# PROGRESS REPORT FOR UTAH’S STATE

**IMPLEMENTATION PLAN FOR REGIONAL HAZE**

**September 22**  **, 2014**

Prepared by staff of the:

Utah Division of Air Quality Utah Department of Environmental Quality

195 N orth 1950 W est Salt Lake City, UT 8411 6

## Table of Contents

1.0 INTRODUCTION

................................ ................................ ....................... Error! Bookmark not defined.

1.1 State Implementation Plan Requirements for the 5

- Year Progress Report

................................ ....... 1

2.0 UTAH CLASS I AREAS

................................ ................................ ................................ .............................. 2

2.1 Progress Towards Reasonable Progress Goals (40 CFR §51.309(d)(10(i))

................................ ......... 3

3.0 REGIONAL HAZE PROGRESS REPORT

................................ ................................ ................................ 4

3.1 40 CFR § 51.309(D)(10)(i) Progress Report Requirements

................................ ................................ 4

3. 2 Status of Implementation Control Measures: 40 CFR §51.309(d)(10)(i)(A)

................................ ..... 5

Enforceability of Utah’s Measures

................................ ................................ ................................ ............ 7

3.3 Summary of Emission Reduction Achieved: 40 CFR § 51.309(d)(10)(i)(B)

................................ ........ 7

3.4 Assessment of Visibility Conditions: 40 CFR § 51.309(d)(10)(i)(C)

................................ .................. 11

3.4.1 Current Visibility Conditions for the Most and Least Impaired Days

................................ .... 12

3.4.2 Differences Bet ween Current Visibility Conditions for the Most and Least Impaired Days and Baseline Visibility Conditions

................................ ................................ ............... 14

3.4.3 Change in Visibility Impairment for the Most Impaired and Least Impaired Days

Over the Past Five Years

................................ ................................ ................................ ..................... 18

3.5 Analysis of Emissions: 40 CFR 40 CFR § 51.309(d)(10)(i)(D)

................................ ............................ 19

3.6 Changes to Anth ropogenic Emissions: § 51.309(d)(10)(i)(E)

................................ ........................... 32

3.7 Assessment of Current SIP Strategy: § 51.309(d)(10)(i)(F)

................................ ............................. 32

3.8 Assessment of Current Monitoring Strategy: § 51.309(d)(10)(i)(G)

................................ ............... 36

3.9 Determination of Adequacy: § 51.309(d)(10)(ii)

................................ ................................ ............. 36

4.0 REGIONAL SUMMARY FOR 309 GCVTC CLASS I AREAS

................................ ................................ ... 37

i

### Tables

Table 2.1. Utah Class I Area IMPROVE Sites Visibility Conditions for the 20% Most and Least Impaired days

– Including 2010 to 2012.

................................ ................................ ................................ ..................... 4

Table 3.1, Utah Class I Area IMPROVE Sites

, Current Visibility Conditions, 2005

- 2009 Progress Period, 20% Most Impaired Days

................................ ................................ ................................ ............................ 13

Table 3.2, Utah Class I Area IMPROVE Sites

, Current Visibility Conditions, 2005

- 2009 Progress Period, 20% Least Impaired Days

................................ ................................ ................................ ............................ 13

Table 3.3. Utah Class I Area IMPROVE Sites

, Difference in Aerosol Extinction by Species, 2000

- 2004

Baseline Period to 2005

- 2009 Progress Period

................................ ................................ ........................... 15

Table 3.4. Utah Cla ss I Area IMPROVE Sites

, Difference in Aerosol Extinction by Species, 2000

- 2004

Baseline Period to 2005

- 2009 Progress Period

, 20% Least Impaired Days

................................ ................ 15

Table 3.5. Utah Class I Area IMPROVE Sites

, Change in Aerosol Extinction by Species

, 200

- 2009 Annual Average Trends

................................ ................................ ................................ ................................ ........... 19

Table 3.6

. Utah

, Pollutants, Aerosol Species, and Major Sources

................................ .............................. 20

Table 3.7

. Sulfur Dioxide Emissions by Category

................................ ................................ ........................ 23

Table 3.8

. Oxides of Nitrogen Emissions by Category

................................ ................................ ................ 24

Table 3.9

. Ammonia Emissions by Category

................................ ................................ ............................... 25

Table 3.10

. Volatile Organic Compound Emissions by Category

................................ ................................ 26

Table 3.11

. Primary Organic Aerosol Emissions by Category

................................ ................................ ..... 27

Table 3.12

. Elemental Carbon Emissions by Category

................................ ................................ ................ 28

Table 3.13

. Fine Soil Emissions by Category

................................ ................................ ............................... 29

Table 3.14

. Coarse Mass Emissions by Category

................................ ................................ ........................ 30

Table 3.15. Ave rage extinction for 20% Worst Days for the Current Progress Period of 2005

- 2009

........ 32

Table 3.16. Utah Class I Area IMPROVE Sites Visibility conditions

– 20% Most and Least Impaired Days Including 2010 to 2012 data

................................ ................................ ................................ ....................... 35

ii

### Table 3.17. Utah CIAs and Representative IMPROVE Monitors

................................ ................................ 36

Table 4.1

. Colorado Plateau Class I Areas and Representative IMPROVE Monitors

................................ .. 38

Table 4.2

. Colorado Plateau Class I Area IMPROVE Sites

, Current Visibility Conditions

, 2005

- 2009 Progress Period, 20% Most Impaired Days

................................ ................................ ................................ . 42

Table 4.3

. Colorado Plateau Class I Area IMPROVE Sites

, Current Visibility Conditions

, 2005

- 2009 Progress Period, 20% Least Impaired Days

................................ ................................ ................................ . 43

Table 4.4

. Colorado Plateau Class I Area IMPROVE Sites

, Difference in Aerosol Extinction by Species

, 2000

- 2004 Baseline Period to 2005

- 2009 Progress Period

, 20% Most Impaired Days

.............................. 44

Table 4.5

. Colorado Plateau Class I Area IMPROVE Sites

, Difference in Aerosol Extinction by Species

, 2000

- 20004 Baseline Period to 2005

- 2009 Progress Period

, 20% Least Impaired Days

............................ 45

Table 4.6

. Colorado Plateau Class I Ar ea IMPROVE Sites

, Change in Aerosol Extinction by Species

, 2000

- 2009 Annual Average Trends

................................ ................................ ................................ ...................... 46

iii

### Figures

Figure 2.1. Map Depicting Federal Class I Areas and Representative IMPROVE Monitors in Utah

............. 2

Figure 3.1. Change in Deciview Extinction between Baseline Period Average (2000

- 2004) and the First Progress Period Average (2005

- 2009) for the 20% Worst Vi sibility Days

................................ ..................... 8

Figure 3.2. Change in Deciview Extinction between Baseline Period Average (2000

- 2004) and the First
Progress Peri od Average (2005

- 2009) for the 20% Best Visibility Days

................................ ....................... 9

Figure 3.3. Regional Average of Aerosol Extinction by Pollutant for Ba seline Period average (2000

- 2004) for 20% Worst Days.

................................ ................................ ................................ ................................ ... 10

Figure 3.4. Regional Average of Aerosol Extinction by Pollutant for the First Progress Period Average (2005

- 2009) for 20% Worst Days.

................................ ................................ ................................ ............... 10

Figure 3.5. Magnitude of Aerosol Extinction Species that have Decreased Between the Baseline Average (2000

- 2004) and the First Progress Period Aver age (2005

- 2009) for the 20% Worst Days.

...................... 11

Figure 3.6. Average Extinction for Current Progress Period (2005

- 2009) for the Worst (Most Impaired) and Best (Least Impaired) Days Measured at Utah Class I Area IMPROVE Sites

................................ ........ 14

Figure 3.7. Average Extinction fo r Baseline and Progress Period Extinction for Worst (Most Impaired) Days Measured at Utah Class I Area IMPROVE Sites.

................................ ................................ ................. 16

Figure 3.8. Difference between Average Extinction for Current Progress Period (2005

- 2009) and Baseline Period (2000

- 2004) for the Worst (Most Impaired) Days Measured at Utah Class I Area IMPROVE Sites. 16

Figure 3.9. Average Extinction for Baseline and Progress Period Extinction for Best (Least Impaired) Days

Measured at Utah Class I Area IMPROVE Sites

................................ ................................ ........................... 17

Figure 3.10. Difference Between Average Extinction for Current Progress Period (2005

- 2009) and Baseline Period (2000

- 2004) for the Best (Least Impaired) Days Mea sured at Utah Class I Area IMPROVE

Sites

................................ ................................ ................................ ................................ ............................. 17

Figure 3.11. 2002 and 2008 Emission and Difference between Emissions Inventory Total s, for Sulfur Dioxide by Source Category for Utah

................................ ................................ ................................ .......... 23

Figure 3.12. 2002 and 2008 Emissions and Difference between Emissions Inventory Totals, for Oxides of Nitrogen by Source Category for Utah

................................ ................................ ................................ ........ 24

iv

### Figure 3.13. 2002

- 2008 Emission and Difference between E mission Inventory Totals, for Ammonia by Source Category for Utah

................................ ................................ ................................ ............................ 25

Figure 3.14. 2002

- 2008 Emission and Difference between Emi ssion Inventory Totals, for Volatile Organic Compounds by Source Category for Utah

................................ ................................ ................................ .. 26

Figure 3.15. 2002

- 2008 Emission and Differ ence between Emission Inventory Totals, for Primary Organic Aerosol by Source Category for Utah

................................ ................................ ................................ ......... 27

Figure 3.16. 2002

- 2008 Emission and Difference between Emission Inventory Totals, for Elemental Carbon by Source Category for Utah

................................ ................................ ................................ .......... 28

Figure 3.17. 200 2

- 2008 Emission and Difference between Emission Inventory Totals, for Fine Soil by Source Category for Utah

................................ ................................ ................................ ............................ 29

Figure 3.18. 200 2

- 2008 Emission and Difference between Emission Inventory Totals, for Coarse Mass by Source Category for Utah

................................ ................................ ................................ ............................ 30

Figure 3.19. Su m of EGU Emissions of SO2 and NOx Reported between 1996 and 2010

.......................... 31

Figure 3.20. Annual and 5

- Year Period Averages for the 20% Worst Days at Canyonlands and Arches National Parks (CANY1 IMPROVE Site)

................................ ................................ ................................ ....... 33

Figure 3.21. Annual and 5

- Year Period Averages for t he 20% Worst Days at Bryce Canyon National Park (BRCA1 IMPROVE Site)

................................ ................................ ................................ ................................ 33

Figure 3.22. Annual and 5

- Year Period Averages for the 2 0% Worst Days at Capitol Reef (CAPI1 IMPROVE Site)

................................ ................................ ................................ ................................ ............. 34

Figure 4.1. Map Depicting Colorado Plateau Class I Areas and Representativ e IMPROVE Monitors in Arizona, Colorado, New Mexico and Utah

................................ ................................ ................................ .. 39

Figure 4.2. Regional Average of Aerosol Extinction by Pollutant for the First Progress Period Average (2005

- 2009) for 20% worst days

................................ ................................ ................................ ................. 41

Figure 4.3. Regional Average of aerosol Extinction by Po llutant for First Progress Period Average (2005

- 2009) for 20% Best Days

................................ ................................ ................................ ............................. 41

Figure 4.4 Chart Depicting Annual Average Ammonium Sulfate Concentrations for the 20% Worst Days

as Measured at the Colorado Plateau CIA IMPROVE Sites

................................ ................................ ......... 47

v

### Figure 4.5. Chart Depicting 3

- Year Average Sum of SO2 Emissions for New Mexico, Utah and Wyoming and the City of Albuquerque/Bernalillo County as Compared to the Section 309 SIP SO2 Milestones

..... 48

vi

### 1.0 INTRODUCTION

On December 12, 2003, the State of Utah submitted a Regional Haze State Implementation Plan (RH SIP )

to meet the requirements of 40 CFR 51.309 (309 SIP) to improve visibility in Utah’s five Federal Class I

Areas . The 2003 version of the 309 SIP and subsequent revisions to it address the first phase of requirements, with an emphasis on stationary source sulfur dioxide (SO 2 

### ) emission reductions , smoke

management, and a focus on improving visibility on the Colorado Plateau.

