1 

Technical Support Document

Proposed Action on the

Area Source Rules and Reasonably Available Control 

Measure Determinations within Utah’s Salt Lake, 

Provo, and Logan 2006 24-Hour PM2.5 State 

Implementation Plans

Air Program 

U.S. EPA Region 8 

August 2015

 
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For further information on this technical support document, please contact: 

Crystal Ostigaard 

Air Program 

U.S. Environmental Protection Agency-Region 8 

1595 Wynkoop St. 

Denver, Colorado 80202 

(303) 312-6602 

ostigaard.crystal@epa.gov 

Documents referenced in this technical support document may be found in the docket for 

this rulemaking, docket no. EPA-R08-OAR-2014-0369, which may be found at 

www.regulations.gov or at the address listed above.

 
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Technical Support Document

Proposed Action on the

Area Source Rules and Reasonably Available Control 

Measure Determinations within Utah’s Salt Lake, 

Provo, and Logan 2006 24-Hour PM2.5 State 

Implementation Plans 

This document provides information and analysis supporting the EPA’s proposed 

action on Utah’s Area Source Rules and other general rule revisions submitted on 

February 2, 2012, May 9, 2013; June 8, 2013; February 18, 2014; April 17, 2014; May 

20, 2014; July 10, 2014; August 6, 2014; and December 9, 2014 and proposed action on 

the reasonably available control measures for the area source rules submitted with Utah’s 

December 16, 2014 2006 24-Hour fine particulate matter (PM2.5) Plans. The Salt Lake, 

Provo, and Logan nonattainment areas in Utah are currently designated nonattainment 

and classified as moderate for the 2006 PM2.5 standard. See 79 FR 31566 (June 2, 2014) 

and 40 CFR § 81.345. 

I. Regulatory Background 

 On October 17, 2006 (71 FR 61144), the EPA strengthened the level of the 24-

hour PM2.5 National Ambient Air Quality Standards (NAAQS), lowering the primary and 

secondary standards from 65 micrograms per cubic meter (μg/m3), the 1997 standard, to 

35μg/m3. On November 13, 2009 (74 FR 58688), the EPA designated three 

nonattainment areas in Utah for the 24-hour PM2.5 NAAQS of 35 μg/m3

. These are the 

Salt Lake City, UT; Provo, UT; and Logan, UT-ID nonattainment areas. The EPA 

originally designated these areas under Clean Air Act (CAA or Act) title I, part D, 
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subpart 1, which required Utah to submit an attainment plan for each area no later than 

three years from the date of their nonattainment designations. These plans needed to 

provide for the attainment of the PM2.5 standard as expeditiously as practicable, but no 

later than five years from the date the areas were designated nonattainment. 

 Subsequently, on January 4, 2013, the U.S. Court of Appeals for the District of 

Columbia held that the EPA should have implemented the 2006 PM2.5 24-hour standard 

based on both CAA title I, part D, subpart 1 and subpart 4. Under subpart 4, 

nonattainment areas are initially classified as moderate, and moderate area attainment 

plans must address the requirements of subpart 4 as well as subpart 1. Additionally, CAA 

subpart 4 sets a different State Implementation Plan (SIP) submittal due date and 

attainment year. For a moderate area, the attainment SIP is due 18 months after 

designation and the attainment year is the end of the sixth calendar year after designation. 

On June 2, 2014 (79 FR 31566), the EPA finalized the Identification of Nonattainment 

Classification and Deadlines for Submission of State Implementation Plan (SIP) 

Provisions for the 1997 Fine Particulate (PM2.5) National Ambient Air Quality Standard 

(NAAQS) and 2006 PM2.5 NAAQS (“the Classification and Deadline Rule”). This rule 

classified to moderate the areas that were designated in 2009 as nonattainment, and set 

the attainment SIP submittal due date for those areas at December 31, 2014. This rule did 

not affect the moderate area attainment date of December 31, 2015. 

 On March 23, 2015, the EPA proposed the Fine Particulate Matter National 

Ambient Air Quality Standards: State Implementation Plan Requirements (“PM2.5

Implementation Rule”), 80 FR 15340, which partially addresses the January 4, 2013 court 

ruling. This proposed rule details how air agencies should meet the statutory SIP 
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requirements that apply under subparts 1 and 4 to areas designated nonattainment for any 

PM2.5 NAAQS, such as: general requirements for attainment plan due dates and 

attainment demonstrations; provisions for demonstrating reasonable further progress; 

quantitative milestones; contingency measures; Nonattainment New Source Review 

(NNSR) permitting programs; and reasonably available control measures (RACM) 

(including reasonably available control technology (RACT)), among other things. The 

statutory attainment planning requirements of subparts 1 and 4 were established to ensure 

that the following goals of the CAA are met: (i) That states implement measures that 

provide for attainment of the PM2.5 NAAQS as expeditiously as practicable; and, (ii) that 

states adopt emissions reduction strategies that will be the most effective, and the most 

cost-effective, at reducing PM2.5 levels in nonattainment areas. 

The PM2.5 Implementation Rule proposed a process for states to determine the 

control strategy for PM2.5 attainment plans. The process consists of identifying all 

technologically and economically feasible control measures, including control 

technologies for all sources of direct PM2.5 and PM2.5 precursors in the emissions 

inventory for the nonattainment area which are not otherwise exempted from 

consideration for controls.1

 From that list of measures, the state must identify those that it 

can implement within four years of designation of the area (and which would thus meet 

the statutory requirements for RACM and RACT) and any “additional reasonable 

measures,” which EPA is proposing in the PM2.5 Implementation Rule to define as those 

technologically and economically feasible measures that the state can only implement on 

 

1

 Such exemptions could be due to a demonstrated lack of significant contribution of a certain PM2.5

precursor to the area’s elevated PM2.5 concentrations or due to a presumptive determination that a certain 

source category contributes only a de minimis amount toward PM2.5 levels in a nonattainment area. 
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sources in the nonattainment area after the four year deadline for RACM and RACT has 

passed. See proposed 40 CFR 51.1000. 

II. RACT and RACM Requirements for PM2.5 Attainment Plans 

Section 172(c)(1) of the Act (from subpart 1) requires that attainment plans, in 

general, provide for the implementation of all RACM as expeditiously as practicable 

(including RACT) and shall provide for attainment of the national primary ambient air 

quality standards. Section 189(a)(1)(C) (from subpart 4) requires moderate area 

attainment plans to contain provisions to assure that RACM is implemented no later than 

4 years after designation. As part of the RACM/RACT analysis, all available controls 

should be evaluated, and reasonable controls should be adopted. 

The EPA stated its interpretation of the RACT and RACM requirements of 

subparts 1 and 4 in the 1992 General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990, 57 FR 13498 (Apr. 6, 1992). For RACT, the EPA 

followed its “historic definition of RACT as the lowest emission limitation that a 

particular source is capable of meeting by the application of control technology that is 

reasonably available considering technological and economic feasibility." 57 FR 13541. 

Like RACT, the EPA has historically considered RACM to consist of control measures 

that are reasonably available, considering technological and economic feasibility. See 

PM2.5 Implementation Rule, 80 FR 15373. 

The EPA recommends that states use the following process to identify 

RACM/RACT: 

1. Develop a comprehensive list of available control measures for all source categories 

in the nonattainment area. In developing this list, the state should identify existing 
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control measures currently being implemented in the area and also include any 

control measures suggested in public comments. 

2. Remove from the list any measure that is unreasonable because emissions from the 

affected source or source category are insignificant (i.e., de minimis). The state 

should appropriately document any determination that a source or source category is 

insignificant. 

3. Evaluate each remaining available control measure for its “reasonableness,” 

considering technological and economic feasibility and any potentially adverse 

impacts. The state should provide a reasoned justification if it rejects a listed control 

measure as unreasonable. 

4. Include in its submitted Moderate area attainment plan, in enforceable form, each 

control measure found to be reasonable unless the measure is already either federally 

promulgated, part of the state’s SIP, or otherwise creditable in SIPs. In areas that 

demonstrate attainment by the Moderate area attainment date, the state may justify 

rejection of an otherwise reasonable measure by demonstrating that the measure 

would not, individually or collectively with other reasonable measures being rejected, 

advance attainment by one year or more. For areas that demonstrate that attainment 

by the Moderate area attainment date is impracticable, the state must provide for the 

implementation of all available control measures that are technologically and 

economically feasible. 

See General Preamble at 13540-13544. 

An evaluation of technological feasibility should include consideration of factors 

such as a source’s process and operating conditions, raw materials, physical plant layout, and 
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non-air quality and energy impacts (e.g., increased water pollution, waste disposal, and 

energy requirements) (57 FR 18070, 18073). 

An evaluation of economic feasibility should include consideration of factors such as 

cost per ton of pollution reduced (cost-effectiveness), capital costs, and annualized cost (57 

FR 18070, 18074). Absent other indications, the EPA presumes that it is reasonable for 

similar sources to bear similar costs of emissions reductions. Economic feasibility of RACM 

and RACT is thus largely informed by evidence that other sources in a source category have 

in fact applied the control technology, process change, or measure in question in similar 

circumstances. Id. 

III. Utah’s PM2.5 Attainment Plan Submittals 

Prior to the January 4, 2013 decision of the D.C. Circuit Court of Appeals, Utah 

developed a PM2.5 attainment plan intended to meet the requirements of subpart 1. The 

EPA submitted written comments dated November 1, 2012 to the Utah Division of Air 

Quality (DAQ) on Utah's draft PM2.5 SIP, technical support document (TSD), and area 

source and other rules. After the court’s decision, Utah amended its attainment plan to 

address requirements of subpart 4. On December 2, 2013, the EPA provided comments 

on Utah's revised draft PM2.5 SIPs for the Salt Lake City and Provo areas, including the 

TSDs and rules in Section IX, Part H. These written comments from EPA included some 

comments applicable to the rules we are proposing to act on today. The comment letters 

can be found within the docket for this action on regulations.gov. 

On May 9, 2013; June 8, 2013; February 18, 2014; April 17, 2014; May 20, 2014; 

July 10, 2014; August 6, 2014; and December 9, 2014 the State of Utah submitted to 

EPA various revisions to the DAR, Title R307 - Environmental Quality, set of rules, most 

of which are applicable to the Utah SIP for PM2.5 nonattainment areas. The new rules or 
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revised rules we are addressing in this proposed rule were provided by Utah in the nine 

different submissions listed above, and these rules are: R307-101-2, General 

Requirements: Definitions; R307-103, Administrative Procedures; R307-303, 

Commercial Cooking; R307-307, Road Salting and Sanding; R307-312, Aggregate 

Processing Operations for PM2.5 Nonattainment Areas; R307-328, Gasoline Transfer and 

Storage; R307-335, Degreasing and Solvent Cleaning Operations; R307-342, Adhesives 

and Sealants; R307-343 Emissions Standards for Wood Furniture Manufacturing 

Operations; R307-344, Paper, Film, and Foil Coatings; R307-345, Fabric and Vinyl 

Coatings; R307-346, Metal Furniture Surface Coatings; R307-347, Large Appliance 

Surface Coatings; R307-348, Magnet Wire Coatings; R307-349, Flat Wood Panel 

Coatings; R307-350, Miscellaneous Metal Parts and Products Coatings; R307-351, 

Graphic Arts; R307-352, Metal Container, Closure, and Coil Coatings; R-307-353, 

Plastic Parts Coatings; R307-354, Automotive Refinishing Coatings; R307-355, Control 

of Emissions from Aerospace Manufacture and Rework Facilities; R307-356, Appliance 

Pilot Light; R307-357, Consumer Products; and R307-361, Architectural Coatings. 

A previous rule, Rule R307-340 Surface Coating Processes, was replaced in these 

submittals by the specific rules for coatings listed above. Utah correspondingly repealed 

R307-340. In addition, Rule R307-342, Adhesives and Sealants, replaces an unrelated 

rule, R307-342 Qualifications of Contractors and Test Procedures for Vapor Recovery 

Systems for Gasoline Delivery Tanks. The removal of the previous version of R307-342 

is addressed by the State’s February 2, 2012 submittal, which repeals R307-342 and 

amends R307-328, Gasoline Transfer and Storage, to account for the repeal of R307-342. 

The final Utah submittal for fourteen of these rules was the December 9, 2014 
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submittal. The final Utah submittals for the remaining rules were from the February 2, 

2012; May 9, 2013; June 8, 2013; February 18, 2014; May 20, 2014; and August 6, 2014 

submittals. 

IV. Utah’s RACM Analyses 

Generally speaking, DAQ’s RACM analyses are of two types. For source 

categories that emit volatile organic compounds (VOCs) because they manufacture or use 

materials with VOC content (such as solvents), DAQ considered the technologically 

feasible controls to be manufacture or use of low-VOC materials, or the use of add-on 

controls with a specified overall control efficiency. To determine economic feasibility for 

the RACM levels for the low-VOC materials and for the control efficiency, DAQ 

examined EPA’s control technique guidelines (CTGs) and rules for similar source 

categories from the South Coast Air Quality Management District (SCAQMD), Bay Area 

Air Quality Management District (BAAQMD), and San Joaquin Valley Air Pollution 

Control District (SJVAPCD). For rules from one of those districts that are cited in this 

TSD, the rule may be found at the following links: 

• BAAQMD: http://www.baaqmd.gov/rules-and-compliance/current-rules

• SCAQMD: http://www.aqmd.gov/home/regulations/rules/scaqmd-rule-book

• SJAVPCD: https://www.valleyair.org/rules/1ruleslist.htm

Finally, DAQ estimated the cost-effectiveness of the rule in 2011 dollars per ton 

of VOC removed. Typically, a cost-effectiveness below $5000/ton may be considered 

reasonable. For source categories other than categories that use materials with VOC 

content (such as source categories that emit nitrogen oxides (NOx), sulfur dioxide (SO2), 

and/or direct PM2.5), DAQ performed a more category-specific analysis of 
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technologically feasible controls and of the economic feasibility of those controls. As 

described below, we propose to determine that Utah reasonably determined RACM for 

the rules we are approving. 

