vapors a isplaced from the underground storage tanks during filling and when gasoline is vehicle tan Regulations now require control during the transfer offuel 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 of7,580 liters (2,000 g ons) or more is r:equired to h erthan 90% of the stems control emissions ck. ine dispensing facility with a installed: The properuse ofsimple balance systems will control om the filling ofunderground 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 inefficientcollection and that there are no leaks in the system. Frequent visual inspections are re to insure proper operation ofmanifolding 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 ofhydrocarbon emissions along the Wasatch Front. Specifically the following areas were reviewed: Control ofvolatile organic emissions (VOC) from (1) Surface coating oflarge appliances, (2) Surface coating for insulation ofmagnet wire, (3) Surface coating ofmetal furniture, and (4) Surface coating ofcans, 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 ofVolatile Organic Compounds from the Use ofCutback Asphalt: Since 1973-74 the Statehas adopted a policy to eliminate as much as possible the use ofcutback 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 ofemulsions do not give satisfactory results and cutback must be employed, primarily during the winter months. The following is a summary ofthe past and projected use ofcutback 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 ofproper operating practices and efficient control equipment, which include but are not limited to: 1) Covering degreasing equipment wheneverpossible

. 2) Proper use ofsolvent sprays. 3) Various means ofreducing the amount ofsolvent carried out ofthe degreaser on cleaned work. 4) Prompt repair ofleaking equipment. 5) Proper disposal ofwastes 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 ofVolatile Organic Emissions from Solvent Metal Cleaning". Conveyorized degreasers smaller than 2.0 m 2 (approx. 21.5 fe) ofair/vapor interface would be exempted from the requirements ofa major control device and open top vapor degreasers smallerthan I m2 (approx. 10.8 fe) ofopen area would be exempted from the application ofrefrigerated chillers (or carbon absorbers). Effective disposal ofwaste 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 ofreducing emissions by at least 90% on their dryer exhausts

.

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

including: Papercoating Fabric and Vinyl coating

Section IX, Part D.l, page 12

# -- Demonstration ofAttainment arid Reasonable FurtherProgress emonstration ofattainmentbased oJi data gathered during 1981 is made based on the hip because it is the onlyyear with adequate ambient hydrocarbon data and the ozone data. The demonstration ofattainment based on the EKMA proc t ozone data collected at SaltLake 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 There ions**iIDplementin.gJh~s** section**oft~~§IP** are containe 5, 340, and 341.eemissions inventory-shows that these sources are only mmo**hy.drc)Cflrb(nn~lss;S:sions**inventory (see Figure IX.D.8). "

ith

## the uses the last " ..... :.:. C­**~(~'~?;**

### ;<~ associated with high hydrocarbon.rea cantreductions ofhydrocarbons i vehicle mile' emission facto 'V 

# A;·,' ,"','

. "!ifuopitored in the urban core of ea 

### are attributable to the gradual result ofthe 

### 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%. 1 1 igure 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.I0, which shows attainment ofthe 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 andRegulations: The State must assure that control measures required inpast Ozone SIP revisions have been implemented and that existing reasonably available control technology (RACT) controls will remain in effectafter redesignation, unless it has demonstrated to EPA's satisfaction through photochemical dispersion modeling, not including EKMA, that the standard can be maintained without one ormore controls. Areas that were required to implement transportation control measures andlor inspection/maintenanceprograms mustprovide evidence that theseprograms have beenfully 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 RACTrequirementsfor all majornon-CTCsources. The State must confirm that all affected

## vac, andNOx sources have either installedorare operating RACTcontrols. T,he State mustassure thatacceptableprovisions exist andare being implemented to providefor new source review. The State mustdemonstrate completion ofrule effectiveness studies andsmall source compliance initiatives, as resources allow.
(1) 

### Enforcement ofExisting Ozone State Implementation Plan Technical SupportDocument, Volume 1, Tab 1.1 '.' This SIPrevision 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 ofthe existing Ozone SIP until the redesignation request is approved. The State also certifies that all existing RACT controls required in past Ozone SIPrevisions, 

