vapors a isplaced from the underground storage tanks during filling and when gasoline is 

vehicle tan Regulations now require control during the transfer of fuel to the undergr 

tanks. 

pensed to 

storage 

Control Strate 

hydrocarbon emission 

from storage tanks durin 

Affected Facilities: Any tionary storage tank located at a 

capacity of 7,580 liters (2,000 g ons) or more is r:equired to h 

er than 90% of the 

stems control emissions 

ck. 

ine dispensing facility with a 

installed: 

The proper use of simple balance systems will control 

om the filling of underground storage tanks. Thes 

lling by returning displaced vapors to the ta 

Vapor Control Systems at Gasoline Stations 

ocarbon emissions from gasoline service station operations occur primarily when hydr rbon 

A vapor return line such that va rs displacedfrom t torage tank during filling are returned to the 

delivery tank. Delivery tank operator e a vapor return system installed on each 

delivery tank to insure all gasoline trans delivery tank is done in such a manner that 

displaced vapors are not vented to the atm her ring transfer operations. In addition, proper 

maintenance and operation are required to inefficient collection and that there are no leaks in the 

system. Frequent visual inspections are re to insure proper operation of manifolding and relief 

valves. Tank trucks and storage tanks ar .intained in vapor tight conditions with leak testing 

..........
 

. major HC source categories for which control 

RefinefY.
 

Stora 5,271
 

Lo gfTransfer 4,460
 

controlled Emissions 2,253
 

Total 24,677 Kg/day
 

1984 

(projected) 

3,339 

3,147 

752 

2,253 

9,411 

-61.5% 

1980 

(reported) 

12,693 

s predicted from 

r Conservation Regula 

conducted at least annually on each t 

requirements exist in the Uta 

Figure IX.D.7 lists the emis 

IX.D.1.d(5) Other Control Technigues 

In addition to the strategies contained in Sections IX.D.1.d(l) - (4), several other guidance documents 

were reviewed in an effort to plan reductions of hydrocarbon emissions along the Wasatch Front. 

Specifically the following areas were reviewed: Control of volatile organic emissions (VOC) from (1) 

Surface coating of large appliances, (2) Surface coating for insulation of magnet wire, (3) Surface coating 

of metal furniture, and (4) Surface coating of cans, coils, paper, fabrics, automobiles, and light duty 

trucks. Although these processes are capable of sizeable VOC emissions, the hydrocarbon inventory 

Section IX, Part D.l, page 11 
.­

55
 '"'­

indicates that their contribution to the ozone problem in the Wasatch Front is insignificant. 

Control of Volatile Organic Compounds from the Use of Cutback Asphalt: Since 1973-74 the State has 

adopted a policy to eliminate as much as possible the use of cutback asphalts and substitute emulsions in 

their place. In 1975 the Federal Highway Administration adopted a similar policy and urged all states to 

comply. 

There are still some applications where the use of emulsions do not give satisfactory results and cutback 

must be employed, primarily during the winter months. The following is a summary of the past and 

projected use of cutback asphalts and emulsions in the Wasatch Front by the Utah Department of 

Transportation: 

Emulsions Cutback 

Three Year Average (1975-1977) 1477 tons 1696 tons 

1982 2000 tons 1200 tons 

Anticipated in 1987 2400 tons 400 tons 

Regulations have been enacted which have reduced these projections. Emulsions are used almost 

exclusively in the nonattainment area. 

Solvent Metal Cleaning: Volatile organic emissions occur when solvents are used during metal cleaning 

operations. Positive emission reductions are required through the use of proper operating practices and 

efficient control equipment, which include but are not limited to: 

1) Covering degreasing equipment whenever possible.
 

2) Proper use of solvent sprays.
 

3) Various means of reducing the amount of solvent carried out of the degreaser on cleaned work.
 

4) Prompt repair of leaking equipment.
 

5) Proper disposal of wastes containing volatile organic solvent.
 

Effective control devices are required on all degreasing operations in the nonattamment area. The level of 

control for major sources is detailed by system B in EPA Publication 45/2-77-022 "Control of Volatile 

Organic Emissions from Solvent Metal Cleaning". Conveyorized degreasers smaller than 2.0 m 2 (approx. 

21.5 fe) of air/vapor interface would be exempted from the requirements of a major control device and 

open top vapor degreasers smaller than I m2 (approx. 10.8 fe) of open area would be exempted from the 

application of refrigerated chillers (or carbon absorbers). Effective disposal of waste solvent would 

require storage in covered containers and disposal by a method which prevents its emission to the 

atmosphere. 

Perchloroethylene Dry Cleaning Plants: Hydrocarbon emissions occur from leaks, waste disposal, and 

dryer exhausts. All dry cleaning plants are required to control leaks promptly and dispose of waste 

properly. In addition, the larger plants are required to install carbon adsorption technology or use some 

other technique capable of reducing emissions by at least 90% on their dryer exhausts. 

. Other Sources: Regulations have been enacted which restrict the emissions from other processes 

including: 

Paper coating 

Fabric and Vinyl coating 

Section IX, Part D.l, page 12 
--

Demonstration of Attainment arid Reasonable Further Progress 

emonstration of attainment based oJi data gathered during 1981 is made based on the 

hip because it is the only year with adequate ambient hydrocarbon data and the 

ozone data. The demonstration of attainment based on the EKMA proc 

t ozone data collected at Salt Lake City and Bountiful. 

;;: 'The' highest oionereadl 

J .:.. -_Salt Lake '.CIty. The most 

g; '1uction in the 'hydrocarbo 

.ons inv~ "f:, 

' 

tt',I.'; r 

,(f ',,;r --if" 

Metal furniture coating
 

Large appliance surface coating
 

Magnet wire coating
 

Flat wood coating
 

Miscellaneous metal parts coating
 

Graphic arts'
 

Synthesized phannaceutical manufacturing
 

The re ions iIDplementin.gJh~ssection oft~~§IP are containe
 

5, 340, and 341.e emissions inventory-shows that these sources are only mmo
 

hy.drc)Cflrb(nn~lss;S:sionsinventory (see Figure IX.D.8). "
 

ith the 

" uses the last

..... :.:. 

C­

~(~'~?;

;<~

associated with high hydrocarbon.rea 

cant reductions of hydrocarbons i 

vehicle mile' emission facto 

'V 

A;·,' ,"',' . "!ifuopitored in the urban core of 

ea are attributable to the gradual 

result of the FMYCP. 

rlgure IX.D.9 shows the estimat core emissions ' ; , "1980 through 1987 and the percent
 

reduction from the 1980 and the 1981
 .' 

As indicated in Section IX.D.l.b the hydroc /--tduction requirement for this area is 32%. 11igure 

IX.D.9 shows the 1981 emission inventory, Kg/day. Therefore, the inventory necessary for
 

attainment is:
 

~?

;._, .' ~06 (1 - 0.32) = 0 Kg/day "J'

{~~("

The estimated inventories fOfi ,?years 1981 through 1987 are in Figure IX.D.I 0, which shows
 

attainment of the ozone st 'ds by November 1, 1985.
 

t" ,'Of' 

EKMA Modelin A .iO~ch: The EKMA approach required that the hest days at each site in the
 

last three years bet"'deled.
 p' ' ,f,~'
 

The fourth p", ~st hydrocarbon reduction requirement at each site is the contro uirement at that site.
 

The high ',r f these site specific control requirements is the overall control requi t for the area.
 

owing are the site specific control requirements: 

Date Peak 0iPPM) Control Requirement
 

Salt Lake: 6/28/80 0.16
 

307-325, 326,327,328,332, 

29% 

Section IX, Part D.l, page 13 
$.D.2.b. EXISTING REGl1LATIONS AND CONTROLS 

Requirements Relating to Existing Controls and Regulations: 

The State must assure that control measures required in past Ozone SIP revisions have 

been implemented and that existing reasonably available control technology (RACT) controls will 

remain in effect after redesignation, unless it has demonstrated to EPA's satisfaction through 

photochemical dispersion modeling, not including EKMA, that the standard can be maintained 

without one or more controls. 

Areas that were required to implement transportation control measures andlor 

inspection/maintenance programs must provide evidence that these programs have been fully 

implemented. 

The State must have an EPA approved SIP control strategy that includes RACT 

requireme',tsfor existing stationary sources covered by control techniques guidelines (CTC), as 

well as RACT requirementsfor all major non-CTC sources. The State must confirm that all 

affected vac, and NOx sources have either installed or are operating RACT controls. 

T,he State must assure that acceptable provisions exist and are being implemented to 

provide for new source review. 

The State must demonstrate completion ofrule effectiveness studies and small source 

compliance initiatives, as resources allow. 

