.. \ ... Cindy Rosenberg To: Larry Svoboda, Jonah Staller, Kerri Fiedler, Kevin Golden,
 

komp.mark@epa.gov, Mike Owens, Carol Smith
 -'03/08/02 03,09 PM cc: 

Subject: PMIO SIP Committment Language and Letter 

I have several items so far that I think need to be added to Rick's list which he's put in the letter
 

(attached below).
 

•	 I think on the "State authorities" item they should add that all director's discretion provisions
 

will be removed from the SIP
 

•	 On the "Wood burning reduction analysis" they should add that they will justify the 83% credit 

taken in the Utah County SIP revision and also justify this for coal burning in addition to wood. 

•	 24·hour emission limits will be provided for the major stationary sources in Salt Lake County 

•	 The SIP narrative will be revised and updated for such sections as the "Provo Canyon Closure
 

to Truck Traffic," Diesel 11M, and the "Maintenance" section.
 

•	 The SIP will be written to require the use of method 202 for measuring back·half condensibles 

from stationary sources. 

That's all I can think of at the moment· I'm sure there's more though. Let me know if you have 

anything. 

Thanks, 

Cindy 

Cindy Rosenberg
 

Particulate Matter Program Manager
 

US EPA Region 8 . Air & Radiation Program
 

999 18th St. Suite 300
 

Denver, CO 80202·2466
 

(303) 312·6436
 

rosenberg.cindy@epa.gov
 

..... Forwarded by Cindy Rosenberg/P2/RS/USEPA/US on 03/0S/02 02:59 PM .....
 

Richard Sprott To: Richard Long/P2/RS/USEPA/US@EPA, Cindy 

<RSPROTT@deq.stat Rosenberg/P2/RS/USEPA/US@EPA, Larry 

e.ut.us> Svoboda/P2/RS/USEPA/US@EPA 

cc: Fred Nelson <FNELSOi'J.ATKEYOl.ATDOMAIi'J@att.state.ut.us>, 03/08/0201:32 PM Brent Bradford <BBRADFOR. EQOAS. EQDOMAI N@deq.state.ut.us>, 

Cheryl Heying <CHEYING.EQAIR.EQDOMAIN@deq.state.ut.us>, 

Dave Mcneill <DMCNEILL.EQAIR.EQDOMAIN@deq.state.ut.us>, 

Dianne Nielson <DRi'JIELSO.EQOAS.EQDOMAIN@deq.state.ut.us>, 

Lenore Epstein <LEPSTEIN .EQAIR.EQDOMAI N@deq.state.ut.us>, 

Reginald Olsen <ROLSEN.EQAIR.EQDOMAIN@deq.state.ut.us>, 

Rusty Ruby <RRUBY.EQAIR.EQDOMAIN@deq.state.ut.us> 

Subject: PMIO SIP Committment Language and Letter 

The following is a copy of my email from last week and is still what we would 

propose go into the SIP. The letter listing the key issues to be resolved is 

attached. Please take a look and let us know what you think. Thanks, Rick 

We would suggest inserting this at some appropriate spot in the SIP revision 

submittal we are sending to you. 

"With this revision to the PMIO SIP, the Utah Air Quality Board commits to 
developing a PM10 maintenance plan or SIP revision, as appropriate, based on 

dispersion modeling." 

I would also send a letter to Dick Long indicating our intent to resolve a 

number of matters listed in the letter as part of the future plan. I will 

finish that draft today with the list of issues to be resolved . 

.

u

C1

MaintPlanlssueLtr3·02Rev2.w 
Richard Long 

Director 

Air and Radiation Program 

EPAR8 

Denver, CO 

Dear Mr. Long: 

This letter is intended to document our agreement to address a number of issues pertaining to the 

Utah PMlO SIPs for Salt Lake and Utah Counties during our ongoing effort to submit a 

maintenance plan (or SIP revisions) for both counties based on a UAM-Aero attainment 

demonstration. We are fully committed to work with Region VIII to find solutions to these 

concerns, but we and our senior management have jointly recognized that there may some aspects 

to some issues that we are unable to settle. We also understand where agreement can't be found 

that the EPA and State may then need to seek other remedies available in the Clean Air Act if 

deemed necessary. Nonetheless, it remains our objective to resolve all issues respectful of each 

other's needs and statutory responsibilities. 

The following issues have been identified and described in a series ofletters and discussions 

between EPA and the State. This letter does not attempt to completely define every aspect of 

each issue since these are generally documented in existing correspondence. The issues consist 

of: 

State authorities
 

Interpollutant trading
 

NSR offset program including emissions banking
 

Unavoidable breakdown rule
 

Wood burning reduction analysis
 

We look forward to completing the new maintenance plans for PMl 0 as soon as possible and are 

optimistic that the above questions can be addressed to our mutual satisfaction. 

Sincerely, 

Rick Sprott 

Director