### and new RACT controls incorporated in these revisions, will remain in effect after redesignation ofthe -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 ThatExisting 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 ofits 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 RACTcontrols in compliance with state law or federal law, Section IX, Part D.2, page 6 vor are on an enforceable compliance schedule. All ofthe 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 SaltLake 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 ofthe 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) oftheAct requires States to implement reasonably available control technology (RACT) with respect to each ofthe 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 ofthe Clean AirAct Amendments of 1990 and the date ofattainment. (B) All VOC sources in the area covered by any CTG issued before the date of the enactment ofthe Clean AirAct Amendments of 1990. (C) All othermajor stationary sources ofVOCs 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, and2.4 Section 183(a) ofthe Act states, "Within 3years afterthe date ofthe enactmentoftheCleanAirAct Amendments of 1990 (November 15, 1993), the Administrator shall issue control techniques guidelines,in accordancewith section 108,for 11 categories ofstationary sourcesofVOCemissions 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 ofthe 11 such source categories was identified in theFederal Register (Vol. 57, No. 82, April 28, 1992, Proposed Rule) by the EPA. These categories are listed in Table 3. Section 183 ofthe Act also requires EPA by November of 1993 to issue CTGs for the following (also listed in Table 3): 1) Reduction ofVOCsfrom aerospacecoatings and solvents from shipbuilding operations and repair and; 2) the completion ofa study ofVOC emissions from consumer/commercial products, and to then regulate those product categories.

Section IX, Part D.2, page 7lough EPA was required to issue CTGs for these 13 categories by November 15, 1993, due to rundingandtimeconstraintsonly twooftheCTGshavebeenissued, whiletheresthave beenissued as final orproposed altemative control techniques (ACTs). ACTs may beused as guidance, but are not considered required controls under Section 182(b)(2) of the Act. Table 3 shows the current status ofeachofthe CTGs, andidentifiesmajorVOCsourcesthatmay be affectedby theCTGwhen 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 areno affected SOCMIsources in theozonenonattainmentarea; therefore thetwo CTGsthat 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 FixedRoofTanks 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 thenonattainment area, and eitherissue negative declaration for that particular source category, meaning that there are no sources for
Section IX, Part D.2, page 8which the CTG is applicable or revise its rules in a manner consistent with a SIP revision to incorporate RACT (in the context ofSection 182(b)(l)(A) ofthe 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 

## i 

# I 2) at any time thereafter as CTGs are published by the EPA. i;

J.

. __ j In the eventthat theEPAshoulddeviatefrom theCTGapproach, the Statewill evaluatethe 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 SupportDocument, Volume 20, Tabs 

### 3.1 and3.2 During the development of the ozone SIPin Section IX.D.l, RACT was established for source categoriesbased on CTGsthathaubeenissuedbyEPA. The sourcecategories coveredby the state's RACT rules and the corresponding Utah Administrative Code numbers are listed below. Copies of these EPA approved RACTrules are onfile at the Division ofAirQuality. 'These categories address all CTGs issued priorto 1990, that are applicableto sources in the nonattainmentarea. Absence of a RACTruleforcertain 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 ofEmissions from Gasoline Transferand Storage (loading of tank trucks, trailers, railroad tank cars, and other transport vehicles).


### • R307-326 Control ofHydrocarbon 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 ofVOCEmissionsAssociated withthe Coatingof Paper, Fabric, Vinyl, Metal Furniture, Large Appliances,

Section IX, Part 0.2, page 91. 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 RACTfor all major sources ofVOC in SaltLake and Davis Counties that are not covered by sections 182(b)(2)(A) and (B) above. The following major sources ofVOC were identified in the Salt LakelDavis nonattainment area: AnJ.')co**Ch~vron** Refinery Crysen Refinery FlyingJ Hill AirForce Base Olympia Sales Phillips Refinery Becauseall ofthesemajor sources are also subjecttopendingCTGs,EPAhas suggested that section l82(b)(2) of the Act requires establishment ofVOC 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 ofthe 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 RACTfor 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 majorVOC sources in the nonattainment area will be affected by one or more ofthese pending CTGs. Because the CTGs are still pending, any RACTrequirement thatis now madeby the Statecouldbedifferent than what will be required by the future CTG. Major sources could be subject to two different requirements within a short period oftime, which could be expensive without providing a significant environmental benefit.