(1) Enforcement of Existing Ozone State Implementation Plan 

Technical Support Document, Volume 1, Tab 1.1 

'.' This SIP revision incorporates federal requirements for demonstrating that the ozone standard can be 

iimaintained in future years in the Salt Lake and Davis County nonattainment areas. The State will 

. continue to enforce the requirements of the existing Ozone SIP until the redesignation request is 

approved. The State also certifies that all existing RACT controls required in past Ozone SIP revisions, 

and new RACT controls incorporated in these revisions, will remain in effect after redesignation of the 

-region to attainment, unless the State demonstrates to EPA's satisfaction through photochemical 

::dispersion modeling that the standard can be maintained without a specific control which the State may 

}·Ptopose to delete.

l.J«2) Assurance That Existing VOC, NOx and Transportation Control Measures Have Been Fully 

~i;;.,lmplemented

!t.:r;~i'. I:~ Technical Support Document, Volume 1, Tab 1.1 

The State certifies that, to the best of its knowledge, volatile organic compound (VOC) and oxides of 

_. nitrogen (NOx) sources covered by State RACT rules in the Salt Lake and Davis County nonattainment 

, 'trea have either installed and are operating RACT controls in compliance with state law or federal law, 

Section IX, Part D.2, page 6 

v 
or are on an enforceable compliance schedule. All of the programs which were implemented before 

and/or during the 1994 attainment year inventory such as Reid Vapor Pressure (RVP), basic inspection 

and maintenance (IIM), and the anti-tampering program are currently required for air quality purposes in 

the Salt Lake and Davis County nonattainment area. The basic UM program and the anti-tampering 

program were included in past attainment demonstrations for ozone SIP revisions. The State will assure 

that all of the programs implemented by the Ozone SIP, including the aforementioned control measures, 

will be maintained in future years in order to maintain the national ambient air quality standards. 

(3) VOC RACT Requirements and CTGs 

Technical Support Document, Volume 20, Tabs J.O, J.J, J.2, J.3, and J.4 

Section 182(b)(2) ofthe Act requires States to implement reasonably available control technology 

(RACT) with respect to each of the following: 

(A)	 Each Category of VOC sources in the area covered by a Control Technique 

Guidance (CTG) document issued by the Administrator between the date of the 

enactment of the Clean Air Act Amendments of 1990 and the date of attainment. 

(B)	 All VOC sources in the area covered by any CTG issued before the date of the 

enactment of the Clean Air Act Amendments of 1990. 

(C)	 All other major stationary sources of VOCs that are located in the area. 

The three RACT categories are addressed in sections (a), (b), and (c). 

(a) VOC Sources Covered by a CTG Issued after 1990 -Negative Declaration 

Technical Support Document, Volume 20, Tabs 2.J, 2.2, 2.3, and 2.4 

Section 183(a) of the Act states, "Within 3 years after the date of the enactment of the Clean Air Act 

Amendments of 1990 (November 15, 1993), the Administrator shall issue control techniques 

guidelines, in accordance with section 108, for 11 categories ofstationary sources ofVOC emissions 

for which such guidelines have not been issued as of such date of enactment, not including the 

categories referred to in paragraphs (3) and (4) of subsection (b)." A tentative list of the 11 such 

source categories was identified in the Federal Register (Vol. 57, No. 82, April 28, 1992, Proposed 

Rule) by the EPA. These categories are listed in Table 3. 

Section 183 of the Act also requires EPA by November of 1993 to issue CTGs for the following 

(also listed in Table 3): 

1) Reduction ofVOCs from aerospace coatings and solvents from shipbuilding operations 

and repair and; 

2) the completion of a study of VOC emissions from consumer/commercial products, and 

to then regulate those product categories. 

Section IX, Part D.2, page 7 
lough EPA was required to issue CTGs for these 13 categories by November 15, 1993, due to 

runding and time constraints only two ofthe CTGs have been issued, while the rest have been issued 

as final or proposed altemative control techniques (ACTs). ACTs may be used as guidance, but are 

not considered required controls under Section 182(b)(2) of the Act. Table 3 shows the current 

status of each of the CTGs, and identifies major VOC sources that may be affected by the CTG when 

it is issued. The two CTGs that have been issued are: 

1. CTG for Synthetic Organic Chemical Manufacturing Industry (SOCMI) 

Distillation, published 11/15/93 

2. CTG for SOCMI Reactor, published 11/15/93 

There are no affected SOCMI sources in the ozone nonattainment area; therefore the two CTGs that 

have been published since 1990 are not applicable in Utah. 

Table 3. VOC CTG Categories Required by the Act 

SOCMI Distillati0n CTG issued 11/15/93 ------+-­

SOCMI Reactors
 CTG issued 11/15/93 ~---

Wood Furniture Finishing ACT (proposed CTG and
 

proposed MA~~
 

Surface Coating of
 ACT No major source
 

Automotive!fransportation Plastic Parts
 

Surface Coating of Business Machine ACT No major source
 

Plastic Parts
 

--------r---------------t--------­

Offset Lithographic Printing
 Draft CTG, ACT, and proposed No major source 

MACT 

----------+---- ------------11 

Industrial Wastewater Draft CTG and proposed MACT No major source (refineries not 

and theHON included in draft CTQL _ 

Automobile Refinishing_ ACT No major source
 

Batch Processes
 CTG proposed No major source
 

Volatile Organic Liquid Storage in
 ACT Yes -Refineries
 

Floating and Fixed Roof Tanks
 

Industrial Cleaning Solvents __--+_A_C_T_a_n_d_M--=-:A.--CT -+...::.N..c.;o::....;::ID:=a"-.:jo::..::...r~...t!rce. _
 

Aerospace Manufacturing and Rework
 MACT Yes -Hill Air Force Base
 

Industry
 r----"------------------j---------------"f---------------1I 

Boat Manufacturin ACT and ro osed MACT Ne ative Declaration 

Commitment to Adopt Future CTGs 

__As each CTG is issued, the State will review the sources in the nonattainment area, and either issue 

negative declaration for that particular source category, meaning that there are no sources for 

Section IX, Part D.2, page 8 
which the CTG is applicable or revise its rules in a manner consistent with a SIP revision to 

incorporate RACT (in the context of Section 182(b)(l)(A) of the Act) for the following categories: 

1)	 those source categories of VOC for which EPA issues a CTG 

document during the time between the submittal of the 

redesignation request, and the time when the area is officially ) , redesignated to attainment in the Federal Register; and
 

iI 2) at any time thereafter as CTGs are published by the EPA.
 

i; 

__ J. . j	 In the event that the EPA should deviate from the CTG approach, the State will evaluate the situation 

on a case-by-case basis. For example, EPA may choose to issue a federal regulation instead of a 

CTG. In that case, if there are affected sources, the State will adopt rules which incorporate the 

federal regulation. 

(b) VOC Sources Covered by a CTG Issued before 1990 

Technical Support Document, Volume 20, Tabs 3.1 and 3.2 

During the development of the ozone SIP in Section IX.D.l, RACT was established for source 

categories based on CTGs that hau been issued by EPA. The source categories covered by the state's 

RACT rules and the corresponding Utah Administrative Code numbers are listed below. Copies of 

these EPA approved RACT rules are on file at the Division ofAirQuality. 'These categories address 

all CTGs issued prior to 1990, that are applicable to sources in the nonattainment area. Absence of 

a RACT rule for certain categories indicates that no sources in these categories have been identified 

in the Salt Lake and Davis County areas. ......

- • R307-32S-1:3 Nonattainment Area Requirements -Ozone (basic ... requirements for existing major and minor sources of 

VOC and NO.). 

•	 R307-327 Control of Emissions from Petroleum Liquid Storage 

(VOC storage tanks, reservoirs or containers). 

• R307-328 Control of Emissions from Gasoline Transfer and Storage 

(loading of tank trucks, trailers, railroad tank cars, and 

other transport vehicles). 

• R307-326 Control of Hydrocarbon Emissions in Refineries. 

I! 

I • R307-33S Control of Emissions 

Cleaning Operations. 

from Degreasing and Solvent 

• R307-341 Restrictions on Cutback Asphalt. 

,> 

• R307-340 Control ofVOC Emissions Associated with the Coating of 

Paper, Fabric, Vinyl, Metal Furniture, Large Appliances, 

Section IX, Part 0.2, page 9 
1. 

Magnet Wire, Flat Wood Paneling, Miscellaneous Metal 

Parts and Products, and Graphic Arts. . 

R307-14-8 Control of Emissions from Perchloroethylene Dry 

Cleaning Plants. 

• R307-325-4 Compliance Schedule (compliance date for affected 

sources). 

(c) Major Stationary Sources That Are Not Covered by a CTG 

Technical Support Document, Volume 20, Tabs 4.1, 4.1.1, 4.1.2, 4.1.3, 4.2, 4.2.1, 4.2.2, 

4.2.3,4.2.4; Volumes 21 and 22; Volume 23, Tabs 4.2.5,4.2.6; and Volume 2, Tab 2.2g 

Utah has established RACT for all major sources of VOC in Salt Lake and Davis Counties that are 

not covered by sections 182(b)(2)(A) and (B) above. The following major sources of VOC were 

identified in the Salt LakelDavis nonattainment area: 

AnJ.')co 

Ch~vron Refinery 

Crysen Refinery 

FlyingJ 

Hill Air Force Base 

Olympia Sales 

Phillips Refinery 

Because all of these major sources are also subject to pendingCTGs, EPA has suggested that section 

l82(b)(2) of the Act requires establishment of VOC RACT for these sources or source categories 

under subsection (A) instead of (C). The State addressed this by referencing both subsections (A) 

and (C) when establishing RACT. 

