Lines of Attack (Cont.)

• Blowdown & Malfunction

• • DEP has been known to exempt emergency & malfunction completely
  • Where malfunctions have happened from human error, DEP has not considered training in evaluating permits
  • We’re on very strong ground here with the Bernville & Koziel incidents
  • • We have a pattern of trouble at Texas Eastern
    • We can hook this to the closeness of the VOC number to Major Source