State ofUtah 

GARY R. HERBERT 

Governor 

SPENCER J. 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 prior to the EPA's action on part of Utah's Moderate 

PM2.5 SIP. The Utah Division of Air Quality (UDAQ) acknowledges that these area source rules, 

R307-101, General Requirements; R307-312, Aggregate Processing Operations for PM2.5 

Nonattainment Areas; and R307-328, Gasoline Transfer and Storage, should be revised. Below 

are the area source rules with the 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 implementation plan 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 with the Utah Air Quality Board to remove this 

definition from R307-101 because the definition is not used in our rules. 

• 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 on a daily basis." 

o UDAQ commits to work with the Utah Air Quality Board to revise this 

195 North 1950 West • Salt Lake 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 I 00% recycled paper 
DAQP-101-15 

Page 2 

sentence to remove "or equivalent method" and add "scale house or belt scale 

records, or manifest statements." After this revision, this section will read: 

"Production shall be determined by scale house records, scale house or belt 

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 installation that receives inbound loads and dispatches 

outbound loads ("bulk plant") need not comply with R307-328-4 if it does not have 

a daily average throughput of more than 3,900 gallons (15,000 or more liters) of 

gasoline based upon a 30-day rolling 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 in EPA 

documents EPA 450/2-77-026 October 1977, "Control ofHydrocarbons from Tank 

Truck Gasoline Loading Terminals," and EPA-450/2-77-035 December 1977, 

"Control of Volatile Organic Emissions from Bulk Gasoline Plants." The design 

effectiveness of such equipment and the operating procedures must be documented 

and submitted to and approved by the executive secretary." 

o UDAQ commits to work with the Utah Air Quality Board to revise this section 

to remove "or alternative equivalent method." After this revision, this section 

will read: "A gasoline storage and transfer installation that receives inbound 

loads and dispatches outbound loads ("bulk plant") need not comply with 

R307-328-4 if it does not have a daily average throughput of more than 3,900 

gallons (15,000 or more liters) of gasoline based upon a 30-day rolling average. 

Such installations shall on-load and off-load gasoline by use of bottom or 

submerged filling. The emission limitation is based on operating procedures 

and equipment specifications using Reasonably Available Control Technology 

as defined in EPA documents EPA 450/2-77-026 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 of such equipment and the operating 

procedures must be documented and submitted to and approved by the 

executive secretary." 

If you have any questions, please contact Joel Karmazyn of my staff at (801) 536-4423. 

4~~?~~ Bryce C. Bird 

Director 

BCB:MB:svw