gas processing Industrial separation Pipeline 374 Enhanced oil recovery

No transport
Santos Basin (off the
Petrobras Santos Basin Pre-Salt Oil Field CCS Operating BRAZIL Approx. 1.0 2013 Natural gas processing Industrial separation required (direct Not applicable Enhanced oil recovery
coast of Rio de Janeiro)
injection)

Boundary Dam Carbon Capture and Storage Operating CANADA Saskatchewan 1.0 2014 Power generation Post-combustion capture Pipeline 66 Enhanced oil recovery

Uthmaniyah CO2-EOR Demonstration Operating SAUDI ARABIA Eastern Province 0.8 2015 Natural gas processing Industrial separation Pipeline 85 Enhanced oil recovery

Dedicated geological storage -

Quest Operating CANADA Alberta Approx. 1.0 2015 Hydrogen production Industrial separation Pipeline 64
onshore deep saline formations

Abu Dhabi CCS Project (Phase 1 being Emirates UNITED ARAB

Operating Abu Dhabi 0.8 2016 Iron and steel production Industrial separation Pipeline 43 Enhanced oil recovery
Steel Industries) EMIRATES

Petra Nova Carbon Capture Operating UNITED STATES Texas 1.4 2017 Power generation Post-combustion capture Pipeline 132 Enhanced oil recovery

Dedicated geological storage -

Illinois Industrial Carbon Capture and Storage Operating UNITED STATES Illinois 1.0 2017 Ethanol production Industrial separation Pipeline 1.6
onshore deep saline formations

Dedicated geological storage -

Gorgon Carbon Dioxide Injection In construction AUSTRALIA Western Australia 3.4-4.0 2017 Natural gas processing Industrial separation Pipeline 7
onshore deep saline formations

Alberta Carbon Trunk Line ("ACTL") with Agrium

In construction CANADA Alberta 0.3-0.6 2018 Fertiliser production Industrial separation Pipeline 240 Enhanced oil recovery
CO2 Stream

Alberta Carbon Trunk Line ("ACTL") with North

In construction CANADA Alberta 1.2-1.4 2018 Oil refining Industrial separation Pipeline 240 Enhanced oil recovery
West Sturgeon Refinery CO2 Stream

Yanchang Integrated Carbon Capture and Storage

In construction CHINA Shaanxi Province 0.41 2018-19 Chemical Production Industrial separation Pipeline 150 Enhanced oil recovery
Demonstration

Sinopec Qilu Petrochemical CCS Advanced development CHINA Shandong Province 0.5 2021 Chemical Production Industrial separation Pipeline 75 Enhanced oil recovery

2022 (Institute
Lake Charles Methanol Advanced development UNITED STATES Louisiana 4.2 Chemical production Industrial separation Pipeline 244 Enhanced oil recovery
estimate)

2022 (Institute
Texas Clean Energy Project Advanced development UNITED STATES Texas 1.5-2.0 Chemical production Industrial separation Pipeline Not specified Enhanced oil recovery
estimate)
Combination of
Dedicated geological storage -
Norway Full Chain CCS Advanced development NORWAY Southern Norway 1.2 2022 Various Various shipping and Under evaluation
offshore deep saline formations
pipeline
Dedicated geological storage -
CarbonNet Advanced development AUSTRALIA Victoria 1.0-5.0 2020's Under evaluation Under Evaluation Pipeline 130
offshore deep saline formations

Sinopec Eastern China CCS Early development CHINA Jiangsu Province 0.5 2020-2021 Fertiliser production Industrial separation Pipeline 200 Enhanced oil recovery

Sinopec Shengli Power Plant CCS Early development CHINA Shandong Province 1.0 2020's Power generation Post-combustion capture Pipeline 80 Enhanced oil recovery

China Resources Power (Haifeng) Integrated Dedicated geological storage -

Early development CHINA Guangdong Province 1.0 2020's Power generation Post-combustion capture Pipeline 150
Carbon Capture and Sequestration Demonstration offshore deep saline formations

Enhanced oil recovery

Pre-combustion capture
Huaneng GreenGen IGCC Project (Phase 3) Early development CHINA Tianjin 2.0 2020's Power generation Pipeline 50-100 important, dedicated geological
(gasification)
storage options under review

Either Gangwon province Dedicated geological storage -

Korea-CCS 1 Early development SOUTH KOREA 1.0 2020's Power generation Post-combustion capture Shipping Under evaluation
or Chungnam Province offshore deep saline formations

Pre-combustion or oxy- Dedicated geological storage -

Korea-CCS 2 Early development SOUTH KOREA Not Decided 1.0 2020's Power generation Shipping Under evaluation
combustion offshore deep saline formations

Dedicated geological storage -

Teesside Collective Early development UNITED KINGDOM Tees Valley 0.8 2020's Various Various Pipeline Under evaluation
offshore deep saline formations
Dedicated geological storage,
offshore deep saline formations
Caledonia Clean Energy Early development UNITED KINGDOM Scotland 3 2024 Power generation Post-combustion capture Pipeline 382
with potential for enhanced oil
recovery

Fertiliser production and Dedicated geological storage -

South West Hub Early development AUSTRALIA Western Australia 2.5 2025 Industrial separation Pipeline 80-110
power generation onshore deep saline formations

Shanxi International Energy Group CCUS Early development CHINA Shanxi Province 2.0 2020's Power generation Oxy-fuel combustion capture Pipeline Not specified Under evaluation

Ningxia Hui Autonomous

Shenhua Ningxia CTL Early development CHINA 2.0 2020's Coal-to-liquids (CTL) Industrial separation Pipeline 200-250 Under evaluation
Region
 EJSCREEN ACS Summary Report
Location: User-specified point center at 29.636760, -89.950810
Ring (buffer): 1-mile radius
Description: Myrtle Grove

Summary of ACS Estimates 2011 - 2015

Population 254
Population Density (per sq. mile) 232
Minority Population 240
% Minority 95%
Households 66
Housing Units 87
Housing Units Built Before 1950 4
Per Capita Income 15,425
Land Area (sq. miles) (Source: SF1) 1.09
% Land Area 54%
Water Area (sq. miles) (Source: SF1) 0.95
% Water Area 46%
2011 - 2015
Percent MOE (±)
ACS Estimates
Population by Race
Total 254 100% 437
Population Reporting One Race 254 100% 581
White 14 5% 107
Black 239 94% 411
American Indian 1 0% 27
Asian 0 0% 12
Pacific Islander 0 0% 12
Some Other Race 0 0% 12
Population Reporting Two or More Races 0 0% 12
Total Hispanic Population 0 0% 12
Total Non-Hispanic Population 253
White Alone 13 5% 107
Black Alone 239 94% 411
American Indian Alone 1 0% 27
Non-Hispanic Asian Alone 0 0% 12
Pacific Islander Alone 0 0% 12
Other Race Alone 0 0% 12
Two or More Races Alone 0 0% 12
Population by Sex
Male 120 47% 289
Female 133 53% 208
Population by Age
Age 0-4 8 3% 42
Age 0-17 68 27% 148
Age 18+ 186 73% 199
Age 65+ 24 9% 64

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race. N/A means not available.
Source: U.S. Census Bureau, American Community Survey (ACS) 2011 - 2015.