V. EPA’s Review of Individual Area Source Rules 

A. R307-101, General Requirement 

Rule R307-101 provides general requirements that pertain to all DAQ R307 rules, 

which constitute the basis for control of air pollution sources in the State of Utah. The 

primary section is R307-101-2 Definitions, which provide definitions that are applicable 

to all R307 rules, except for those definitions as specified in individual rules. As part of 

the development of the SIP for PM2.5, three new definitions were originally proposed for 

section R307-101-2, General Requirements, Definitions. These new definitions were: 

“condensable PM2.5,” “filterable PM2.5,” and “PM2.5 precursor.” Also, under the 

definition of “significant,” a level of 10 tons per year (tpy) of PM2.5 was added in 

reference to a net emissions increase or the potential of a source to emit. Then, in 

reference to public comments received on that original proposal, definitions for “primary 

PM2.5” and “secondary PM2.5” were added. The definition of PM2.5 precursor did not 

include ammonia, which is factually a precursor to PM2.5 and should be included in the 

emissions inventory. DAQ has committed in their letter dated August 4, 2015 to remove 

the definition of “PM2.5 precursor,” as that definition is not used for regulatory purposes 

in Utah’s SIP. Under section 110(k)(4) of the Act, EPA may approve a SIP revision 

based on a commitment by the State to adopt specific enforceable measures by a date 

certain, but not later than 1 year after the date of approval of the plan revision. 

DAQ submitted these revisions of R307-101-2 to the EPA on May 9, 2013. The 
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Board proposed for public comment R307-101-2 on September 5, 2012, and the public 

comment period was held from October 1 to November 1, 2012. Public hearings were 

held on October 15, 16, and 17, 2012. DAQ made changes to section R307-101-2 based 

on comments that were received, then held a second comment period from January 1 to 

January 31, 2013 for those revisions. No additional comments were received on section 

R307-101-2. Lastly, a “Nonsubstantive Rule Amendment” was made by Utah to correct a 

citation to the United States Code of Federal Regulations 40 CFR 51.100. In accordance 

with Utah Code Title 19, Chapter 2, Air Conservation Act, Utah Code Title 63G, Chapter 

3, Administrative Rulemaking Act, and Utah Administrative Code, R15, Administrative 

Rules, this change was made without public comment, as appropriate for a nonsubstantive change. This submittal was made by DAQ on May 20, 2014 to the EPA. 

The final revision of Rule R307-101 was effective July 9, 2013, and is applicable 

to the entire State of Utah. Utah’s rule analysis can be found within the docket on 

regulations.gov. EPA is proposing conditional approval of revisions done to R307-101. If 

we finalize our proposed conditional approval, Utah must adopt and submit the specific 

revisions it has committed to within one year of our finalization. If Utah does not submit 

these revisions within one year, or if we find Utah’s revisions to be incomplete, or we 

disapprove Utah’s revisions, this conditional approval will convert to a disapproval. If 

any of these occur and our conditional approvals converts to a disapproval, that will 

constitute a disapproval of a required plan element under part D of title I of the Act, 

which starts an 18-month clock for sanctions, see section 179(a)(2), and the 2-year clock 

for a federal implementation plan (FIP), see section 110(c)(1)(B). 

B. R307-103, Administrative Procedures 
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Rule R307-103 provides administrative procedures that pertains to all R307 rules, 

which constitute the basis for control of air pollution sources in the State of Utah. R307-

103 has only one section, R307-103-1 - Administrative Procedures. The section 

previously stated: “Administrative proceedings under Utah Air Quality Act are governed 

by Rule R305-6.” The State’s May 20, 2014 submission documented a non-substantial 

change that had become effective January 1, 2014. The revision corrected the Rule R305 

citation within the rule which now states: “Administrative proceedings under Utah Air 

Quality Act are governed by Rule R305-7.” There was no changes to rule R305 itself. 

R305 governs all adjudicative procedures conducted under the authority of the 

Environmental Quality Code, Utah Code Ann. Title 19. This rule does not govern the 

proceedings that result in an initial determination by the Director, including the issuance 

of the initial determination itself. In accordance with Utah Code Title 19, Chapter 2, Air 

Conservation Act, Utah Code Title 63G, Chapter 3, Administrative Rulemaking Act, and 

Utah Administrative Code, R15, Administrative Rules, this change was made without 

public comment, as appropriate for a non-substantive change. Utah’s rule analysis can be 

found within the docket on regulations.gov. EPA is proposing approval of the nonsubstantive revisions in R307-103-1. We note that the CAA does not specify detailed 

requirements for administrative procedures, with the exception of section 128 of the Act, 

regarding conflicts of interest. We are not proposing to determine that this nonsubstantive revision addresses the requirements of section 128. 

C. R307-303, Commercial Cooking 

Rule R307-303 is a new rule that establishes emission control device 

requirements to reduce VOC and PM2.5 emissions from certain commercial cooking 
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equipment. Per the rule requirements, owners or operators of all chain-driven charbroilers 

in food service establishments must install, maintain and operate a catalytic oxidizer for 

treatment of air emissions from the charbroilers. The rule applies to all such 

establishments in the 2006 24-hour PM2.5 nonattainment areas, which include Box Elder, 

Cache, Davis, Salt Lake, Tooele, Utah and Weber counties. There are specific 

maintenance, performance and recordkeeping requirements to ensure proper operation, 

and the opacity of the exhaust stream is not to exceed 20% opacity as determined by 

using EPA Method 9. EPA proposes to approve the rule as an enforceable control 

measure with adequate monitoring, recordkeeping, and reporting, including adequate test 

methods. 

DAQ’s RACM analysis for this rule was based on review of the BAAQMD and 

the SJVAPCD RACT analyses and the City of Aspen rule. DAQ made direct contact with 

the staff at these three air districts, which was made to gain actual implementation and 

front-line performance information and cost. DAQ considered as feasible technologies a 

catalytic oxidizer, a water scrubber, and an electronic precipitator. DAQ eliminated the 

latter two as economically infeasible due to cost-effectiveness of $15,000/ton of pollutant 

removal. As a result, DAQ determined that RACM consisted of a catalytic oxidizer, with 

an estimated annual cost of $2,028. EPA proposes to approve DAQ’s RACM 

determination. 

On June 8, 2013 DAQ submitted R307-303 as a new rule to EPA for approval. 

The Board proposed R307-303 for public comment on July 11, 2012, and had a public 

comment period from August 1 to August 31, 2012. Additionally, a public hearing was 

held on August 15, 2012. No comments were received, and no one appeared at the 
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hearing. 

Rule R307-303 was effective April 10, 2013, and required compliance with the 

rule beginning September 1, 2013. Utah’s RACM and rule analysis can be found within 

the docket regulations.gov. EPA is proposing approval of the new rule R307-303 and also 

that R307-303 currently constitutes RACM for the Nonattainment Areas for Commercial 

Cooking for the Utah PM2.5 SIP. 

D. R307-307, Road Salting and Sanding 

R307-307 is an existing rule that was part of the coarse particulate matter (PM10) 

SIP approved by EPA on December 6, 1999 (64 FR 68031). This rule establishes 

requirements for the composition of salt, or abrasives such as crushed slag and sand, 

applied to roads in PM10 and PM2.5 nonattainment and maintenance areas as defined in 40 

CFR 81.345 (July 1, 2011). The rule also establishes recordkeeping requirements 

associated with such applications. The applicable areas is geographically described 

within the rule as all regions of Davis, Salt Lake, and Utah counties; all portions of the 

Cache Valley; all regions in Weber County west of the Wasatch mountain range; in Box 

Elder County, from the Wasatch mountain range west to the Promontory mountain range 

and south of Portage; and in Tooele County, from the northernmost part of the Oquirrh 

mountain range to the northern most part of the Stansbury mountain range and north of 

Route 199. 

The rule was amended by expanding the applicability to include PM2.5

nonattainment areas; adding magnesium chloride (MgCl2), calcium chloride (CaCl2), and 

potassium chloride (KCl) to the Records, Content, and Alternatives sections of the rule; 

and adding specific road sections that are exempt from certain parts of R307-307. 
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Additional revisions to the rule include non-substantive changes. The RACT analysis 

approved as part of the PM10 SIP approval in 1999 demonstrated a reduction in the PM10

emissions from road dust and road salting and sanding by 20%. DAQ discusses in their 

TSD that the reduction in PM2.5 emissions are an unknown quantity and considered to be 

minimal, thus no SIP credit will be taken for this rule. Nonetheless this rule will 

contribute to PM2.5 reductions in the non-attainment area by increasing the geographic 

applicability and adds value to the SIP. 

DAQ submitted revisions to R307-307 to the EPA on May 9, 2013. The Board 

proposed these revisions to R307-307 on September 5, 2012, and the public comment 

period was held from October 1 to October 31, 2012. Public hearings were held on 

October 15, 16, and 17, 2012, and public comments were received from Utah Department 

of Transportation (UDOT) and the EPA for the proposed R307-307 rule revisions. The 

November 21, 2012 Memo in the docket on regulations.gov summarizes the comments 

and provides DAQ’s response to these comments. R307-307 became effective on 

February 1, 2013 after updating the rule to address the public comments. 

Finally, a “Non-substantive Rule Amendment” was submitted to EPA by Utah on 

May 20, 2013 to correct a mistakenly omitted word. In several occurrences where the 

applicable salts applied to roads in Salt Lake, Davis, or Utah counties were detailed, the 

sentence read “NaCl, MgCl2, CaCl2, or KCl.” The sentence was corrected to read “NaCl, 

MgCl2, CaCl2, and/or KCl.” In accordance with Utah Code Title 19, Chapter 2, Air 

Conservation Act, Utah Code Title 63G, Chapter 3, Administrative Rulemaking Act, and 

Utah Administrative Code, R15, Administrative Rules, this change was made without 

public comment, as appropriate for a non-substantive change. These revisions became 
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effective on February 15, 2013. 

Required compliance with the rule was already October 1, 1993 for Salt Lake, 

Davis and Utah counties, and the compliance date for the remaining affected counties 

began January 1, 2014. Utah’s rule analysis can be found within the docket on 

regulations.gov. Additionally, EPA requested clarification pertaining to R307-

307(5)(1)(a) which states “demonstrate to the director that the material applied has no 

more PM10 or PM2.5 emissions than salt which is at least 92% NaCl, MgCl2, CaCl2, 

and/or KCl.” The clarification requested is for what the Director of DAQ receives from a 

source that demonstrates the road salt meets the rules 92%. DAQ provided a letter on 

August 4, 2015 clarifying that the sources provide a compositional analysis of the road 

salt to show that it meets the 92% standard found in R307-307(5)(1)(a). EPA is satisfied 

with this clarification and is proposing to approve the revisions to R307-307 but not that 

R307-307 currently constitutes RACM because DAQ did not take SIP credit for this rule. 

E. R307-312, Aggregate Processing Operations for PM2.5 Nonattainment Areas 

R307-312 is a new rule that establishes emission standards for sources in the 

aggregate processing industry, including aggregate processing equipment, hot mix 

asphalt plants, and concrete batch plants. The rule applies to all crushers, screens, 

conveyors, hot mix asphalt plants, and concrete batch plants located within a PM2.5

nonattainment and maintenance area as defined in 40 CFR 81.345 (July 1, 2011). This 

area includes all regions of Salt Lake and Davis counties; all portions of the Cache 

Valley; all regions in Weber and Utah counties west of the Wasatch mountain range; in 

Box Elder County, from the Wasatch mountain range west to the Promontory mountain 

range and south of Portage; and in Tooele County, from the northernmost part of the 
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Oquirrh mountain range to the northern most part of the Stansbury mountain range and 

north of Route 199. The provisions of R307-312 do not apply to temporary hot mix 

asphalt plants. 

The rule addresses two aspects of the industry to limit emissions. One is to limit 

emissions of direct PM2.5 from the aggregate processing industry. This is essentially the 

material handling aspects of aggregate processing operations, including crushers, screens, 

and conveyance systems. Second is addressing the emissions of PM2.5 precursors from 

hot mix asphalt plants. This includes emissions from combustion sources, mobile sources, 

generators, engines, heaters, and dryers. For aggregate processing operations, visible 

emissions from subject sources may not exceed specific opacity limits of 12% for 

crushers, and 7% for screens, conveyor transfer points and concrete batch plants. The 

limit on filterable PM2.5 emissions from a hot mix asphalt plant dryer is 0.024 gr/dscf. 

Combustion product emissions from a hot asphalt plant are controlled by the fuel burned. 

Natural gas (NG) or liquefied petroleum gas (LPG) must be used to avoid production 

limitations. If fuel other than NG or LPG is used from November 1 to March 1, a hot mix 

asphalt plant may not produce at more than 50% of its rated capacity during that period. 

Many sources are already meeting several of the required limits. Modifications to 

existing equipment have recently been made or will be made in the near future. All hot 

mix asphalt plants will be required to comply with the 0.024 gr/dscf limit by December 

14, 2015. All remaining sources have already had to comply with R307-312 by June 7, 

2013. 

For the opacity limit, compliance is based on opacity observations of emissions 

conducted according to 40 CFR 60, Appendix A, EPA Method 9. Filterable PM2.5
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emissions compliance is determined by 40 CFR 51, Appendix M, Method 201A. For the 

fuel usage requirements, compliance is based on either the daily amount of hot mix 

asphalt produced averaged over the operating day or the daily amount of hot mix asphalt 

produced while burning a fuel other than natural gas or LPG averaged over the time the 

plant is operating while burning a fuel other than natural gas or LPG each day. 