On December 14, 2012

, the EPA approved the majority of Utah’s RH SIP, but disapproved the BART determination for nitrogen oxide (NOx) and particulate matter (PM). Utah is in the process of updating

the five

- factor analysis to address EPA’s con cerns . The results of that analysis will be addressed in a

separate SIP submittal. The 2008 BART determination has been fully implemented and significant emission reductions of NOx, SO 2 

### , and PM have already been achieved.

**1.1 State Implementation Plan Re**  **quirements for the 5**

**- Year Progress Report** 

Provisions of the Regional Haze ( RH ) rule contained in 40 CFR § 51.309(d)(10) require that each state submit a progress report five years after the submittal of their initial RH SIP. The progress report must be in the form of a SIP revision and must include a determination regarding the adequacy of the existing regional haze SIP. This report has been prepared to fulfill all applicable requirements pertaining to the
five

- year progress report of the initial RH SIP. The State of Utah c oncludes that b ased on the progress made over the five year period reviewed, no revisions to the Ut ah Regional Haze SIP are needed at this
time.

The progress report SIP must include 1) the status fo r implementation of control measures included in the original regional haze SIP, 2) a summary of emission reductions achieved through the implementation of

c ontrol measures, 3) an assessment of visibility conditions, 4) an analysis of the changes in emission pollutants, 5) an assessment of significant changes in emissions that may have limited or impeded progress in improving visibility, 6) an assessment of wh ether the current SIP elements and strategies are sufficient to meet reasonable progress goals and 7) a review of the State’s visibility monitoring strategy.

The technical data included in this progress report are from the “ Western Regional Air Partnership Regional Haze Rule Reasonable Progress Summary Report” (Appendix A) developed by the Western Regional Air Partnership (WRAP) 1 

### in June of 2013 and the WRAP Technical Support System (TSS). The WRAP progress report technical support document (TSD) has been prepared on behalf of the 15

western state members in the WRAP region

. It serves as the technical basis for use by states to develop the first of their individual reasonable progress reports for the 116 Federal Class I areas located in the

western states

. Data are presented in this report on a regional, state , and Class I area

- specific basis that
characterize the difference between 2000

- 2004 baseline conditions and current conditions, represented here by the most recent successive 5

- year average. T he WRAP progress report TSD was focused on the
first 5

- year period , 2005

- 2009 , and therefore the monitoring and emission inventory data reflect that time

1 The WRAP is a collaborative effort of tribal governments, state governments and various federal agencies representing the western states that provides technical and policy tools for the western states and tribes to comply with the EPA’s RH regulations. De tailed information regarding WRAP support of air quality management issues for western states is provided on the WRAP website, www.wrapair2.org . Data summary descriptions and tools specific to RHR support are availa ble on the WRAP Technical Support System website, http://vista.cira.colostate.edu/tss/.



### 1

### period

. Changes in visibility impairment are characterized using aerosol measurements form the
IMPROVE netwo rk (the primary monitoring network for regional haze, both nationwide and in Utah)

, and the differences between emissions inventory years represent both the baseline and current progress period.

As required by 40 CFR § 51.308(i) , the regional haze SIP must include procedures for continuing
consultation between the states and federal land managers (FLMs) on the implementation of the visibility protection program, including development and review of implementation plan revisions an d 5

- year progress reports, and on the implementation of other programs having the potential to contribute to impairment of visibly in any mandatory Federal Class I area within the state

. Utah intends to consult with
fe deral land as required under 40 CFR § 51.308. The state of Utah reaffirms its commitment to participate in a regional planning process with Alaska, Arizona, California, Colorado, Idaho, Montana, New Mexico, North Dakota, Oregon, South Dakota, Washington, Wyoming, the United States Department o f Interior (USDI) Fish and Wildlife Services (FWS) and National Park Services (NPS), and the United States Department of agriculture (USDA) Forest Service (FS).

Pursuant to the Tribal Authority Rule, any tribe whose lands are within the boundaries of the S tate of Utah has the option to develop a RH Tribal Implementation Plan (TIP) for their lands to assure reasonable progress in the five Class I areas in Utah. Accordingly, no provisions of this periodic report shall be construed as being applicable to Indi an Country.



### 2.0 **UTAH CLASS I AREAS**

Utah has five Federal Class I areas within its borders: Arches National Park, Bryce Canyon National Park, Canyonlands National Park, Capitol Reef National Park, and Zion National Park. All five of Utah’s
Federal Class I areas are located on the Colorado Plateau (Figure 2.1)

.

**Figure 2.1. Map Depicting Federal Class I Areas and Representative IMPROVE Monitors in Utah**



### 2

### Utah’s Department of Environmental Quality’s (DEQ) Division of Air Quality (DAQ) is responsible for developing the RH progress report. This progress report compares the current visibility conditions at each of these Class I areas to the 2018 reasonable pr ogress goals to determine if Utah is on track to reach these goals. The progress report also reviews the long

- term strategy to determine if there have been any changes that need to be addressed.

In developing the initial RH SIP, DAQ also considered that e mission sources outside of Utah may affect the visibility at Utah’s Class I areas, and that emission sources within Utah may affect the visibility at Class I areas in neighboring states. Through WRAP, the western states worked together to assess state

by

- state contributions to visibility impairment in specific Class I areas, including those in Utah and those affected by emissions from Utah. The sources identified in the initial RH SIP either impacting Utah’s
Class I areas or Class I areas outside Utah wil l be reviewed as part of this progress report.

**2.1 Progress**  **Towards Reasonable Progress Goals (40 CFR §51.309(d)(10(i))** 
Based on IMPROVE monitoring data, all of Utah’s Class I areas show visibility improvement on the 20% least impaired days, while on the 20% most impaired days

, three areas (Arches, Canyonlands and Zion National Parks) show visibility improvement and two areas (Bryce Canyon and Capitol Reef National Parks) do not. The largest contributor to increases at these sites was particulate organic mass which was associated with large fire events in July and August of 2009. These increases were offset by

decreases in ammonium nitrate and ammonium sulfate.

The baseline and current visibility conditions as well as the reasonable progress goals for 2018 for the 20% worst and 20% best days are displayed in Table 2.1.

3**Table 2.1. Utah Class I Area IMPROVE Sites Visibility**  **Conditions for the 20% Most and Least Impaired days**

**– Including**  **2010 to 2012**

**.**

Class I Area Baseline (2000

- 2004) (dv) Current (2005

- 2009) (dv) (2010

- 2012) (dv) 2018 Preliminary
Reasonable Progress Case

(PRP18a)

(dv)

20% Worst Days

Arches NP (CANY1) 11.2 11.0 10.6 10.9 Bryce Canyon NP (BRCA1) 11.6 11.9 10.0 11.2
Canyonlands NP (CANY1) 11.2 11.0 10.6 10.9 Capitol Reef NP (CAPI1) 10.9 11.3 10.1 10.5 Zion NP (ZICA1) 12.5 2 12.3 10.8 3 N/A 4

20% Best Days
Arches NP (CANY1) 3.7 2.8 2.8 3.5 Bryce Canyon NP (BRCA1) 2.8 2.1 1.7 2.6
Canyonlands NP (CANY1) 3.7 2.8 2.8 3.5 Capitol Reef NP (CAPI1) 4.1 2.7 2.4 3.9
Zion NP (ZICA1) 5.0 4.3 4.4 (see footnote 2) N/A (see footnote 3)



### 3.0 **REGIONAL HAZE PROGRESS REPORT**
The requirements for regional haze progress report s are outlined in 51.309(d)(10)(i). The progress report
for Section 309 RH SIPs must be in the form of a formal SIP subm ittal and at a minimum must contain the following elements:

**3.1 40 CFR § 51.309(D)(10)(**  **i ) Progress Report Requirements** 
( A ) A description of the status of implementation of all measures included in the SIP for achieving reasonable progress goals for mand atory Class I Federal areas both within and outside the state

.
( B ) A summary of the emission reductions achieved throughout the state through implementation of the measures described in ( A ) above.

( C ) For each mandatory Class I Federal area within the st ate , an assessment of the following : t he current visibility conditions for the most impaired and least impaired days; t he difference between current visibility conditions for the most impaired and least impaired days and baseline visibility conditions; and

t he change in visibility impairment for the most impaired and least impaired days over the past 5 years.

2 The monitor originally intended to represent Zion National Park was the ZION1 IMPROVE monitor, which began operation in 2000. In 2003, a second site, ZICA1, was esta blished approximately 19 miles from the original ZION1 monitor. The second site was installed in part because elevated ammonium nitrate at the original site was influenced by mobile sources from the interstate highway that were not representative of park conditions. Section 6.13.1.1 in the WRAP Report (Appendix A)
describes how the baseline for the ZICA1 was determined.

3 Includes 2012 data only; there were no results available for 2011 and 2012

4 There is no PRP18a established for the new ZICA1 monitor. The PRP18a was originally established for the original ZIONI IMPROVE monitor, which was discontinued on July 29, 2004.



### 4

### ( D ) An analysis tracking the change over the past 5 years in emissions of pollutants contributing to visibility impairment from all sources and ac tivities with the state. Emissions changes should be identified by type of source or activity. The analysis must be based on the most recent updated emissions inventory, with estimates projected forward as necessary and appropriate, to account for emissi ons changes during the applicable 5

- year period.

( E ) An assessment of any significant changes in anthropogenic emissions within or outside the state that have occurred over the past 5 years that have limited or impeded progress in reducing pollutant emiss ions and improving visibility.

( F ) An assessment of whether the current SIP elements and strategies are sufficient to enable the state, or
other states with mandatory Federal Class I areas affected by emissions from the state, to meet all
established reas onable progress goals.

( G ) A review of the state’s visibility monitoring strategy and any modifications to the strategy as

necessary.