Section IX, Part D.2, page 102. 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 areahas not violated the Ozone standard since 1991. 5. The definition ofRACT in 40 CFR 51.100(0) says that the necessity ofimposing 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 ofproviding for attainment and maintenance of the standard are to be taken into account in the establishment ofRACT. 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 eitherissue 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. Thenew sourcereview rules inR307-401,405,406,410,413,414,155, 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 thatthemosteffectiveengineeringtechniques and equipmentbeused 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 B**YA1'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 VaporRecovery

----­**------~** 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 OrderE-0300-95 dated April 13, 1995. This Approval Order was based on BACT at the time it was issued. Allknown majorsources ofVOChavebeenaddressedthrough acase-by-caseRACTdetermination, which ensured that VOC RACT was implemented as ofMay 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 ofcase-by-case RACT determinations, for all known stationary sources ofVOC covered bySection 182(b)(2) ofthe Act in the SaltLake and Davis County nonattainmentarea. The

Section IX, Part D.2, page 12State also certifies that, upon completion ofthe 1990Base YearInventory 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 orby the EPA in the future, the source willberequired to apply RACTunderthegeneric VOC RACTrulein R307-325-2. TheState 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 and5.2 Any new majororminor source permitted in the future shall be required to meet the BestAvailable Control Technology (BACT) requirements in R307-401.:.6, which will be at least as stringent as RACT. TheBACTdetermination process accomplishedby the Division ofAir Quality will include an evaluation ofpublished orpending CTGs and ACTs. The BACTdetermination 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 ofNO, as categorized in Section 182(b)(2)(A) and (C) oftheAct. 'The following sections identify NOxRACT that was implemented to demonstrate attainment and maintenance ofthe ozone standard. On May 2, 1997, Utah reqljested apartial NOxRACTexemption under 182(f)(2) ofthe Act because the area had attained the standard and further NOxreductions were not needed in the area. Thisrequest 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) ofthe Act and may be referred to as "generic" NOx RACT as it does not prescribe RACT to specific source categories. TheEPAhas already identified presumptive levels ofRACTfor "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 outputcapacity 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 131) The Gadsby Plant owned by PacifiCorp. This plant underwent a RACT determination in 1990 for the PM IO SIP and is now regulated under Section IX.H ofthe SIP. Under that determination the facility is prohibited from burning coal, the fuel for which each of the threeunits was primarily designed, and is required to meet limits for NO. which werebased on the installation oflowNO.burnertechnology. Subsequentto that RACTdetermination, the Gadsby plant identified itself, for the purposes ofthe Acid Rain program, as a gas fired utility. It could be construed from this declaration that this facility should be subjectto the RACTlevelsidentifiedfor gas fired units; however, it is the State'spositionthatthis facility was designed as, and has been historically operated as, a coal fired unit. Were it not for the PMIO SIP, coal would still betheprimary fuel burned at the facility. Thus, one viable means ofcompliance 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) ofthe three units, the historic level ofNO. 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 PM IO, 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 ofcontrol that are attainable when retrofittingolderunitsthatwere not designed with any level ofNO. control in mind, and allows regional averaging amongst different facilities, an argument could be made that this facility has not only metthe 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 ofthe generic RACT rule which applies to any existing major source ofNO.. In order to comply with the PM 10 SIP, KUC has switched fuels from coal to natural ga,s in each ofits fourboilersduringthewintertimePM 10season (NovemberthroughFebruarY). Becausecoal is still burned throughout the remainder of the year, RACT was re-evaluated due to subsequent NO. RACT requirements in the Clean AirAct Amendments of 1990. Recent stacktestingwhileburningcoal shows thatboilerno. 4 (an 83.3MWtangentially 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 willingto accept an equivalentemissionlimit (in terms of384ppmand 377lblhrratherthan 0.45Ib/mmbtu) forboilerno. 4 in orderto comply with the genericNO.RACTrequirement.