Compliance is determined by production records and fuel records. 

DAQ submitted revisions to R307-312 to EPA on May 9, 2013. The Board 

proposed R307-312 for public comment on September 5, 2012, with the public comment 

period held from October 1 to November 1, 2012. Three public hearings were held on 

October 15, 16, and 17, 2012. Written comments were received from industry, the public 

and the EPA. 

R307-312 was effective February 1, 2013 and required compliance with the rule 

began June 7, 2013. Utah’s RACM and rule analysis can be found in the docket posted on 

regulations.gov. For direct PM2.5, the RACM analysis considered the following as 

technologically feasible control measures for aggregate processing: water application, 

enclosures, and add-on control devices, including a baghouse, electrostatic precipitator, 

wet scrubber, and cyclone. DAQ considered enclosures and add-on controls to be not 

economically feasible for aggregate processing equipment and determined water 

application to be RACM at a cost-effectiveness of $650/ton. However, water application 

was not considered feasible for the one existing concrete batch plant; DAQ determined 

RACM to be the existing baghouse and fabric filter controls. The RACM analysis 

consider the following add-on controls as technologically feasible for filterable PM from 

hot mix asphalt plants: baghouse, electrostatic precipitator, wet scrubber, and cyclone. 
20 

DAQ did not find any controls technologically feasible for condensable PM. The analysis 

considered all the add-on controls to be economically feasible; DAQ correspondingly set 

a direct PM2.5 limit of 0.024 gr/dscf. For NOx, DAQ considered low-NOx burners, 

NSCR, SCR, and use of natural gas to be technically feasible. DAQ determined that use 

of natural gas should be RACM. 

Additionally, EPA requested that DAQ commit to revise R307-312-5(2)(a) which 

states “Production shall be determined by scale house records or equivalent method on a 

daily basis.” The requested change is to provide what the “equivalent method” that could 

be used. DAQ committed in their August 4, 2015 letter to remove “equivalent method” 

and state “Production shall be determined by scale house records, scale house or belt 

scale records, or manifest statements on a daily basis.” 

Under section 110(k)(4) of the Act, EPA may approve a SIP revision based on a 

commitment by the State to adopt specific enforceable measures by a date certain, but not 

later than 1 year after the date of approval of the plan revision. If we finalize our 

proposed conditional approval, Utah must adopt and submit the specific revisions it has 

committed to within one year of our finalization. If Utah does not submit these revisions 

within one year, or if we find Utah’s revisions to be incomplete, or we disapprove Utah’s 

revisions, this conditional approval will convert to a disapproval. If any of these occur 

and our conditional approvals converts to a disapproval, that will constitute a disapproval 

of a required plan element under part D of title I of the Act, which starts an 18-month 

clock for sanctions, see section 179(a)(2), and the 2-year clock for a FIP, see section 

110(c)(1)(B). 

EPA agrees with the revisions that DAQ has committed to and is proposing a 
21 

conditional approval of the revisions to R307-312 and also that R307-312 currently 

constitutes RACM for the Nonattainment Areas for Aggregate Processing Operations for 

the Utah PM2.5 SIP. 

F. R307-328, Gasoline Transfer and Storage 

On January 5, 2011, the Board proposed for public comment revisions to R307-

328, Gasoline Transfer and Storage, and held the public comment period from February 1 

to March 3, 2012. No public hearings were held due to lack of a request and DAQ 

received no comments addressing the revisions to R307-328. 

The proposal removes the “Qualified contractor” definition, eliminates the current 

December to March testing window, replaces the current testing and vapor tightness 

standards with the more stringent standard in the federal maximum achievable control 

technology (MACT) for Gasoline Distribution Facilities (specifically 40 CFR 6.425(e)), 

and general administrative changes. Since the MACT standard does not require a 

certified Tester, the test method and certification requirements in R307-342 were no 

longer needed thus the reference in R307-328 to R307-342 was removed. 

The compliance schedule for the vapor tightness testing standard in R307-328-

7(1) were to apply to tests conducted after June 7, 2011 and all gasoline cargo tanks were 

to be tested using the vapor tightness testing standard in R307-328-7(1) by June 7, 2012. 

The revisions to R307-328 was adopted by the Board on April 6, 2011 and was effective 

on June 7, 2011. Utah’s rule analysis can be found in the docket posted on 

regulations.gov. 

Additionally, EPA requested that DAQ commit to revise R307-328-4(6) which 

states “A gasoline storage and transfer installation that receives inbound loads and 
22 

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 offload gasoline by use of bottom 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 of Hydrocarbons 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.” The requested change is to remove the “alternative equivalent 

method” from this section. DAQ committed in their August 4, 2015 letter to remove 

“alternative equivalent method” and state: “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 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 
23 

approved by the executive secretary.” 

Under section 110(k)(4) of the Act, EPA may approve a SIP revision based on a 

commitment by the State to adopt specific enforceable measures by a date certain, but not 

later than 1 year after the date of approval of the plan revision. If we finalize our 

proposed conditional approval, Utah must adopt and submit the specific revisions it has 

committed to within one year of our finalization. If Utah does not submit these revisions 

within one year, or if we find Utah’s revisions to be incomplete, or we disapprove Utah’s 

revisions, this conditional approval will convert to a disapproval. If any of these occur 

and our conditional approvals converts to a disapproval, that will constitute a disapproval 

of a required plan element under part D of title I of the Act, which starts an 18-month 

clock for sanctions, see section 179(a)(2), and the 2-year clock for a FIP, see section 

110(c)(1)(B). 

EPA agrees with the revisions that DAQ has committed to and is proposing to 

conditionally approve the revisions in R307-328. 

G. R307-335, Degreasing and Solvent Cleaning Operations 

Rule R307-335 establishes control measures for VOC emissions from parts 

degreasing in tanks and conveyorized systems and to control emissions during equipment 

cleaning. The rule applies to all degreasing or solvent cleaning operations that use VOCs 

and that are located in PM10 and PM2.5 nonattainment and maintenance plan areas as 

defined in 40 CFR 81.345 (July 1, 2011). 

The rule is divided into two sections, the first is the tank degreasing portion that 

has its roots in the 1994 degreasing MACT and the second portion is the new section, 

R307-335-7 Industrial Solvent Cleaning, which is based on EPA CTG for Industrial 
24 

Cleaning Solvents, EPA 453/R-06-001, September 2006. DAQ estimated a cost 

effectiveness of $1640/ton of VOC in 2011 dollars for batch and conveyorized systems, 

and cost neutral (unless add-on controls are used) for cleaning solvents. We note that the 

stringency of this rule is generally in line with other VOC rules for this source category, 

for example SCAQMD Rule 1122. Types of processes addressed by R307-335 include: 

cold cleaning facilities; open top vapor degreasers; conveyorized degreasers; and, general 

industrial solvent cleaning. The emissions reductions are accomplished through 

prohibition of certain high VOC emitting products and specification of equipment design 

specifics, solvent storage and handling, equipment operation and maintenance, allowed 

solvents and their properties, emission control system requirements, and recordkeeping 

and compliance requirements. 

There are exemptions for the type and use of industrial cleaning solvents for 

specific sectors of industry where such requirements are addressed in other rules. The 

solvent handling, storage, and disposal, and specific solvent properties requirements 

detailed in R307-335-7 do not apply to aerospace, wood furniture, shipbuilding and 

repair, flat wood paneling, large appliance, metal furniture, paper film and foil, plastic 

parts, miscellaneous metal parts coat and light auto body and truck assembly coatings, 

flexible packaging, lithographic and letterpress printing materials, fiberglass boat 

manufacturing materials, and operations that are exclusively covered by Department 24 

of Defense military technical data and performed by a Department of 25 Defense 

contractor and/or on site at installations owned and/or 26 operated by the United States 

Armed Forces. The individual industry specific rules address requirements, as applicable. 

On May 9, 2013 DAQ submitted revisions for R307-335 to the EPA. The Board 
25 

proposed these revisions to R307-335 for public comment on July 11, 2012 and had a 

public comment period from August 1 to August 31, 2012 with a public hearing on 

August 15, 2012. DAQ received many written comments from the aerospace industry, 

from one industry that treats miscellaneous metals parts, and the EPA. The public hearing 

attendees were solely from the aerospace industry. 

On July 22, 2014, DAQ submitted additional revisions to R307-335 to the EPA. 

This submittal contained multiple revisions to R307-335, multiple Board hearings, and 

multiple public comment periods. Initially the Board proposed amendments to R307-335 

for public comment on July 3, 2013 with a public comment period from August 1 to 

September 3, 2013. The amendments to the rule include adding an exemption for 

operations that are exclusively covered by the Department of Defense military technical 

specifications and/or performed by a Department of Defense contractor on site at 

installations owned or operated by the United States Armed Forces. Also, language was 

added to clarify the 15-pound/day rule applicability is from the cleaning process. DAQ 

received written comments from industry concerning industrial safety concerns and 

widely available commercial products. Details of the comments and the State’s rationale 

in addressing those comments are in DAQ’s July 22, 2014 submittal within the 

memorandum DAQ-088-13 dated October 23, 2013. 

Due to additional concerns from industry, on November 6, 2013, the Board 

proposed for public comment further amendments to R307-335. The public comment 

period was initially held from December 1 to December 31, 2013. However, during the 

public comment period, in response to a request, the comment period was extended to 

January 10, 2014. The proposed amendments were to: clarify that the requirements of 
26 

R307-335-7(2) apply to operators of industrial solvent cleaning that emit 15 pounds of 

VOCs or more per day from the cleaning process; exempt military technical data orders 

in R307-335-7(1); and, propose a general VOC solvent content limit of 2.49lb/gal in 

R307-335-7(3)(b). Based on comments to these proposed changes and additions, VOC 

content limits were again adjusted. Details of the comments and the State’s rationale in 

addressing those comments are in DAQ’s July 22, 2014 submittal within the 

memorandum DAQ-015-14 dated February 11, 2014. 

On December 9, 2014, DAQ submitted additional revisions of R307-335 to the 

EPA. These revisions were due to ongoing EPA concerns associated with the amount of 

control removal specified in R307-335, as well as in other similar area source rules, that 

control removal be based on the entire control system, and that the inspection and 

recordkeeping requirements for the rules be expanded before they could be approved. On 

July 2, 2014, the Board proposed for public comment amendments to R307-335 and the 

public comment period was held from August 1 to September 2, 2014. The proposed 

amendments were approved by the Board on October 1, 2014 and the final version of 

R307-335 was effective on December 1, 2014. The final rule contains applicable 

language to provide for sufficient operating, testing, maintenance, reporting and 

recordkeeping requirements to allow proper compliance verification and enforcement, as 

well as appropriate changes associated with our December 2, 2013 comment letter. 

In the “Add-On Emission Control Systems Operations” section it reads “An 

alternative test method may be substituted for the preceding test methods after review and 

approval by the EPA Administrator.” EPA interprets this language to mean that such an 

alternate test method will be submitted by the State as a SIP revision that is subsequently 
27 

approved by the EPA through the EPA public notice and SIP approval process. 

The May 9, 2013 submittal from DAQ specified that all sources within Salt Lake 

and Davis counties were to be in compliance with R307-335-3 through R307-335-6 and 

R307-335-8 on January 1, 2013. Additionally in the May 9, 2013 submittal, all other 

sources defined in R307-335-2 were to be in compliance with all sections of this rule by 

September 1, 2013. The July 10, 2014 submittal from DAQ specified that all sources 

within Box Elder, Cache, Utah, Weber, and Tooele counties were to be in compliance 

with R307-335-7 by August 1, 2014. 

Utah’s RACM and rule analysis can be found in the docket posted on 

regulations.gov. EPA is proposing approval of all revisions of R307-335 and that R307-

335 currently constitutes RACM for the Nonattainment Areas for Degreasing and Solvent 

Cleaning Operations for the Utah PM2.5 SIP. 

H. Repeal of R307-340, Surface Coating Processes 

On September 5, 2012, the Board proposed for public comment the repeal of 

R307-340 and held the public comment period from October 1 to October 31, 2012. 

Public hearings were held on October 15, 16, and 17, 2012 for this rule repeal and 

multiple others. DAQ received no comments addressing the repeal of this rule. DAQ did 

receive comments for several of the individual coatings rules that will replace this rule, 

however those comments will be discussed in each individual rule below. 

Since the coatings industries regulated in R307-340 emit VOCs, DAQ staff 

wanted to expand the applicability of this rule to include the seven counties found in the 

PM2.5 nonattainment areas. While Utah looked into amending this rule to expand 

applicability, add new requirements to new coatings industries and attempted to clarify 
28 

regulatory requirements for coating industries, a repeal of R307-340 and writing new 

rules for each individual industry was preferable. These individual rules include R307-

343, R307-344, R307-345, R307-346, R307-347, R307-348, R307-349, R307-350, R307-

351, and R307-352. 

The repeal of Rule R307-340 was effective on February 1, 2013 and submitted to 

the EPA on May 9, 2013. Utah’s rule analysis can be found in the docket posted on 

regulations.gov. EPA is proposing that Rule R307-340, Surface Coating Processes be 

repealed from the Utah SIP. 

I. Repeal of R307-342, Qualifications of Contractors and Test Procedures for Vapor 

Recovery Systems for Gasoline Delivery Tanks. 

On January 5, 2011, the Board proposed for public comment the repeal of R307-

342, Qualifications of Contractors and Test Procedures for Vapor Recovery Systems for 

Gasoline Delivery Tanks and held the public comment period from February 1 to March 

3, 2012. No public hearings were held due to lack of a request and DAQ received no 

comments addressing the repeal of this rule. 