The State has established RACT on a case-by-case basis for each of the major sources. Existing 

rules, approval orders, and other applicable requirements were reviewed in conjunction with the 

ACTs or draft CTGs that have been issued by EPA to determine RACT for each source. The 

following factors were considered when determining RACT for an individual source: 

EPA was required to issued CTGs for 13 source categories by November 15, 1993, but has 

only finalized two of the CTGs. EPA has issued ACTs or draft CTGs for the other 

categories, but these documents have not gone through rulemaking, and could change 

significantly before the final CTG is issued. All major VOC sources in the nonattainment 

area will be affected by one or more of these pending CTGs. Because the CTGs are still 

pending, any RACT requirement that is now made by the State could be different than what 

will be required by the future CTG. Major sources could be subject to two different 

requirements within a short period of time, which could be expensive without providing a 

significant environmental benefit. 

Section IX, Part D.2, page 10 
2.	 Utah has adopted specific VOC RACT requirements for all source categories covered by 

final CTGs which apply to sources in Utah. These rules (R307-325, 326, 327, 328, 332, 

335, 340,341) are currently in effect, and have resulted in significant emission reductions 

from the five refineries and Hill Air Force Base. 

3.	 The existing VOC RACT requirements in R307-325, 326, 327, 328, 332, 335, 340, 341 

were a major factor in reaching attainment of the ozone standard in Salt Lake and Davis 

Counties. 

4.	 The Salt LakelDavis nonattainment area has not violated the Ozone standard since 1991. 

5.	 The definition of RACT in 40 CFR 51.100(0) says that the necessity of imposing controls 

in order to attain and maintain a national ambient air quality standard, the social, 

environmental and economic impact of such controls, and alternative means of providing 

for attainment and maintenance of the standard are to be taken into account in the 

establishment of RACT. 

6.	 The State is committed to adopt RACT rules for all sources (minor and major) that are 

affected by a finalized CTG. At the time the CTG is finalized and a presumptive nonn is 

established, the State will either issue a negative declaration or revise its rules in a manner 

consistent with a SIP revision to incorporate RACT that is at least as stringent as the 

presumptive nOrm outlined in the final CTG for the affected sources. 

7.	 The new source review rules in R307-401,405, 406, 410, 413, 414,155, 165,305,307, 403 

and R307-150-2 require all new or modified sources to obtain an approval order before 

beginning construction. When issuing the approval order, the State requires that the Best 

Available Control Technology (BACT) be applied to the new or modified source. BACT 

requires that the most effective engineering techniques and equipment be used to minimize 

emis<;ions into the environment. 

After considering the above factors, the State is establishing RACT, as required by Section 182 of 

the federal CAA, to be: 

(i) For Amoco, Chevron, Crysen, Flying J, and Phillips: The applicable R307-325:341 rules. 

(ii) For Hill Air Force Base: The specification and control requirements in the conditions which 

regulate VOC emissions in the Approval Orders (AOs) listed in Table 4: 

Table 4. Hill Air Force Base Approval Orders 

ACTIVITIES COyERED BYA1'PR~V.t\:)j,bRDERS

Medium Pressure Water & Chemical Paint Stripping of 

Aircraft 

"--C-S_etu--,,-p_C=-h_e_--,,-m=i~c_al=-M~i=-1I=in:£...g Process Lin_e C', 

E-163-96 Feb. 9, 1996 

E-I134_-9_5__-,--_D_e_c_.7-,,_1_9_9_5 

-
 Section IX, Part D.2, page II 
-


=
 -


@ 

E-860-95 Sept. 20, 1995 Phase II Vapor Recovery at Building 454 (letter) 

E-775-95 Aug. 30, 1995 Engine Test Facilities 

E-403-95 May 8,1995 Boilers 

E-067-95 Jan. 31, 1995 Painting Operations 

E-068-95 Jan. 30, 1995 Toxic Calculations 

E-824-94 Sept. 29, 1994 Used Oil BurnerlBoiler 

E-752-93 Aug. 27, 1993 Boilers, Carbon Brake Coating 

E-719-93 Aug. 20, 1993 Emergency Power Generators 

E-0103-93 Feb. 11, 1993 Aircraft Purge System 

E-1171-92 Jan. 4, 1993 Emergency Generators and Media Blast Booth 

E-416-92 April 28, 1992 Wastewater Treatment Plant 

E-167-92 Feb. 19, 1992 JP-4 Tank Throughput 

E-894-91 Nov. 25, 1991 Boilers 

E-039-91 Feb. 7, 1991 Dip Tank, Bake Oven 

E-669-88 Dec. 20, 1988 Paint Distillation Unit 

E-525-88 Oct. 13, 1988 Dip Tanks, Steam Cleaning Booth, Boiler, Bead Blast 

Unit 

E-353-88 July 21, 1988 Cold Solvent Cleaning Tanks 

E-026-88 Jan. 20, 1988 Solvent Spray Booth 

Feb. 20, 1986 Industrial Waste Treatment Plant Air Stripper 

Feb. 5, 1985 Hydrazine Incinerator 

July 18, 1983 Fuel Tank Vapor Recovery ----­ ------~

June 27, 1978 Fume Scrubber, Process Ovens, Melt Furnaces 

(iii) For Olympia Sales: The specifications and control requirements in the conditions which 

regulate VOC emissions in Approval Order E-0300-95 dated April 13, 1995. This Approval Order 

was based on BACT at the time it was issued. 

All known major sources ofVOC have been addressed through a case-by-case RACT determination, 

which ensured that VOC RACT was implemented as of May 15, 1995. In addition, R307-325-2 

covers the possibility that major sources ofVOC may exist in the nonattainment area that have not 

been identified. This "generic RACT rule" requires all existing major sources to apply RACT. If 

an existing source is identified in the future, the State shall make a RACT determination for the 

source, and shall submit the determination to the EPA for approval as a SIP revision. 

(d) Certification That All Known Sources Have Been Addressed 

The State certifies that it has adopted RACT rules, or has established a schedule and commitment 

for development of case-by-case RACT determinations, for all known stationary sources of VOC 

covered by Section 182(b)(2) of the Act in the Salt Lake and Davis County nonattainment area. The 

Section IX, Part D.2, page 12 
State also certifies that, upon completion of the 1990 Base Year Inventory and the 1994 Attainment 

Inventory, it is unaware of any major source of VOC which is not included in the above list of 

sources which are subject to a case-by-case RACT determination. 

If any additional existing major source is found by either the State or by the EPA in the future, the 

source will be required to apply RACTunderthe generic VOC RACTrule in R307-325-2. The State 

shall expeditiously develop a case-by-case RACT determination based on the existing CTG or as 

defined in 40 CPR 51.100(0) for such sources upon their discovery, and shall submit such 

determination to EPA for approval as an approval order or as a specific SIP revision. 

(e) New Sources ofVOC 

Technical Support Document, Volume 23,5.1 and 5.2 

Any new major or minor source permitted in the future shall be required to meet the Best Available 

Control Technology (BACT) requirements in R307-401.:.6, which will be at least as stringent as 

RACT. The BACT determination process accomplished by the Division of Air Quality will include 

an evaluation of published or pending CTGs and ACTs. The BACT determination will be at least 

as stringent as any published CTG. 

(4) NO. RACT Requirements 

Technical Support Document, Volume 1, Tabs 1.2.c, 1.2.d, and 1.2.e 

OL-' 

Section 182(f) of the Act requires that the SIP contain RACT rules for major sources of NO, as 

categorized in Section 182(b)(2)(A) and (C) of the Act. 'The following sections identify NOxRACT 

that was implemented to demonstrate attainment and maintenance of the ozone standard. On May 

2, 1997, Utah reqljested a partial NOxRACT exemption under 182(f)(2) of the Act because the area 

had attained the standard and further NOxreductions were not needed in the area. This request was 

approved by the EPA on July 17, 1997. 

(a) NO. RACT 

R307-325-2 has been amended to require that all existing major sources of NO, in the ozone 

nonattainment area (and Salt Lake and Davis Counties) utilize RACT. This is analogous to section 

182(b)(2)(C) of the Act and may be referred to as "generic" NOx RACT as it does not prescribe 

RACT to specific source categories. 

The EPA has already identified presumptive levels ofRACT for "certain utility boilers." A "utility 

boiler" is defined as any steam electric generating unit that is constructed for the purpose of 

supplying more than one-third ofits potential electric output capacity and more than 25 MW electric 

output to any utility power distribution system for sale. The State identified two sources in Salt 

Lake County that were potentially affected by this rule, the Gadsby Plant owned by PacifiCorp and 

the Utah Power Plant owned by Kennecott Utah Copper. 

