14 of the Guam Environmental Protection Agency is understood by GP.\ to demonstrate that the present control strategy is adequate to meet all standards. The wind-based emission control strategy is implemented without difficulty. At its station on Guam, the U.S. Navy monitors wind conditions throughout the South Pacific and winddireetion information s constantly ‘available. The conversion from high to low sulfur fuel is accomplished in a minimal amount of time by simply closing the valve on one fuel line and opening it on another. The Guam Environmental Protection Agency oversees the control etratery andis able to do so without any ‘significant resource comiitment because of the dearth of emission sources on Guain. The Clear Air Act does not permit the present control strategy on a long-term basis. As noted earlier, the aet requires a system ‘of continuous emission controls. In terms of specific control methods, this requires either burning low culfurfuel continuously, or installing flue gas desulfurization technology (“scrubber”). At Tanguisson there exists the third alternative of buiiding a tall stack. There is no provision in the Clean .\ir Act for a waiver or variance from these requirements. Only Congressional legislation can accomplish such a result. GPA uses the present. strategy at Cabras only because it is expressly permitted by a consent decreeentered into with EPA pending the installation of a scrubber or the construction of sufficient storage facilities for the continuous burning of low sulfur fuel. GPA uses the present strategy at Tanguisson beeause it is permitted by the latest revision to the Guam SIP adopted by the Guam Mnvironmental Protection Agency. This SIP revision is presently before EPA Revion TX. for approval, but in the ahsenee of legislative rehef EPA ust reject the revision under Section 232) (2) of the Act. tte a SP raneyee tl,ie ee eee eee Loe! Pars mteld albrane Ot Rind NOP cbs rir: ae sicgTuardh Sit, iota! iitath eat also include a 3-hour and a 24-hourstandard. Data in the possession ee imposed without regard to air quality. GPA. also operates two fossil fuel fired steam electric generating facilities at Tanguisson Point, Guam (“Tanguisson 1 and.2”). ‘Tanguisson 1 and 2 were built before 1970 and are not subject to NSPS. ‘I hey are, however, subject to the requirementsof continuous emission contro], without regard to whether air quality standards could be attained witha lesser degree of control. Guam lies in an easterly trade wind belt and experiences winds from the east almost constantly. The Cabras and Tanguisson facilities are all located on the western side of Guam, Accordingly, their emissions are almost constantly blown directly out to sea. GPA currently utilizes the prevailing winds as part of its system of sulfur dioxide control, When the wind blows frem the land toward the sea, which is 88.6 percent of the time, GPA burns fuel with 3 percent sulfur. The remaining 11-f percent of the time, when the wind blows toward land, GI’A burns low sulfur fuel (0.75percent sulfur). Monitoring data demonstrates that this strategy is more than adequate to meet the annual NAAQS for sulfur dioxide. Indeed, the average annual concentration of 10 micrograms per cubic meter far exceeds the standard of 80 micrograms per cubic meter. The NAAQS ihe the emission limitation and the continuous control requirement are