R307-342, Qualifications of Contractors and Test Procedures for Vapor Recovery 

Systems for Gasoline Delivery Tanks originally required contractors that performed tests 

of the vapor recovery systems to follow specified procedures and to be qualified annually 

by the Executive Secretary. DAQ subsequently revised R307-328, Gasoline Transfer and 

Storage (see discussion above for this revision), which amended the testing requirements 

for trucks and replacing it with the Federal MACT for Gasoline Distribution Facilities 

(specifically 40 CFR 63.425(e)). Since the MACT standard does not require a certified 

Tester, the test method and certification requirements in R307-342 were no longer 
29 

needed. Thus, DAQ repealed the language within R307-342, Qualifications of 

Contractors and Test Procedures for Vapor Recovery Systems for Gasoline Delivery 

Tanks, and replaced it with R307-342, Adhesives and Sealants (see discussion below on 

this rule). 

The repeal of R307-342, Qualifications of Contractors and Test Procedures for 

Vapor Recovery Systems for Gasoline Delivery Tanks, was adopted by the Board on April 

6, 2011 and was effective on June 7, 2011. This repeal was submitted to EPA from DAQ 

on February 2, 2012. Utah’s rule analysis can be found in the docket posted on 

regulations.gov. EPA finds that the revisions in R307-328 and reference to the Federal 

MACT standard adequately covers the repeal of this rule and does not signify backsliding 

within the SIP. Thus, EPA is proposing that R307-342 Qualifications of Contractors and 

Test Procedures for Vapor Recovery Systems for Gasoline Delivery Tanks be repealed 

from the Utah SIP and replaced by new R307-342 as discussed next. 

J. R307-342, Adhesives and Sealants 

R307-342 is a new rule that establishes requirements to limit VOC emissions 

from adhesives, sealants, primers and cleaning solvents. R307-342 applies to any person 

who manufactures any adhesive, sealant, adhesive primer or sealant primer in Box Elder, 

Cache, Davis, Salt Lake, Utah or Weber counties and to any person who sells, supplies, 

or applies any adhesive, sealant, adhesive primer or sealant primer in Box Elder, Cache, 

Davis, Salt Lake, Tooele, Utah or Weber counties. The emissions reductions are 

accomplished through prohibition of certain high VOC emitting products and practices. 

The rule limits product sales and use, and places requirements on application and removal 

methods of the allowed products. There are some exemptions consistent with the 
30 

guidelines discussed in the next paragraph. The rule also creates product labeling and 

recordkeeping requirements as part of rule compliance. 

The rule, which sets maximum VOC content, is based on other guidelines and 

similar rules, including EPA issued CTG for Miscellaneous Industrial Adhesives, EPA453/R-08-005, September 2008. EPA developed its recommended approaches in the CTG 

based on the analysis of existing state and local emission reduction approaches. Within 

DAQ’s TSD it is discussed that in 1998, the California Air Resources Board (CARB) 

issued a guidance document for the industry that was based on eight existing California 

air pollution control district rules. The Board determined that their guidance was RACT. 

In 2007, the Ozone Transport Commission (OTC) issued a model rule for adhesives and 

sealants that was based on the 1998 RACT determination. The model rule achieves VOC 

reductions through two basic components: sale and manufacture restrictions that limit 

VOC content of specified adhesives, sealants and primers sold and use restrictions that 

apply to commercial/industrial applications. Area source VOC reduction occurs by 

reducing the availability of higher VOC content adhesives and sealants within the 

nonattainment areas. EPA notes that the VOC content limits are generally consistent with 

other state rules, for example BAAQMD rule 8-51-300. DAQ estimates the costeffectiveness of Utah’s rule at $5730/ton in 2011 dollars. 

R307-342, largely based on the OTC model rule, addresses both these areas, and 

based on national product development programs with REs at 100%, consistent with use 

by other states (AirControlNET, 2006). Finally, the final rule is based on the most current 

OTC Model Rule which requires an overall capture and control efficiency of at least 85%

for any add-on emissions control systems operations. We note that this is more stringent 
31 

than (for example) the 80% requirement in SCAQMD rule 1168. 

DAQ submitted the new rule, R307-342 to EPA on February 18, 2014. The Board 

approved the new rule, R307-342 on February 6, 2013, and the public comment period 

was held from March 1 to April 1, 2013. A public hearing was held on March 13, 2013. 

DAQ received written comments from industry pertaining to the new proposed rule 

R307-342. 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-342, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that test methods and recordkeeping 

requirements for the rules be expanded, on July 2, 2014, the Board proposed for public 

comment amendments to R307-342. The amendments included language for control 

removal to be based on the entire control system and for the inspection and recordkeeping 

requirements. A public comment period was held from August 1 to September 2, 2014. 

After the comment period, DAQ made a change to the proposed rule that included the 

addition of language “(excluding compounds not classified as VOC)” within R307-342-

6(2)(b). 

In the “Add-On Controls Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The proposed revisions were adopted by the Board on October 1, 2014 and was 

effective on December 1, 2014. Compliance with these revisions were required 
32 

immediately. DAQ submitted these revisions to EPA on December 9, 2014. The final rule 

contains applicable language to provide for sufficient operating, testing, maintenance, 

reporting and recordkeeping requirements to allow proper compliance verification and 

enforcement, as well as appropriate changes associated with our December 2, 2013 

comment letter. 

Utah’s RACM and rule analysis can be found in the docket posted on 

regulations.gov. Additionally, EPA requested that DAQ clarify what VOC content test 

method would be used since the VOC definition found in R307-101-2 adopted and 

incorporated by reference 40 CFR 51.100(s) and how the transfer efficiency is 

determined. The VOC definition generally signifies test methods found in 40 CFR part 60 

Appendix A but does not provide a specific test method within Appendix A for this rule 

to follow. DAQ provided a clarification letter on August 4, 2015 that specifies EPA Test 

Method 24 from 40 CFR part 60 Appendix A would be used for R307-342 and that the 

manufacturer certifies the transfer efficiency. EPA agrees with these clarifications and is 

proposing to approve the new rule, R307-342, and also the subsequent revisions to this 

rule. Additionally, EPA is proposing that R307-342 currently constitutes RACM for the 

Nonattainment Areas for Adhesives and Sealants Operations for the Utah PM2.5 SIP. 

K. R307-343, Emissions Standards for Wood Furniture Manufacturing Operations 

R307-343 establishes requirements to limit VOC emissions from wood furniture 

manufacturing. These emission reductions are accomplished through limiting VOC 

content of coatings/materials used, establishing requirements for application equipment, 

work practice and recordkeeping, and selection, operation and maintenance of add-on 

VOC control equipment and systems. R307-343 applies to wood furniture manufacturing 
33 

operations, including related cleaning activities, that have the potential to emit 2.7 tons or 

more per year of VOCs and that are located in Box Elder, Cache, Davis, Salt Lake, Utah, 

Tooele, and Weber counties. 

The rule is based on the EPA CTG Control of VOC Emissions from Wood 

Furniture Manufacturing Operations, EPA 453/R-96-007, April 1996, as well as a review 

of similar current applicable California rules. Results from the evaluation of this rule in 

comparison to other coating rules resulted in the applicability being set to 2.7 tpy to gain 

further VOC reductions. VOC content limits are in-line with SCAQMD rules 1104 Wood 

Flat Stock Coating Operations and 1134 Wood Products Coatings. The SJVAPCD rule 

4606 was selected for the RACT comparative analysis. That rule requires an overall 

system efficiency of 85% and the same 85% requirement is proposed by Utah for any 

add-on emissions control systems operations. DAQ estimates a cost-effectiveness of 

$2,260/ton for this rule. 

On June 8, 2013 DAQ submitted revisions of R307-343 to the EPA. The Board 

proposed for public comment these revisions on September 5, 2012, and the public 

comment period was held from October 1 to November 1, 2012. Public hearings were 

held on October 15, 16, and 17, 2012. No public comments were received. 

Sources in Salt Lake and Davis counties that have the potential to emit between 

2.7 and 24 tons of VOC per year was scheduled to be in compliance by September 1, 

2013. Sources in Salt Lake and Davis counties that have the potential to emit 25 tons or 

more of VOC per year was to be in compliance by the effective date of this rule. All 

sources in Box Elder, Cache, Tooele, Utah, and Weber counties were to be in compliance 

by January 1, 2014. The effective date of these rule revisions was May 1, 2013 
34 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-343, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that the inspection and recordkeeping 

requirements for the rules be expanded before they could be approved, on July 7, 2014, 

the Board proposed for public comment amendments to R307-343. A public comment 

period was held from August 1 to September 2, 2014. The proposed amendments were 

adopted by the Board on October 1, 2014. The final rule contains applicable language to 

provide for sufficient operating, testing, maintenance, reporting and recordkeeping 

requirements to allow proper compliance verification and enforcement, as well as 

appropriate changes associated with our December 2, 2013 comment letter. 

In the “Add-On Controls Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The final version of Rule R307-343 was effective December 1, 2014, and 

compliance was immediate. Utah’s RACM and rule analysis can be found in the docket 

posted on regulations.gov. 

The revisions to R307-343 found within the June 8, 2013 and December 9, 2014 

submittals include changes to the rule applicability from sources that have the potential to 

emit 25 tons VOC per year to 2.7 tons of VOC per year and has been expanded to include 

all sources in Box Elder, Cache, Davis, Salt Lake, Utah, Tooele, and Weber counties. The 

definition section was updated to remove old definitions and to add new ones. Sources 
35 

are required to use a compliant coating method as described in the new Table 1 or to use 

a control system method that achieves 85% or greater VOC emissions reduction. A new 

section is added for application equipment requirements. This section requires all 

coatings to be applied using equipment that has a minimum 65% transfer efficiency and 

establishes requirements for when conventional air spray methods may be used. A control 

system operations section is added. This section requires owners and operators of 

emissions to operate and maintain control systems in accordance with the manufacturer 

recommendations; to provide certification from the control system manufacturer that the 

emission control system will attain the required efficiency performance; and to maintain 

for two years records of operating and maintenance of the control system. A new section 

for work practices and recordkeeping is added that establish required control techniques 

to reduce VOC emissions. A compliance schedule was added and the methodology for 

determining capture efficiency was clarified. Removal of sections that were obsolete. 

Additionally, EPA requested that DAQ clarify what VOC content test method 

would be used since the VOC definition found in R307-101-2 adopted and incorporated 

by reference 40 CFR 51.100(s) and how the transfer efficiency is determined. The VOC 

definition generally signifies test methods found in 40 CFR part 60 Appendix A but does 

not provide a specific test method within Appendix A for this rule to follow. DAQ 

provided a clarification letter on August 4, 2015 that specifies EPA Test Method 24 from 

40 CFR part 60 Appendix A would be used for R307-342 and that the manufacturer 

certifies the transfer efficiency. EPA agrees with these clarifications and is proposing 

approval of the revisions to R307-343 found within these two submittals, June 8, 2013 

and December 9, 2014 and also that R307-343 currently constitutes RACM for the 
36 

Nonattainment and Maintenance Areas for Wood Furniture Manufacturing Operations for 

the Utah PM2.5 SIP. 

L. R307-344, Paper, Film, and Foil Coatings 

Rule R307-344 is a new individual rule created when R307-340 was repealed in 

its entirety. R307-344 establishes requirements to limit VOC emissions from roll, knife, 

and rotogravure coaters and drying ovens of paper, film, and foil coating operations. The 

emission reductions are accomplished through limiting VOC content of 

coatings/materials used, requirements for application equipment, work practice and 

recordkeeping, and selection, operation and maintenance of add-on VOC control 

equipment and systems. R307-344 applies to sources located in Box Elder, Cache, Davis, 

Salt Lake, Tooele, Utah and Weber counties that have the potential to emit 2.7 tpy or 

more of VOC, including related cleaning activities. 

The RACM analysis done for R307-344 was based on the EPA CTG for Paper, 

Film, and Foil Coatings, EPA 453/R-07-003, September 2007. As background, in May 

1977, EPA issued a CTG for surface coating on paper that was used in rulemaking for 

R307-340-5 and promulgated the new source performance standards (NSPS) in 1983 for 

coatings of pressure sensitive tape and labels, a subset of paper, film and foil. EPA 

promulgated the national emission standards for hazardous air pollutants (NESHAP) in 

2002 for paper and other web coating. EPA developed the recommendations in the 2007 

CTG after reviewing the earlier CTG, the NSPS and NESHAP. The VOC RACT limits 

were taken from the CTG, Table 1, page 18. Utah applied the CTG-recommended 90% 

overall system efficiency for any add-on emissions control systems operations. DAQ 

estimates the cost-effectiveness of this rule at $1440/ton in 2011 dollars. 
37 

DAQ submitted the new Rule R307-344 to the EPA on May 9, 2013. The Board 

approved R307-344 for public comment on September 5, 2012 and the public comment 

period was held from October 1 to November 1, 2012. Public hearings were held on 

October 15, 16, and 17, 2012, and the EPA was the only commenter. 

Davis and Salt Lake counties were subject to R307-345 by the effective date and 

Box Elder, Cache, Tooele, Utah, and Weber counties were to be in compliance by 

January 1, 2014. The effective date of R307-345 was February 1, 2013. 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-344, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that the inspection and recordkeeping 

requirements for the rules be expanded before they could be approved, on July 2, 2014, 

the Board proposed for public comment amendments to R307-344. A public comment 

period was held from August 1 to September 2, 2014. The proposed amendments were 

adopted by the Board on October 1, 2014. The final rule contains applicable language to 

provide for sufficient operating, testing, maintenance, reporting and recordkeeping 

requirements to allow proper compliance verification and enforcement, as well as 

appropriate changes associated with our December 2, 2013 comment letter. 