Section IX, Part D.2, page 13 
1) The Gadsby Plant owned by PacifiCorp. This plant underwent a RACT determination 

in 1990 for the PMIO SIP and is now regulated under Section IX.H of the SIP. Under that 

determination the facility is prohibited from burning coal, the fuel for which each of the 

three units was primarily designed, and is required to meet limits for NO. which were based 

on the installation of low NO. burner technology. Subsequent to that RACT determination, 

the Gadsby plant identified itself, for the purposes of the Acid Rain program, as a gas fired 

utility. It could be construed from this declaration that this facility should be subject to the 

RACT levels identified for gas fired units; however, it is the State's position that this facility 

was designed as, and has been historically operated as, a coal fired unit. Were it not for the 

PMIO SIP, coal would still be the primary fuel burned at the facility. Thus, one viable means 

of compliance with the RACT levels for such coal fired units would be to switch fuels to 

natural gas, and to install low NO. burners. This has already been accomplished. After 

taking into account the different firing configurations (and therefore different levels of 

RACT) of the three units, the historic level of NO. while firing coal is estimated at 0.77 

lb/mmbtu, while the new federal levels of RACT for coal firing would require 0.48 

lb/mmbtu. Due to the RACT determination for PMIO, the facility is now operating at 0.28 

lb/mmbtu, whereas the new federal levels of RACT for gas firing would require 0.26 

lb/mmbtu. Because EPA has acknowledged the inherent variability in the levels of control 

that are attainable when retrofitting older units that were not designed with any level of NO. 

control in mind, and allows regional averaging amongst different facilities, an argument 

could be made that this facility has not only met the NO. RACT requirements for coal fired 

units, but for gas fired units as well. 

2) The Utah Power Plant owned and operated by Kennecott Utah Copper (KUC). This 

plant does not meet the definition of "utility boiler" because the plant has not sold any 

electricity since 1949. The State has, however, evaluated the facility under the provisions 

of the generic RACT rule which applies to any existing major source of NO.. In order to 

comply with the PM10 SIP, KUC has switched fuels from coal to natural ga,s in each of its 

four boilers during the wintertime PM10 season (November through FebruarY). Because coal 

is still burned throughout the remainder of the year, RACT was re-evaluated due to 

subsequent NO. RACT requirements in the Clean Air Act Amendments of 1990. Recent 

stack testing while burning coal shows that boiler no. 4 (an 83.3 MW tangentially fired unit) 

can operate within an emission limit equivalent to 0.45 lb NO. per mmbtu. This limit is 

identified by EPA in its NO. RACT Guidance (57 FR 55620) for tangentially fired coal 

burning "utility" boilers and EPA has historically prescribed less stringent NO. standards 

for industrial boilers than for electric utility boilers. KUC has informed the State that it is 

willing to accept an equivalent emission limit (in terms of 384 ppm and 377lblhr rather than 

0.45Ib/mmbtu) for boiler no. 4 in order to comply with the generic NO. RACT requirement. 

To evaluate what NO. RACT might be for boilers 1, 2 and 3 (398 mmbtulhr wall fired wet 

bottom boilers), KUC investigated various ways to reduce NO. emissions. These 

alternatives along with the respective conclusions that were reached are summarized below. 

a. Fuel Switching to low nitrogen coal - ruled out as either infeasible or ineffective 

Section IX, Part D.2, page 14 
b. Fuel Switching to natural gas - ruled out as not cost effective (on the order of 

$5,000/ton) 

c. Low-NO Burners - remained a distinct possibility x 

d. Overfire Air - rejected because lower flame temperatures would cause problems 

with slag tapping (remember that these are wet bottom boilers) 

e. Staged Air Combustion - infeasible because of the tight burner configuration and 

short residence time 

f. Gas Reburn - also found to be infeasible because of the tight burner 

configuration and short residence time 

g. Flue Gas Recirculation - rejected as infeasible because there is no practical place 

for flue gas recirculation to be introduced into these boilers 

h. Ammonia or Urea Injection - found to provide only marginally better NOx 

reduction than 10w-NOx burners, with similar capital costs, but significantly higher 

operating costs. This technique can also present operational difficulties in terms of 

furnace temperature sensitivity, and in addition may present potential safety 

hazards. 

i. NOx Scrubbing - may be technically feasible, but would provide no better NOx 

reduction than 10w-NOx burners at a much greater cost 

As identified above, 10w-NOx burners remained a distinct possibility. Preliminary estimates 

suggested that 426.5 ppm, and 216 lblhr (which is the equivalent of 0.50 lb NOx per 

mmbtu) was an'attainable and enforceable emission rate for each ofthese three boilers. This 

is also the rate identified by EPA as representative of RACT for dry bottom wall fired units 

in the case of electric utility boilers. Of note is the fact that EPA did not prescribe a level 

of NOx RACT for wet bottom "utility" boilers. Because these are wet bottom boilers KUC 

was somewhat skeptical about the possibility ofslag tapping problems, and proposed testing 

the performance of low NOx burners in one of the boilers on a trial basis before the State 

made a final RACT determination. 

The State accepted KUC's proposal. An approval order (AO) was issued on May 26, 1994 

that required installation of low NOx burners on all three boilers if the initial tests were 

successful. The AO established a NOx emission limitation of 216 lblhr and 426.5 ppmdv 

(measured at 3% oxygen) for each of the three boilers, effective after May 31,1995. The 

AO stated "If the 10w-NOx burners fail the initial trial, then the post-May 31,1995, NOx 

limit for Boilers #1, #2, and #3 must be re-evaluated and revised by a subsequent AO." 

KUC completed the installation of 10w-NOx burners in Boiler #3 in October 1994. Testing 

revealed that slag tapping was not possible until the burners were modified. Once modified, 

the burners performed acceptably during the limited period of testing time that was 

available. Preliminary results of the stack test performed on November 14, 1994 indicate 

Section IX, Part D.2, page 15 
that the burners, as modified, meet the emission limits in the approval order. KUC 

completed the installation of 10w-NOx burners in Boiler #2 in March 1995 and in Boiler #1 

in October 1995. 

Based on the successful results of the initial trial, the NOx emission limitation of 216 lblhr 

and 426.5 ppmdv (measured at 3% oxygen) is established as Reasonably Available Control 

Technology for Boilers #1, #2, and #3. The limitation is enforceable through the SIP and 

the approval order dated May 26, 1994, and was effective May 31, 1995, which is the 

deadline for implementation of NOx RACT in the Clean Air Act. 

Upon review of the infonnation listed in items 1 and 2 above, the State is hereby issuing as part of 

this SIP revision, a negative declaration, or a statement to the effect that RACT has already been 

applied to any facility qualifying as a utility boiler, within the meaning of the RACT detennination 

made by EPA for this source category. This detennination was perfonned on facilities located 

within the Salt Lake and Davis County nonattainment area. Ifsuch sources are found by either the 

State or by the EPA in the future, the State shall expeditiously develop specific RACT rules for such 

sources upon their discovery, and shall submit such rules to EPA for approval as specific SIP 

revisions. 

(b) Other NOx Control Strategies 

In addition to the revisions made to accommodate the NOx RACT requirements of section 182(£) of 

the Act as it applies to section 182(b)(2), the state has also implemented the following NOx 

strategies. These additional controls fulfill the requirement of the generic NO x RACT rule. --.

(i) Low Oxides of Nitrogen Burner Technology. 

R307-401-lOrequires sources to install low oxides of nitrogen burners or controls resultiJ)g from 

application of an equivalent technology, as detennined by the Executive Secretary, whenever 

existing fuel combustion burners are replaced, unless such replacement is not physically practical 

or cost effective. This requirement applies throughout the state, including Salt Lake and Davis 

Counties. 

(ii) PM10 SIP Requirements 

The existing PM10 SIP emission limit requirements for NOx are contained in Section IX, Part H, and 

are source specific limitations. These limitations affect sources of NOx in Salt Lake County and 

areas of Davis County which impact the Salt Lake nonattainment area. Application of RACT for 

the PM10 SIP addressed sources greater than or equal t040 TPY rather than the standard of l00TPY. 

Although within the context of PM10 it is pennissible to consider emissions of primary PMIO and its 

precursors (e.g. NOx or S02) on an equal basis for the purpose of obtaining emission offsets, this is 

an exception to the overall rule. Any major source or major modification requiring offset to attain 

or maintain the NAAQS for ozone will be required to secure such offset from the same pollutant for 

which there is a proposed increase. 

(5) Permitting of Existing, New, or Modified Sources 

Section IX, Part D.2, page 16 
R307-325, 326, 327, 328, 332, 335, 340, 341 specify state requirements for conducting 

preconstruction review of new sources and modifications to existing sources. It was included in 

.­ previous SIPs and, therefore, is incorporated by reference into this SIP revision. The rule requires 

all new or modified sources with a potential to emit any type of air pollutant to submit a Notice of 

Intent to construct and to obtain a permit from the State if necessary before construction of the 

source may begin. The pennit will require installation of best available control technology. 