September 25, 2017 1/3

 EJSCREEN ACS Summary Report
Location: User-specified point center at 29.636760, -89.950810
Ring (buffer): 1-mile radius
Description: Myrtle Grove

2011 - 2015
Percent MOE (±)
ACS Estimates
Population 25+ by Educational Attainment
Total 148 100% 206
Less than 9th Grade 22 15% 59
9th - 12th Grade, No Diploma 17 11% 67
High School Graduate 76 51% 147
Some College, No Degree 23 15% 62
Associate Degree 2 1% 16
Bachelor's Degree or more 11 7% 48
Population Age 5+ Years by Ability to Speak English
Total 246 100% 437
Speak only English 246 100% 369
Non-English at Home1+2+3+4 0 0% 13
1
Speak English "very well" 0 0% 12
2
Speak English "well" 0 0% 12
3
Speak English "not well" 0 0% 12
4
Speak English "not at all" 0 0% 13
3+4
Speak English "less than well" 0 0% 13
2+3+4
Speak English "less than very well" 0 0% 13
Linguistically Isolated Households*
Total 0 0% 12
Speak Spanish 0 0% 12
Speak Other Indo-European Languages 0 0% 12
Speak Asian-Pacific Island Languages 0 0% 12
Speak Other Languages 0 0% 12
Households by Household Income
Household Income Base 66 100% 99
< $15,000 14 22% 64
$15,000 - $25,000 13 19% 55
$25,000 - $50,000 8 13% 65
$50,000 - $75,000 12 18% 53
$75,000 + 19 28% 74
Occupied Housing Units by Tenure
Total 66 100% 99
Owner Occupied 63 97% 91
Renter Occupied 2 3% 35
Employed Population Age 16+ Years
Total 197 100% 343
In Labor Force 111 56% 143
Civilian Unemployed in Labor Force 6 3% 27
Not In Labor Force 86 44% 313

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race. N/A means
not available. Source: U.S. Census Bureau, American Community Survey (ACS) 2011 - 2015.
*Households in which no one 14 and over speaks English "very well" or speaks English only.

September 25, 2017 2/3

 EJSCREEN ACS Summary Report
Location: User-specified point center at 29.636760, -89.950810
Ring (buffer): 1-mile radius
Description: Myrtle Grove

2011 - 2015
Percent MOE (±)
ACS Estimates
Population by Language Spoken at Home*
Total (persons age 5 and above) 246 100% 437
English N/A N/A N/A
Spanish N/A N/A N/A
French N/A N/A N/A
French Creole N/A N/A N/A
Italian N/A N/A N/A
Portuguese N/A N/A N/A
German N/A N/A N/A
Yiddish N/A N/A N/A
Other West Germanic N/A N/A N/A
Scandinavian N/A N/A N/A
Greek N/A N/A N/A
Russian N/A N/A N/A
Polish N/A N/A N/A
Serbo-Croatian N/A N/A N/A
Other Slavic N/A N/A N/A
Armenian N/A N/A N/A
Persian N/A N/A N/A
Gujarathi N/A N/A N/A
Hindi N/A N/A N/A
Urdu N/A N/A N/A
Other Indic N/A N/A N/A
Other Indo-European N/A N/A N/A
Chinese N/A N/A N/A
Japanese N/A N/A N/A
Korean N/A N/A N/A
Mon-Khmer, Cambodian N/A N/A N/A
Hmong N/A N/A N/A
Thai N/A N/A N/A
Laotian N/A N/A N/A
Vietnamese N/A N/A N/A
Other Asian N/A N/A N/A
Tagalog N/A N/A N/A
Other Pacific Island N/A N/A N/A
Navajo N/A N/A N/A
Other Native American N/A N/A N/A
Hungarian N/A N/A N/A
Arabic N/A N/A N/A
Hebrew N/A N/A N/A
African N/A N/A N/A
Other and non-specified N/A N/A N/A
Total Non-English N/A N/A N/A

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race. N/A means
not available. Source: U.S. Census Bureau, American Community Survey (ACS) 2011 - 2015.
*Population by Language Spoken at Home is available at the census tract summary level and up.

September 25, 2017 3/3

 EJSCREEN Census 2010 Summary Report
Location: User-specified point center at 29.636760, -89.950810
Ring (buffer): 1-mile radius
Description: Myrtle Grove

Summary Census 2010

Population 224
Population Density (per sq. mile) 205
Minority Population 199
% Minority 89%
Households 66
Housing Units 95
Land Area (sq. miles) 1.09
% Land Area 54%
Water Area (sq. miles) 0.95
% Water Area 46%

Population by Race Number Percent

Total 224 -------
Population Reporting One Race 220 98%
White 26 11%
Black 186 83%
American Indian 6 2%
Asian 2 1%
Pacific Islander 0 0%
Some Other Race 1 0%
Population Reporting Two or More Races 4 2%
Total Hispanic Population 2 1%
Total Non-Hispanic Population 222 99%
White Alone 25 11%
Black Alone 186 83%
American Indian Alone 5 2%
Non-Hispanic Asian Alone 2 1%
Pacific Islander Alone 0 0%
Other Race Alone 1 0%
Two or More Races Alone 3 1%

Population by Sex Number Percent

Male 108 48%
Female 116 52%

Population by Age Number Percent

Age 0-4 14 6%
Age 0-17 54 24%
Age 18+ 170 76%
Age 65+ 32 14%

Households by Tenure Number Percent

Total 66
Owner Occupied 62 93%
Renter Occupied 5 7%

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race.
Source: U.S. Census Bureau, Census 2010 Summary File 1.