In the sections to follow, the Utah DAQ will address the various periodic review requirements as outlined
above.

**3.2 Status of Implementation Control Measures: 40 CFR**  **§51.309(d)(10 )**  **(i)(A)**
40 CFR §51.309(d)(10 ) (i)(A) requires “a description of the status of implementation of all measures included in the implementation plan for achieving reasonable progress goals for ma ndatory Class I
Federal areas both within and outside the State.”

This section provides a description of the emission reduction measures that were included in the State of
Utah’s Section 309 RH SIP . A s ummary of the most significant emission reduction strategies and the
status of controls is provided below

.
Utah has been and continues to be committed to implementing the long

- term strategies adopted into the
state’s Section 309 RH SIP. The implementation status of these emission reduction measures are
d escribed below.

SO 2 

### Milestone and Backstop Trading Program

As a 309 state, Utah continues to participate in the Regional SO 2 

### Milestone and Backst op Trading Program. Utah has been participating in this program since 2003, and in March of 2014

, submitted th e annual Regional SO 2 

### Emissions and Milestone Report for 2012. The report shows that the regional SO 2 

### emissions of 115,115 tons were below the 2012 milestone of 200,722 tons. Further information on emissions reductions from this program are summarized in Section 3.3 of this report.

Prevention of Significant Deterioration (PSD) ; New Source Review (NSR) Permitting; and Visibility Program s

Utah’s PSD program, promulgated in SIP Section VII and R307

- 405; NSR permitting program, promulgated in SIP Section II an d R307

- 401; and Visibility program, promulgated in SIP Section XVII
and R307

- 406 continue to protect Class I area visibility by requiring best available control technology for

5

### new sources and assuring that there is not a significant degradation in visibili ty at Class I areas due to new or modified major sources.

BART

Utah has four BART

- eligible sources that are subject to BART. They are PacifiCorp Hunter Units 1 and
2 and PacifiCorp Huntington Units 1 and 2.

Utah’s 2008 BART determination for Hunter Units 1 and 2 include d conversion of existing electrostatic precipitators to pulse jet fabric fil ter bag

- houses; the replacement of existing, first generation low

- NOx
burners with Alstom TSF 2000TM low

- NOx firing system and installation of two elevations of sep arated overfire air; and the upgrading of the existing flue gas desulfurization system to >90% sulfur dioxide
removal. These controls were installed on Hunter Unit 2 in 201 1 and Hunter Unit 1 in 201 4

. Average
annual emissions decreased by 1,306 tons SO 2 

### and 3,028 tons NOx for these two units between 2001

- 3
and 2012

- 13

.

For Huntington Units 1 and 2, the 2008 BART determination included converting existing electrostatic precipitators to pulse jet fabric filter bag

- houses; the replacement of existing, firs t generation low

- NOx firing system and installation of two elevation s of separated overfire air; the installation of a new wet

lime, flue gas de

- sulfurization system at Unit 2 (FGD); and upgrading existing flue gas desulfurization system to >90% sulfur dio xide removal at Unit 1. These controls were installed on Huntington Unit 1 in 2010 and Huntington Unit 2 in 2006

. Average annual emissions decreased by 12,344 tons SO 2 

### and 4,324
tons NOx for these two units between 2001

- 3 and 2012

- 13

.

EPA disapproved Utah’s BART determination for NOx and PM on December 14, 2012

, because they determined that Utah did not perform an adequate 5

- factor analysis as required by 40 CFR Part 51, Appendix Y. Utah is addressing EPA’s concerns in a separate SIP submittal concurr ent with this progress
report.

Enhanced Smoke Management Program

The State of Utah has developed The Utah Smoke Management Plan (SMP) which provides operating procedures for federal and state agencies that use prescribed fire, wildfire , and wildland fire o n federal, state and private wildlands in Utah. The SMP includes the program elements listed in 40 CFR 51.309(d)(6)(i), with the exception of alternatives to fire. The SMP was certified by the EPA on November 8, 1999 under EPA’s April 1998 Interim Air Qu ality Policy on Wildland and Prescribed Fires (Policy). The requirements of the SMP were also codified into Utah’s Air Quality Rule R307

- 204 , which applies to all persons using prescribed fire or wildland fire on land they own or manage, including federal, state, and private wildlands.

New Source Performance Standards Program

Utah’s New Source Performance Standards (NSPS) rule, R307

- 210, incorporates the latest version of 40
CFR Part 60 into Utah’s administrative rules . These technology based standards which apply to specific categories of stationary sources, result in s ignificant emissions reductions

– 40 CFR Part 60 Subpart JJJJ,
Standards of P erformance for Stationary Spark Ignition Internal Combustion Engines; and Subpart IIII,

6

### Standards of performan ce for Stationary Compression Ignition Internal Combustion Engines

, are just two examples.

Maximum Achievable Control Technology (MACT) Standards Program

Utah’s administrative rule, R307

- 214, National Emission Standards for Hazardous Air Pollutants, incorp orates the latest version of 40 CFR Parts 61 and 63 into Utah’s Air Quality rules. NESHAPs are the result of MACT standards, performance

- based standards, EPA has developed specific to source categories. As with NSPS, these NESHAPS result in significant e missions reductions

– 40 CFR Part 63
Su b p art ZZZZ , Standards for Reciprocating Internal Combustion Engines, is just one example.

Mobile Sources

The adoption of new on

- road vehicle emission and fuel standards by EPA resulted in a substantial reduction of projected mobile source emissions. As stated in Section F.2.b of the SIP, Utah is committed to monitoring the emissions from mobile sources to as sure a continuous decline in emissions as defined in 40 CFR 51.309(b)(6). If Utah determines that a continuous decline in emissions is not being achieved, additional control measures will be reviewed to determine if they are needed to make reasonable prog ress.

Enforceability of Utah’s Measures
40 CFR §51.309(d)(9) of the RH rule requires states to ensure that emission limitations and control measures used to meet reasonable progress goals are enforceable.

Utah has ensured that all existing emission limita tions and control measures for which it is responsible
that were used to meet reasonable progress goals are enforceable

, either through Utah ’s Administrative Rules or SIP measures previously approved by the Utah Air Quality Board and the EPA. Enforceabili ty of future emission limitations and control measures for which the State is responsible will be enforceable through permit conditions or SIP measures to be approved in the future by EPA.

**3.3 Summary of Emission Reduction Achieved: 40 CFR § 51.309(d)(10**  **) (i)(B)** 
40 CFR § 51.309(d)(10 ) (i)(B) requires “a summary of the emissions reductions achieved throughout the State through implementation of the measures in paragraph (g)(1).”

This section provides a summary of emissions reduced as a result of implementati on measures discussed in Section 3.2. Since the submittal of Utah’s Section 309 SIP in 2003, there has been a significant
decrease in SO 2 

### emissions in accordance with the state’s SO 2 

### Milestone and Backstop Trading Program. Each year since 2003, states h ave been able to demonstrate through milestone reports that actual SO 2 

### emissions have declined every year and are well below the milestones. Sulfur dioxide emission reductions associated with the Backstop Trading Program will continue through 2018

, as shown through declining milestone commitments. The actual emissions and their respective milestones are shown below:

7

### Regional Sulfur Dioxide Emissions and Milestone Report Summary

Year 3

- State Adjusted SO 2 

### Emissions (tons) 3

- Year Average (tons) Mi lestone (tons) 2003 214,780 214,780 303,264
2004 232,388 223,584 303,264
2005 215,793 220,987 303,264
2006 207,316 218,499 303,264
2007 187,599 203,569 303,264
2008 165,595 186,837 269,083
2009 143,704 165,633 234,903
2010 131,124 146,808 200,722
2011 117,976 130,935 200,722
2012 96,246 115,115 200,722

While Utah has not quantified the emissions reductions due to the remaining strategies , the state saw an overall improvement in visibility at all of Utah’s Class I areas for the 20% best days and an overall improvement in visibility at three of Utah’s Class I areas for the 20% worst days between 2000 and 2009 (See Figures 3.1 and 3.2). Changes in the ove rall emission inventory are described in section 3.5 of this
report.

**Figure 3.1. Change in Deciview Extinction between Baseline Period Average (2000**

**- 2004) and the First**  **Progress Period Average (2005**

**- 2009) for the 20% Worst Visibility Days** 



### 8**Figure 3.2. Change in Deciview Extinction between Baseline Period Average (2000** 

**- 2004) and the First**  **Progress Period Average (2005**

**- 2009) for the 20% Best Visibility Days**  

### The RH rule haze index, as defined using deciview units, does not provide information regarding th e relative contributions of specific pollutants to overall visibility impairment. The calculation of visib i l it y impairment is based on the cumulative impacts of several different species measures at IMPROVE network sites. Analyzing the behavior of each i ndividual species has important implications for control measures, as some species originate from largely anthropogenic sources while others may originate form a mixture of both anthropogenic and natural sources.

Figures 3.3 and 3.4 present regional maps of average aerosol extinction for the most impaired days during the baseline period (2000

- 2004), and the first progress period average (2005

- 2009), respectively, for the IMPROVE monitors representing Federal Class I areas in the WRAP region. The size of t he pie chart is related to the magnitude of visibility impairment, and colors represent the relative contribution of the pollutants measured by the IMPROVE network.

9**Figure 3.3. Regional Average of Aerosol Extinction by Pollutant for Baseline Period aver age (2000** 

**- 2004)**  **for 20% Worst Days.**

**Figure 3.4. Regional Average of Aerosol Extinction by Pollutant for the First Progress Period Average (2005** 

**- 2009) for 20% Worst Days.** 



### 10

### Figure 3.5 presents the individual species of haze that have decreased between the 2000

- 2004 baseline period and the 2005

- 2009 progress period, where sites with corresponding decreases in deciview measurements are highlighted with blue circles.

For Utah, Figure 3.5 depicts most of the dec r eases in deciview averages that were associated with decreases in ammonium nitrate, ammonium sulfate, coarse mass and particulate organic mass. The decrease in ammonium nitrate and ammonium sulfate is most likely due to the implementation of the SO 2 

### milestones beginning in 2003 , BART con trols beginning at the end of 2006 and federal mobile source regulations. The decrease in coarse mass and particulate organic mass is likely due to the decreasing effect of natural events, such as windblown dust storms and wild fires.

**Figure 3.5. Magnit ude of Aerosol Extinction Species that have Decreased Between the Baseline Average**  **(2000**

**- 2004) and the First Progress Period Average (2005** 

**- 2009) for the 20% Worst Days.** 



### 3.4 **Assessment of Visibility**  **Conditions: 40 CFR § 51.309(d)(10 )**  **(i)( C**  **)**
40 CFR § 51.309 (d)(10)(i)(C) requires “ for each mandatory Class I Federal area within the State, the State must assess the following visibility conditions and changes, with values for most impaired and least impaired days expressed in terms of 5

- year averages of these an nual values

The current visibility conditions for the most impaired and least impaired days; The difference between current visibility conditions for the most impaired and least days and baseline visibility conditions; The changes in visibility impairment for the most impaired and least impaired days over the past 5

-
years. ”

11

### This section addresses RH rule regulatory requirements for monitored data as measured by IMPROVE monitors representing Federal Class I areas in Utah.