Because the Salt Lake and Davis County area is currently designated nonattainment for ozone, the 

nonattainment area "new source review" provisions of the state's pennit rule are currently being 

enforced in addition to the general preconstruction requirements ofR307-325, 326, 327, 328, 332, 

335, 340, 341. These provisions require all new sources with a potential emission rate of 100 tons 

per year or more of VOC, and 100 tons per year or more of NO" and/or CO, as well as existing 

sources seeking modifications that will increase potential VOC, NO" and CO emissions, to adhere 

to all existing and future "new source review" sections contained within R307-403. Part C of Title 

1 of the Act, Prevention of Significant Deterioration, which is addressed in R307-405 will apply to 

the Salt Lake and Davis County areas after they have been redesignated to attainment rather than the 

nonattainment area "new source review" requirements. However, the State has already changed its 

rules to specify "Salt Lake and Davis Counties" as well as "ozone nonattainment areas" in specific 

sections of the "new source review" rules. Therefore, the Emissions Offset, Emission Statement, 

and VOC and NO, RACT rules will continue to apply in Salt Lake and Davis Counties after 

redesignation. Further, it should be noted that the existing NO, offset requirements in the PMIO 

nonattainment area, which includes Salt Lake County, apply to any new source or modification of 

greater than 25 tons/year. 

Utah has implemented a new operating pennit program that applies to all major sources in the state. 

A major source in a moderate ozone area or an attainment area is any source with the potential to 

emit 100 tons/yr of VOC, NO, or CO. The pennit program was submitted to EPA for approval, as 

required by Title V of the Act, in April of 1994 and received full approval effective July 10, 1995. 

.. The new operating permits will incorPoTateexisting applicable requirements, including· the' 

requirements of this Maintenance Plan, and will also contain monitoring, recordkeeping, and 

reporting requirements. The new permit program will impact this redesignation request by 

improving the State's existing permit program. 

(6) Recent Controls that Contributed to Attainment After the Ozone SIP was Adopted 

Technical Support Document, Volume 1, Tabs 1.3 and l.3.a 

The number of exceedances of the ozone standard dropped steadily between 1985 and 1991. This 

improvement in air quality is the result of the ozone SIP that was adopted in 1984, and additional 

federal emission control requirements. The ozone standard has not been violated since 1991. It is 

the position of the State, that Salt Lake and Davis Counties did not violate the ozone standard during 

these years due to a combination of new emission reductions resulting from 1) significant changes 

in the existing IJM program promulgated in 1991; 2) the clean-up of the Utah Air Conservation 

Rules pertaining to ozone nonattainment areas as required by the Phase I SIP call; and 3) the new 

federal Reid Vapor Pressure (RVP) regulations. 

Section IX, Part D.2, page 17 
(a) Emission Reductions due to 11M Revisions 

A major revision of Utah, Davis and Salt Lake County's IIM programs was fully implemented prior 

to September 1, 1991. Weber County implemented an almost identical IIM program in January of 

1992. The revision was made in response to a 1990 legislative mandate that IIM counties use 

computerized analyzers, standardize their programs, and provide for reciprocity. Major 

improvements include: the use ofBAR90technology emissions analyzers; the inclusion of vehicles 

owned by federal agencies, federal employees, and university and college employees and students 

into the program; an increased fail rate; the exclusive issuance of waivers by IIM technical center 

staff; a substantial increase in the dollar amount spent on emission-related repairs to qualify for a 

waiver ($100 for 1981 or older model cars, $200 for 1981 and newer models); automated data 

management and audit functions; and coverage of more emission control devices by the Salt Lake 

County anti-tampering program. As a result of separate legislation, the number of vehicles 

qualifying for exemption from the IIM program because of "farm truck" classification has been 

reduced. Substantial emission reductions have resulted from these IIM program revisions. A 

significant increase in enforcement efforts is believed to have brought about reductions in mobile 

vehicle emissions. The VOC and NOx reductions in Salt Lake and Davis Counties due to these 

revisions have contributed to attainment of the ozone National Ambient Air Quality Standard 

(NAAQS), but have not been quantified. 

In 1992, the emission reductions due to revisions in the basic IIM program in the two counties 

accounted for an additional emission reduction of 1.23 tons/day VOC and a negligible reduction of 

NOx when compared with the IIM program which existed during the 1990 base year. 

(b) Emission Reductions Due to the Revision of R307-14 

As stated in Section IX.D.2.a, to comply with Phase I of the May 1988 SIP call, numerous 

·deficiencies.~needer:Uo be, ,-,orrected and additional requirements addedtqthe Gx~~ting o~onerul.es

which ar~ included in R307-325:341. The rulemaking process began in1989 to~ these n~cessary

changes, and all rule changes were finally completed and officially submitted to EPA in July 1991. 

The ozone nonattainment rules became much more stringentfor controlling fugitive VOC emissions 

from: petroleum refineries; gasoline transfer, storage, and loading facilities; degreaser operations; 

and numerous surface coating operations. The most significant reductions in emissions resulted from 

the removal of an exemption from the monitoringlrepairing requirements of R307-326-7 for pipes, 

valves, pumps, and flanges smaller than 3/4" in diameter. The revised rules lead to improved 

enforcement procedures and source compliance determinations, and resulted in significant 

reductions in fugitive VOC emissions. The actual emission reductions obtained from revising the 

rules are difficult to quantify since they are fugitive emissions, the method of calculating reductions 

is specific to each refinery, and questions are raised as to when the actual reductions were obtained. 

However, the resulting reductions in VOC emissions from these rule changes are significant and 

contributed to attainment of the ozone standard. 

(c) Emission Reductions Due to Federal Restrictions on Gasoline Volatility 

Volatility of a liquid is a measure of its tendency to evaporate. Fuel volatility is most commonly 

measured in Reid Vapor Pressure (RVP), which is the pressure of the vapor in pounds per square 

inch (PSI) at 100 degrees F. The higher the RVP, the more emissions to the atmosphere of the fuel's 

Section IX, Part D.2, page 18 
components, including VOCs. Gasoline vapors escape into the ambient air during gasoline 

marketing, transfer, and vehicle refueling at service stations. Vapors also escape from gasoline 

storage facilities, service station tanks, and vehicle gas tanks. In addition to evaporative emissions 

from the gasoline marketing and distribution network, VOC emissions from vehicle tailpipe exhaust 

increase as gasoline volatility rises. 

In response to evidence that VOC emissions were increasing due to higher motor vehicle fuel 

volatility, EPA promulgated Phase I volatility standards effective in the summer of 1989. Phase I 

established a volatility limit of 9.5 psi RVP during the hottest summer months (July through August) 

for ozone nonattainment areas. During this period, the Salt Lake and Davis County nonattainment 

areas were well below the limit at 8.3 psi. Phase II volatility restrictions became effective in the 

summer of 1992 and lowered RVP even further to 7.8 psi in Salt Lake and Davis Counties. The 

Phase II volatility restrictions are factored into the MOBILE5A model, which is used to determine 

emission factors for the emission inventory, and are reflected in the '1994 emissions inventory. 

Since the RVP limitation was imposed by federal law, it is the federal government who insures that 

RVP is at 7.8 during the ozone season. The State has neither theequipment nor the personnel to 

perform RVP testing to assist the EPA with enforcement of this regulation; therefore, the State will 

rely upon the federal government enforcement of its own requirement to insure that no violations 

of the RVP limitation occur. 

(7) Rule Effectiveness Studies and Small Source Compliance Initiatives 

is Technical Support Document, Volume 1, Tab 1.4 

EPA has established a high national priority on conducting voe rule effectiveness studies and small 

source compliance initiatives in ozone nonattainment areas. In recognition of this federal priority, 

the State has undertaken a hileeffeetiv'erless stridyofR307-325:341 addressing tank truck tightness.. 

This study covered the efficiency of the leak tight testing program in the State of Utah, and the 

efficiency of the control equipment associated with the tank trucks. 

The State has established a Small Business Assistance Program (SBAP). This program helps the 

small business community in the State to better prepare themselves for future EPA regulations and 

subsequent rules which the State will implement to enforce those federal regulations. The SBAP 

assists small businesses to begin the process of coming into compliance with those rules in the 

future. In recognition of other federal priorities, the State will undertake other activities in 

cooperation with EPA and local air pollution control agencies as state and local resources allow. 

Particular attention will be paid to the autobody industry, as well as degreasing, chromium 

electroplating, and small surface coating operations to determine compliance rates and rule 

effectiveness. 

Section IX, Part D.2, page 19 
·D.2.d VERIFICATION OF AIR QUALITY IMPROVEME~J.JtlJilllll"""""

Statio ea, and mobile source emlS must be examinedfor evidence 

of eco own-tum that may have contributed to aUal i appropriate, the 

must assure that recovery from the down-tum will not jeo continued 

maintenance ofthe standard. 