In the “Add-On Controls Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The final version of R307-344 was effective December 1, 2014, and compliance 
38 

was immediate. On December 9, 2014, DAQ submitted this final version of R307-344 to 

the EPA. Utah’s RACM and rule analysis can be found in the docket posted on 

regulations.gov. Additionally, EPA requested that DAQ clarify what VOC content test 

method would be used since the VOC definition found in R307-101-2 adopted and 

incorporated by reference 40 CFR 51.100(s). This definition generally signifies test 

methods found in 40 CFR part 60 Appendix A but does not provide a specific test method 

within Appendix A for this rule to follow. DAQ provided a clarification letter on August 

4, 2015 that specifies EPA Test Method 24 from 40 CFR part 60 Appendix A would be 

used for R307-344. EPA agrees with this clarification and is proposing approval of the 

new Rule R307-344, with subsequent revisions, and that R307-344 currently constitutes 

RACM for the Nonattainment and Maintenance Areas for Paper, Film, and Foil Coatings 

Operations for the Utah PM2.5 SIP. 

M. R307-345, Fabric and Vinyl Coatings 

Rule R307-345 is a new individual rule created when R307-340 was repealed in 

its entirety. R307-345 establishes requirements to limit VOC emissions from fabric and 

vinyl coating operations, which use roll, knife, or rotogravure coaters and drying ovens. 

The emission reductions are accomplished through limiting VOC content of 

coatings/materials used, requirements for application equipment, work practice and 

recordkeeping, and selection, operation and maintenance of add-on VOC control 

equipment and systems. R307-345 applies to sources located in Box Elder, Cache, Davis, 

Salt Lake, Tooele, Utah and Weber counties that have the potential to emit 2.7 tpy or 

more of VOC, including related cleaning activities. 

The RACM analysis done for R307-345 was based on the EPA CTG, Surface 
39 

Coating of Cans, Coils, Paper, Fabrics, Automobiles and Light-Duty Trucks, EPA 450/2-

77-008. However, as the CTG is aged (published in 1977), DAQ also considered other 

state rules as part of the RACM analysis. The SCAQMD rule 1128 and the SJVAPCD 

rule 4607 were evaluated. Both rules include a VOC content limit of 2.2 lb/gal for these 

materials. DAQ chose to adopt the 2.2 lb/gal limit, phased in by January 1, 2015. The 

SJVAPCD rule 4607 is a comparable rule with a requirement of 90% overall system 

efficiency, which Utah used for this rule for any add-on emissions control systems 

operations. DAQ estimates a cost-effectiveness of $3500/ton in current dollars. 

DAQ submitted the new Rule R307-345 to the EPA on May 9, 2013. The Board 

proposed R307-345 for public comment on September 5, 2012, and the public comment 

period was held from October 1 to November 1, 2012. Public hearings were held on 

October 15, 16, and 17, 2012. EPA provided written comments, no other comments were 

received. 

Davis and Salt Lake counties were subject to this R307-345 upon the effective 

date and Box Elder, Cache, Tooele, Utah, and Weber counties were to be in compliance 

by January 1, 2014. These revisions to R307-345 became effective on February 1, 2013. 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-345, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that the inspection and recordkeeping 

requirements for the rules be expanded before they could be approved, on July 2, 2014, 

the Board proposed for public comment amendments to R307-345. A public comment 

period was held from August 1 to September 2, 2014. The proposed amendments were 

adopted by the Board on October 1, 2014. The final rule contains applicable language to 
40 

provide for sufficient operating, testing, maintenance, reporting and recordkeeping 

requirements to allow proper compliance verification and enforcement, as well as 

appropriate changes associated with our December 2, 2013 comment letter. 

In the “Add-On Controls Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The final version of R307-345 was effective December 1, 2014, and compliance 

was immediate. On December 9, 2014, DAQ submitted this final version of R307-345 to 

the EPA. Utah’s RACM and rule analysis can be found in the docket posted on 

regulations.gov. Additionally, EPA requested that DAQ clarify what VOC content test 

method would be used since the VOC definition found in R307-101-2 adopted and 

incorporated by reference 40 CFR 51.100(s). This definition generally signifies test 

methods found in 40 CFR part 60 Appendix A but does not provide a specific test method 

within Appendix A for this rule to follow. DAQ provided a clarification letter on August 

4, 2015 that specifies EPA Test Method 24 from 40 CFR part 60 Appendix A would be 

used for R307-345. EPA agrees with this clarification and is proposing approval the new 

Rule R307-345, with the subsequent revisions, and also that R307-345 currently 

constitutes RACM for the Nonattainment and Maintenance Areas for Fabric and Vinyl 

Coatings Operations for the Utah PM2.5 SIP. 

N. R307-346, Metal Furniture Surface Coatings 

Rule R307-346 is a new individual rule created when R307-340 was repealed in 
41 

its entirety. R307-346 establishes requirements to limit VOC emissions from metal 

furniture surface coating operations in application areas, flash-off areas, and ovens of 

metal furniture coating lines involved in prime and top-coat or single coat operations. The 

emission reductions are accomplished through limiting VOC content of 

coatings/materials used, requirements for application equipment, work practice and 

recordkeeping, and selection, operation and maintenance of add-on VOC control 

equipment and systems. R307-346 applies to sources located in Box Elder, Cache, Davis, 

Salt Lake, Tooele, Utah and Weber counties that have the potential to emit 2.7 tpy or 

more of VOC, including related cleaning activities. There are exemptions to the 

requirements of R307-346 for stencil coatings, safety-indicating coatings, solid-film 

lubricants, electrical-insulating and thermal-conducting coatings, touch-up and repair 

coatings, or coating applications utilizing hand-held aerosol cans. These exemptions are 

consistent with EPA CTG for Metal Furniture Coatings, EPA 453/R-07-005, September 

2007. 

The RACM analysis done for R307-346 was based on the EPA CTG for Metal 

Furniture Coatings, EPA 453/R-07-005, September 2007. This CTG supersedes the 

original CTG published in 1977. EPA published the NSPS in 1982 and the NESHAP in 

2003. The 2007 CTG incorporated recommendation from the first CTG, the NSPS and 

the NESHAP. DAQ chose to apply the limits directly from the CTG listed on page 23. 

These limits are similar to those in, for example, BAAQMD Rule 8-14-300. Utah has 

proposed applying the CTG recommended 90% overall system efficiency for any add-on 

emissions control systems operations, which is more stringent than, for example, the 85% 

efficiency in BAAQMD Rule 8-14-302. DAQ estimates the cost-effectiveness of this rule 
42 

at $2020/ton in 2011 dollars. 

DAQ submitted the new Rule R307-346 to the EPA on May 9, 2013. The Board 

proposed for public comment R307-346 on September 5, 2012, and the public comment 

period was held from October 1 to November 1, 2012. Public hearings were held on 

October 15, 16, and 17, 2012. EPA provided written comments, no other comments were 

received. 

All sources in Davis and Salt Lake counties were subject to this R307-346 upon 

the effective date and sources in Box Elder, Cache, Tooele, Utah, and Weber counties 

were to be in compliance by January 1, 2014. These revisions to R307-346 became 

effective on February 1, 2013. 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-346, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that the inspection and recordkeeping 

requirements for the rules be expanded before they could be approved, on July 2, 2014, 

the Board proposed for public comment amendments to R307-346. A public comment 

period was held from August 1 to September 2, 2014. The proposed amendments were 

adopted by the Board on October 1, 2014. The final rule contains applicable language to 

provide for sufficient operating, testing, maintenance, reporting and recordkeeping 

requirements to allow proper compliance verification and enforcement, as well as 

appropriate changes associated with our December 2, 2013 comment letter. 

In the “Add-On Controls Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 
43 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The final version of Rule R307-346 was effective December 1, 2014, and 

compliance was immediate. On December 9, 2014, DAQ submitted this final version of 

R307-346 to the EPA. Utah’s RACM and rule analysis can be found in the docket posted 

on regulations.gov. Additionally, EPA requested that DAQ clarify what VOC content test 

method would be used since the VOC definition found in R307-101-2 adopted and 

incorporated by reference 40 CFR 51.100(s). This definition generally signifies test 

methods found in 40 CFR part 60 Appendix A but does not provide a specific test method 

within Appendix A for this rule to follow. DAQ provided a clarification letter on August 

4, 2015 that specifies EPA Test Method 24 from 40 CFR part 60 Appendix A would be 

used for R307-346. EPA agrees with this clarification and is proposing to approve the 

new Rule R307-346, with subsequent revisions, and also that R307-346 currently 

constitutes RACM for the Nonattainment and Maintenance Areas for Metal Furniture 

Surface Coatings Operations for the Utah PM2.5 SIP. 

O. R307-347, Large Appliance Surface Coatings 

Rule R307-347 is a new individual rule created when R307-340 was repealed in 

its entirety. R307-347 establishes requirements to limit VOC emissions from large 

appliance surface coating operations. The emission reductions are accomplished through 

limiting VOC content of coatings/materials used, requirements for application equipment, 

work practice and recordkeeping, and selection, operation and maintenance of add-on 

VOC control equipment and systems. R307-347 applies to sources located in Box Elder, 

Cache, Davis, Salt Lake, Tooele, Utah and Weber counties that have the potential to emit 
44 

2.7 tpy or more of VOC, including related cleaning activities. There are exemptions to 

the requirements of R307-347 for stencil coatings, safety-indicating coatings, solid-film 

lubricants, electrical-insulating and thermal-conducting coatings, touch-up and repair 

coatings, or coating applications utilizing hand-held aerosol cans. These exemptions are 

consistent with EPA CTGs for Metal Furniture Coatings, EPA 453/R-07-004, September 

2007. 

The RACM analysis done for R307-347 was modeled after the EPA CTGs for 

Large Appliance Coatings, EPA 453/R-07-004, September 2007. This CTG supersedes 

the original CTG published in 1977. EPA published the NSPS in 1982 and promulgated a 

NESHAP in 2002. EPA developed the recommendations in the 2007 CTG after 

reviewing the earlier CTG, the NSPS and NESHAP. The DAQ chose to apply the limits 

in the CTG recommended on page 19 of the CTG. These limits are similar to those in, for 

example, BAAQMD Rule 8-14-300. Utah has proposed applying the CTG-recommended 

90% overall system efficiency for any add-on emissions control systems operations, 

which is more stringent than, for example, the 85% efficiency in BAAQMD Rule 8-14-

302. DAQ estimates this rule to have a cost-effectiveness of $2027/ton in 2011 dollars. 

DAQ submitted the new Rule R307-347 to the EPA on May 9, 2013. The Board 

proposed for public comment R307-347 on September 5, 2012, and the public comment 

period was held from October 1 to November 1, 2012. Public hearings were held on 

October 15, 16, and 17, 2012. EPA provided written comments, no other comments were 

received. 

All sources in Davis and Salt Lake counties were subject to this R307-347 upon 

the effective date and sources in Box Elder, Cache, Tooele, Utah, and Weber counties 
45 

were to be in compliance by January 1, 2014. These revisions to R307-347 became 

effective on February 1, 2013. 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-347, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that the inspection and recordkeeping 

requirements for the rules be expanded before they could be approved, on July 2, 2014, 

the Board proposed for public comment amendments to R307-347. A public comment 

period was held from August 1 to September 2, 2014. The proposed amendments were 

adopted by the Board on October 1, 2014. The final rule contains applicable language to 

provide for sufficient operating, testing, maintenance, reporting and recordkeeping 

requirements to allow proper compliance verification and enforcement, as well as 

appropriate changes associated with our December 2, 2013 comment letter. 

In the “Add-On Controls Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The final version of Rule R307-347 was effective December 1, 2014, and 

compliance was immediate. On December 9, 2014, DAQ submitted this final version of 

R307-347 to the EPA. Utah’s RACM and rule analysis can be found in the docket posted 

on regulations.gov. Additionally, EPA requested that DAQ clarify what VOC content test 

method would be used since the VOC definition found in R307-101-2 adopted and 

incorporated by reference 40 CFR 51.100(s). This definition generally signifies test 
46 

methods found in 40 CFR part 60 Appendix A but does not provide a specific test method 

within Appendix A for this rule to follow. DAQ provided a clarification letter on August 

4, 2015 that specifies EPA Test Method 24 from 40 CFR part 60 Appendix A would be 

used for R307-347. EPA agrees with this clarification and is proposing to approve the 

new Rule R307-347, with subsequent revisions, and also that R307-347 currently 

constitutes RACM for the Nonattainment and Maintenance Areas for Large Appliance 

Surface Coatings Operations for the Utah PM2.5 SIP. 

P. R307-348, Magnet Wire Coatings 

Rule R307-348 is a new individual rule created when R307-340 was repealed in 

its entirety. R307-348 establishes requirements to limit VOC emissions from ovens of 

magnet wire coating operations. The emission reductions are accomplished through 

limiting VOC content of coatings/materials used, requirements for application equipment, 

work practice and recordkeeping, and selection, operation and maintenance of add-on 

VOC control equipment and systems. R307-348 applies to sources located in Box Elder, 

Cache, Davis, Salt Lake, Tooele, Utah and Weber counties that have the potential to emit 

2.7 tpy or more of VOC, including related cleaning activities. 

There are no EPA guidance documents (ACT or CTGs) that directly apply to this 

industry, so the RACM analysis done for R307-348 was based on a review and 

application of the following source materials. The NESHAP - Surface Coating of 

Miscellaneous Metal Parts and Products, FR Vol. 69, No. 1, January 2, 2004, applies to 

facilities with 10 tpy or more of any single hazardous air pollutants (HAP) or 25 tpy or 

more of any combination of HAPs. While this NESHAP is not directly applicable, some 

components are similar, so DAQ used applicable control efficiency and cost information 
47 

from the NESHAP. The SCAQMD rule 1126 - coating limits requires an overall system 

efficiency of 90%. Based on this California rule, Utah has proposed the VOC content 

limits and a 90% overall system efficiency for any add-on emissions control systems 

operations for R307-348. DAQ estimates the cost-effectiveness of this rule at $6560/ton 

in 2011 dollars. 