To evaluate what NO. RACT might be for boilers 1, 2 and 3 (398 mmbtulhrwall fired wet bottom boilers), KUC investigated various ways to reduce NO. emissions. These alternatives alongwiththe respective conclusions that werereached are summarizedbelow.

a. Fuel Switchingto low nitrogen coal

- ruled out as eitherinfeasible orineffective

Section IX, Part D.2, page 14b. 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

- rejectedbecauselowerflame temperatures would causeproblems with slag tapping (remember that these are wet bottom boilers)

e. StagedAirCombustion

- infeasiblebecauseofthetightburnerconfiguration and short residence time f. Gas Reburn

- also found to be infeasible because of the tight burner configuration and short residence time g. Flue GasRecirculation

- rejected as infeasiblebecausethereis no practicalplace 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-NOxburners, with similarcapitalcosts,but significantly higher operatingcosts. Thistechniquecan 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-NOxburners remained adistinctpossibility. Preliminary estimates suggested that 426.5 ppm, and 216 lblhr (which is the equivalent of 0.50 lb NOx per mmbtu) was an'attainable andenforceableemissionrateforeachofthesethreeboilers. This is also the rate identifiedby EPA as representative ofRACTfor dry bottom wall fired units in the case ofelectric utility boilers. Ofnote is the fact that EPA did not prescribe a level ofNOx RACTfor wet bottom "utility" boilers. Because these are wet bottomboilers KUC was somewhatskeptical about thepossibilityofslagtappingproblems,andproposedtesting the performance oflow NOx burners in one ofthe 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 of216 lblhr and 426.5 ppmdv (measured at 3% oxygen) for each ofthe three boilers, effective after May 31,1995. The AO stated "Ifthe 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." KUCcompleted the installation of10w-NOx burners in Boiler#3 in October 1994. Testing revealed that slagtappingwas not possibleuntil theburners weremodified. Oncemodified, the burners performed acceptably during the limited period of testing time that was available. Preliminary results ofthe stack test performed on November 14, 1994 indicate

Section IX, Part D.2, page 15that the burners, as modified, meet the emission limits in the approval order. KUC completed the installation of10w-NOx burners in Boiler#2 in March 1995 and in Boiler#1 in October 1995. Based on the successful results ofthe 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 ofNO x RACT in the Clean Air Act. Upon review ofthe 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 autility boiler, within the meaning ofthe RACTdetennination 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 eitherthe State orby the EPAin the future, the State shall expeditiously develop specific RACTrulesfor 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 RACTrequirements ofsection 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 ofthe generic NO x RACT rule. 

# --. (i) Low Oxides ofNitrogen Burner Technology. R307-401-lOrequires sources to install low oxides ofnitrogen burners orcontrols resultiJ)gfrom 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) PM 10 SIP Requirements The existingPM 10SIPemissionlimitrequirements for NOx arecontained in SectionIX, PartH,and are source specific limitations. These limitations affect sources ofNOx in Salt Lake County and areas ofDavis County which impact the Salt Lake nonattainment area. Application ofRACT for the PM 10 SIPaddressed sources greaterthan orequal t040TPYratherthan the standard ofl00TPY. Although within the context ofPM 10it is pennissible to consideremissions ofprimaryPM IO and its precursors (e.g. NOx or S02) on an equal basis for the purpose ofobtaining emission offsets, this is an exception to the overall rule. Any major source or major modification requiring offset to attain ormaintain the NAAQS for ozone will be required to secure such offset from the samepollutantfor which there is a proposed increase.
(5) Permitting ofExisting, New, or Modified Sources
Section IX, Part D.2, page 16R307-325, 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 SIPrevision. The rule requires all new or modified sources with a potential to emit any type ofair 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 ofbest 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 ofVOC, 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 ofTitle 1ofthe Act, Prevention ofSignificant Deterioration, which is addressed in R307-405 will applyto the SaltLake and DavisCounty areas afterthey havebeen redesignated to attainmentratherthan the nonattainment area "new source review" requirements. However, the Statehas already changed its rules to specify "SaltLake and Davis Counties" as well as "ozone nonattainment areas" in specific sections ofthe "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 PM IO 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 operatingpennitprogram 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 ofVOC, NO, orCO. The pennit program was submitted to EPA for approval, as required by Title V ofthe 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 AttainmentAfter the Ozone SIP was Adopted Technical Support Document, Volume 1, Tabs 1.3 and l.3.a The number ofexceedances ofthe ozone standard dropped steadily between 1985 and 1991. This improvement in air quality is the result ofthe 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 ofthe State, that SaltLake and Davis Counties did not violate the ozone standardduring these years due to a combination ofnew 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 majorrevision ofUtah, Davis and SaltLake County's IIM programs was fully implemented prior to September 1, 1991. WeberCounty 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: theuse ofBAR90technologyemissions analyzers; theinclusion ofvehicles 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 ofmore emission control devices by the SaltLake 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 notbeen quantified. In 1992, the emission reductions due to revisions in the basic IIM program in the two counties accounted for an additional emissionreduction of 1.23 tons/day VOC anda negligiblereduction of NOx when compared with the IIM program which existed during the 1990 base year. (b) Emission Reductions Due to the Revision ofR307-14 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. Theozonenonattainmentrulesbecamemuchmore stringentforcontrollingfugitiveVOC emissions from: petroleum refineries; gasoline transfer, storage, and loading facilities; degreaser operations; andnumerous surfacecoatingoperations.Themostsignificantreductions in emissionsresultedfrom the removal ofan 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 difficultto quantify since they are fugitiveemissions, the method ofcalculatingreductions 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 ofthe ozone standard. (c) Emission Reductions Due to Federal Restrictions on Gasoline Volatility Volatility of a liquid is a measure ofits tendency to evaporate. Fuel volatility is most commonly measured in Reid Vapor Pressure (RVP), which is the pressure ofthe vapor in pounds per square inch (PSI) at 100degrees F. The higherthe RVP, the more emissions to the atmosphere ofthe fuel's