Regional haze progress in Federal Class I areas is tracked using calculations based on speciated aerosol mass as collected by IMPROVE monitors. The RH rule calls for tracking haze in units of deciviews, where the deciview metric was designed to be linearly associated with human perception of visibility. I n a pristine atmosphere, the deciview metric is near zero, and a one deciview change is approximately equivalent to a 10% change in cumulative species extinction. To better understand visibility conditions,
summaries here include both th e deciview metric and the apportionment of haze into extinction due to the various measured species in units of inverse megameters (Mm - 1 

### ).

**3.4.1 Current Visibility Conditions for the Most and Least Impaired Days** 

EPA guidance for the 2003 RH SIP specif ies that 5

- year averages be calculated over successive 5

- year periods; i.e., 2000

- 2004, 2005

- 2009, 2010

- 2014, etc. 5 

### Current visibility conditions are represented in
Table 3.1 and 3.2 as the most recently incorporated successive 5

- year average period avail able, the 2005

- 2009 period average. While the most recent IMPROVE monitoring data currently available in the WRAP
TSS includes 201 2 data , the 2005

- 2009 period was the most recent data set available when the WRAP summary report was generated. The informat ion and data presented in this section are from that “ Western Regional Air Partnership Regional Haze Rule Reasonable Progress Summary Report” (Appendix A)

.
Tables 3.1 and 3.2 present the calculated deciview values for current conditions at each site, along with the percent contribution to extinction from each aerosol sp ecies for the 20% worst and bes t days for each
of the Federal Class I area IMPROVE monitors in Utah. Appendix M of the WRAP Progress Report includes figures that represent the annual and 5

- y ear period averages for the 20% most and least impaired visibility days at each IMPROVE site from 2000 to 2010.

Figure 3.6 presents 5

- year average extinction for the current progress period for both the 20% worst and best days. Note that the percentages i n the tables consider only the aerosol species which contribute to extinction, while the charts also show R a y leigh , or scattering due to background gases in the atmosphere. Specific observations for the current visibility conditions on the 20% most impair ed days are as follows:

• The largest contributors to aerosol extinction at Utah sites were particulate organic mass,
ammonium sulfate and coarse mass.

• The highest aerosol extinction (12.3 dv) was measured at the ZICA1 site, where particulate organic mass wa s the largest contributor to aerosol extinction, followed by coarse mass.

• The lowest aerosol extinction (11.0 dv) was measured at the CANY1 site.

Specific observations for the current visibility conditions on the 20% least impaired days are as follows:

• T he aerosol contribution to total extinction on the beset days was less than Rayleigh , or the background scattering that would occur in clean air.

• Average extinction (including Ra y leigh ) ranged from 2.1 dv (BRCA2) to 4.3 dv (ZICA1).

5 EPA’s September 2003 Guidance for Tracking Progress Under the Regional Haze Rule specifies that progress is tracked against the 200 0

- 2004 baseline period using corresponding averages over successive 5

- year periods; i.e.,
2005

- 2009, 2010

- 2014, etc. (see page 4

- 2 in the Guidance document).



### 12

### • For all sites, ammoniu m sulfate was the largest contributor to the non

- Rayleigh aerosol species of
extinction.

**Table 3.1, Utah Class I Area IMPROVE Sites Current Visibility Conditions, 2005** 

**- 2009 Progress Period,**  **20% Most Impaired Days**

**Table 3.2, Utah Class I Area IMPROVE Sites**  **Current Visibility Conditions, 2005**

**- 2009 Progress Period,**  **20% Least Impaired Days**



### 13**Figure 3.6. Average Extinction for Current Progress Period (2005**

**- 2009) for the Worst (Most Impaired)**  **and Best (Least Impaired) Days Measured at Utah Class I Area IMPROVE Sites** 



### 3.4.2 Differences Between Current Visibility Conditions for the Most and Least **Impaired Days and Baseline Visibility Conditions**
Included here are comparisons between the 5

- year average baseline conditions (2000

- 20 04) and the current progress period extinction (2005

- 2009).

Table 3.3 presents the differences between the 2000

- 2004 baseline period average extinction and the
2005

- 2009 progress period average for each site in Utah for the 20% most impaired days, and Tabl e 3.4 presents similar data for the least impaired days. Averages that increased are depicted in red text, and averages that decreased are depicted in blue.

Figure 3.7 presents the differences in the 5

- year average extinction for the baseline and current progress period average for the worst days and Figure 3.8 presents the differences in averages by aerosol species, with increases represented above the zero line and decreases below the zero line. Figures 3.9 and 3.10 present similar plots for the best da ys.

For the 20% most impaired days, the 5

- year average Regional Haze Rule ( RHR ) deciview metric
increased between the 2000

- 2004 and 2005

- 2009 periods at the BRCA1 and CAPI1 sites and decreased at
the CANY1 and ZICA1 sites. Notable differences for individu al species averages were as follows:

Increases in 5

- year average deciviews at the BRCA1 and CAPI1 sites were mostly due to increases in particulate organic mass, with some increases also measured in elemental carbon and soil. Coarse mass
also contributed to increases at the CAPI1 site. Increases were offset by decreases in ammonium nitrate
and ammonium sulfate at both sites.

14

### Ammonium sulfate decreased at all sites except ZICA1. Note that data was not collected at the ZICA site during the baseline years, a nd changes reported here are proportional to average changes in extinction as measured at regional sites.

Increases in ammonium nitrate at CANY1 may be due to decreases in SO 2 

### emissions that reduce the
formation of ammonium sulfate and therefore result in an increase in ammonium nitrate in ammonia
limited conditions.

For the 20% least impaired days, the 5

- year average deciview metric decreased at all sites. Notable differences for individual species averages on the 20% least impaired days were as follows:

All species at all sites either decreased or stayed the same between the baseline and current progress period for the best days. The largest decreases on the best days were measured in particulate organic mass, ammonium nitrate, ammonium sulfate, and coars e mass.

**Table 3.3. Utah Class I Area IMPROVE Sites Difference in Aerosol Extinction by Species, 2000** 

**- 2004 Baseline Period to 2005** 

**- 2009 Progress Period** 

**Table 3.4. Utah Class I Area IMPROVE Sites Difference in Aerosol Extinction by Species, 2000** 

**- 2004**  **Baseline Period to 2005**

**- 2009 Progress Period**  **20% Least Impaired Days**

Si te Dec i v i ew ( d v ) C h a n g e i n E x t in ct i o n b y Sp e c i es ( M m - 1 )*

200 0

- 04 Ba s e lin e Per i o d 200 5

- 09 Progre s s Per i o d C h a n ge i n d v * A m m
. Sul f a te A m m
. N i trate P OM EC S o i l CM S ea S a l t

B R C A 1 2 .8 2 .1

- 0 .7

- 0 .1

- 0 .2

- 0 .3

- 0 .2 0 .0

- 0 .1 0 .0

C A NY1 3 .7 2 .8

- 0 .9

- 0 .3

- 0 .1

- 0 .5

- 0 .1

- 0 .1

- 0 .2 0 .0

C A P I1 4 .1 2 .7

- 1 .4

- 0 .3

- 0 .4

- 0 .5

- 0 .3

- 0 .1

- 0 .4 0 .0

Z I C A1 5 .0 4 .3

- 0 .7

- 0 .1

- 0 .2

- 0 .5

- 0 .2 0 .0

- 0 .1 0 .0

* C h a ng e i s ca l c u l a t ed as p r o g re s s p er i o d a v era g e m i n u s b a s e li n e p er i o d a v era g e. Va l u e s i n red i n d i ca t e i n crea s e s i n

e x t i n c ti o n a n d v a l u es i n b l u e i n d i ca t e d ecrea s e s.



### 15**Figure 3.7 . Average Extinction for Baseline and Progress Period Extinction for Worst (Most Impaired) Days**  **Measured at Utah**  **Class I Area IMPROVE Sites** 

**.**

**Figure 3.8 . Difference between Average Extinction for Current Progress Period (2005** 

**- 2009) and Baseline** 

**Period (2 000** 

**- 2004) for the Worst (Most Impaired) Days Measured at Utah Class I Area IMPROVE Sites.** 



### 16**Figure 3.9 . Average Extinction for Baseline and Progress Period Extinction for Best (Least Impaired) Days**  **Measured at Utah Class I Area IMPROVE Sites**

**Figure 3. 10**  **. Difference Between Average Extinction for Current Progress Period (2005**

**- 2009) and Baseline**  **Period (2000**

**- 2004) for the Best (Least Impaired) Days Measured at Utah Class I Area IMPROVE Sites** 



### 17

### 3.4.3 **Change in Visibility Impairment for the Most Impair ed and Least Impaired Days** 
**Over the Past Five Years**
Included here are changes in visibility impairment as characterized by annual average trend statistics and some general observations regarding local and regional events and outliers on a daily and annual basis
that affected the current 5

- year progress period. The regulatory requirement asks for a description of changes over the past 5

- year progress period, but trend analysis is better suited to longer periods of time,
so trends for the entire 10

- year planning period are presented here.

Trend statistics for the years 2000

- 2009 for each species at each site in Utah are summarized in Table
3.5 6 

### . Only trends for aerosol species trends with p

- value statistics less than 0.15 (85% confiden ce level) are presented in the table here, with increasing slopes in red and decreasing slopes in blue 7 

### . In some

cases , trends may show decreasing tendencies while the difference between the 5

- year averages do not (or vice versa). In these cases, the 5

- y ear average for the best and worst days is the important metric for the RHR regulatory purposes, but trend statistics may be of value to understand and address visibility impairment issues for planning purposes.

For each site, a more comprehensive list of all trends for all species, including the associated p

- values, is provided in Appendix M of the Western Regional Air Partnership Regional Haze Rule Reasonable Progress Summary Report . Additionally, the appendix includes plots depicting 5

- year, annual, mo nthly and daily average extinction for each site. Some general observations regarding changes in visibility impairment at sites in Utah are as follows:

• Particulate organic mass was the largest contributor to aerosol extinction at all sits in Utah. The
la rgest difference between the 5

- year average baseline and progress periods was measured for particulate organic mass at the BRCA1 site. This difference average was influenced by high particulate organic mass events in July and August, 2009.

• For ammonium s ulfate, annual average trend statistics for all measured days indicated decreasing trends at all Utah sites. A slight increase in the 5

- year average ammonium sulfate was reported for the ZICA1 site, but this was based on a baseline average estimate (Secti on 6.13.1.1 of Appendix M of the WRAP Report) . Actual data measured between 2004 and 2009 at the ZICA1 site indicated a slightly decreasing annual average trend.