DAQ submitted the new Rule R307-348 to the EPA on May 9, 2013. The Board 

proposed for public comment R307-348 on September 5, 2012, and the public comment 

period was held from October 1 to November 1, 2012. Public hearings were held on 

October 15, 16, and 17, 2012. One industry source and the EPA provided written 

comments, no other comments were received. 

All sources in Davis and Salt Lake counties were subject to this R307-348 upon 

the effective date and sources in Box Elder, Cache, Tooele, Utah, and Weber counties 

were to be in compliance by January 1, 2014. These revisions to R307-348 became 

effective on February 1, 2013. 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-348, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that the inspection and recordkeeping 

requirements for the rules be expanded before they could be approved, on July 2, 2014, 

the Board proposed for public comment amendments to R307-348. A public comment 

period was held from August 1 to September 2, 2014. The proposed amendments were 

adopted by the Board on October 1, 2014. The final rule contains applicable language to 

provide for sufficient operating, testing, maintenance, reporting and recordkeeping 

requirements to allow proper compliance verification and enforcement, as well as 
48 

appropriate changes associated with our December 2, 2013 comment letter. 

In the “Add-On Control Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The final version of Rule R307-348 was effective December 1, 2014, and 

compliance was immediate. On December 9, 2014, DAQ submitted this final version of 

R307-348 to the EPA. Utah’s RACM and rule analysis can be found in the docket posted 

on regulations.gov. Additionally, EPA requested that DAQ clarify what VOC content test 

method would be used since the VOC definition found in R307-101-2 adopted and 

incorporated by reference 40 CFR 51.100(s). This definition generally signifies test 

methods found in 40 CFR part 60 Appendix A but does not provide a specific test method 

within Appendix A for this rule to follow. DAQ provided a clarification letter on August 

4, 2015 that specifies EPA Test Method 24 from 40 CFR part 60 Appendix A would be 

used for R307-348. EPA agrees with this clarification and is proposing to approve the 

new Rule R307-348, with subsequent revisions, and also that R307-348 currently 

constitutes RACM for the Nonattainment and Maintenance Areas for Magnet Wire 

Coatings operations for the Utah PM2.5 SIP. 

Q. R307-349, Flat Wood Panel Coatings 

Rule R307-349 is a new individual rule created when R307-340 was repealed in 

its entirety. R307-349 establishes requirements to limit VOC emissions from flat wood 

paneling coating sources. The emission reductions are accomplished through limiting 
49 

VOC content of coatings/materials used, requirements for application equipment, work 

practice and recordkeeping, and selection, operation and maintenance of add-on VOC 

control equipment and systems. R307-349 applies to sources located in Box Elder, 

Cache, Davis, Salt Lake, Tooele, Utah and Weber counties that have the potential to emit 

2.7 tpy or more of VOC, including related cleaning activities. 

The RACM analysis done for R307-349 was based on the EPA CTG for Flat 

Wood Paneling Coatings, EPA 453/R-06-004, September 2006. This CTG supersedes the 

original CTG published in 1978. The CTG did include consideration of the NESHAPs 

issued in 2003. For all flat wood operations, the CTG recommends the use of a new limit 

of 2.1 lb VOC/gallon or an add-on control with 90% efficiency. DAQ also evaluated air 

quality rules in California. For example, the SJVAPCD Rule 4606 permits higher coating 

limits for a variety of categories. DAQ chose to amend the rule per the CTG using one 

coating limit across all categories, and has applied the CTG-recommended 90% overall 

system efficiency for any add-on emissions control systems operations. DAQ estimates 

the cost-effectiveness of this rule at $2600/ton. 

DAQ submitted the new Rule R307-349 to the EPA on May 9, 2013. The Board 

proposed for public comment R307-349 on September 5, 2012, and the public comment 

period was held from October 1 to November 1, 2012. Public hearings were held on 

October 15, 16, and 17, 2012. The EPA provided written comments, no other comments 

were received. 

All sources in Davis and Salt Lake counties were subject to R307-349 as of the 

effective date of this rule. Sources within Box Elder, Cache, Tooele, Utah, and Weber 

counties were to be in compliance with R307-349 by January 1, 2014. The effective date 
50 

for the new Rule R307-349 was February 1, 2013. 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-349, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that the inspection and recordkeeping 

requirements for the rules be expanded before they could be approved, on July 2, 2014, 

the Board proposed for public comment amendments to R307-349. A public comment 

period was held from August 1 to September 2, 2014. The proposed amendments were 

adopted by the Board on October 1, 2014. The final rule contains applicable language to 

provide for sufficient operating, testing, maintenance, reporting and recordkeeping 

requirements to allow proper compliance verification and enforcement, as well as 

appropriate changes associated with our December 2, 2013 comment letter. 

In the “Add-On Controls Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The final version of Rule R307-349 was effective December 1, 2014, and 

compliance was immediate. On December 9, 2014, DAQ submitted this final version of 

R307-349 to the EPA. Utah’s RACM and rule analysis can be found in the docket posted 

on regulations.gov. Additionally, EPA requested that DAQ clarify what VOC content test 

method would be used since the VOC definition found in R307-101-2 adopted and 

incorporated by reference 40 CFR 51.100(s). This definition generally signifies test 

methods found in 40 CFR part 60 Appendix A but does not provide a specific test method 
51 

within Appendix A for this rule to follow. DAQ provided a clarification letter on August 

4, 2015 that specifies EPA Test Method 24 from 40 CFR part 60 Appendix A would be 

used for R307-349. EPA agrees with this clarification and is proposing to approve the 

new Rule R307-349, with subsequent revisions, and also that R307-349 currently 

constitutes RACM for the Flat Wood Panel Coatings operations for the Utah PM2.5 SIP. 

R. R307-350, Miscellaneous Metal Parts and Products Coatings 

Rule R307-350 is a new individual rule created when R307-340 was repealed in 

its entirety. R307-350 establishes requirements to limit VOC emissions from 

miscellaneous metal parts and products coating operations. There are exemptions in 

R307-350-3 for items covered by other rules and certain special materials. The emissions 

reductions are accomplished through limiting VOC content of coatings/materials used, 

requirements for application equipment, work practice and recordkeeping, and selection, 

operation and maintenance of add-on VOC control equipment and systems. R307-350 

applies to sources located in Box Elder, Cache, Davis, Salt Lake, Tooele, Utah and 

Weber counties that have the potential to emit 2.7 tpy or more of VOC, including related 

cleaning activities. 

The RACM analysis done for R307-350 was based on the EPA CTG for 

Miscellaneous Metal and Plastic Parts Coatings, EPA 453/R-08-003, September 2008. 

EPA published the NSPS in 1988 and an Alternate Control Techniques (ACT) document 

in 1994. Further, EPA promulgated a NESHAP in 2004. EPA developed the 

recommendations in the 2008 CTG after reviewing the cited references. DAQ chose to 

apply the VOC content limits recommended in the CTG on Table 2, page 33. Utah chose 

to apply the CTG-recommended 90% overall system efficiency for any add-on emissions 
52 

control systems operations. DAQ estimates the cost-effectiveness of this rule at 

$2020/ton in 2011 dollars. 

DAQ submitted the new Rule R307-350 to the EPA on May 9, 2013. The Board 

proposed for public comment R307-350 on September 5, 2012, and the public comment 

period was held from October 1 to November 1, 2012. Public hearings were held on 

October 15, 16, and 17, 2012. Comments were received from the EPA and industry. The 

effective date of this new rule was February 1, 2013. 

All sources within Davis and Salt Lake counties were to be in compliance with 

this new rule by September 1, 2013. All sources within Box Elder, Cache, Tooele, Utah, 

and Weber counties were to be in compliance by January 1, 2014. 

After the rule was adopted by the Board in December 2012, a number of 

additional public concerns were provided to the DAQ from the regulated community. In 

those comments, the regulated community notified the DAQ staff of technical difficulties 

they were having implementing the rule and also requested that clarifications be made to 

the rule applicability. The primary difficulty concerned military contractors who must 

meet military technical data orders that required certain specific materials not authorized 

by the rule. The Board proposed amendments to R307-350 which were put out for public 

comment from August 1 to September 3, 2013. Several industry comments were received 

requesting further clarification. The Board determined that these comments were valid 

and adopted amendments to R307-350 on October 2, 2013. 

DAQ submitted these revisions of R307-350 to the EPA on April 17, 2014. These 

revisions included clarification within the Applicability and Exemption sections; adding 

and updating definitions; and other administrative changes. The Compliance Schedule 
53 

was updated to read that all sources shall be in compliance with the requirements of 

R307-350 by January 1, 2014. These revisions became effective on December 3, 2013. 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-350, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that the inspection and recordkeeping 

requirements for the rules be expanded before they could be approved, on July 2, 2014, 

the Board proposed for public comment amendments to R307-350. A public comment 

period was held from August 1 to September 2, 2014. The proposed amendments were 

adopted by the Board on October 1, 2014. The final rule contains applicable language to 

provide for sufficient operating, testing, maintenance, reporting and recordkeeping 

requirements to allow proper compliance verification and enforcement, as well as 

appropriate changes associated with our December 2, 2013 comment letter. 

In the “Add-On Controls Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The final version of Rule R307-350 was effective December 1, 2014, and 

compliance was immediate. On December 9, 2014, DAQ submitted this final version of 

R307-350 to the EPA. Utah’s RACM and rule analysis can be found in the docket posted 

on regulations.gov. Additionally, EPA requested that DAQ clarify what VOC content test 

method would be used since the VOC definition found in R307-101-2 adopted and 

incorporated by reference 40 CFR 51.100(s). This definition generally signifies test 
54 

methods found in 40 CFR part 60 Appendix A but does not provide a specific test method 

within Appendix A for this rule to follow. DAQ provided a clarification letter on August 

4, 2015 that specifies EPA Test Method 24 from 40 CFR part 60 Appendix A would be 

used for R307-350. EPA agrees with this clarification and is proposing to approve the 

new Rule R307-350, with subsequent revisions, and also that R307-350 currently 

constitutes RACM for the Miscellaneous Metal Parts and Products Coatings operations 

for the Utah PM2.5 SIP. 

S. R307-351, Graphic Arts 

Rule R307-351 is a new individual rule created when R307-340 was repealed in 

its entirety. R307-351 establishes requirements to limit VOC emissions from graphic arts 

printing operations. The emission reductions are accomplished through limiting VOC 

content of coatings/materials used, requirements for application equipment, work practice 

and recordkeeping, and selection, operation and maintenance of add-on VOC control 

equipment and systems. R307-351 applies to existing sources and new sources, with the 

lower emissions cut-off points for applicability range from 25 tons/year to 2.7 tons/year 

VOCs, depending on the specific process, and includes related cleaning activities. 

The RACM analysis done for R307-351 was based on two EPA CTG: the CTG 

for Offset Lithographic printing and Letterpress Printing, EPA 453/R-06-002, September 

2006; and, the CTG for Flexible Package Printing, EPA 453/R-06-003, September 2006. 

EPA 453/R-06-002, September 2006, is based on findings EPA made in their initial 

studies dating back to 1993. EPA 453/R-06-003, September 2006, incorporates the 

recommendations made in a CTG published in 1978 for rotogravure printing and flexible 

printing. The 1996 NESHAP for the printing and publishing industry is also given 
55 

consideration in this CTG. The industry NESHAP has spurred significant coating 

reformulation nationwide, even though the NESHAP targeted larger facilities. The DAQ 

applied the most current content limits from the CTG’s and also worked with the 

National Printing Association to update applicable portions to reflect current practices. 

DAQ estimates a cost-effectiveness of $5,890/ton of VOC removed in 2011 dollars. 

Based on this higher cost-effectiveness, DAQ set an applicability limit of 25 tons VOC 

per year (tpy), as compared with most of the other VOC rules, with an applicability limit 

of 2.7 tpy. 

DAQ submitted the new Rule R307-351 to the EPA on May 9, 2013. The Board 

proposed R307-351 for public comment on September 5, 2012, and the public comment 

period was held from October 1 to November 1, 2012. Public hearings were held on 

October 15, 16, and 17, 2012. Comments were received from the EPA and industry. 

The compliance schedule for this new rule is that all sources within Salt Lake and 

Davis counties be in compliance with this rule by the effective date of this rule and that 

all sources within Box Elder, Cache, Tooele, Utah, and Weber counties were to be in 

compliance by January 1, 2014. The effective date of this new rule, R307-351, was 

February 1, 2013. 

Finally, a “Non-substantive Rule Amendment” was made by Utah to correct 

several incorrect subsection citations within the rule. In accordance with Utah Code Title 

19, Chapter 2, Air Conservation Act, Utah Code Title 63G, Chapter 3, Administrative 

Rulemaking Act, and Utah Administrative Code, R15, Administrative Rules, this change 

was made without public comment, as appropriate for a non-substantive change. The 

non-substantive changes made to R307-351-4 and R307-351-2 were effective on 
56 

February 15, 2013 and October 8, 2014, respectfully, and submitted to the EPA on May 

20, 2014. 

Utah’s RACM and rule analysis can be found in the docket posted on 

regulations.gov. Additionally, EPA requested that DAQ clarify what VOC content test 

method would be used since the VOC definition found in R307-101-2 adopted and 

incorporated by reference 40 CFR 51.100(s). This definition generally signifies test 

methods found in 40 CFR part 60 Appendix A but does not provide a specific test method 

within Appendix A for this rule to follow. DAQ provided a clarification letter on August 

4, 2015 that specifies EPA Test Method 24 from 40 CFR part 60 Appendix A would be 

used for R307-343. EPA agrees with this clarification and is proposing to approve the 

new Rule R307-351, with subsequent revisions, and also that R307-351 currently 

constitutes RACM for Graphic Arts operations for the Utah PM2.5 SIP. 

