To: Libby Faulk/P2/R8/USEPA/US@EPA, Jonah 

Staller/RC/R8/USEPA/US@EPA 

cc: 

Subject: Utah--1 5 Air Issues 

FYI 

----. Forwarded by Richard Long/P2/R8/USEPA/US on 08/25/03 01 :34 PM ----­

Kerry Clough To: dnielson@utah.gov 

08/19/03 04:41PM cc: Robbie Roberts/RA/R8/USEPA/US@EPA, Richard 

Long/P2/R8/USEPA/US@EPA 

Subject: Utah--15 Air Issues 

Dianne, Robbie asked me to forward you this summary of our discussions last Friday. I have asked 

staff to follow-up on several of the items and I'll send you an annotated version of this summary 

early next week. Hope this is helpful. Of course, if you or your staff spot any errors in this, please 

let me know. Kerry 

----- Forwarded by Kerry Ciough/RA/R8/USEPA/US on 08/19103 04:38 PM _.--­

Linda Wolfe To: Kerry Clough/RA/R8/USEPA/US@EPA 

··08/19/03 04:42 PM cc: 

Subject: Utah--15 Air Issues 

15UtahAirIssues.rer. 

Linda Wolfe 

Office of the Deputy Regional Administrator 

USEPA Region 8, Denver, Colorado 

303.312.6162 
August 19, 2003 

Robert E. Roberts 

A There are 15 items in the agreement with Utah re PMl 0 air issues. Here is how I understand 

we dealt with them on Friday, 15 August 2003. 

1. Director's Discretion/Variance. State put together a policy and sent it to EPA for 

review. EPA committed to providing an answer by 29 August 2003. 

2. DAM-Aero based modeling. In progress-next check-in date: 30 September 2003. 

3. Stationary source modeling to test SIP limits. Have completed agreement 

with EPA. Modeling in progress. Will be included in the SIP. 

4. Enforceable emission limits for major sources (including 24-hr based). Ninety percent 

complete. State needs to meet with sources. Will be in SIP. 

5. Refinery SRUIFLARES. State is waitingfor Department ofJustice andfor action by 

EPA. Discussed at length. It was agreed that the DOJ national agreement might not be 

suffiCientfor state action, and EPA is not expected to take its Billings FIP action any 

time 

soon. We encouraged the State to move on this subject without waitingfor others. 

6. Emissions inventory and modeling analysis for sources in nonattainment areas. Have 

completed agreement with EPA. Working on the modeling. Will be in SIP. 

7. NSR/Banking/Trading. State thinks profusion ofrules interferes with making 

changes. Richard Long is to attend meeting this week that deals with this subject, and 

he will report back to the State. 

8. Breakdown Rule. State is waitingfor response from EPA. EPA is not aware that we 

have this, but committed to providing an answer by 15 September 2003 ifwe do, and a 

report that we don't have it ifwe don't. 

9. Inclusion of annual growth rates. Completed in that there is no longer any 

disagreement. Will be included in the SIP. 

10. Woodburning credit. State needs to provide study that is done to EPA for review. 

Will be included in SIP. 

11. Back Half. State says that no other state in Region 8 is doing this. DEQ suggested 

that this issue be taken offthe table, unless someone has another explanation. 

12. General language cleanup. Will be completed by June I, 2004 or when State submits 

the SIP to EPA. 

13. Diesel IIM revision or program withdrawal. We suggested giving up to 2 percent 

credit. State needs to provide the justification to EPA for review. 

14. Emission budgets for PMI0 and NOx in S.L. County. DEQ completed agreement 

with EPA and MPOs. Will be in SIP. 

15. Inventory and modeling analysis of any changes to the 1M program (the Harper Bill). 

Have completed agreement with EPA. State will use Mobile 6 and is doing so now. Will 

be included in SIP. 

B. Discussed Ogden City clean data issue. State now has almost 3 years of clean data. EPA 

owes State an answer to an analysis submitted earlier or State simply could go ahead with the 

3 years of data that is almost complete. 
C. Discussed continuing on the path of a combined SIP and maintenance plan. State wishes to 

continue plan of a combined action, but that is linked to resolution of violations at Magna. EPA 

agreed to relook, one more time, at the flagged events and discuss with the State. State and EPA 

will discuss the potential of subdividing the county for NAAQS attainment purposes.