6 Annual trends were calculated for the years 2000

- 2009, with a trend defined as the slope derived using Theil statistics. Trends derived from Theil statistics are useful in analyzing changes in air quality data because these statistics can show the overall tendency of measurements over long periods of time, while minimizing the effects of year

- to

- year fluctuations which are common in air quality data. Theil statistics are also used in EPA’s National Air EPA’s National Air Quality Trends Reports (http://www.epa.gov/airtrends/) and the IMPROVE program trend reports ( http://vista.cira.colostate.edu/improve/Publications/improve_reports.htm )

7 The significance of the trend is represented with p

- values calculated using Mann

- Kendall trend statistics. Determining a significance level helps to distinguish random variability in data from a real tendency to increase or decrease over time, where lower p

- values indicate higher confidence levels in the computed slopes.



### 18

### • For ammonium nitrate, annual average trend statistics for all measured days indicated a
decr easing trend at the CAPI1 site and either no trend or insignificant trends at the other Utah
sites.

• For soil, slightly increasing annual average tends were measured at the ZICA1 site and an increasing trend for the worst days was measured at the CAPI1 site.

• Coarse mass increased at the CAPI1 and CANY1 sites, but these sites did not show increasing trends. Higher 5

- year current period averages were influenced by higher than average coarse mass events in late April of 2008 at both sites.

**Table 3.5. Ut ah Class I Area IMPROVE Sites** 

**Change in Aerosol Extinction by Species**

**200**

**- 2009 Annual Average Trends** 



### 3.5 **Analysis of Emissions: 40 CFR 40 CFR § 51.309(d)(10)(i)(D)**
40 CFR §51.309(d)(10(i)(D) requires “ An analysis tracking the change over the past 5 years in emissions of pollutants contributing to visibility impairment from all sources and activities within the State. Emissions changes should be identified by type of source or activity. The analysis must be based on the most recent updated emissions inventory, with estimates projected forward as necessary and appropriate, to account for emissions changes during the applicable 5

- year period. ”

Included here are summaries depicting differences between two emission inventory ye a rs that are used to

repres ent the 5

- year baseline and current progress periods. The baseline period is represented using a 2002 inventory developed by the WRAP for use in the initial WRAP state SIPs, and the progress period is represented by a 2008 inventory which leverages recent WRAP inventory work for modeling efforts. For reference, Table 3.6 lists the pollutants inventoried, the related aerosol species, some of the key sources for each pollutant, and some notes regarding implications of these pollutants. Differences between these

19

### baseline and progress period inventories, and a separate summary of annual emissions from electrical generating units (EGUs), are presented in this section.

**Table 3.6**

**Utah Pollutants, Aerosol Species, and Major Sources** 

E m i tted
P o llu t a nt Re l a ted Aer o s o l Ma j o r S o u rces N o tes

S u l f ur D i o x i de ( S O 2 ) A m m o n i u m S u l f a t e P o i n t S o u rce s ; O n

- a n d O f f

R o ad M ob il e S o u rces S O 2 e m i ssi o n s are g e n era l l y a ss o c i a t ed w i t h a n t h r opo g e n i c

s o u rces s u ch as c o a l

- b u r n i n g p o w er p l a n ts

, o t h er i n d u st r i al

s o u rces s u ch a s re f i n er i es a n d c e m e n t p l a n ts

, a n d bo t h o n

- a nd

o f

f

- r o ad d i e s el e n g i n e s

. O x i d es of
N it ro g en (NO X ) A m m o n i u m N it ra te O n

- a n d O f f

R o ad M ob il e S o u rce s ; P o i n t S o u rce s ; A

rea S o u rc e s NO X e m i s si on s are g e n era ll y a s s o c i a t ed w i t h a n t h r opo g e n i c

s o u rce s

. C o mm o n s o u rces i n c l u d e v i r t u a l l y a l l c o m bu sti o n

ac ti v iti e s , e s p ec i a l l y t h o s e i n v o l v i n g car s , t r u c k s , p o w er p l a n ts

, a n d o t h er i n du st r i al p r o ce ss e s

.

A m m o n i a (NH 3 ) A m m o n i u m S u l f a t e

a nd
Am m o n i um N it ra te A rea S o u rc e s ; O n

- R o ad
M ob il e S o u rces Ga s e o u s NH 3 h as i m p li ca ti o n s i n p ar ti c l e f o r m a ti o n b ec a u s e it

can f o r m p ar ti c u l a t e a m m o n i u m

. A m m o n i u m i s n o t generally d i rec t l y m ea s u red b y t h e IM P R O V E p r o g ra m , b u t af f ec t s f o r m a ti o n po t e n ti al o f a mm o n i u m s u l f a t e a n d a m m o n i u m

n i t ra t e. A ll m ea s u red n it ra t e a n d s u l f a t e i s a s s u m ed t o b e

a ss o c i a t ed w i t h a mm o n i u m f o r IM P R OVE re po r ti n g p u r po s e s

. V o l a tile Or g a n i c C o m pou n ds (VO Cs) P ar ti c u l a te Or g a n i c Ma ss ( P OM) B i o g e n i c E m i s si on s ; Ve h i c l e E m i s si on s ; A

rea S o u rc e s VO C s are g a s e o u s e m i s si on s o f car bo n c o m po un d s , w h i c h are

o f

t en c on v er t ed t o P OM t h r o ug h c h e mi cal reac ti o n s i n t h e

a t m o s p h ere.

E st i m a t es f o r b i o g e n i c e m i ssi on s o f V O C s h a v e u n d e r g o n e si g n i f i c a n t u pd a t es si n ce 2002

, s o c h a n g es re po r t ed h ere are m o re

re f l ec t i v e o f m e t h odo l og y c h a n g es t h a n ac t u al c h a ng es i n

e m i s si on s ( s ee S ec ti o n 3

. 2

. 1 ).
P r i m a r y P OM W il d f i re s ; P OA re p re s e n t s o r g a n i c ae r o s o l s t h at are e m i tt ed d i rec t l y as Or g a n i c A rea S o u rc e s p ar ti c l e s , as oppo s ed t o g a s e s

. W il d f i res i n t h e w e s t g e n era l l y A er o s ol do m i n a t e PO A e m i s si on s , a n d l ar g e w il d f i re e v e n t s are g e n e ra l l y ( P O A) s po ra d i c a n d h i g h l y v ar i a b l e f r o m y ear

- t o

- y ear. E l e m e n t al EC W il d f i re s ; L ar g e EC e v e n t s are o f t en a ss o c i a t ed w i t h l a r g e P OM e v e n t s C ar bon O n

- a n d O f f

- d u r i n g w il d f i re s

. O t h er s o u r ces i n c l u d e bo t h on

- a n d o ff

- r o ad (E C ) R o ad M ob il e d i e s el e n g i n e s

. S o u rces Fi n e S o i l S o i l W i n db l o w n D u s t ; F u g it i v e D u st ; R o ad D u st ; A

rea S o u rc e s Fi n e s o i l i s re po r t ed h ere as t h e cr u st a l o r s o i l c o m po n e n t s of
P M 2

. 5 .

C o ar se Ma ss ( P M C) C o ar se Ma s s W i n db l o w n D u s t ; F u g it i v e D u s t C o ar s e m a s s i s re po r t ed b y t h e IM P R OVE Ne t w o rk a s t h e d i ff er e n ce b e t w e e n P M 10 a n d P M 2

. 5 m a s s m e a s u r e m e n ts

. Co ar s e

m a s s i s n o t s e p ara t ed b y s p e c i es i n t h e s a m e w a y t h at P M 2

. 5 i s

s p ec i a t e d

, b u t t h e s e m ea s u r e m e n t s are g e n era l l y a ss o c i a t e d w ith

cr u st al c o m po n e n t s

. S i mil ar t o cr u st al P M 2

. 5 , n a t u ral w i n d b l o w n d u s t i s o f t en t h e l ar g e s t c o n t r i b u t o r t o P M C.



### 20

### For these summaries, emissions during the baseline years are represented using a 2002 inventory, which was developed with support from the WRAP for use in the original RH SIP strategy development (termed plan02d). Differences between inventories are represented as the difference between the 2002 inventory and a 2008 inventory which leverages recent inventory development work performed by the WRAP for
the West

- wide Jumpstart Air Quality Modeling Study (WestJumpAQMS) and Deterministic & Empirical Assessment of Smoke's contribution to Ozone (DEASCO 3 

### ) modeling projects (termed WestJump2009). Note that the comparison of differences between inventories does not necessarily reflect a change in emissions, as a number of methodology changes and enhancements have occurred between development of the individual inventories (See Appendix A). Inventories for all major visibility impairing pollutants are presented for major source categories, and cate gorized as either anthropogenic or natural emissions.

Table 3.7 and Figure 3.11 present the differences between the 2002 and 2008 sulfur dioxide (SO 2 

### )
inventor ies by source category. Table 3.8 and Figure 3.11 present data for oxides of nitrogen (NO
x 

### ), and Tales 3.9 through 3.14 and Figures 3.12 through 3.18 present data for ammonia (NH 3 

### ), volatile organic compounds (VOCs), primary organic aerosol (POA), elemental carbon (EC), fine soil, and coarse mass. General observations regarding emissions inventory c omparisons are listed below.

• The l argest differences for point source inventories were a decrease in SO 2 

### emissions and an
increase in NO X 

### .

• Area source inventories showed decreases in SO 2 

### and increases in NO X 

### , NH 3 

### , POA, and VOCs. These changes may be due t o a combination of population changes and differences in methodologies used to estimate these emissions (see Section 3.2.1 of Appendix A) . One methodology change was the reclassification of some off

- road mobile sources (such as some types of marine vessels and locomotives) into the area source category in 2008, which may have contributed to increases in area source inventory totals, but decreases in off

- road mobile totals.

• On

- road mobile source inventory comparisons showed decreases in most parameters, esp ecially NOX and VOCs, with increases in POA, EC, and coarse mass. Reductions in NOX and VOC are likely influenced by federal and state emissions standards that have already been implemented. The increases in POA, EC, and coarse mass occurred in all of the WRAP states for on

- road mobile inventories, regardless of reductions in NO X 

### and VOCs, indicating that these increases were likely due use of different on

- road models, as referenced in Section 3.2.1 of Appendix A

.

• Off

- road mobile source inventories showed decreases in NO
x 

### , SO 2 

### , and VOCs, and increases in fine soil and coarse mass, which was consistent with most contiguous WRAP states. These differences were likely due to a combination of actual changes in source contributions and methodology differences, as referenced in Section 3.2.1 of Appendix A. As noted previously, one major methodology difference was the reclassification of some off

- road mobile sources (such as some types of marine vessels and locomotives) into the area source category in 2008, which m ay have contributed to decreases in the off

- road inventory totals, but increases in area source totals.

• Inventory comparison results for area oil and gas showed an increase in NOX and a decrease in VOCs. Note that inventory methodologies for these sources may have evolved substantially between the baseline and 2008 inventories as referenced in Section 3.2.1. Also, WRAP Phase III oil and gas inventories are reported here for entire basins, and include oil and gas emissions
within tribal boundaries.