T. R307-352, Metal Container, Closure, and Coil Coatings 

Rule R307-352 is a new individual rule created when R307-340 was repealed in 

its entirety. R307-352 establishes requirements to limit VOC emissions from metal 

container, closure, and coil coating operations. The emission reductions are accomplished 

through limiting VOC content of coatings/materials used, requirements for application 

equipment, work practice and recordkeeping, and selection, operation and maintenance of 

add-on VOC control equipment and systems. R307-352 applies to sources located in Box 

Elder, Cache, Davis, Salt Lake, Tooele, Utah and Weber counties that have the potential 

to emit 2.7 tpy or more of VOC, including related cleaning activities. 

The RACM analysis done for R307-352 was based on the EPA CTG, Surface 

Coating of Cans, Coils, Paper, Fabrics, Automobiles and Light-Duty Trucks, EPA 450/2-
57 

77-008. The CTG provided a comparative analysis of existing rules, and based on that 

analysis, DAQ used the BAAQMD Regulation 8, Rule 11 as the primary reference 

source, and the SCAQMD Rule 1125 as a secondary, for the development of this rule. 

The state is applying the same 90% overall system efficiency requirement the BAAQMD 

used in Regulation 8 Rule 11 for any add-on emissions control systems operations. DAQ 

estimates a cost-effectiveness of $3,221/ton in 2011 dollars. 

DAQ submitted the new Rule R307-352 to the EPA on May 9, 2013. The Board 

proposed R307-352 for public comment on September 5, 2012, and the public comment 

period was held from October 1 to November 1, 2012. Public hearings were held on 

October 15, 16, and 17, 2012 and the effective date for this new rule was February 1, 

2013. The EPA provided written comments, no other comments were received. 

The compliance schedule for R307-352 was for all sources within Box Elder, 

Cache, Davis, Salt Lake, Tooele, Utah, and Weber counties to be in compliance with this 

rule by January 1, 2014. 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-352, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that the inspection and recordkeeping 

requirements for the rules be expanded before they could be approved, on July 2, 2014, 

the Board proposed for public comment amendments to R307-352. A public comment 

period was held from August 1 to September 2, 2014. The proposed amendments were 

adopted by the Board on October 1, 2013. The final rule contains applicable language to 

provide for sufficient operating, testing, maintenance, reporting and recordkeeping 

requirements to allow proper compliance verification and enforcement, as well as 
58 

appropriate changes associated with our December 2, 2013 comment letter. 

In the “Add-On Controls Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The final version of Rule R307-352 was effective December 1, 2014, and 

compliance was immediate. On December 9, 2014, DAQ submitted this final version of 

R307-352 to the EPA. Utah’s RACM and rule analysis can be found in the docket posted 

on regulations.gov. Additionally, EPA requested that DAQ clarify what VOC content test 

method would be used since the VOC definition found in R307-101-2 adopted and 

incorporated by reference 40 CFR 51.100(s). This definition generally signifies test 

methods found in 40 CFR part 60 Appendix A but does not provide a specific test method 

within Appendix A for this rule to follow. DAQ provided a clarification letter on August 

4, 2015 that specifies EPA Test Method 24 from 40 CFR part 60 Appendix A would be 

used for R307-343. EPA agrees with this clarification and is proposing to approve the 

new Rule R307-352, with subsequent revisions, and also that R307-352 currently 

constitutes RACM for the Metal Container, Closure, and Coil Coatings operations for the 

Utah PM2.5 SIP. 

U. R307-353, Plastic Parts Coatings 

Rule R307-353 is a new rule that establishes requirements to limit VOC emissions 

from plastic parts coating operations. There are exemptions for certain special materials. 

The emission reductions are accomplished through limiting VOC content of 
59 

coatings/materials used, requirements for application equipment, work practice and 

recordkeeping, and selection, operation and maintenance of add-on VOC control 

equipment and systems. R307-353 applies to sources located in Box Elder, Cache, Davis, 

Salt Lake, Tooele, Utah and Weber counties that have the potential to emit 2.7 tpy or 

more of VOC, including related cleaning activities. 

The RACM analysis was based on the EPA CTG for Miscellaneous Metal and 

Plastic Parts Coatings, EPA 453/R-08-003, September 2008. This guidance document 

provides a presumptive RACT. EPA promulgated a NESHAP in 2004. EPA developed 

the recommendations in the 2008 CTG after review of the NESHAP. The VOC content 

limits for R307-353 were taken directly from the CTG. Utah is applying the CTGrecommended 90% overall system efficiency for any add-on emissions control systems 

operations. DAQ estimates a cost-effectiveness of $2,020/ton in 2011 dollars. 

DAQ submitted the new Rule R307-353 to the EPA on June 8, 2013. The Board 

proposed R307-353 for public comment on September 5, 2012, and the public comment 

period was held from October 1 to November 1, 2012. Public hearings were held on 

October 15, 16, and 17, 2012. EPA noted that the CTGs for Miscellaneous Metal and 

Plastic Parts Coatings, EPA 453/R-08-003 contains industrial segments that were not 

included in the rule. Due to this DAQ modified the rule to include the missing coating 

limits and on December 5, 2012, the Board re-proposed the rule for public comment on 

January 1 to January 31, 2013. No comments were received, however, DAQ determined 

that a few minor changes were needed to clarify the Applicability section of the rule. 

The compliance schedule for R307-353 was for all sources within Box Elder, 

Cache, Davis, Salt Lake, Tooele, Utah, and Weber counties to be in compliance with the 
60 

rule by January 1, 2014. R307-353 was effective on May 1, 2013. 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-353, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that the inspection and recordkeeping 

requirements for the rules be expanded before they could be approved, on July 2, 2014, 

the Board proposed for public comment amendments to R307-353. A public comment 

period was held from August 1 to September 2, 2014. The proposed amendments were 

adopted by the Board on October 1, 2014. The final rule contains applicable language to 

provide for sufficient operating, testing, maintenance, reporting and recordkeeping 

requirements to allow proper compliance verification and enforcement, as well as 

appropriate changes associated with our December 2, 2013 comment letter. 

In the “Add-On Controls Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The final version of R307-353 was effective December 1, 2014, and compliance 

was immediate. On December 9, 2014, DAQ submitted this final version of R307-353 to 

the EPA. Utah’s RACM and rule analysis can be found in the docket posted on 

regulations.gov. EPA is proposing to approve the new Rule R307-353, with subsequent 

revisions, and also that R307-353 currently constitutes RACM for the Plastic Parts 

Coatings operations for the Utah PM2.5 SIP. 

V. R307-354, Automotive Refinishing Coatings 
61 

Rule R307-354 is a new rule that establishes requirements to limit VOC emissions 

from automotive refinishing operations. The emission reductions are accomplished 

through limiting VOC content of coatings/materials used, requirements for application 

equipment, work practice and recordkeeping, and selection, operation and maintenance of 

add-on VOC control equipment and systems. R307-354 applies to sources located in Box 

Elder, Cache, Davis, Salt Lake, Tooele, Utah and Weber counties that have the potential 

to emit 2.7 tpy or more of VOC, including related cleaning activities. The requirements 

of R307-354 do not apply to any canned aerosol coating products. 

The RACM analysis for R307-354 was based on the EPA CTG for VOC 

Emissions from Automobile Refinishing (EPA 450/3-88-009, 1988/10) and ACT 

Document: Automotive Refinishing (EPA 453/R-94-031, 1994/04). These documents 

provide information on the application processes, VOC emissions and emission 

reductions, and costs associated with the use of alternative coating formulations and 

equipment used in automotive refinishing operations. As 40 CFR Part 63, Subpart 

HHHHHH - NESHAP: Paint Stripping and Miscellaneous Surface Coating applies to all 

area sources, some aspects of the NESHAP were considered. Also, applicable portions of 

the OTC model rule, and the SCAQMD, and SJVAPCD automotive rules were utilized in 

developing R307-354. These documents do not provide a system efficiency 

recommendation; therefore, Utah is applying an overall system efficiency level of 90% 

for any add-on emissions control systems operations, which is near the expected level of 

reduction by applying low-VOC coatings. DAQ estimates a cost-effectiveness of 

$2,740/ton. 

DAQ submitted the new Rule R307-354 to the EPA on May 9, 2013. The Board 
62 

proposed R307-354 for public comment on September 5, 2012, and the public comment 

period was held from October 1 to November 1, 2012. Public hearings were held on 

October 15, 16, and 17, 2012. There were a number of public and industry comments. 

The compliance schedule for R307-354 is for all sources within Box Elder, 

Cache, Davis, Salt Lake, Tooele, Utah, and Weber counties were to be in compliance by 

January 1, 2014. The effective date of R307-354 was February 1, 2013. 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-354, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that the inspection and recordkeeping 

requirements for the rules be expanded before they could be approved, on July 2, 2014, 

the Board proposed for public comment amendments to R307-354. A public comment 

period was held from August 1 to September 2, 2014. The proposed amendments were 

adopted by the Board on October 1, 2014. The final rule contains applicable language to 

provide for sufficient operating, testing, maintenance, reporting and recordkeeping 

requirements to allow proper compliance verification and enforcement, as well as 

appropriate changes associated with our December 2, 2013 comment letter. 

In the “Add-On Controls Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The final version of R307-354 was effective December 1, 2014, and compliance 

was immediate. On December 9, 2014, DAQ submitted this final version of R307-354 to 
63 

the EPA. Utah’s RACM and rule analysis can be found in the docket posted on 

regulations.gov. Additionally, EPA requested that DAQ clarify what VOC content test 

method would be used since the VOC definition found in R307-101-2 adopted and 

incorporated by reference 40 CFR 51.100(s). This definition generally signifies test 

methods found in 40 CFR part 60 Appendix A but does not provide a specific test method 

within Appendix A for this rule to follow. DAQ provided a clarification letter on August 

4, 2015 that specifies EPA Test Method 24 from 40 CFR part 60 Appendix A would be 

used for R307-343. EPA agrees with this clarification and is proposing to approve the 

new Rule R307-354, with subsequent revisions, and also that R307-354 currently 

constitutes RACM for the Automotive Refinishing Coatings operations for the Utah 

PM2.5 SIP. 

W. R307-355, Control of Emissions from Aerospace Manufacture and Rework 

Facilities 

Rule R307-355 is a new rule that establishes requirements to limit VOC emissions 

from aerospace coatings and adhesives, organic solvent cleaning, and the storage and 

disposal of solvents and waste solvent materials associated with the use of aerospace 

coatings and adhesives. There are exceptions for cleaning and coating associated with 

research and development, quality control, laboratory testing and electronic parts and 

assemblies, (cleaning and coating of completed assemblies are not exempt); in 

manufacturing or rework operations involving space vehicles; and, for rework operations 

performed on antique aerospace vehicles or components. The emissions reductions are 

accomplished through limiting VOC content of coatings/materials used, requirements for 

application equipment, work practice and recordkeeping, and selection, operation and 
64 

maintenance of add-on VOC control equipment and systems. R307-355 applies to 

sources located in Box Elder, Cache, Davis, Salt Lake, Utah, Tooele and Weber counties 

that have the potential to emit 10 tpy or more of VOC, including related cleaning 

activities. 

The RACM analysis for R307-355 was based on the EPA CTG for VOC 

Emissions from Coating Operations at Aerospace Manufacturing and Rework Operations, 

EPA-453/R-97-004, December 1997. The CTG, Control of Volatile Organic Compound 

Emissions from Coating Operations at Aerospace manufacturing and rework Operations, 

EPA-453/R-97-004, December 1997, page B-8, provides a model rule with a system 

efficiency of at least 81%. The model rule includes some exemptions that were not 

adopted in the proposed rule in order to gain greater VOC reductions. DAQ believes that 

EPA took great care working with industry to craft a RACM model rule and that DAQ 

should follow its requirements at a minimum. DAQ reviewed aerospace rules 

implemented by the State of Missouri and the SJVAPCD. Both of these jurisdictions 

crafted their rules generally along the EPA model rule. The SJVAPCD rule 4605 was 

selected by Utah for the RACM comparative analysis. That rule requires a system 

efficiency of 85%. The Missouri rule 10CSR 10-5.295 was also used as a RACM 

comparative rule, and it requires the control system to reduce VOCs by 81%. Given the 

warehouse size operating areas common to these sources, it would be challenging at best 

to meet an efficiency value beyond 81%; therefore, Utah applied the EPA guidance value 

and the Missouri RACM value of 81%. 

DAQ submitted the new Rule R307-355 to the EPA on May 9, 2013. The Board 

proposed R307-355 for public comment on September 5, 2012, and the public comment 
65 

period was held from October 1 to November 1, 2012. Public hearings were held on 

October 15, 16, and 17, 2012. There were comments from industry and the EPA. 

The compliance schedule for R307-355 are for all sources within Box Elder, 

Cache, Davis, Salt Lake, Tooele, Utah, and Weber counties were to be in compliance by 

January 1, 2014. The effective date for R307-355 is February 1, 2013. 

A “Non-substantive Rule Amendment” was made by Utah to correct subsection 

R307-355-5 citation within the rule. The second (1)(d) was changed to (1)(e) to correct 

the numbering sequence. In accordance with Utah Code Title 19, Chapter 2, Air 

Conservation Act, Utah Code Title 63G, Chapter 3, Administrative Rulemaking Act, and 

Utah Administrative Code, R15, Administrative Rules, this change was made without 

public comment, as appropriate for a non-substantive change. This non-substantive 

change was effective on February 15, 2013 and submitted by DAQ to the EPA on May 

20, 2014. 