1/1
 EJSCREEN Report (Version 2017)
1 mile Ring Centered at 29.636760,-89.950810, LOUISIANA, EPA Region 6
Approximate Population: 254
Input Area (sq. miles): 3.14
Myrtle Grove
State EPA Region USA
Selected Variables
Percentile Percentile Percentile
EJ Indexes
EJ Index for PM2.5 78 66 77
EJ Index for Ozone 84 71 82
EJ Index for NATA* Diesel PM 70 63 72
EJ Index for NATA* Air Toxics Cancer Risk 73 66 77
EJ Index for NATA* Respiratory Hazard Index 73 66 75
EJ Index for Traffic Proximity and Volume 66 56 67
EJ Index for Lead Paint Indicator 69 68 73
EJ Index for Superfund Proximity 70 64 71
EJ Index for RMP Proximity 64 56 68
EJ Index for Hazardous Waste Proximity 70 63 71
EJ Index for Wastewater Discharge Indicator 95 90 92

This report shows the values for environmental and demographic indicators and EJSCREEN indexes. It shows environmental and demographic raw data (e.g., the
estimated concentration of ozone in the air), and also shows what percentile each raw data value represents. These percentiles provide perspective on how the
selected block group or buffer area compares to the entire state, EPA region, or nation. For example, if a given location is at the 95th percentile nationwide, this
means that only 5 percent of the US population has a higher block group value than the average person in the location being analyzed. The years for which the
data are available, and the methods used, vary across these indicators. Important caveats and uncertainties apply to this screening-level information, so it is
essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of
these issues before using reports.
September 25, 2017 1/3
 EJSCREEN Report (Version 2017)
1 mile Ring Centered at 29.636760,-89.950810, LOUISIANA, EPA Region 6

Approximate Population: 254

Input Area (sq. miles): 3.14
Myrtle Grove

Sites reporting to EPA

Superfund NPL 0
Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDF) 0

September 25, 2017 2/3

 EJSCREEN Report (Version 2017)
1 mile Ring Centered at 29.636760,-89.950810, LOUISIANA, EPA Region 6
Approximate Population: 254
Input Area (sq. miles): 3.14
Myrtle Grove
EPA %ile in
Value State %ile in USA %ile in
Selected Variables Region EPA
Avg. State Avg. USA
Avg. Region
Environmental Indicators
Particulate Matter (PM 2.5 in µg/m3) 6.82 8.67 0 9.15 5 9.14 9
Ozone (ppb) 39.7 36.7 99 40.2 43 38.4 72
NATA* Diesel PM (µg/m3) 0.365 0.889 28 0.721 <50th 0.938 <50th
NATA* Cancer Risk (lifetime risk per million) 31 49 1 42 <50th 40 <50th
NATA* Respiratory Hazard Index 1.2 1.9 2 1.8 <50th 1.8 <50th
Traffic Proximity and Volume (daily traffic count/distance to road) 15 250 28 320 21 590 22
Lead Paint Indicator (% Pre-1960 Housing) 0.059 0.22 28 0.18 45 0.29 28
Superfund Proximity (site count/km distance) 0.022 0.083 27 0.078 31 0.13 19
RMP Proximity (facility count/km distance) 0.1 0.89 16 0.8 14 0.73 16
Hazardous Waste Proximity (facility count/km distance) 0.021 0.076 18 0.083 29 0.093 22
Wastewater Discharge Indicator 0.01 0.44 88 0.37 85 30 80
(toxicity-weighted concentration/m distance)
Demographic Indicators
Demographic Index 76% 40% 89 45% 86 36% 92
Minority Population 95% 41% 91 50% 90 38% 93
Low Income Population 56% 40% 77 39% 76 34% 82
Linguistically Isolated Population 0% 2% 62 6% 35 5% 44
Population With Less Than High School Education 26% 17% 80 17% 76 13% 85
Population Under 5 years of age 3% 7% 17 7% 15 6% 19
Population over 64 years of age 9% 13% 29 12% 41 14% 31
* The National-Scale Air Toxics Assessment (NATA) is EPA's ongoing, comprehensive evaluation of air toxics in the United States. EPA developed the NATA to
prioritize air toxics, emission sources, and locations of interest for further study. It is important to remember that NATA provides broad estimates of health risks
over geographic areas of the country, not definitive risks to specific individuals or locations. More information on the NATA analysis can be found
at: https://www.epa.gov/national-air-toxics-assessment.

For additional information, see: www.epa.gov/environmentaljustice

EJSCREEN is a screening tool for pre-decisional use only. It can help identify areas that may warrant additional consideration, analysis, or outreach. It does not
provide a basis for decision-making, but it may help identify potential areas of EJ concern. Users should keep in mind that screening tools are subject to substantial
uncertainty in their demographic and environmental data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this
screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see
EJSCREEN documentation for discussion of these issues before using reports. This screening tool does not provide data on every environmental impact and
demographic factor that may be relevant to a particular location. EJSCREEN outputs should be supplemented with additional information and local knowledge
before taking any action to address potential EJ concerns.
September 25, 2017 3/3
 EJSCREEN ACS Summary Report
Location: User-specified point center at 29.625705, -89.930812
Ring (buffer): 1-mile radius
Description:

Summary of ACS Estimates 2011 - 2015

Population 28
Population Density (per sq. mile) 71
Minority Population 22
% Minority 79%
Households 15
Housing Units 32
Housing Units Built Before 1950 0
Per Capita Income 13,007
Land Area (sq. miles) (Source: SF1) 0.40
% Land Area 54%
Water Area (sq. miles) (Source: SF1) 0.33
% Water Area 46%
2011 - 2015
Percent MOE (±)
ACS Estimates
Population by Race
Total 28 100% 437
Population Reporting One Race 28 100% 581
White 6 21% 107
Black 22 77% 411
American Indian 1 2% 27
Asian 0 0% 12
Pacific Islander 0 0% 12
Some Other Race 0 0% 12
Population Reporting Two or More Races 0 0% 12
Total Hispanic Population 0 0% 12
Total Non-Hispanic Population 28
White Alone 6 21% 107
Black Alone 22 77% 411
American Indian Alone 1 2% 27
Non-Hispanic Asian Alone 0 0% 12
Pacific Islander Alone 0 0% 12
Other Race Alone 0 0% 12
Two or More Races Alone 0 0% 12
Population by Sex
Male 15 54% 289
Female 13 46% 208
Population by Age
Age 0-4 0 0% 12
Age 0-17 9 31% 148
Age 18+ 20 69% 199
Age 65+ 3 10% 64

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race. N/A means not available.
Source: U.S. Census Bureau, American Community Survey (ACS) 2011 - 2015.