21

### • For most parameters, especially POAs, VOCs, and EC, fire emission inventory estimates decreased. Note that these differences are not necessarily reflective of changes in monitored data, as the baseline period is represented by an average of 2000

- 2004 fire emission s, and the progress period is represented only by the fires that occurred in 2008, as referenced in Section 3.2.1 of Appendix A

.

• Comparisons between VOC inventories showed large decreases in biogenic emissions, which was consistent with other contiguous WR AP states. Estimates for biogenic emissions of VOCs have undergone significant updates since 2002, so changes reported here are more reflective of methodology changes than actual changes in emissions, as referenced in Section 3.2.1 of Appendix A

.

• Fine soil and coarse mass increased for the windblown dust inventory comparisons and the combined fugitive/road dust inventories. Large variability in changes in windblown dust was observed for the contiguous WRAP states, which was likely due in large part to enhan cements in dust inventory methodology rather than in changes in actual emissions.

22**Table 3.7 Sulfur Dioxide Emissions by Category** 

**Figure 3.11. 2002 and 2008 Emission and Difference between Emissions Inventory Totals, for Sulfur Dioxide by Source Category for Utah** 



### 23**Table 3.8 Oxides of Nitrogen Emissions by Category** 

O x id es o f N i tr og en E m i ssi o n s (t o ns/ y e a r) S o u rce C a te go ry 2002 (P l a n 02 d ) 2008 (We s t J u m p 2008) D i ffere n ce (Perce n t C h a n g e)
A n t h r o p og e ni c S o u rces P o i nt 84

, 2 1 8 87

, 6 2 3 3

, 405
A

rea 6

, 146 17

, 2 6 9 11

, 1 2 4
O n

- R o ad M ob il e 77

, 3 8 1 64

, 1 8 6

- 13

, 195
Of f

- R o ad M ob il e 47

, 1 0 0 13

, 2 4 9

- 33

, 851
A

rea O i l a n d Gas 3

, 335 4

, 136 801
F u g it i v e a n d R o ad D u s t 0 0 0
A n t h r opo g e n i c Fi re 319 65

- 254
T o t a l A n t h r o p og e ni c 218 , 4 99 186 , 5 28

- 31 , 9 7 1 (

- 15 %)
N a t u r a l S o u rces Na t u ral Fi re 8

, 873 650

- 8

, 223
B i o g e n i c 12

, 5 9 7 6

, 144

- 6

, 453
W i n d B l o w n D u s t 0 0 0
T o t a l N a t u r al 21 , 4 7 0 6 , 793

- 14 , 6 7 6 (

- 68 %)
A l l S o u rces T o t a l E m i s si o n s 239 , 9 69 193 , 3 22

- 46 , 6 4 7 (

- 19 %)

**Figure 3.12. 2002 and 2008 Emissions and Difference between Emissions Inventory Totals, for Oxides of**  **Nitrogen by Source Category for Utah**



### 24**Table 3.9 Ammonia Emissions by Category** 

A m m o ni a E m i s si o n s (t o ns/ y e a r) S o u rce C a te go ry 2002 (P l a n 02 d ) 2008 (We s t J u m p 2008) D i ffere n ce (Perce n t C h a n g e)
A n t h r o p og e ni c S o u rces P o i nt 1

, 905 556

- 1

, 349
A

rea 23

, 6 4 2 37

, 6 3 9 13

, 9 9 7
O n

- R o ad M ob il e 2

, 453 1

, 048

- 1

, 405
Of f

- R o ad M ob il e 32 16

- 16
A

rea O i l a n d Gas 0 0 0
F u g it i v e a n d R o ad D u s t 0 0 0
A n t h r opo g e n i c Fi re 75 37

- 38
T o t a l A n t h r o p og e ni c 28 , 1 0 7 39 , 2 95 11 , 1 8 9 ( 40 %)
N a t u r a l S o u rces Na t u ral Fi re 1

, 893 449

- 1

, 444
B i o g e n i c 0 0 0
W i n d B l o w n D u s t 0 0 0
T o t a l N a t u r al 1 , 893 449

- 1 , 4 4 4 (

- 76 %)
A l l S o u rces T o t a l E m i s si o n s 29 , 9 9 9 39 , 7 44 9 , 74 4 ( 3 2 %)

**Figure 3.13. 2002**

**- 2008 Emission and Difference between**  **Emission Inventory Totals, for Ammonia by Source Category for Utah** 



### 25**Table 3.10 Volatile Organic Compound Emissions by Category** 

S o u rce C a te go ry V o l a t il e O r ga ni c C o mp o un d E m i s si o n s (t o ns/ y e a r)

2002 (P l a n 02 d ) 2008 (We s t J u m p 2008) D i ffere n ce (Perce n t C h a n g e)
A n t h r o p og e ni c S o u rces P o i nt 7

, 367 9

, 285 1

, 919
A

rea 46

, 6 7 9 72

, 8 1 1 26

, 1 3 2
O n

- R o ad M ob il e 49

, 0 7 5 27

, 1 3 8

- 21

, 937
Of f

- R o ad M ob il e 26

, 9 3 3 23

, 2 1 3

- 3

, 720
A

rea O i l a n d Gas 35

, 9 6 1 25

, 3 5 8

- 10

, 603
F u g it i v e a n d R o ad D u s t 0 0 0
A n t h r opo g e n i c Fi re 536 126

- 410
T o t a l A n t h r o p og e ni c 166 , 5 50 157 , 9 31

- 8 , 6 1 9 (

- 5 %)
N a t u r a l S o u rces Na t u ral Fi re 19

, 4 8 4 720

- 18

, 764
B i o g e n i c 641

, 4 81 237

, 7 99

- 403

, 682
W i n d B l o w n D u s t 0 0 0
T o t a l N a t u r al 660 , 9 65 238 , 5 18

- 422 , 44 6 (

- 6 4 %)
A l l S o u rces T o t a l E m i s si o n s 827 , 5 15 396 , 4 49

- 431 , 06 5 (

- 5 2 %)

**Figure 3.14. 2002**

**- 2008 Emission and Difference between Emission Inventory Totals, for Volatile Organic**  **Compounds by Source Category for Utah**



### 26**Table 3.11 Primary Organic Aerosol Emissions by Category** 

S o u rce C a te go ry Pr i m a ry O r ga ni c Aer o s o l E m i s s i o n s (t o ns/ y e a r)

2002 (P l a n 02 d ) 2008 (We s t J u m p 2008) Difference (Perce n t C h a n g e)
A n t h r o p og e ni c S o u rces P o i n t * 392 75

- 317
A

rea 578 3

, 045 2

, 468
O n

- R o ad M ob il e 637 1

, 573 937
Of f

- R o ad M ob il e 965 666

- 299
A

rea O i l a n d Gas 0 28 28
F u g it i v e a n d R o ad D u s t 141 886 745
A n t h r opo g e n i c Fi re 507 106

- 401
T o t a l A n t h r o p og e ni c 3 , 219 6 , 380 3 , 16 1 ( 9 8 %)
N a t u r a l S o u rces Na t u ral Fi re 26

, 1 8 7 1

, 167

- 25

, 020
B i o g e n i c 0 0 0
W i n d B l o w n D u s t 0 0 0
T o t a l N a t u r al 26 , 1 8 7 1 , 167

- 25 , 0 2 0 (

- 96 %)
A l l S o u rces T o t a l E m i s si o n s 29 , 4 0 7 7 , 547

- 21 , 8 5 9 (

- 74 %)

**Figure 3.15. 2002**

**- 2008 Emission and Difference between Emission Inventory Totals, for Primary Organic**  **Aerosol by Source Category for Utah**



### 27**Table 3.12 Elemental Carbon Emissions by Category** 

El e m e n t a l C a r b o n E m i ssi o n s (t o ns/ y e a r) S o u rce C a te go ry 2002 (P l a n 02 d ) 2008 (We s t J u m p 2008) D i ffere n ce (Perce n t C h a n g e)
A n t h r o p og e ni c S o u rces P o i n t * 102 24

- 77
A

rea 12 513 500
O n

- R o ad M ob il e 663 2

, 593 1

, 930
Of f

- R o ad M ob il e 2

, 492 715

- 1

, 777
A

rea O i l a n d Gas 0 0 0
F u g it i v e a n d R o ad D u s t 11 21 11
A n t h r opo g e n i c Fi re 85 23

- 62
T o t a l A n t h r o p og e ni c 3 , 364 3 , 889 52 5 ( 16 %)
N a t u r a l S o u rces Na t u ral Fi re 5

, 405 209

- 5

, 196
B i o g e n i c 0 0 0
W i n d B l o w n D u s t 0 0 0
T o t a l N a t u r al 5 , 405 209

- 5 , 1 9 6 (

- 96 %)
A l l S o u rces T o t a l E m i s si o n s 8 , 769 4 , 098

- 4 , 6 7 1 (

- 53 %)

**Figure 3.16. 2002**

**- 2008 Emission and Difference between Emission Inventory Totals, for Elemental Carbon**  **by Source Category for Utah**



### 28**Table 3.13 Fine Soil Emissions by Category** 

F in e S o i l E m i s s i o n s (t o ns/ y e a r) S o u rce C a te go ry 2002 (P l a n 02 d ) 2008 (We s t J u m p 2008) D i ffere n ce (Perce n t C h a n g e)
A n t h r o p og e ni c S o u rces P o i n t * 2

, 933 712

- 2

, 222
A

rea 160 1

, 595 1

, 435
O n

- R o ad M ob il e 426 257

- 170
Of f

- R o ad M ob il e 0 47 47
A

rea O i l a n d Gas 0 479 479
F u g it i v e a n d R o ad D u s t 2

, 411 14

, 1 6 4 11

, 7 5 3
A n t h r opo g e n i c Fi re 81 43

- 38
T o t a l A n t h r o p og e ni c 6 , 011 17 , 2 9 6 11 , 2 8 5 ( > 1 0 0 %)
N a t u r a l S o u rces Na t u ral Fi re 1

, 719 429

- 1

, 290
B i o g e n i c 0 0 0
W i n d B l o w n D u s t 7

, 573 10

, 8 1 0 3

, 237
T o t a l N a t u r al 9 , 292 11 , 2 3 9 1 , 94 8 ( 2 1 %)
A l l S o u rces T o t a l E m i s si o n s 15 , 3 0 2 28 , 5 3 5 13 , 2 3 2 ( 86 %)

**Figure 3.17. 2002**

**- 2008 Emission and Difference between Emission Inventory Totals, for Fine Soil by**  **Source Category for Utah**



### 29**Table 3.14 Coarse Mass Emissions by Category** 

C oa r s e M a s s E m i s si o n s (t o n s/ y e a r) S o u rce C a te go ry 2002 (P l a n 02 d ) 2008 (We s t J u m p 2008) D i ffere n ce (Perce n t C h a n g e)
A n t h r o p og e ni c S o u rces P o i n t * 8

