### State ofUtah GARY R. HERBERT Governor SPENCERJ. COX Lieutenant Governor
August 4, 2015 Department of Environmental Quality Alan Matheson Executive Director DIVISION OF AIR QUALITY Bryce C. Bird

Director

Carl Daly, Air Program Director U.S. Environmental Protection Agency, Region VIII Mailcode 8P-AR 1595 Wynkoop Street Denver, Colorado 80202-1129 Dear Mr. Daly, DAQP-101-15

The U.S. Environmental Protection Agency (EPA) has noted potential deficiencies in certain area source rules that should be addressed priorto the EPA's action onpart ofUtah's Moderate PM2.5 SIP. The Utah Division ofAir Quality (UDAQ) acknowledges that these area source rules, R307-101, General Requirements; R307-312, Aggregate Processing Operations for PM2.5 NonattainmentAreas; and R307-328, Gasoline Transfer and Storage, should be revised. Below are the area source rules withthe original language and with the language UDAQ is committing to submit, upon final adoption by the Utah Air Quality Board, in a revision.

• R307-101, General Requirements. Definition for PM2.5 Precursors originally states "means any chemical compound or substance which, after it has been emitted into the atmosphere, undergoes chemical or physical changes that convert it into particulate matter, specifically PM2.5, and has been identified in the applicable implementationplan for PM2.5 as significant for the purpose of developing control measures. Specifically, PM2.5 precursors include S02, NOx, and VOC."
o UDAQ commits to work withthe UtahAir Quality Boardto remove this definition from R307-101 because the definition is not used in ourrules.
• R307-312-5(2)(a), Aggregate Processing Operations for PM2.5 Nonattainment Areas. This section originally reads: "Production shall be determined by scale house records or equivalent method ona daily basis."
o UDAQ commits to work with the Utah Air Quality Board to revise this

195 North 1950 West • SaltLake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801)536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on I00%recycledpaperDAQP-101-15 Page 2 sentence to remove "orequivalent method" and add "scale house orbelt scale records, ormanifest statements." After this revision, this section will read: "Production shall be determined by scale house records, scale house orbelt scale records, or manifest statements on a daily basis."

• R307-328-4(6), Gasoline Transfer and Storage. This section originally reads: "A gasoline storage and transfer installationthat receives inbound loads and dispatches outbound loads ("bulkplant") need not comply with R307-328-4 ifitdoes not have a daily average throughput ofmore than 3,900 gallons (15,000 or more liters) of gasoline based upon a 30-dayrolling average. Such installations shall on-load and off-load gasoline by use ofbottom or submerged filling or alternate equivalent methods. The emission limitation is based on operating procedures and equipment specifications using Reasonably Available Control Technology as defined inEPA documents EPA450/2-77-026 October 1977, "Control ofHydrocarbons from Tank Truck Gasoline Loading Terminals," and EPA-450/2-77-035 December 1977, "Control ofVolatile Organic Emissions from Bulk Gasoline Plants." The design effectiveness ofsuch equipment andthe operating procedures mustbe documented and submittedto and approved bythe executive secretary."

o UDAQ commits to work withthe Utah Air Quality Boardto revise this section to remove "or alternative equivalent method." Afterthis revision, this section will read: "A gasoline storage and transfer installationthat receives inbound loads and dispatches outbound loads ("bulkplant") need not comply with R307-328-4 ifit does nothave a daily average throughput ofmore than 3,900 gallons (15,000 ormore liters) ofgasoline based upon a 30-dayrolling average. Suchinstallations shall on-load and off-load gasoline by use ofbottom or submerged filling. The emission limitation is based on operating procedures and equipment specifications using Reasonably Available Control Technology as defined inEPA documents EPA450/2-77-026 October 1977, "Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals," and EPA-450/2- 77-035 December 1977, "Control ofVolatile Organic Emissions from Bulk Gasoline Plants." The design effectiveness ofsuch equipment andthe operating procedures mustbe documented and submittedto and approved bythe executive secretary." Ifyouhave any questions, please contact Joel Karmazyn ofmy staffat (801) 536-4423.



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Bryce C. Bird Director BCB:MB:svw