September 25, 2017 1/3

 EJSCREEN ACS Summary Report
Location: User-specified point center at 29.625705, -89.930812
Ring (buffer): 1-mile radius
Description:

2011 - 2015
Percent MOE (±)
ACS Estimates
Population 25+ by Educational Attainment
Total 14 100% 206
Less than 9th Grade 1 7% 49
9th - 12th Grade, No Diploma 1 7% 30
High School Graduate 9 64% 147
Some College, No Degree 2 16% 62
Associate Degree 0 0% 12
Bachelor's Degree or more 1 6% 28
Population Age 5+ Years by Ability to Speak English
Total 28 100% 437
Speak only English 28 100% 369
Non-English at Home1+2+3+4 0 0% 12
1
Speak English "very well" 0 0% 12
2
Speak English "well" 0 0% 12
3
Speak English "not well" 0 0% 12
4
Speak English "not at all" 0 0% 12
3+4
Speak English "less than well" 0 0% 12
2+3+4
Speak English "less than very well" 0 0% 12
Linguistically Isolated Households*
Total 0 0% 12
Speak Spanish 0 0% 12
Speak Other Indo-European Languages 0 0% 12
Speak Asian-Pacific Island Languages 0 0% 12
Speak Other Languages 0 0% 12
Households by Household Income
Household Income Base 15 100% 99
< $15,000 5 30% 64
$15,000 - $25,000 1 8% 31
$25,000 - $50,000 4 29% 65
$50,000 - $75,000 4 23% 53
$75,000 + 1 9% 25
Occupied Housing Units by Tenure
Total 15 100% 99
Owner Occupied 14 88% 91
Renter Occupied 2 12% 35
Employed Population Age 16+ Years
Total 21 100% 343
In Labor Force 7 33% 91
Civilian Unemployed in Labor Force 0 1% 13
Not In Labor Force 14 67% 313

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race. N/A means
not available. Source: U.S. Census Bureau, American Community Survey (ACS) 2011 - 2015.
*Households in which no one 14 and over speaks English "very well" or speaks English only.

September 25, 2017 2/3

 EJSCREEN ACS Summary Report
Location: User-specified point center at 29.625705, -89.930812
Ring (buffer): 1-mile radius
Description:

2011 - 2015
Percent MOE (±)
ACS Estimates
Population by Language Spoken at Home*
Total (persons age 5 and above) 28 100% 437
English N/A N/A N/A
Spanish N/A N/A N/A
French N/A N/A N/A
French Creole N/A N/A N/A
Italian N/A N/A N/A
Portuguese N/A N/A N/A
German N/A N/A N/A
Yiddish N/A N/A N/A
Other West Germanic N/A N/A N/A
Scandinavian N/A N/A N/A
Greek N/A N/A N/A
Russian N/A N/A N/A
Polish N/A N/A N/A
Serbo-Croatian N/A N/A N/A
Other Slavic N/A N/A N/A
Armenian N/A N/A N/A
Persian N/A N/A N/A
Gujarathi N/A N/A N/A
Hindi N/A N/A N/A
Urdu N/A N/A N/A
Other Indic N/A N/A N/A
Other Indo-European N/A N/A N/A
Chinese N/A N/A N/A
Japanese N/A N/A N/A
Korean N/A N/A N/A
Mon-Khmer, Cambodian N/A N/A N/A
Hmong N/A N/A N/A
Thai N/A N/A N/A
Laotian N/A N/A N/A
Vietnamese N/A N/A N/A
Other Asian N/A N/A N/A
Tagalog N/A N/A N/A
Other Pacific Island N/A N/A N/A
Navajo N/A N/A N/A
Other Native American N/A N/A N/A
Hungarian N/A N/A N/A
Arabic N/A N/A N/A
Hebrew N/A N/A N/A
African N/A N/A N/A
Other and non-specified N/A N/A N/A
Total Non-English N/A N/A N/A

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race. N/A means
not available. Source: U.S. Census Bureau, American Community Survey (ACS) 2011 - 2015.
*Population by Language Spoken at Home is available at the census tract summary level and up.

September 25, 2017 3/3

 EJSCREEN Census 2010 Summary Report
Location: User-specified point center at 29.625705, -89.930812
Ring (buffer): 1-mile radius
Description:

Summary Census 2010

Population 25
Population Density (per sq. mile) 63
Minority Population 17
% Minority 68%
Households 18
Housing Units 36
Land Area (sq. miles) 0.40
% Land Area 54%
Water Area (sq. miles) 0.33
% Water Area 46%

Population by Race Number Percent

Total 25 -------
Population Reporting One Race 24 97%
White 8 33%
Black 13 54%
American Indian 2 10%
Asian 0 0%
Pacific Islander 0 0%
Some Other Race 0 1%
Population Reporting Two or More Races 1 3%
Total Hispanic Population 0 1%
Total Non-Hispanic Population 25 99%
White Alone 8 32%
Black Alone 13 54%
American Indian Alone 2 10%
Non-Hispanic Asian Alone 0 0%
Pacific Islander Alone 0 0%
Other Race Alone 0 1%
Two or More Races Alone 1 3%

Population by Sex Number Percent

Male 12 48%
Female 13 52%

Population by Age Number Percent

Age 0-4 1 5%
Age 0-17 6 23%
Age 18+ 19 77%
Age 65+ 4 16%

Households by Tenure Number Percent

Total 18
Owner Occupied 17 92%
Renter Occupied 1 8%

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race.
Source: U.S. Census Bureau, Census 2010 Summary File 1.

1/1
 EJSCREEN Report (Version 2017)
1 mile Ring Centered at 29.625705,-89.930812, LOUISIANA, EPA Region 6
Approximate Population: 28
Input Area (sq. miles): 3.14

State EPA Region USA

Selected Variables
Percentile Percentile Percentile
EJ Indexes
EJ Index for PM2.5 79 68 78
EJ Index for Ozone 86 73 84
EJ Index for NATA* Diesel PM 75 68 75
EJ Index for NATA* Air Toxics Cancer Risk 75 67 78
EJ Index for NATA* Respiratory Hazard Index 74 67 76
EJ Index for Traffic Proximity and Volume 75 64 73
EJ Index for Lead Paint Indicator 62 61 68
EJ Index for Superfund Proximity 71 64 71
EJ Index for RMP Proximity 66 57 69
EJ Index for Hazardous Waste Proximity 70 63 72
EJ Index for Wastewater Discharge Indicator 95 90 92