Section IX, Part D.2, page 18components, 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 gasolinemarketing and distributionnetwork, VOCemissionsfrom vehicle tailpipeexhaust 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 establishedavolatility limitof9.5 psi RVPduring the hottest summermonths (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 imposedby federal law, it is thefederal government who insures that RVP is at 7.8 during the ozone season. The State has neither theequipment nor the personnel to perform RVPtesting to assist theEPA with enforcement ofthis regulation; therefore, the State will rely upon the federal government enforcement ofits own requirement to insure that no violations ofthe RVP limitation occur.
(7) Rule Effectiveness Studies and Small Source ComplianceInitiatives 

# is Technical SupportDocument, Volume 1, Tab 1.4 EPA has established ahigh nationalpriority on conducting

## voe rule effectiveness studies and small source compliance initiatives in ozone nonattainment areas. In recognition ofthis federal priority, the Statehasundertaken ahileeffeetiv'erless stridyofR307-325:341 addressingtanktrucktightness

.. This study covered the efficiency of the leak tight testing program in the State of Utah, and the efficiency ofthe 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 betterprepare themselves for future EPAregulations 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 mustbe examinedfor evidence ofeco own-tum that may have contributed to aUal i appropriate, the must assure that recovery from the down-tum will not jeo continued maintenance of the standard.


### (1) Demonstration thatAir Quality Improvements are Permanentand Enforceable (a) Enforceable Emission Reductions Theimprovementin air quality already achievedin SaltLake and Davis Counties has resulted from implementation of the emission controls listed below. Because these controls have been either federally approved orare pending federal approval, the resulting VOC andNOxemission reductions are federally enforceable. This plan includes a state commitment to continue to enforce all applicable requirements ofpastrevisions to the StateImplementationPlan, even after the SaltLake 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 havebeen accounted for in completing the VOC and NOx emission inventories for these maintenance provisions to the SIP

.

. 1')

. ExistingRACTcontrols on stationary sources covered by CT(jsin categoriesI, II, and III, as well as RACT controls on existing major non-CfGsources ofvves. 2) The Federal Motor Vehicle Emission Control Program. 3) The Federal Gasoline Volatility Control Program (Phase II). 4) Basic lIM Program with improvements. Acontinuedimprovementto airquality through theyear2007 for SaltLakeandDavis Counties will result from the following emission controls which have been promulgated, or may be implemented as a result oftherequirements ofthe 1990CleanAirAct Amendments. Thesecontrol 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) ContinuingenforcementofexistingR307-325 :341 rules coveringVOC controls 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 255) The development and implementation of new Control Technology Guidance (CTGs) and Maximum Available Control Technology (MACT) required by Title III ofthe 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. ofthis maintenance plan.