(1) Demonstration that Air Quality Improvements are Permanent and Enforceable 

(a) Enforceable Emission Reductions 

The improvement in air quality already achieved in Salt Lake and Davis Counties has resulted from 

implementation of the emission controls listed below. Because these controls have been either 

federally approved or are pending federal approval, the resulting VOC and NOx emission reductions 

are federally enforceable. This plan includes a state commitment to continue to enforce all 

applicable requirements of past revisions to the State Implementation Plan, even after the Salt Lake 

and Davis County areas are redesignated to attainment. This commitment, detailed in Section 

IX.D.2.b, makes permanent the emission reductions achieved from these requirements. The 

emission impacts of the controls listed below have been accounted for in completing the VOC and 

NOx emission inventories for these maintenance provisions to the SIP. 

. 1') . ExistingRACT controls on stationary sources covered by CT(js in categories I, II, 

and III, as well as RACT controls on existing major non-CfGsources of vves. 

2) The Federal Motor Vehicle Emission Control Program. 

3) The Federal Gasoline Volatility Control Program (Phase II). 

4) Basic lIM Program with improvements. 

A continued improvement to air quality through the year 2007 for Salt Lake and Davis Counties will 

result from the following emission controls which have been promulgated, or may be implemented 

as a result of the requirements of the 1990 Clean Air Act Amendments. These control requirements 

will produce VOC and NOx emission reductions that are pennanent and federally enforceable. 

1)	 Continuation of the Federal Motor Vehicle Emission Control Program, and 

particularly the implementation of the Tier II controls. The Federally enforced 

program limits emissions from new motor vehicles manufactured or approved for 

sale in the United States. 

2) Continuing enforcement ofexistingR307-325 :341 rules covering VOCcontrols and 

basic lIM with improvements. 

3) New requirements covering New Source Review, NO, RACT, VOC RACT, and 

Emission Offsets. 

4) Requirements for sources covered in the Emission Statement. 

Section IX, Part D.2, page 25 
5) The development and implementation of new Control Technology Guidance 

(CTGs) and Maximum Available Control Technology (MACT) required by Title 

III of the Clean Air Act Amendments. 

6) Implementation of improvements to the IIM programs in Salt Lake and Davis 

Counties. 

Items 1 through 5 above have been implemented in the Salt Lake and Davis County areas and are 

discussed in greater detail in Section IX.D.2.b. Item 6 is discussed in more detail in Section 

IX.D.2.g. of this maintenance plan. 

ga 

t, it becomes 

o permanently 

ear meteorological 

lar intensity (equated 

ather Service records compiled 

ational Airport, which is centrally 

ares the average high temperature, 

e number of measured exceedances for' 

- September) for the years 1985 through 

and August for each year, since typically the 

ng t e two months. Ozone exceedance values 

ake and is Counties. 

90° does not show acein meteorological patterns at 

began to show attainment the ozone standard in 1992. 

e and after 1992. 90° F was sele' based on a temperature 

son at the Salt Lake City station for 1 through 1992. Wind 

rm variability throughout the same period. 

chnical Support Document, Volume 2, Tab 2.4 

Meteorology and Ambient Concentration 

f the Salt LakelDavis County ozone nonattainment area to att 

important to sho hat reductions in ambient ozone concentrations are 

enforceable emission uctions, and not to reductions resulting from ye 

variations. Ozone photo ical reactions are forced primarily by str 

to high temperature), and sta wind conditions. 

The numbers contained in Table 6 

from data collected from 1985 through 5 at the Salt Lake 

located inside the nonattainment bounda . Table 6 

number of days above 90° F, the average win 

each month for the Utah ozone monitoring seas 

1995. Meteorological numbers were averaged 

highest measured ozone concentrations occu 

were measured at monitoring sites within 

A comparison of the number of days 

the time Salt Lake and Davis Co 

There were hot and cold years 

versus ozone exceedance co 

speed also exhibits fairly 

An attempt was m 

make further co 

(during the pe 

hadmeasu 

Graphs 

sign 

te 

use a larger data base for both exceedance and non-exce ance days to 

sons between the years. This comparison was based on 15 exce ance days 

985 through 1988) and 9 non-exceedance days from 1989 (non excee e days 

3 concentrations between 0.090 and 0.120 ppm), but was limited to temperatur nly. 

d in the Technical Support Document suggest that the 1989 ozone season was t 

tly different from the 1986 and 1988 seasons. The graphs show that the average 198 

ature was well within ± 1 standard deviation from the mean 1986, 1988 temperature. The 

again suggests that meteorological variables did not significantly influence the reduction of 

ambient ozone concentrations in Salt Lake and Davis Counties. 

Section IX, Part D.2, page 26 
IX.D.2.e. ATTAINMENT EMISSION INVENTORY -1994 

yirements relating to Attainment Emission Inventory: 

The state can choose to demonstrate mainte 'ce ofthe NAAQS using an emissions . ""', mven approach. This approach requires t _ evelopment ofan "attainment emission 

inventory identify the level of emissio rh the area which is sufficient to attain and 

maintain the s 

The 1994 attainment e '. tons inventory was prep .using the methodology that had been used 

for the 1990 base ye . Inventory. The 1990 base year 1 tory has been submitted to EPA, and 

approval is still. ,nding. The 1990 base year inventory is' orated by reference into this 

maintenance 

The e' s'ions inventory is divided into three major sections: point sources, ources, and 

mo " 'sources. A discussion of each of these three sections follows. Summary tab owing 

,Cand NO. peak ozone season daily emissions in tons/day for Davis and Salt Lake Counties, are 

included as Table 7. 

(1) Point Source Emissions Inventory 

Technical Support Document, Volumes 8,9, 10, and 11 

Point source estimates of VOC and NO. emissions were based on questionnaires sent to :)art 70 

sources and sources permitted for more than 10 ton/yr of VOC within the Salt Lake City/Ogden 

Metropolitan Statistical Area (MSA). In accordance with EPA guidance on rate of progress 

inventories and projection inventories, stationary sources within the 25 mile boundary surrounding 

the MSA were not included in the 1994 attainment year inventory for purposes of redesignation. 

As part of the 1994 inventory submittal, VOC sources within the nonattainment area were required 

to fulfill the emission statement requirements as listed in R307-158. This included ozone season 

(June 1 - August 31) activity levels and operating schedules. This information was used to calculate 

ozone season daily emissions of VOC and NOx' An example of such calculations can be found in 

the 1994 attainment emission inventory TSD. If specific seasonal activity was not available, the 

method shown on page 27 of the Inventory Preparation Plan was used. This method involves 

converting annual emission rates to a daily rate by using a source's operating schedule. 

The sources included in the point source portion of the attainment year (1994) inventory include all 

stationary sources with actual emissions of 10 ton/year or more ofVOC, and/or 100 ton/year or more 

of NO.. Stationary sources with 1994 actual emissions less than 10 ton/year of VOC or less than 

100 ton/year of NO. were considered a part of the area source portion of the inventory for Salt Lake 

and Davis Counties, The mobile-source emissions, such as haul trucks and bulldozers, that were 

Section IX, Part D,2, page 29 
reported by industries in their emission inventories are included in the non-road section of the 1994 

emission inventory. The 1994 emissions inventory for stationary sources, with the exception of the 

Salt Lake City International Airport, are based on actual activity levels and reflect actual estimated 

emissions. 

The 1994 point source emission estimates reflect control measures that are already implemented. 

In accordance with EPA guidance, 1994 attainment year emissions were adjusted to incorporate an 

80 percent rule effectiveness assumption wherever applicable, for point sources controlled under 

state VOC and NO. rules. Rule effectiveness is a measure of the ability of the regulatory program 

to achieve all of the emission reductions possible by full compliance with applicable rules at all 

covered sources, at all times. It reflects the assumption that rules are not typically 100 percent 

effective at all times. The State will conduct rule effectiveness studies to verify the compliance rate 

in Utah for various rules as resources allow and will change the emissions inventory to reflect the 

results of those studies. 

ventory estimates VOC and NO. emissions by county. This inventory incl ources 

whose emissions any single source location are 10 TPY or less for VOC and 100 TP ess for NO•. 

The area source inv was examined for double-counting of emissions alread' uded in the state's 

point source inventory ~usted accordingly. All emission estimates in th a source inventory were 

reported in tons per peak oz eason day to reflect conditions most typic igher ozone concentrations. 

issions from on-road 

igned for travel on 

onn of tailpipe 

nning and 

'buted 

tionary sources such as g me stations and degreasing operations 

rules. In compI" e with EPA guidance, emission estimates 

e adjusted t ect a rule effectiveness factor of 80%. In the 

th ate which covered gasoline transport vehicles, a 

m motor vehicle tailpipe emissions and refueling are 

s from vehicle refueling are included in the area 

ocument, Volume 6, Tabs 3 through 3.2.3 

Area source emissions include sm 

that are controlled through VOC re 

for area sources covered by existing rule 

Mobile sources aivided into two categories: on-road and non-road soure 

case of the rule effectiveness study comple 

factor of 95% was used. VOC and NO. emissi 

included in the mobile source inventory. VO 

source emissions inventory. 