This report shows the values for environmental and demographic indicators and EJSCREEN indexes. It shows environmental and demographic raw data (e.g., the
estimated concentration of ozone in the air), and also shows what percentile each raw data value represents. These percentiles provide perspective on how the
selected block group or buffer area compares to the entire state, EPA region, or nation. For example, if a given location is at the 95th percentile nationwide, this
means that only 5 percent of the US population has a higher block group value than the average person in the location being analyzed. The years for which the
data are available, and the methods used, vary across these indicators. Important caveats and uncertainties apply to this screening-level information, so it is
essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of
these issues before using reports.
September 25, 2017 1/3
 EJSCREEN Report (Version 2017)
1 mile Ring Centered at 29.625705,-89.930812, LOUISIANA, EPA Region 6

Approximate Population: 28
Input Area (sq. miles): 3.14

Sites reporting to EPA

Superfund NPL 0
Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDF) 0

September 25, 2017 2/3

 EJSCREEN Report (Version 2017)
1 mile Ring Centered at 29.625705,-89.930812, LOUISIANA, EPA Region 6
Approximate Population: 28
Input Area (sq. miles): 3.14

EPA %ile in
Value State %ile in USA %ile in
Selected Variables Region EPA
Avg. State Avg. USA
Avg. Region
Environmental Indicators
Particulate Matter (PM 2.5 in µg/m3) 6.83 8.67 0 9.15 6 9.14 9
Ozone (ppb) 39.1 36.7 98 40.2 38 38.4 66
NATA* Diesel PM (µg/m3) 0.486 0.889 39 0.721 <50th 0.938 <50th
NATA* Cancer Risk (lifetime risk per million) 31 49 1 42 <50th 40 <50th
NATA* Respiratory Hazard Index 1.2 1.9 2 1.8 <50th 1.8 <50th
Traffic Proximity and Volume (daily traffic count/distance to road) 46 250 46 320 39 590 39
Lead Paint Indicator (% Pre-1960 Housing) 0.022 0.22 15 0.18 30 0.29 17
Superfund Proximity (site count/km distance) 0.021 0.083 24 0.078 28 0.13 18
RMP Proximity (facility count/km distance) 0.11 0.89 20 0.8 16 0.73 19
Hazardous Waste Proximity (facility count/km distance) 0.02 0.076 16 0.083 28 0.093 21
Wastewater Discharge Indicator 0.0094 0.44 87 0.37 84 30 80
(toxicity-weighted concentration/m distance)
Demographic Indicators
Demographic Index 83% 40% 94 45% 93 36% 96
Minority Population 79% 41% 83 50% 76 38% 84
Low Income Population 87% 40% 98 39% 98 34% 98
Linguistically Isolated Population 0% 2% 62 6% 35 5% 44
Population With Less Than High School Education 14% 17% 46 17% 50 13% 63
Population Under 5 years of age 0% 7% 3 7% 3 6% 3
Population over 64 years of age 10% 13% 36 12% 47 14% 37
* The National-Scale Air Toxics Assessment (NATA) is EPA's ongoing, comprehensive evaluation of air toxics in the United States. EPA developed the NATA to
prioritize air toxics, emission sources, and locations of interest for further study. It is important to remember that NATA provides broad estimates of health risks
over geographic areas of the country, not definitive risks to specific individuals or locations. More information on the NATA analysis can be found
at: https://www.epa.gov/national-air-toxics-assessment.

For additional information, see: www.epa.gov/environmentaljustice

EJSCREEN is a screening tool for pre-decisional use only. It can help identify areas that may warrant additional consideration, analysis, or outreach. It does not
provide a basis for decision-making, but it may help identify potential areas of EJ concern. Users should keep in mind that screening tools are subject to substantial
uncertainty in their demographic and environmental data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this
screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see
EJSCREEN documentation for discussion of these issues before using reports. This screening tool does not provide data on every environmental impact and
demographic factor that may be relevant to a particular location. EJSCREEN outputs should be supplemented with additional information and local knowledge
before taking any action to address potential EJ concerns.
September 25, 2017 3/3
9/19/2017 EJSCREEN Report

Save as PDF

EJSCREEN Report (Version 2017)

1 mile Ring Centered at 29.648453,-89.961390
LOUISIANA, EPA Region 6
Approximate Population: 145
Input Area (sq. miles): 3.14

Selected Variables Percentile in State Percentile in EPA Region Percentile in USA

EJ Indexes
EJ Index for Particulate Matter (PM 2.5) 79 68 78
EJ Index for Ozone 86 73 84
EJ Index for NATA* Diesel PM 75 68 75
EJ Index for NATA* Air Toxics Cancer Risk 75 67 78
EJ Index for NATA* Respiratory Hazard Index 74 67 76
EJ Index for Traffic Proximity and Volume 75 64 73
EJ Index for Lead Paint Indicator 62 61 68
EJ Index for Superfund Proximity 71 64 71
EJ Index for RMP Proximity 66 57 69
EJ Index for Hazardous Waste Proximity 70 63 72
EJ Index for Wastewater Discharge Indicator 95 90 92

https://ejscreen.epa.gov/mapper/ejscreen_SOE.aspx 1/4
9/19/2017 EJSCREEN Report

EJ Index for the Selected Area Compared to All People's Blockgroups in the State/Region/US
100

75
Percentile

50

25

0
PM Oz NA NA NA Tr Le Su RM Ha Wa
2.5 on TA TA TA aff ad pe PP za ste
e Di Ca Re ic Pa rfu r rd wa
es nc sp Pro int nd oxim ous
el ira xim ter
PM er In Pr ity W Di
Ris to ity dica oxim aste sc
k ry to ha
HI r ity Pr rg
ox eI
im nd
ity ica
to
r

EJ Indexes
State Percentile Regional Percentile USA Percentile

This report shows the values for environmental and demographic indicators and EJSCREEN indexes. It shows environmental and demographic raw data (e.g., the estimated concentration of
ozone in the air), and also shows what percentile each raw data value represents. These percentiles provide perspective on how the selected block group or buffer area compares to the entire
state, EPA region, or nation. For example, if a given location is at the 95th percentile nationwide, this means that only 5 percent of the US population has a higher block group value than the
average person in the location being analyzed. The years for which the data are available, and the methods used, vary across these indicators. Important caveats and uncertainties apply to
this screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for
discussion of these issues before using reports.