, 442 4

, 216

- 4

, 226
A

rea 2

, 387 2

, 017

- 371
O n

- R o ad M ob il e 414 2

, 801 2

, 387
Of f

- R o ad M ob il e 0 76 76
A

rea O i l a n d Gas 0 12 12
F u g it i v e a n d R o ad D u s t 12

, 3 7 4 107

, 0 79 94

, 7 0 5
A n t h r opo g e n i c Fi re 59 20

- 39
T o t a l A n t h r o p og e ni c 23 , 6 7 7 116 , 2 21 92 , 5 4 4 ( > 1 0 0 %)
N a t u r a l S o u rces Na t u ral Fi re 5

, 671 224

- 5

, 448
B i o g e n i c 0 0 0
W i n d B l o w n D u s t 68

, 1 5 3 97

, 2 8 9 29

, 1 3 6
T o t a l N a t u r al 73 , 8 2 4 97 , 5 1 3 23 , 6 8 9 ( 32 %)
A l l S o u rces T o t a l E m i s si o n s 97 , 5 0 1 213 , 7 33 116 , 2 3 3 ( > 100 %)

**Figure 3.18. 2002**

**- 2008 Emission and Difference between Emission Inventory Totals, for Coarse Mass by**  **Source Category for Utah**



### 30

### As described above, differences between the baseline and progress period inventories presented here do not necessarily represent changes in actual emissions because numerous updates in inventory methodologies have occurred between the development of the separate inventories. Also, the 2002
baseline and 2008 progress period inventories represent only annual snapshots of emissions estimates, which may not be representative of the entire 5

- year monitoring periods compared. To better account for

year

- to

- year changes in emissions, annual emissions totals for Uta h electrical generating units (EGUs) are presented here. EGU emissions are some of the more consistently reported emissions, as tracked in EPA’s Air Markets Program Database for permitted Title V facilities in the state ( http://ampd.epa.gov/ampd ). RHR implementation plans are required to pay specific attention to certain major stationary sources, including EGUs, built between 1962 and 1977.

Figure 3.19 presents a sum of annual NOx and SO 2 

### emissions as reported fo r Utah EGU sources between 1996 and 2010. While these types of facilities are targeted for controls in state regional haze SIPs, it should be noted that many of the controls planned for EGUs in the WRAP states had not taken place yet in 2010, while other controls separate from the RHR may have been implemented. The chart shows some periods of decline for both NOx and SO 2 

### , with a sharp decline in SO 2 

### emissions between 2006 and 2007.

**Figure 3.19. Sum of EGU Emissions of SO 2**  **and NOx Reported between 1996 a nd 2010** 



### 31

### 3.6 **Changes to Anthropogenic Emissions: § 51.309(d)(10)(i)(E)**
40 CFR §51.309(d)(10)(i)(E) requires an assessment of any significant changes in anthropogenic emissions within or outside the State that have occurred over the past 5 years that have limited or impeded progress in reducing pollutant emissions and improving visibility.”

Table 3.15 displays the average light extinction for the 20% worst days over the 5

- year period 2005 through 2009 for all Class I areas in Utah. The table demonstrates t hat on the 20% worst days in the Class I areas in Utah, particulate organic mass and ammonium sulfate are the major concern for visibility impairment. Appendix M includes monitoring data summaries over the 5

- year period 2005

- 2009 for the
20% worst and bes t days for each Class I area in Utah.

**Table 3.15. Average extinction for 20% Worst Days for the Current Progress Period of 2005**

**- 2009** 

Si te Dec i v i e w s ( d v ) Perce n t C o n tr ibu t i o n to Aer o s o l E x t in ct i o n b y S p ec i es ( E x c l u d es R ay l e i g h ) (% o f M m - 1 ) a n d R a n k *

A m m o n iu m Sul f a te A m m o n iu m N i tr a te Part i c ul ate O r ga ni c

Ma s s El e m e n tal C a r b on S o i l Coar s e Ma s s S ea S a l t

B R C A 1 11 .9 19 % ( 2) 9 % ( 5) 45 % ( 1) 10 % ( 4) 5 % ( 6) 12 % ( 3 ) 0 % ( 7)

C A NY1 11 .0 23 % ( 2) 14 % ( 4) 27 % ( 1) 7 % ( 5) 7 % ( 6) 20 % ( 3) 0 % ( 7)

C A P I1 11 .3 24 % ( 2) 12 % ( 4) 32 % ( 1) 8 % ( 5) 7 % ( 6) 17 % ( 3) 0 % ( 7)

Z I C A1 12 .3 21 % ( 3) 7 % ( 5) 33 % ( 1) 9 % ( 4) 7 % ( 6) 22 % ( 2) 0 % ( 7)



### The primary sources of anthropogenic particulate organic mass in Utah include prescribed burning, vehicle exhaust, vehicle refueling, solvent evaporation (e.g., paints), food cooking, and various commercial and industrial sources. Anthropogenic sources of SO 2 

### include coal

- burning power plants and other industrial sources, such as boilers

, oil refineries and copper smelters . Stationary point so urces account for approximately 90% of SO 2 

### emissions in Utah.

There do not appear to be any anthropogenic emissions within Utah that would have limited or impeded progress in reducing pollutant emissions or improving visibility.

**3.7 Assessment of Current**  **SIP Strategy: § 51.309(d)(10)(i)(F)**
40 CFR § 51.309(d)(10)(i)(F) requires “an assessment of whether the current implementation plan elements and strategies are sufficient to enable the State, or other States with mandatory Federal Class I
areas affected b y emissions from the State, to meet all established reasonable progress goals.”

Figure 3.20 shows the annual and 5

- year period averages for the 20% worst days at Canyonlands National
Park and Arches National Park from 2000 to 2010. This figure demonstrate s that on the 20% worst days, visibility continues to improve at these Class I areas from the baseline average through the first progress period. Similar results are seen for Zion National Park at the ZICA1 monitor (Appendix M) . Figures
3.21 and 3.22 sho w the annual and 5

- year period averages for the 20% worst days at Bryce Canyon

32

### National Park (BRCA1 site) and Capitol Reef Nation Park (CANY1 Site)

. At both of these monitors, the
5

- year period average from 2005 to 2009 is higher than the baseline. Note th at the increase in deciviews
in 2009 from these monitors is attributed to peak increases of particulate organic mass, which was a result of large fire events throughout the region in both July and August of that year. Utah should not be held
accountable f or visibility impairing emissions that are uncontrollable. However, even with wildfire emissions included in the assessment, monitoring data shows that visibility continues to improve for both the 20% best and worst days through 2010 at all IMPROVE sites (Appendix M).

**Figure 3.20. Annual and 5**

**- Year Period Averages for the 20% Worst Days at Canyonlands and Arches**  **National Parks (CANY1 IMPROVE Site)**

**Figure 3.21. Annual and 5**

**- Year Period Averages for the 20% Worst Days at Bryce Canyon National Park**  **(BR CA1 IMPROVE Site)** 



### 33**Figure 3.22. Annual and 5**

**- Year Period Averages for the 20% Worst Days at Capitol Reef (CAPI1 IMPROVE**  **Site)**



### As table 3.16 shows, Utah is showing improvement in visibility on the most impaired days and no degradation on the least impaired days between baseline and current monitoring data. The first 5

- year progress period evaluated in this report covers the 2005

- 2009 timeframe, as it represents the most recent
successive 5

- year averaging period; however, the WRAP TSS has been updated to include data up through 201 2. The average of the first three years of the next successive 5

- year progress period (2010

- 2014) ind icates that visibility at Utah’s Class I areas is improving on both the 20% worst and 20% best days.

34**Table 3.16 . Utah Class I Area IMPROVE Sites Visibility conditions** 

**– 20% Most and Least Impaired Days Including** 

**2010 to 2012 data** 

Class I Area Baseline (2000

- 2004) (dv) Current (2005

- 2009) (dv) (2010

- 201 2 ) (dv) 2018 Preliminary
Reasonable Progress Case

(PRP18a)

(dv) 20% Worst Days

Arches NP (CANY1) 11.2 11.0 10. 6 10.9 Bryce Canyon NP (BRCA1) 11.6 11.9 10.0 11.2
Canyonlands NP (CANY1) 11.2 11.0 10.6 10.9 Capitol Reef NP (CAPI1) 10.9 11.3 10.1 10.5 Zion NP (ZICA1) 12.5 12.3 10.8 8 N/A 9

20% Best Days

Arches NP (CANY1) 3.7 2.8 2.8 3.5 Bryce Canyon NP (BRCA1) 2.8 2.1 1.7 2.6
Canyonlands NP (CANY1) 3.7 2.8 2. 8 3.5 Capitol Reef NP (CAPI1) 4.1 2.7 2.4 3.9
Zion NP (ZICA1) 5.0 4.3 4.4 (see footnote 7 ) N/A (see footnote 7 )



### Utah believes that the current control strategies in the state’s Regional Haze SIP are sufficient to improve visibility at Federal Class I areas in the state and to benefit all Class I areas outside of Utah that might be impacted by emissions from Utah.

Northern Utah, which may impact Federal Class I areas in Idaho, Nevada, and Wyoming , is an urban area with emissions predominately coming from mobile sources. Mobile NO
x 

### emissions in the four main urban counties (Weber, Salt Lake, and Utah) are projected to decrease 42,000 tons/yr or 61% between
2002 and 2018.

BART controls installed to plants in central Utah (as described in Section 3.2 of this report) are projected
to decrease SO 2 

### emissions by 13,200 and NO
x 

### emissions by 6,200 tons between 2002 and 2018. And as is the case with northern Utah, southern Utah has an emissions inventory dominated by mobile sources. In Washington County, NO
x 

### emissions from mobile sources are projected to decrease 2,300 tons or 57% between 2002 and 2018. These emissions reductions benefit Federal Class I areas in Colorado, New
Mexico and Arizona.

8 Includes 2012 data only; there were no results avail able for 2010 and 2011.

9 There is no PRP18a established for the new ZICA1 monitor. The PRP18a was originally established for the original ZIONI IMPROVE monitor, which was discontinued on July 29, 2004.



### 35

### As stated in Section K of the SIP, oil and gas emissions in eas tern Utah are increasing. Approximately 90% of current emissions from oil and gas development in Uintah and Duchesne Counties occur on land that is under the jurisdiction of the Ute Indian Tribe and EPA and is therefore not covered under Utah's
SIP. For the areas under state jurisdiction, the WRAP Phase III inventory estimated that NOx emissions from oil and gas production would increase by about 1,000 tons/yr between 2006 and 2012. Figure 19 in Utah's SIP shows the expected impact from Utah sources on C lass I areas in western Colorado. While NOx emissions from oil and gas production are increasing, mobile source NOx emissions are decreasing in the urban area along the Wasatch Front, and NOx emissions are decreasing due to BART in Central Utah, showing a n overall decreased contribution to nitrate levels in western Colorado. In addition, new federal engine standards (NSPS IIII and JJJJ, NESHAP ZZZZ) are leading to additional reductions in
NOx emissions that will be reflected in future inventories.