Due to ongoing EPA concerns associated with the amount of control removal 

specified in R307-355, as well as in other similar area source rules, that control removal 

be based on the entire control system, and that the inspection and recordkeeping 

requirements for the rules be expanded before they could be approved, on July 2, 2014, 

the Board proposed for public comment amendments to R307-355. A public comment 

period was held from August 1 to September 2, 2014. The proposed amendments were 

adopted by the Board on October 1, 2014. The final rule contains applicable language to 

provide for sufficient operating, testing, maintenance, reporting and recordkeeping 

requirements to allow proper compliance verification and enforcement, as well as 

appropriate changes associated with our December 2, 2013 comment letter. 
66 

In the “Add-On Controls Systems Operations” section it reads “An alternative test 

method may be substituted for the preceding test methods after review and approval by 

the EPA Administrator.” EPA interprets this language to mean that such an alternate test 

method will be submitted by the State as a SIP revision that is subsequently approved by 

the EPA through the EPA public notice and SIP approval process. 

The final version of Rule R307-355 was effective December 1, 2014, and 

compliance was immediate. On December 9, 2014, DAQ submitted this final version of 

R307-355 to the EPA. Utah’s RACM and rule analysis can be found in the docket posted 

on regulations.gov. Additionally, EPA requested that DAQ clarify what VOC content test 

method would be used since the VOC definition found in R307-101-2 adopted and 

incorporated by reference 40 CFR 51.100(s). This definition generally signifies test 

methods found in 40 CFR part 60 Appendix A but does not provide a specific test method 

within Appendix A for this rule to follow. DAQ provided a clarification letter on August 

4, 2015 that specifies EPA Test Method 24 from 40 CFR part 60 Appendix A would be 

used for R307-343. EPA agrees with this clarification and is proposing to approve the 

new Rule R307-355, with subsequent revisions, and also that R307-355 currently 

constitutes RACM for the Aerospace Manufacture and Rework Facilities operations for 

the Utah PM2.5 SIP. 

X. R307-356, Appliance Pilot Light 

Rule R307-356 is a new rule that establishes requirements to limit VOC emissions 

from natural gas-fired fan-type central furnaces, gas fireplaces, and gas stoves. The 

emissions reductions are accomplished through prohibition of any person from 

manufacturing for sale, distributing, selling, offering for sale, or installing any natural 
67 

gas-fired fan-type central furnaces, gas fireplaces, or gas stoves that require the use of a 

continuous pilot light for ignition. Exemptions to the rule apply to units using a fuel other 

than natural gas, units used in recreational vehicles, and units manufactured that are for 

shipment and use outside of the PM2.5 nonattainment counties. R307-356 applies to 

manufacturers, distributors, retailers, and installers of residential, institutional and 

commercial natural gas-fired fan-type central furnaces, fireplaces, stoves, and cooktops in 

Box Elder, Cache, Davis, Salt Lake, Tooele, Utah, and Weber counties. 

R307-356 is based on national product development programs, similar state rules 

and other guidelines. R307-356 achieves area source VOC reductions through sale and 

manufacture restrictions that restrict the ignition type of specified products within the 

nonattainment areas. Tools for DAQ inspectors to use for compliance verification include 

review of production, shipment and installation records, and inspection of product 

installations. DAQ estimates this rule should be cost-neutral, due to fuel savings. 

DAQ analysis of appliance type resulted in the following apportionment. Most 

gas stoves/ranges (even low end units) now come with electronic ignition. It is assumed 

that pilot lighted ignition units are no longer marketable. DAQ assumed that 0% should 

be applied to the apportionment of all appliances. For furnaces, it is indicated that all 

homes have at least one, and that it is the predominate appliance in the home. Furnaces 

have a general life expectancy of 20 years, with repairs favored over replacement due to 

replacement cost. Electronic ignition has become popular in recent years. Because of 

their longevity and recent conversion to electronic ignition, it is assumed that all heaters 

use pilot light ignition that will be phased out in 10 years. DAQ assumed that 40% should 

be applied to the apportionment of all appliances. Each home has at least one water heater 
68 

and it is the other predominate appliance in the home. DAQ assumed that 40% should be 

applied to the apportionment of all appliances. With gas fireplaces pilot ignition is still 

common, and DAQ assumed that all units are pilot ignition. DAQ assumed that 20% 

should be applied to the apportionment of all appliances. 

On May 9, 2013, DAQ submitted the new Rule R307-356 to the EPA. The public 

comment period was held from September 1 to October 1, 2012, with a public hearing 

held on September 12, 2012. Comments were received from industry. 

Rule R307-356 was effective January 1, 2013. Any person who manufactures for 

sale, distributes, sells, offers for sale, or installs any natural gas- fired fan-type central 

furnaces, gas fireplaces, or gas stoves that require the use of a continuous pilot light for 

ignition must be in compliance beginning January 1, 2014. Utah’s RACM and rule 

analysis can be found in the docket posted on regulations.gov. EPA is proposing to 

approve the new Rule R307-356, with subsequent revisions, and also that R307-356 

currently constitutes RACM for Appliance Pilot Lights for the Utah PM2.5 SIP. 

Y. R307-357, Consumer Products 

Rule R307-357 is a new rule that establishes requirements to limit VOC emissions 

from consumer products. The emission reductions are accomplished through prohibition 

of certain VOC emitting products. R307-357 applies to any person who sells, supplies, 

offers for sale, distributes for sale, or manufactures for sale consumer products for use in 

Box Elder, Cache, Davis, Salt Lake, Tooele, Utah, and Weber counties. The rule also 

creates product labeling and recordkeeping requirements as part of rule compliance. 

There are some limited exemptions consistent with the EPA national rule promulgated in 

1998 (40 CFR, Part 59, Subpart C), other states rules, and certain products that have been 
69 

granted an innovative products, or certain other exemptions by the CARB as of the 

effective date of R307-357. 

The rule, which sets maximum VOC content for consumer products, is based on 

other guidelines and similar rules, including: The EPA national rule promulgated in 1998 

(40 CFR, Part 59, Subpart C) for consumer products, the CARB rules, and the OTC 

Model Rule and OTC member states rules. The OTC rules, which are the basis for the 

Utah rule, achieve additional VOC reductions over EPA’s national rule. R307-357 

achieves VOC reductions through two basic components: sale and manufacture 

restrictions that limit VOC content of specified consumer products. Area source VOC 

reduction occurs by reducing the availability of higher VOC content consumer products 

within the nonattainment areas. DAQ estimates the cost-effectiveness of this rule to be 

$3000/ton. 

Any person who manufactures for sale, sells, supplies, or offers for sale any of the 

applicable consumer products must be in compliance based on Table 1 in R307-357 

beginning September 1, 2014 for the majority of products, and by January 1, 2015 or 

January 1, 2016 for the remaining products. Consumer products manufactured for 

shipment and use outside the specified counties are exempt from this rule. Tools for DAQ 

inspectors to use for compliance verification include review of production and 

application records, labels of products used and inspection of application facilities. 

DAQ submitted the new Rule R307-357 to the EPA on February 18, 2014. The 

Board proposed for public comment on February 6, 2012, and the public comment period 

was held from March 1 to April 1, 2012. A public hearing was held on March 13, 2012. 

Comments were received from the public, a community organization and industry. This 
70 

rule became effective on August 1, 2013. 

A correction was made by Utah on March 5, 2014 to correct the percent VOC by 

weight for general purpose adhesives. This changes the VOC content limit for general 

purpose adhesives to the correct limit of ten percent (from 80, a typographical error), 

which is the content limit derived from the federal rule published at 63 FR 48831, Sept. 

11, 1998, and as amended at 69 FR 18803, April 9, 2004. The State also made other 

nonsubstantial changes to improve the formatting of the VOC-content limit table in the 

rule. A public comment period was held from April 1, 2014 to May 1, 2014, during 

which no comments were received and no public hearing was requested. These 

nonsubstantive changes were adopted by the Board on May 7, 2014 and became effective 

on May 29, 2014. The submittal for these nonsubstantive changes was made by DAQ to 

the EPA on August 6, 2014. 

Utah’s RACM and rule analysis can be found in the docket posted on 

regulations.gov. EPA is proposing to approve the new Rule R307-357, with subsequent 

revisions, and also that R307-357 currently constitutes RACM for Consumer Products for 

the Utah PM2.5 SIP. 

Z. R307-361, Architectural Coatings 

R307-361 is a new rule that establishes requirements to limit VOC emissions 

from architectural coatings. This rule applies to any person who supplies, sells, offers for 

sale, applies, or solicits the application of any architectural coating, or who manufactures, 

blends or repackages any architectural coating for use within Box Elder, Cache, Davis, 

Salt Lake, Tooele, Utah, and Weber counties. The emissions reductions are accomplished 

through limiting VOC content of coatings/materials used, storage, cleanup, 
71 

recordkeeping, and labeling requirements. There are exemptions for certain special 

materials, quantity, and any architectural coating that is supplied, sold, offered for sale, or 

manufactured for use outside of the non-attainment counties. Test methods are provided 

for determining VOC content and certain exempt materials. 

The RACM analysis was based on the OTC model AIM rule in developed in 2001 

based on the work conducted by the CARB in 2000, the CARB and several California air 

management districts architectural and industrial maintenance (AIM) rules implemented 

in the late 1990’s-2000 based on RACT analysis and their updates, and the EPA national 

AIM rule promulgated in January 2005 (40 CFR Part 59 Subpart D). Area source VOC 

reduction occurs by reducing the availability of higher VOC architectural coatings within 

the nonattainment areas. DAQ cited an initial cost of $6,628 per ton for the OTC model 

rule; DAQ reasoned that the current cost-effectiveness would be substantially lower 

given that the initial capital costs had already been realized. 

Any person who supplies, sells, offers for sale, applies, or solicits the application 

of any architectural coating, or who manufactures, blends or repackages any architectural 

coating must be in compliance by January 1, 2015. A coating manufactured prior to 

January 1, 2015, may be sold, supplied, or offered for sale for up to three years after 

January 1, 2015, and a coating manufactured before January 1, 2015, may be applied at 

any time. Tools for DAQ inspectors to use for compliance verification include review of 

production and application records, labels of products used and inspection of application 

methods. 

DAQ submitted the new Rule R307-361 to the EPA on February 18, 2014. The 

Board proposed R307-361 for public comment on June 5, 2013, and the public comment 
72 

period was held from July 1 to July 31, 2013. Comments were received from the public, a 

community organization and industry. 

Rule R307-361 was effective October 31, 2013. Utah’s RACM and rule analysis 

can be found in the docket posted on regulations.gov. EPA is proposing to approve the 

new Rule R307-361, with subsequent revisions, and also that R307-361 currently 

constitutes RACM for Architectural Coatings for the Utah PM2.5 SIP. 

VI. Proposed Action

EPA is proposing approval of the revisions to Administrative Rules R307-101-2 

and R307-103, along with the additions/revisions/repeals in R307-300 Series; 

Requirements for Specific Locations (Within Nonattainment and Maintenance Areas), 

R307-303, R307-307, R307-312 (conditionally approved, see below), R307-335, R307-

340 (repealed), R307-342 (repealed and replaced), R307-343, R307-344, R307-345, 

R307-346, R307-347, R307-348, R307-349, R307-350, R307-351, R307-352, R307-353, 

R307-354, R307-355, R307-356, R307-357, and R307-361 for incorporation to the Utah 

SIP as submitted by the State of Utah on May 9, 2013, June 8, 2013, February 18, 2014, 

April 17, 2014, May 20, 2014, July 10, 2014, August 6, 2014, and December 9, 2014. We 

are proposing to approve Utah’s determination that the above rules in R307-300 Series; 

Requirements for Specific Locations (Within Nonattainment and Maintenance Areas) 

constitute RACM for the Utah PM2.5 SIP for the specific source categories addressed; 

however, we are not proposing to determine that Utah’s PM2.5 attainment plan has met all 

requirements regarding RACM under subparts 1 and 4 of Part D, title I of the Act. We 

intend to act separately on the remainder of Utah’s PM2.5 attainment plan. 

EPA is proposing to conditionally approve revisions to R307-312 and R307-328. 
73 

Additionally, EPA is proposing to conditionally approve Utah’s determination that R307-

312 constitutes RACM for the Utah PM2.5 SIP for aggregate processing operations. As 

stated above, we are not proposing to determine that Utah’s PM2.5 attainment plan has 

met all requirements regarding RACM under subparts 1 and 4 of Part D, title I of the Act. 

Under section 110(k)(4) of the Act, EPA may approve a SIP revision based on a 

commitment by the State to adopt specific enforceable measures by a date certain, but not 

later than one year after the date of approval of the plan revision. On August 4, 2015, 

Utah submitted a commitment letter to adopt and submit specific revisions within one 

year of our final action on these submittals; specifically to remove the phrase “or 

equivalent method” in one rule and to specify three equivalent methods in the other rule. 

If we finalize our proposed conditional approval, Utah must adopt and submit the specific 

revisions it has committed to within one year of our finalization. If Utah does not submit 

these revisions within one year, or if we find Utah’s revisions to be incomplete, or we 

disapprove Utah’s revisions, this conditional approval will convert to a disapproval. If 

any of these occur and our conditional approvals convert to a disapproval, that will 

constitute a disapproval of a required plan element under part D of title I of the Act, 

which starts an 18-month clock for sanctions, see CAA section 179(a)(2), and the twoyear clock for a federal implementation plan (FIP), see CAA section 110(c)(1)(B). 

Finally, EPA is proposing to approve the repeal of R307-342, Qualification of 

Contractors and Test Procedures for Vapor Recovery Systems for Gasoline Delivery 

Tanks, submitted by DAQ on February 2, 2012.