https://ejscreen.epa.gov/mapper/ejscreen_SOE.aspx 2/4
9/19/2017 EJSCREEN Report

Sites reporting to EPA

Superfund NPL 0
Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDF) 0

EPA
State Percentile Percentile in USA Percentile
Selected Variables Value Region
Average in State EPA Region Average in USA
Average
Environmental Indicators

https://ejscreen.epa.gov/mapper/ejscreen_SOE.aspx 3/4
9/19/2017 EJSCREEN Report

Particulate Matter (PM 2.5 in µg/m3) 6.83 8.67 0 9.15 6 9.14 9

Ozone (ppb) 39.1 36.7 98 40.2 38 38.4 66
NATA* Diesel PM (µg/m3) 0.486 0.889 39 0.721 <50th 0.938 <50th
NATA* Air Toxics Cancer Risk (risk per MM) 31 49 1 42 <50th 40 <50th
NATA* Respiratory Hazard Index 1.2 1.9 2 1.8 <50th 1.8 <50th
Traffic Proximity and Volume (daily traffic count/distance to road) 46 250 46 320 39 590 39
Lead Paint Indicator (% pre-1960s housing) 0.022 0.22 15 0.18 30 0.29 17
Superfund Proximity (site count/km distance) 0.021 0.083 24 0.078 28 0.13 18
RMP Proximity (facility count/km distance) 0.11 0.89 20 0.8 16 0.73 19
Hazardous Waste Proximity (facility count/km distance) 0.02 0.076 16 0.083 28 0.093 21
Wastewater Discharge Indicator (toxicity-weighted concentration/m distance) 0.0094 0.44 87 0.37 84 30 80
Demographic Indicators
Demographic Index 83% 40% 94 45% 93 36% 96
Minority Population 79% 41% 83 50% 76 38% 84
Low Income Population 87% 40% 98 39% 98 34% 98
Linguistically Isolated Population 0% 2% 62 6% 35 5% 44
Population with Less Than High School Education 14% 17% 46 17% 50 13% 63
Population under Age 5 0% 7% 3 7% 3 6% 3
Population over Age 64 10% 13% 36 12% 47 14% 37
*The National-Scale Air Toxics Assessment (NATA) is EPA's ongoing, comprehensive evaluation of air toxics in the United States. EPA developed the NATA to prioritize air toxics, emission
sources, and locations of interest for further study. It is important to remember that NATA provides broad estimates of health risks over geographic areas of the country, not definitive risks to
specific individuals or locations. More information on the NATA analysis can be found at: https://www.epa.gov/national-air-toxics-assessment.

For additional information, see: www.epa.gov/environmentaljustice

EJSCREEN is a screening tool for pre-decisional use only. It can help identify areas that may warrant additional consideration, analysis, or outreach. It does not provide a basis for decision-
making, but it may help identify potential areas of EJ concern. Users should keep in mind that screening tools are subject to substantial uncertainty in their demographic and environmental
data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this screening-level information, so it is essential to understand the limitations on
appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of these issues before using reports. This screening tool does not
provide data on every environmental impact and demographic factor that may be relevant to a particular location. EJSCREEN outputs should be supplemented with additional information and
local knowledge before taking any action to address potential EJ concerns.

https://ejscreen.epa.gov/mapper/ejscreen_SOE.aspx 4/4
 EJSCREEN ACS Summary Report
Location: User-specified point center at 29.648453, -89.961390
Ring (buffer): 1-mile radius
Description:

Summary of ACS Estimates 2011 - 2015

Population 145
Population Density (per sq. mile) 130
Minority Population 114
% Minority 79%
Households 22
Housing Units 45
Housing Units Built Before 1950 0
Per Capita Income 13,007
Land Area (sq. miles) (Source: SF1) 1.11
% Land Area 54%
Water Area (sq. miles) (Source: SF1) 0.94
% Water Area 46%
2011 - 2015
Percent MOE (±)
ACS Estimates
Population by Race
Total 145 100% 437
Population Reporting One Race 145 100% 581
White 30 21% 107
Black 112 77% 411
American Indian 3 2% 27
Asian 0 0% 12
Pacific Islander 0 0% 12
Some Other Race 0 0% 12
Population Reporting Two or More Races 0 0% 12
Total Hispanic Population 0 0% 12
Total Non-Hispanic Population 145
White Alone 30 21% 107
Black Alone 112 77% 411
American Indian Alone 3 2% 27
Non-Hispanic Asian Alone 0 0% 12
Pacific Islander Alone 0 0% 12
Other Race Alone 0 0% 12
Two or More Races Alone 0 0% 12
Population by Sex
Male 78 54% 289
Female 67 46% 208
Population by Age
Age 0-4 0 0% 12
Age 0-17 44 31% 148
Age 18+ 100 69% 199
Age 65+ 15 10% 64

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race. N/A means not available.
Source: U.S. Census Bureau, American Community Survey (ACS) 2011 - 2015.

September 19, 2017 1/3

 EJSCREEN ACS Summary Report
Location: User-specified point center at 29.648453, -89.961390
Ring (buffer): 1-mile radius
Description:

2011 - 2015
Percent MOE (±)
ACS Estimates
Population 25+ by Educational Attainment
Total 70 100% 206
Less than 9th Grade 5 7% 49
9th - 12th Grade, No Diploma 5 7% 30
High School Graduate 45 64% 147
Some College, No Degree 11 16% 62
Associate Degree 0 0% 12
Bachelor's Degree or more 4 6% 28
Population Age 5+ Years by Ability to Speak English
Total 145 100% 437
Speak only English 145 100% 369
Non-English at Home1+2+3+4 0 0% 12
1
Speak English "very well" 0 0% 12
2
Speak English "well" 0 0% 12
3
Speak English "not well" 0 0% 12
4
Speak English "not at all" 0 0% 12
3+4
Speak English "less than well" 0 0% 12
2+3+4
Speak English "less than very well" 0 0% 12
Linguistically Isolated Households*
Total 0 0% 12
Speak Spanish 0 0% 12
Speak Other Indo-European Languages 0 0% 12
Speak Asian-Pacific Island Languages 0 0% 12
Speak Other Languages 0 0% 12
Households by Household Income
Household Income Base 22 100% 99
< $15,000 7 30% 64
$15,000 - $25,000 2 8% 31
$25,000 - $50,000 6 29% 65
$50,000 - $75,000 5 23% 53
$75,000 + 2 9% 25
Occupied Housing Units by Tenure
Total 22 100% 99
Owner Occupied 19 88% 91
Renter Occupied 3 12% 35
Employed Population Age 16+ Years
Total 106 100% 343
In Labor Force 35 33% 91
Civilian Unemployed in Labor Force 1 1% 13
Not In Labor Force 71 67% 313

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race. N/A means
not available. Source: U.S. Census Bureau, American Community Survey (ACS) 2011 - 2015.
*Households in which no one 14 and over speaks English "very well" or speaks English only.