(3) 

mobile sourc ncIude all VOC and NO. from automobiles, trucks, and motorcyc 

establish ederal, state, or local roads. Calculated emissions from these vehicles are 1 

exha , evaporation from the engine and fuel systems, and any other vapor losses durin 

resti .g of the vehicles. Vapor losses from fuel tanks, after filling the tank at a refueling station, 

to this category. 

chnical Support Document, Volume 5, Tabs 2 through 2.13.5 

The area sour .. ' 

Section IX, Part D.2, page 30 
IXoDo2or FUTURE AIR QUALITY PROJECTIONS 

rojected Emission Inventory, 1994 - 2007 

elating to Projected Inventories: 

Pro ion inventories must be completed that show the acan be maintained in the 

future (i. e. fo r ten s after redesignation), especially no . erfuture increases in VOC and 

NOA emissions are expe nd can be accommoda ut additional controls, or whether new 

controls need to be implemente ce ofthe standard. 

... no.... ....D.2.e documents a level of emissions in 

the Salt Lake/ Davis County area w . sufficient to mal . the NAAQS for ozone. Emissions 

projections for each source cate used to detennine if expecte .on levels in future years will 

exceed the 1994 attainment n inventory level. Maintenance of the S is demonstrated if the 

projected emissions re ow the 1994 level. 

sions inventory is divided into three major sections: point sources, area 

A discussion of how emissions were projected for each of these three sections s. 

rough 5 graphically demonstrate that the emission inventory remains below the 1994 level 

the year 2007. Summary tables, showing VOC and NOx peak ozone season daily emissions in 

tons/day, are included in the TSD. 

(a) Point Sources 

Technical Suppon Document, Volume 16, Tabs 7 through 7.2 

EPA guidance establishes accepted methods ofprojecting emissions from point sources. EPA-4521R93-002, 

"Guidance for Growth Factors, Projections, and Control Strategiesfor the 15 PercentRate-of-Progress Plan", 

outlines criteria for the use of actual and allowable emissions in projected inventories. Actual emissions 

from a source are the emissions reported based on actual operating hours, production rates, and control 

equipment for the processes carried out at the source. The 1994 attainment emissions inventory is based on 

actual emissions. Allowable emissions are based on the regulatory element ofthe source's operating permit, 

or Approval Order, which represents a regulatory limit on emissions from the source. 

When allowable emissions are used in projection inventories, the guidance document cited above 

recommends that an allowable emission limit be calculated for the source based on the regulatory emission 

limit multiplied by an expected level of activity. It is important to note that allowable projections are not 

fully allowable emissions; i.e., allowable emissions are the allowable emissions limit multiplied by the 

maximum theoretical activity level. 

The use of actual emissions is limited to certain circumstances. For sources or source categories that are 

currently subject to Approval Order regulation and the State does not anticipate subjecting the source(s) to 

additional regulation (i.e., a new or modified Approval Order is not pending), the projected emissions may 

be based on actual emissions. Actual emissions may also be used for sources or source categories which are 

unregulated and for which no future regulation is anticipated. For sources that are expected to be subject 

Section IX, Part D.2, page 35 
.

•
 

to new regulation or a new Approval Order, the projections are to be made using allowable emission limits 

based on the new allowable emissions. 

Both actual and allowable emissions have been used in this Maintenance Plan's projected inventories. The 

activities at major point sources were evaluated to detennine whether actual or allowable emissions, or some 

combination of the two, should be used. Evidence of those evaluations is provided in the TSD in the fonn 

of letters submitted to the State by sources which note that a meeting was held in which the EPA guidance 

was reviewed and future plans ofthe source were discussed. The result ofthose evaluations and a summary 

of emissions selected for use in projections is contained in the TSD. 

Employment growth factors from the State of Utah Economic & Demographic Projections 1994 are used 

to project point source emissions. The growth factors begin in 1995 and are incorporated into the projected 

emissions until a source is predicted to reach 100% of its NO, allowable limit, if a limit exists. Once the 

limit is reached, emissions are projected to remain flat. VOC projected emissions change in proportion with 

NO, projected emissions. Kennecott Utah Copper is an exception, because NO, emissions are affected by 

new NO, RACT requirements that do not affect the other pollutants. In this case, NO, projections decrease, 

while VOC increases. 

The projected VOC and NO. emissions are demonstrated to remain below the 1994 attainment year 

emissions level. The accuracy of these projections is reinforced by the maintenance of existing rules (R307­

325:341) which continue to apply to sources in Salt Lake and Davis Counties and regulate the operational 

practices of VOC sources. The NSR and Offset rules which cover any new sources or modifications to· 

existing sources also reinforce emission projection accuracy. 

The 1994 attainment year and projection year VOC and NO, daily emissions for individual point sources are 

summarized in the TSD. The point source attainment year inventory contains a listing of emissions by 

individual sources that compose each plant's actual emissions. 

ical Support Document, Volume 14, tabs 5 through 5.12 

Growth factors for ..... ating projection year emissions were bas population and sector-specific 

employment growth de '. from the Office of Planning udget's State of Utah Economic & 

Demographic Projections 1 . confonnance with E Idance on preparing area source inventories 

for ozone planning. 

(c) Mobile Sources 

(i) 

ojected emissions were generated by combining VOC and x • ion factors with 

estima~ S summer weekday vehicle miles of travel (VMT) within Salt Lake and Davis . s. The peak 

ozone day emissions are aggregated by county for each pollutant. The details of how the emissl 

for the on-road mobile source inventory were calculated are in the Technical Support Document. 

Section IX, Part D.2, page 36 
IX.D.2.h. CONTINGENCY MEASURES 

Requirement Relating to Contingency Measures: 

Section 175A ofthe Act requires that areas seeking redesignationfrom nonattainment to 

attainment develop contingency measures that include state commitments to implement 

additional control measures in response to future violations ofthe NAAQS. 

(1) Purpose of Contingency Planning 

Section 175A of the Act requires that maintenance plans include VOC and NO. control measures 

necessary to assure prompt action to correct any violation of the standard which occurs after the area is 

redesignated to attainment. The maintenance plan is to include a state commitment to implement 

additional VOC and/or NO. control measures which were contained in the SIP for the area before 

redesignation to attainment. For attainment areas, additional controls are to be implemented in response 

to ozone violations, and/or increases in VOC or NO. emissions that threaten the standard after an area is 

redesignated to attainment. The purpose of these controls in attainment areas is to achieve sufficient 

VOC and/or NO. emission reductions to eliminate further ozone violations. Implementing controls in 

response to ozone violations in attainment areas can occur without federal redesignation of the area to 

nonattainment. It should also be noted that the pollutant of concern is ozone, for which VOCs and 

oxides of nitrogen are precursors. 

The State collected information based on discussions and information from industry, metropolitan 

planning organizations, EPA and other states regarding the magnitude of VOC and NO. emission 

reductions from various control strategies. The eff~ctiveness and viability of possible control measures 

were compared. Some controls interact with other controls thereby decreasing the overall effectiveness. 

Estimates of the emission reductions expected from implementation of mobile source measures have 

. been obtained from MOBILE5A estimates where applicable. The major considerations that went into 

choosing the following control strategies were: 

ecost effectiveness;
 

eeasily realized reductions with minimal lead in time, and;
 

eoverall benefit of controls.
 

2) Determination of Contingency Action Level 

On July 18, 1 Environmental Protection Agency replaced the one-hour ozone standard, which is 

the basis of this plan, WI i ht-hour s~t~an~d;a~rd~a;ta~le~v~e~IJo;fjO~.O~8~pa:rt~s~p::er~m~illll~iolllo.;;J...'ftII~e~,il"99'98 the one-hour standard was officla Ok~d in all counties in 

The contingency action level w· ger be auto triggered by a violation of the one-hour 

ozone standard bec standard has been revoked in Uta . emoval of the automatic trigger for 

continge easures is consistent with EPA guidance entitled "Guidanc lementing the I-Hour 

o and Pre-Existing PMIO NAAQS", signed by Richard D. Wilson, Acting ASSJ:IS:;m""IMI_~IiilIW~

for Air and Radiation on December 29, 1997. 

Section IX, Part D.2, page 49 
· the intent of the Board to periodically review the ambient monitoring data, emission inv 

grow ·ons, and other relevant data to determine whether the con· es 10 this plan 

should be implem	 . the n s andard. This determination by 

the Board shall be consi	 ac 10 that the Board determines that one 

or rno cy measures should be implemented shall be consi	 gency n ate 

or at contingency measure. 

(3) Contingency Measures 

(a) Offset Ratio for VOC and NOx 

R307-403-6 contains more stringent offset requirements for VOC and NOx that would be triggered as a 

contingency measure. The offset requirements will become effective the day after the contingency 

trigger date. The emission threshold for applicability to VOC and NOx offset requirements is lowered 

from 100 tons to 50 tons. In addition, the offset ratio is increased from 1.15:1 to 1.2:1 to require 

increased reductions of VOC and NO in Salt Lake and Davis Counties. The more stringent emission x 

threshold and offset ratio were both selected on the basis that these are the parameters that apply to 

"serious" nonattainment areas; "serious" being the next category up the level of hierarchy specified by 

the Clean Air Act, Section 182. The Salt LakelDavis County nonattainment area for ozone is presently 

classified as a "moderate" area. 

