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 303.312.6162August 19, 2003 Robert E. Roberts


### A There are 15 items in the agreement with Utah re PMl0 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 EPAfor review. 

### EPA committed toprovidingan answer by 29

### August 2003. 2. DAM-Aero based modeling. 

### Inprogress-next check-in date: 30September 2003. 3. Stationary source modeling to test SIP limits. 

### Have completedagreement with EPA. Modeling inprogress. Will be includedin the SIP. 4. Enforceable emission limits for major sources (including 24-hr based). 

### Ninetypercent complete. State needs to meetwith sources. Will be in SIP. 5. Refinery SRUIFLARES. 

### State is waiting for Department of Justice andforaction by EPA. Discussedat length. It was agreedthat the DOJnationalagreement might not be suffiCient for state action, andEPA is not expectedto take its Billings FIP action any time
soon. We encouragedthe State to move on this subjectwithout waiting for others. 6. Emissions inventory and modeling analysis for sources in nonattainment areas. 

### Have completedagreement with EPA. Working on the modeling. Will be in SIP. 7. NSR/Banking/Trading. 

### State thinksprofusion of rules interferes with making changes. RichardLongis to attend meeting this week that deals with this subject, and he will report back to the State. 8. BreakdownRule. 

### State is waiting for responsefrom EPA. EPA is not aware thatwe have this, but committedtoprovidingan answer by 15 September 2003 

## if we do, anda report thatwe don't have it

## if we don't. 9. Inclusion ofannual growth rates. 

### Completed in that there is no longer any disagreement. Will be included in the SIP. 10. Woodburning credit. 

### State needs toprovide study that isdone to EPAfor review. Will be includedin SIP. 11. BackHalf. 

### State says that no other state inRegion 8 

### is doing this. DEQ suggested that this issue be taken off the table, unless someone hasanother explanation. 12. General language cleanup. 

### Will be completed by June I, 2004 orwhen State submits the SIP to EPA. 13. Diesel IIM revision or program withdrawal. 

### We suggestedgiving up to 2

### percent credit. State needs toprovide thejustification to EPAfor review. 14. Emission budgets for PMI0 and NOx in S.L. County. 

### DEQ completedagreement with EPA andMPOs. Will be in SIP. 15. Inventory and modeling analysis ofany changes to the 1M program (the Harper Bill). 

### Have completedagreement with EPA. State will use Mobile 6 

### and is doing so 

### now. Will be includedin SIP.

B. Discussed Ogden City clean data issue. State now has almost 3 years ofclean data. EPA
owes State an answer to an analysis submitted earlier or State simply could go ahead with the 3 years ofdata that is almost complete.C. Discussed continuing on the path ofa combined SIP and maintenance plan. State wishes to continue plan ofa combined action, but that is linked to resolution ofviolations 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 ofsubdividing the county for NAAQS attainment purposes.