September 19, 2017 2/3

 EJSCREEN ACS Summary Report
Location: User-specified point center at 29.648453, -89.961390
Ring (buffer): 1-mile radius
Description:

2011 - 2015
Percent MOE (±)
ACS Estimates
Population by Language Spoken at Home*
Total (persons age 5 and above) 145 100% 437
English N/A N/A N/A
Spanish N/A N/A N/A
French N/A N/A N/A
French Creole N/A N/A N/A
Italian N/A N/A N/A
Portuguese N/A N/A N/A
German N/A N/A N/A
Yiddish N/A N/A N/A
Other West Germanic N/A N/A N/A
Scandinavian N/A N/A N/A
Greek N/A N/A N/A
Russian N/A N/A N/A
Polish N/A N/A N/A
Serbo-Croatian N/A N/A N/A
Other Slavic N/A N/A N/A
Armenian N/A N/A N/A
Persian N/A N/A N/A
Gujarathi N/A N/A N/A
Hindi N/A N/A N/A
Urdu N/A N/A N/A
Other Indic N/A N/A N/A
Other Indo-European N/A N/A N/A
Chinese N/A N/A N/A
Japanese N/A N/A N/A
Korean N/A N/A N/A
Mon-Khmer, Cambodian N/A N/A N/A
Hmong N/A N/A N/A
Thai N/A N/A N/A
Laotian N/A N/A N/A
Vietnamese N/A N/A N/A
Other Asian N/A N/A N/A
Tagalog N/A N/A N/A
Other Pacific Island N/A N/A N/A
Navajo N/A N/A N/A
Other Native American N/A N/A N/A
Hungarian N/A N/A N/A
Arabic N/A N/A N/A
Hebrew N/A N/A N/A
African N/A N/A N/A
Other and non-specified N/A N/A N/A
Total Non-English N/A N/A N/A

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race. N/A means
not available. Source: U.S. Census Bureau, American Community Survey (ACS) 2011 - 2015.
*Population by Language Spoken at Home is available at the census tract summary level and up.

September 19, 2017 3/3

9/19/2017 EJSCREEN Report

Save as PDF

EJSCREEN Report (Version 2017)

1 mile Ring Centered at 29.646430,-89.939440
LOUISIANA, EPA Region 6
Approximate Population: 332
Input Area (sq. miles): 3.14

Selected Variables Percentile in State Percentile in EPA Region Percentile in USA

EJ Indexes
EJ Index for Particulate Matter (PM 2.5) 77 66 77
EJ Index for Ozone 84 71 82
EJ Index for NATA* Diesel PM 69 61 70
EJ Index for NATA* Air Toxics Cancer Risk 73 65 76
EJ Index for NATA* Respiratory Hazard Index 73 66 75
EJ Index for Traffic Proximity and Volume 60 50 63
EJ Index for Lead Paint Indicator 71 70 75
EJ Index for Superfund Proximity 70 63 71
EJ Index for RMP Proximity 64 55 68
EJ Index for Hazardous Waste Proximity 70 63 71
EJ Index for Wastewater Discharge Indicator 95 90 92

https://ejscreen.epa.gov/mapper/ejscreen_SOE.aspx 1/4
9/19/2017 EJSCREEN Report

EJ Index for the Selected Area Compared to All People's Blockgroups in the State/Region/US
100

75
Percentile

50

25

0
PM Oz NA NA NA Tr Le Su RM Ha Wa
2.5 on TA TA TA aff ad pe PP za ste
e Di Ca Re ic Pa rfu r rd wa
es nc sp Pro int nd oxim ous
el ira xim ter
PM er In Pr ity W Di
Ris to ity dica oxim aste sc
k ry to ha
HI r ity Pr rg
ox eI
im nd
ity ica
to
r

EJ Indexes
State Percentile Regional Percentile USA Percentile

This report shows the values for environmental and demographic indicators and EJSCREEN indexes. It shows environmental and demographic raw data (e.g., the estimated concentration of
ozone in the air), and also shows what percentile each raw data value represents. These percentiles provide perspective on how the selected block group or buffer area compares to the entire
state, EPA region, or nation. For example, if a given location is at the 95th percentile nationwide, this means that only 5 percent of the US population has a higher block group value than the
average person in the location being analyzed. The years for which the data are available, and the methods used, vary across these indicators. Important caveats and uncertainties apply to
this screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for
discussion of these issues before using reports.

https://ejscreen.epa.gov/mapper/ejscreen_SOE.aspx 2/4
9/19/2017 EJSCREEN Report

Sites reporting to EPA

Superfund NPL 0
Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDF) 0

EPA
State Percentile Percentile in USA Percentile
Selected Variables Value Region
Average in State EPA Region Average in USA
Average
Environmental Indicators

https://ejscreen.epa.gov/mapper/ejscreen_SOE.aspx 3/4
9/19/2017 EJSCREEN Report

Particulate Matter (PM 2.5 in µg/m3) 6.81 8.67 0 9.15 5 9.14 9

Ozone (ppb) 39.9 36.7 99 40.2 45 38.4 74
NATA* Diesel PM (µg/m3) 0.327 0.889 24 0.721 <50th 0.938 <50th
NATA* Air Toxics Cancer Risk (risk per MM) 31 49 1 42 <50th 40 <50th
NATA* Respiratory Hazard Index 1.2 1.9 3 1.8 <50th 1.8 <50th
Traffic Proximity and Volume (daily traffic count/distance to road) 5.4 250 18 320 11 590 11
Lead Paint Indicator (% pre-1960s housing) 0.078 0.22 34 0.18 50 0.29 32
Superfund Proximity (site count/km distance) 0.022 0.083 28 0.078 31 0.13 20
RMP Proximity (facility count/km distance) 0.098 0.89 16 0.8 13 0.73 15
Hazardous Waste Proximity (facility count/km distance) 0.022 0.076 19 0.083 30 0.093 23
Wastewater Discharge Indicator (toxicity-weighted concentration/m distance) 0.011 0.44 88 0.37 85 30 80
Demographic Indicators
Demographic Index 73% 40% 87 45% 84 36% 90
Minority Population 100% 41% 96 50% 97 38% 98
Low Income Population 47% 40% 64 39% 64 34% 72
Linguistically Isolated Population 0% 2% 62 6% 35 5% 44
Population with Less Than High School Education 29% 17% 86 17% 80 13% 88
Population under Age 5 4% 7% 25 7% 22 6% 28
Population over Age 64 9% 13% 27 12% 39 14% 30
*The National-Scale Air Toxics Assessment (NATA) is EPA's ongoing, comprehensive evaluation of air toxics in the United States. EPA developed the NATA to prioritize air toxics, emission
sources, and locations of interest for further study. It is important to remember that NATA provides broad estimates of health risks over geographic areas of the country, not definitive risks to
specific individuals or locations. More information on the NATA analysis can be found at: https://www.epa.gov/national-air-toxics-assessment.