Specific costs for implementation of this contingency measure must be determined on a case-by-case 

basis and could not be easily estimated, but it is assumed that any costs incurred by industry will be 

passed on to the consumer. 

(b) Stage II Vapor Recovery 

Technical Suppon Document. Volume 19, Tab 19.3 

The Air Quality Board has adopted R307-332, "Stage II Vapor Recovery Systems," which would require 

installation of Stage II vapor recovery systems in Davis and Salt Lake Counties if Stage II is triggered as 

a contingency measure. The schedule for implementation of Stage II after the contingency has been 

triggered is contained in R307-332. The following condition applies to this contingency measure: 

Pressure Test Exemption. If, for each county in the nonattainment area, the authorized body required 

under federal law to utilize an IIM program has established a gas cap pressure test program, the State 

may delay implementation of Stage II as a contingency measure. To qualify for this exemption: 

1)	 The gas cap pressure test program must have been legally adopted and implemented 

before the contingency trigger date. 

2)	 The gas cap pressure test program must have been in place for less than a year. 

If the counties in the nonattainment area qualify for this exemption, the gas cap pressure test program 

may be substituted for Stage II Vapor Recovery as the required contingency measure. If the action level 

identified in Section IX.D.2.h(2) is exceeded after the gas cap pressure test program has been in place for 

a year, Stage II must also be implemented as a contingency measure. 

Section IX, Part D.2, page 50 
Stage II vapor recovery was chosen as a contingency measure for the following reasons: 

I)	 VOC emission reductions can be achieved expeditiously. After the rules are 

implemented, the high volume stations will be required to install controls before the next 

ozone season. The remaining affected stations would be phased in over the following 

two years. 

2)	 Significant VOC emissions reductions due to implementation of Stage II have been 

estimated from MOBILE5A runs. The documentation is contained in the Technical 

Support Document. 

3)	 EPA has documented that Stage II is a cost-effective strategy for controlling VOC 

emissions. 

4)	 There is an extra health benefit from implementing Stage II controls, in that it will also 

significantly reduce exposure to benzene, a component of gasoline and a known human 

carcinogen, 

(c) More Stringent Low-NOx Burner Controls 

R307-401-1O contains more comprehensive low NOx burner requirements which would be implemented 

as contingency measures. The existing rule, which requires all new or replacement burners to meet low 

NOx burner emission levels, would be expanded to include all existing sources in Salt Lake and Davis 

Counties. Within 2 months of the contingency trigger date, existing sources that have not installed low 

NOx burners would be required to submit a schedule either for replacement of their burners, or for 

controls resulting from application of an equivalent technology. A source may request an exemption if 

replacement of the existing burner is not physically practical or cost effective. The required equipmem 

shall be operational as soon as practicable or within a reasonable time frame agreed upon between the 

source and the Executive Secretary. 

Section IX, Part D.2, page 51 
IX.D.2.i. OTHER CONTROL MEASURES 

Technical Support Document, Volume 19, Tab 19.5 

(1) Employer-based Trip Reduction (ETR) Programs 

The goal of the Employer-Based Trip Reduction (ETR) Program is to introduce and implement strategies 

designed to reduce the amount of measurable miles driven by employees commuting to and from work. 

The desired result would be a heightened awareness ofthe direct relationship between driving and air 

pollution, and a reduction in the amount of vehicle-related pollution in Salt Lake and Davis Counties. 

R307-320, the Employer-based Trip Reduction Program is applicable for federal, state, and local 

government agencies with 100 or more employees at a work site. The rule may be extended to include 

all employers with 100 or more employees at a work site if it is determined necessary to maintain the 

national ambient air quality standard for ozone. The Trip Reduction Program which includes 

government agencies in Salt Lake and Davis Counties was implemented in 1995. For the first year of the 

program, 13 of 26 government agencies submitting trip reduction plans exceeded the first-year target. 

Wasatch Front Regional Council prepared estimates of emission reductions that could be obtained by the 

years 2005 and 2015 if Trip Reduction Programs were implemented. See Table 12. 

The State recognizes that emission reductions will be achieved through the Trip Reduction Program, but 

these reductions have not been included in the projected emission inventory, and credit for these 

reductions has not been included in this maintenance plan. 

The Trip Reduction Program will require a 20% decrease in the drive alone rate. Strategies include: 

. . 

a. MaSs Transit 

(1) Subsidized Bus Passes 

(2) Worker ServicelExpress Bus 

(3) Regular Bus Service 

b. Vanpool/Carpool Programs 

(1) No-Interest Vanpool Program 

(2) Vanpool Leasing Program 

(3) State Motor Pool Vanpool (for state employees) 

(4) Ridesharing 

(5) Match Lists 

c. Telecommuting 

d. Compressed Work WeekIFlexible Work Schedule
 

e.Work Site Parking FeesfPreferential Parking
 

f. Transportation for Business-Related Activities 

g. On-Site Facility Improvements 

h. BicyclinglWalking 

Section IX, Part D.2, page 52 
Table 12. Emissions Reductions from a 20% Reduction in the Drive-Alone Rate 

Work Trip Vehicle Miles SummerNOx SummerVOC

Trips Length Eliminated Eliminated Eliminated 

Eliminated (miles) (tons/wkday) (tons/wkday) 

Salt Lake County 

2005 74,000 9.5 703,000 1.34 1.33 

2015 146,000 9.5 1,387,000 2.63 2.62 

South Davis County 

2005 6,500 9.5 61,750 0.11 0.09 

2015 8,000 9.5 76,000 0.14 0.11 

Section IX, Part D.2, page 53 
IX.D.2.j MEASURES TO VERIFY CONTINUED OZONE MAINTENANCE 

Requirement Relating to Verification o/Continued Maintenance: 

The maintenance plan must indicate how the state will track the progress and the 

Maintenance Plan. 

(1) Tracking System for Verification of Emission Inventory 

Continued maintenance of the ozone standard in Salt Lake and Davis Counties depends in large measure 

upon the ability of the state to track VOC and NO. emissions in future years. Consequently, the State 

will perform the following to verify maintenance: 

(a)	 As required by the Act, the State will submit NO. and VOC emission inventories to EPA 

for Salt Lake and Davis Counties every three years, beginning with the inventory for 

1996. As required by the Act, the 1996 inventory will be submitted to EPA by 

November 15, 1998, and later inventories will be submitted on a three-year schedule 

from this date. These inventories will follow the same procedures used to develop the 

1994 attainment emission inventory, by applying the Inventory Preparation Plan and 

Quality Assurance Checklist. The emission inventories will be based on the most 

current VMT data, actual point source emissions, and area source emissions founded on 

the most current population and industry growth information. This submittal will also 

include summary tables and graphs of VOC and NO. comparing projected emissions 

with actual emissions. 

(b)	 The State will develop an emissions inventory for point sources in the nonattainment 

arer, as established in R307-150 Criteria Pollutant Inventory, and R307-~58 Emi:;sioD 

Statement Inventory. 

(c)	 Projects will be coordinated between the Small Business Assistance Program, the Toxics 

Program, and the Planning Branch to obtain more accurate information on area sources, 

and to update the emission inventories to reflect the most recent emissions obtained from 

these sources. An example of this would be results obtained from auto body painting 

workshops and inventories. 

(d)	 The State will coordinate the efforts of the Operating Permit Program with the Planning 

Branch. Inspectors and emission inventory personnel will monitor sources to verify all 

major point source emissions, as well as a percentage of area source emissions reported 

in the emission inventory and/or/their operating permits. 

(e)	 Projects will be coordinated between the Engineering Branch and the Planning Branch. 

By using the comprehensive engineering tracking system, the Planning Branch will be 

informed of all NOI's that have been submitted, new sources that receive approval 

orders, and sources that fall below the de minimis limit for approval orders. This 

tracking system will reveal estimated emissions, modifications, etc. that should be 

tracked and reflected in the emission inventory for Salt Lake and Davis Counties. 

Section IX, Part D.2, page 54 
(2) Annual Review of the Ozone Monitoring Network 

The State will continue to evaluate the ambient ozone monitoring network to ensure that the network 

meets all applicable federal regulations and guidelines. The results of this evaluation will be submitted 

to EPA by October 1st of each year in the annual Network Review. 

(3) Provisions for Revising the Maintenance Plan 

The State will revise the Plan as necessary in response to revisions of the national primary ambient ozone 

standard, or to take advantage of improved or more expeditious methods of maintaining the standard. 

The State will also revise the Plan as necessary to complY with any future EPA finding that the Plan is 

inadequate to attain or maintain the national ambient ozone standard, or every eight years in compliance 

~ith Section 175A of the Act. 

(4) Provision for Prohibiting Emissions That Interfere With Attainment In Other States 

The State will take steps as necessary to prohibit emissions within the state that have been shown to 

interfere with attainment or maintenance of a NAAQS in another state. 

Section IX, Part D.2, page 55