**3.8 Assessment of Current Monitoring Strategy: § 51.309(d)(10)(i)(G)** 

40 CFR § 51.309(d)(10)(i)(G) requires “ a review of the State’s visibility monitoring strategy and any modifications to the strategy as necessary.”

The primary monitoring network for regional haze, both nationwide and in Utah, is the IMPROVE monitoring network. Given that IMPROVE monitoring data from 200 0 to 2004 serves as the baseline for the regional haze program, the future regional haze monitoring strategy must necessarily be based on, or directly comparable to the current IMPROVE network. The IMPROVE measurements provide the only long

- term record available for tracking visibility improvement or degradation; therefore, Utah intends to continue reliance on the IMPROVE network for complying with the RH monitoring requirement in the
RH rule.

There are currently four IMPROVE sites in Utah (Table 3.17), and no modifications to the existing visibility monitoring strategy are necessary at this time.

**Table 3.17. Utah CIAs and Representative IMP ROVE Monitors** 



### 3.9 **Determination of Adequacy : § 51.309(d)(10)(ii**  **)**
40 CFR § 51.309(d)(10)(ii)(d)(10)(ii) requires “ Determination of the adequacy of existing implementation plan. At the same time the State is required to submit any 5

- year progress report to EPA in accordance with paragraph (d)(10)(i) of this section, the State must also take one of the following actions based upon the information presented in the progress report:

36

### (1) If the State determines that the existing implementation plan re quires no further substantive revision at this time in order to achieve established goals for visibility improvement and emissions reductions, the State must provide to the administrator a negative declaration that further revision of the existing implemen tation plan is not needed at this time.

(2) If the State determines that the implementation plan is or may be inadequate to ensure reasonable progress due to emissions from sources in another State(s) which participated in a regional planning process, th e State must provide notification to the administrator and to the other State(s) which participated in the regional planning process with the States. The State must also collaborate with the other State(s) through the regional planning process for the pur pose of developing additional strategies to address the plan’s deficiencies.

(3) Where the State determines that the implementation plan is or may be inadequate to ensure reasonable progress due to emissions from sources in another country, the State sha ll provide notification, along with available information, to the Administrator.

(4 ) Where the State determines that the implementation plan is or may be inadequate to ensure reasonable progress due to emissions from sources within the State, the State s hall revise its implementation plan to address the plan’s deficiencies within one year. ”

The State of Utah has provided the information required under 40 CFR § 51.309(d)(10)(ii)(d)(10)(i) in
this 5

- year progress report. Based on this information, the Stat e believes that its current RH SIP is adequate to continue to improve visibility in all five Federal Class 1 areas; therefore, a revision to the RH SIP is not required.



### 4.0 **REGIONAL SUMMARY FOR 309 GCVTC CLASS I AREAS**

Section 309 rules were based on reco mmendations from the Grand Canyon Visibility Transport Commission (GCVTC) Recommendations report

, 10 

### specific to visibility impacts at the 16 Class I areas on the Colorado Plateau. Of the nine western states originally eligible for Section 309 RH rule imple mentation, only the states of New Mexico, Utah, and Wyoming and the city of Albuquerque/Bernalillo County currently exercise this option.

The 16 Class I areas on the Colorado Plateau are depicted in Figure 4.1 and listed in Table 4.1. Note that
the ZION1 site, which originally represented Zion Canyon National Park, has since been replaced with the ZICA1 site. This section presents regional progress summaries specific to monitoring and emissions
data at these Colorado Plateau sites.

10 The Grand Canyon Visibility Transport Commissi on Recommendations for Improving Western Vistas Report is archived on the WRAP website at www.wrapair.org/WRAP/reports/GCVTCFinal.PDF

.



### 37**Table 4.1**
**Colorado Plat eau Class I Areas and Representative IMPROVE Monitors** 



### 38**Figure 4.1. Map Depicting Colorado Plateau Class I Areas and Representative IMPROVE Monitors in Arizona, Colorado, New Mexico and Utah** 



### Monitoring Data

Figures 4.2 and 4.3 present the 2005

- 2009 visibility averages for the 20% worst and best days for the IMPROVE sites representing Class I areas on the Colorado Plateau. The size of the pie chart is relative to the magnitude of visibility impairment, and colors represent the relative contribution of the pollutants which are measured by the IMPROVE network. Tables 4.2 and 4.3 present the difference between the
2000

- 2004 baseline period average and the 2005

- 2009 first progress period average for the 20% wor st and best days, respectively, for the Class I area sites in the Colorado Plateau region.

39

### Table 4.4 presents the differences between the 200 0

- 2004 baseline period average extinction and the
2005

- 2009 progress period average for each Class I area site in t he Colorado Plateau region for the 20% most impaired days, and Table 4.5 presents similar data for the least impaired days. Averages that increased are depicted in red text and averages that decreased in blue.

Trend statistics for the years 2000

- 2009 for each species at each Class I area site in the Colorado Plateau region are presented in Table 4.6. Only trends for aerosol species trends with p

- value statistics less than 0.15 (85% confidence level) are presented in the table here, with increasing slopes in red and decre a sing slopes in blue.

Some general observations for the current visibility conditions and the difference between current and
baseline conditions are listed below:

• The largest contributors to aerosol extinction at the Colorado Plateau sites were particulate organic mass, ammonium sulfate, and coarse mass.

• For all sites, the 5

- year average as measured in deciview metric decreased for the best days between the baseline and first progress period.

• For most sites, the 5

- year average as measured in deciview metric decreased for the worst days between the baseline and first progress period. Exceptions included GRCA2 and BALD1 in Arizona and BRCA1 and CAPI1 in Utah. Some contributing factors for aerosol measurements that affected increased in 5

- year average deciviews are listed below.

• The increase at GRCA2 was due to increases in ammonium sulfate, elemental carbon, particulate organic mass and soil, partially offset by decreases in ammonium nitrate and coarse mass. The particulate organic carbon increase was associated with high measurements due to fire events in June and August of 2009. No statistically significant increasing annual trends were measured for any of the species at the GRCA2 site.

• Extin ction remained relatively unchanged in terms of deciviews for the worst days measured at the BALD1 site. Increases in coarse mass, soil, and ammonium sulfate were offset by decreases in particulate organic mass, elemental carbon, and ammonium nitrate. Tren d statistics showed an increasing coarse mass trend at the BALD1 and PEFO1 sites in eastern Arizona.

• At the BRCA1 and CAPI1 sites, the largest contributor to increases was particulate organic mass which, similar to GRCA2, was associated with large fires events in July and August 2009. These increases were offset by decreases in ammonium nitrate and ammonium sulfate. An increasing soil trend was measured for the worst days at the CAPI1 site.

• Increases in 5

- year average ammonium sulfate were measured at many regional sites, although most sites showed decreasing annual average ammonium sulfate trends. The 5

- year average was influenced by relatively high regional measurements of ammonium sulfate in 2005. Figure 5.1.3 presents a plot of the annual averages f or all Colorado Plateau sites, showing the high values measured in 2005, followed by generally decreasing trends.

40**Figure 4.2. Regional Average of Aerosol Extinction by Pollutant for the First Progress Period Average (2005** 

**- 2009) for 20% worst days** 

**Fi gure 4.3. Regional Average of aerosol Extinction by Pollutant for First Progress Period Average (2005** 

**- 2009) for 20% Best Days** 



### 41**Table 4.2**
**Colorado Plateau Class I Area IMPROVE Sites Current Visibility Conditions** 
**2005**

**- 2009 Progress Period, 20% Most Impaired**  **Days**



### 42**Table 4.3**
**Colorado Plateau Class I Area IMPROVE Sites Current Visibility Conditions** 
**2005**

**- 2009 Progress Period, 20% Least Impaired Days** 



### 43**Table 4.4**
**Colorado Plateau Class I Area IMPROVE Sites Difference in Aerosol Extinction by Species** 

**2000**

**- 2004 Bas**  **eline Period to 2005**

**- 2009 Progress Period**  **20% Most Impaired Days**



### 44**Table 4.5**
**Colorado Plateau Class I Area IMPROVE Sites Difference in Aerosol Extinction by Species** 

**2000**

**- 20004 Baseline Period to 2005** 

**- 2009 Progress Period**  **20% Least Impaired Days**



### 45**Table 4.6** 
**Colorado Plateau Class I Area IMPROVE Sites Change in Aerosol Extinction by Species** 

**2000**

**- 2009 Annual Average Trends** 



### 46**Figure 4.4 Chart Depicting Annual Average Ammonium Sulfate Concentrations for the 20% Worst Days as Measured at the Colorado Platea**  **u CIA IMPROVE Sites** 

### Similar to 308 requirements, Section 309 states are required to address how total state emissions have changed over the past five years (51.309(d)(10)(i)(D)). Emission inventory summaries using 2002 and 2008 inventories to represent ch anges between the baseline and progress periods are described in detail
for the entire state in Section 3.5.

I n addition to tracking these differences in inventories, for the initial SIPs, Section 309 states were required to identify “clean air corridors” and track emissions inside and outside of these corridors that may affect impairment on the cleanest days. 11 

### In these initial Section 309 SIPs, an area covering major portions of Nevada, southern Utah, eastern Oregon and southwestern Idaho was defined as a “clean air corridor,” which was intended to represent a region from which clean air transport influences ma ny of the clean air days at Grand Canyon National Park. Visibility has improved for the best days at all of the Class I area sites on the Colorado Plateau, so emissions specific to the “clean air corridor” counties are not presented separately here.

As pa rt of the Western Backstop Sulfur Dioxide Trading Program, the participating states (and county)
identified SO 2 

### emissions milestones, where a milestone is a maximum level of annual emissions for a given year. WRAP supports the Section 309 states with the submittal of annual regional SO 2 

### and emission milestone reports which compare actual emissions estimates to the pre

- defined milestones. 12 

### Figure 4.5 presents a plot from the most recent SO 2 

### milestone report, showing the 3

- year average of
current emissions t hrough 201 2 , which indicated that actual emissions were below the SO 2 

### milestone.

11 Section 51.309(d)(3) states, for treatment of clean

- air corridors, “the plan must describe and provide for implementati on of comprehensive emission tracking strategies for clean

- air corridors to ensure that the visibility does not degrade on the least

- impaired days at any of the 16 Class I areas.”

12 Annual regional SO2 emissions and milestone reports are located on the WRA P website at http://www.wrapair2.org/reghaze.aspx.



### 47

### Additionally, SO 2 

### emissions specific to EGU sources are presented in Figure 3.19 on an annual basis showing changes in these sources between 1996 and 2010 for Utah.

**Figure 4.5. Chart Depicting 3** 

**- Year Average Sum of SO**  **2 Emissions for New Mexico, Utah and Wyoming and**  **the City of Albuquerque/Bernalillo County as Compared to the Section 309 SIP SO 2**  **Milestones** - 50,000 100,000 150,000 200,000 250,000 300,000 350,000

2000 2005 2010 2015 2020tons/yr SO2 

### SO 2 

### Milestones and Emission Trends New Mexico, Utah, Wyoming

Three Year Average

Milestone



### 48