For additional information, see: www.epa.gov/environmentaljustice

EJSCREEN is a screening tool for pre-decisional use only. It can help identify areas that may warrant additional consideration, analysis, or outreach. It does not provide a basis for decision-
making, but it may help identify potential areas of EJ concern. Users should keep in mind that screening tools are subject to substantial uncertainty in their demographic and environmental
data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this screening-level information, so it is essential to understand the limitations on
appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of these issues before using reports. This screening tool does not
provide data on every environmental impact and demographic factor that may be relevant to a particular location. EJSCREEN outputs should be supplemented with additional information and
local knowledge before taking any action to address potential EJ concerns.

https://ejscreen.epa.gov/mapper/ejscreen_SOE.aspx 4/4
 EJSCREEN ACS Summary Report
Location: User-specified point center at 29.646430, -89.939440
Ring (buffer): 1-mile radius
Description:

Summary of ACS Estimates 2011 - 2015

Population 332
Population Density (per sq. mile) 1,051
Minority Population 331
% Minority 100%
Households 93
Housing Units 105
Housing Units Built Before 1950 7
Per Capita Income 15,425
Land Area (sq. miles) (Source: SF1) 0.32
% Land Area 46%
Water Area (sq. miles) (Source: SF1) 0.37
% Water Area 54%
2011 - 2015
Percent MOE (±)
ACS Estimates
Population by Race
Total 332 100% 437
Population Reporting One Race 332 100% 581
White 2 1% 107
Black 330 99% 411
American Indian 0 0% 27
Asian 0 0% 12
Pacific Islander 0 0% 12
Some Other Race 0 0% 12
Population Reporting Two or More Races 0 0% 12
Total Hispanic Population 1 0% 12
Total Non-Hispanic Population 331
White Alone 1 0% 107
Black Alone 330 99% 411
American Indian Alone 0 0% 27
Non-Hispanic Asian Alone 0 0% 12
Pacific Islander Alone 0 0% 12
Other Race Alone 0 0% 12
Two or More Races Alone 0 0% 12
Population by Sex
Male 151 45% 289
Female 181 55% 208
Population by Age
Age 0-4 13 4% 42
Age 0-17 85 26% 148
Age 18+ 247 74% 199
Age 65+ 30 9% 64

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race. N/A means not available.
Source: U.S. Census Bureau, American Community Survey (ACS) 2011 - 2015.

September 19, 2017 1/3

 EJSCREEN ACS Summary Report
Location: User-specified point center at 29.646430, -89.939440
Ring (buffer): 1-mile radius
Description:

2011 - 2015
Percent MOE (±)
ACS Estimates
Population 25+ by Educational Attainment
Total 205 100% 206
Less than 9th Grade 34 17% 59
9th - 12th Grade, No Diploma 26 13% 67
High School Graduate 98 48% 147
Some College, No Degree 31 15% 62
Associate Degree 3 1% 16
Bachelor's Degree or more 16 8% 48
Population Age 5+ Years by Ability to Speak English
Total 319 100% 437
Speak only English 318 100% 369
Non-English at Home1+2+3+4 1 0% 13
1
Speak English "very well" 0 0% 12
2
Speak English "well" 0 0% 12
3
Speak English "not well" 0 0% 12
4
Speak English "not at all" 1 0% 13
3+4
Speak English "less than well" 1 0% 13
2+3+4
Speak English "less than very well" 1 0% 13
Linguistically Isolated Households*
Total 0 0% 12
Speak Spanish 0 0% 12
Speak Other Indo-European Languages 0 0% 12
Speak Asian-Pacific Island Languages 0 0% 12
Speak Other Languages 0 0% 12
Households by Household Income
Household Income Base 93 100% 99
< $15,000 19 20% 64
$15,000 - $25,000 20 22% 55
$25,000 - $50,000 8 8% 65
$50,000 - $75,000 15 16% 53
$75,000 + 31 33% 74
Occupied Housing Units by Tenure
Total 93 100% 99
Owner Occupied 92 99% 91
Renter Occupied 1 1% 35
Employed Population Age 16+ Years
Total 263 100% 343
In Labor Force 166 63% 143
Civilian Unemployed in Labor Force 9 3% 27
Not In Labor Force 97 37% 313

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race. N/A means
not available. Source: U.S. Census Bureau, American Community Survey (ACS) 2011 - 2015.
*Households in which no one 14 and over speaks English "very well" or speaks English only.

September 19, 2017 2/3

 EJSCREEN ACS Summary Report
Location: User-specified point center at 29.646430, -89.939440
Ring (buffer): 1-mile radius
Description:

2011 - 2015
Percent MOE (±)
ACS Estimates
Population by Language Spoken at Home*
Total (persons age 5 and above) 319 100% 437
English N/A N/A N/A
Spanish N/A N/A N/A
French N/A N/A N/A
French Creole N/A N/A N/A
Italian N/A N/A N/A
Portuguese N/A N/A N/A
German N/A N/A N/A
Yiddish N/A N/A N/A
Other West Germanic N/A N/A N/A
Scandinavian N/A N/A N/A
Greek N/A N/A N/A
Russian N/A N/A N/A
Polish N/A N/A N/A
Serbo-Croatian N/A N/A N/A
Other Slavic N/A N/A N/A
Armenian N/A N/A N/A
Persian N/A N/A N/A
Gujarathi N/A N/A N/A
Hindi N/A N/A N/A
Urdu N/A N/A N/A
Other Indic N/A N/A N/A
Other Indo-European N/A N/A N/A
Chinese N/A N/A N/A
Japanese N/A N/A N/A
Korean N/A N/A N/A
Mon-Khmer, Cambodian N/A N/A N/A
Hmong N/A N/A N/A
Thai N/A N/A N/A
Laotian N/A N/A N/A
Vietnamese N/A N/A N/A
Other Asian N/A N/A N/A
Tagalog N/A N/A N/A
Other Pacific Island N/A N/A N/A
Navajo N/A N/A N/A
Other Native American N/A N/A N/A
Hungarian N/A N/A N/A
Arabic N/A N/A N/A
Hebrew N/A N/A N/A
African N/A N/A N/A
Other and non-specified N/A N/A N/A
Total Non-English N/A N/A N/A

Data Note: Detail may not sum to totals due to rounding. Hispanic population can be of any race. N/A means
not available. Source: U.S. Census Bureau, American Community Survey (ACS) 2011 - 2015.
*Population by Language Spoken at Home is available at the census tract summary level and up.

September 19, 2017 3/3