# ga t, itbecomes o permanently earmeteorological larintensity (equated

atherService records compiled ational Airport, which is centrally ares the average high temperature, e number ofmeasured exceedances for'

- September) for the years 1985 through and August for each year, sincetypicallythe ng t e two months. Ozone exceedance values ake and is Counties. 90° does not show ace in 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

ftheSaltLakelDavisCountyozonenonattainmentareato att important to sho hat reductions in ambient ozone concentrations are enforceable emission uctions, and not to reductions resulting from ye variations. Ozonephoto ical reactions are forced primarily by str to high temperature), and sta wind conditions. The numbers contained in Table 6 from datacollectedfrom1985through 5 at theSaltLake located inside the nonattainment bounda

. Table 6 number ofdays 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 ofthe number ofdays 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-exceedancedays from 1989(non excee e days 3concentrationsbetween0.090and0.120ppm),butwas limitedto 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 AttainmentEmission Inventory: The state can choose to demonstrate mainte 'ce of theNAAQSusing an emissions



### . 

### ""', mven approach. This approach requires t
_ evelopment of an "attainment emission inventory identify the level ofemissio 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 ofeach ofthese three sections follows. Summary tab owing 

## ,C andNO.peak ozone season daily emissions in tons/day for Davis and SaltLakeCounties, 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 ofredesignation. Aspart ofthe 1994 inventory submittal, VOC sources within the nonattainment area wererequired to fulfill the emission statement requirements as listed in R307-158. This included ozone season (June 1 - August 31) activity levels andoperating schedules. This information was used tocalculate ozone season daily emissions ofVOC 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 sourceportion ofthe attainmentyear(1994) inventory include all stationary sources with actual emissions of 10ton/yearormoreofVOC, and/or 100ton/yearormore ofNO.. Stationary sources with 1994 actual emissions less than 10 ton/year ofVOC or less than 100ton/yearofNO. were considered a part ofthe area source portion ofthe inventory for SaltLake and Davis Counties, The mobile-source emissions, such as haul trucks and bulldozers, that were
Section IX, Part D,2, page 29reported by industries in theiremissioninventories areincluded in the non-road section ofthe 1994 emission inventory. The 1994emissions inventory for stationary sources, with the exception ofthe SaltLake 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 ofthe ability ofthe 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 conductrule effectiveness studies to verify the compliancerate in Utah for various rules as resources allow and will change the emissions inventory to reflect the results ofthose studies.

ventory estimates VOC and NO. emissions by county. This inventory incl ources whose emissions any single source location are 10TPYorless forVOC and 100 TP ess for NO•. The area source inv was examined for double-counting ofemissions alread' uded in the state's point source inventory**~usted** accordingly. All emission estimates in th a source inventory were reported in tons perpeakoz eason day toreflect conditionsmosttypic igherozoneconcentrations.

issions from on-road igned fortravel on onnoftailpipe 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 

### of80%. 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 of95% 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. Calculatedemissions from these vehicles are 1 exha , evaporation from the engine and fuel systems, and any other vapor losses durin resti .g ofthe vehicles. Vaporlosses from fuel tanks, afterfilling the tankat arefueling 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 FUTUREAIR QUALITY PROJECTIONS
rojected Emission Inventory, 1994

- 2007 elating to ProjectedInventories:

Pro ion inventories must be completed that show the 

# acan be maintained in the future (i.e.forten safterredesignation), especiallyno . erfutureincreases in VOCand NOA emissionsare expe ndcan beaccommoda utadditionalcontrols, orwhethernew controls need to be implemente ce of the standard.

...no.... ....D.2.e documents a level ofemissions in the Salt Lake/ Davis County area w . sufficient to mal

. the NAAQS for ozone. Emissions projections for each source cate used to detennine ifexpecte
.on levels in future years will exceed the 1994 attainment n inventory level. Maintenance ofthe S is demonstrated ifthe 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 thesethree 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 EPAguidanceestablishesacceptedmethodsofprojectingemissionsfrom pointsources. EPA-4521R93-002, "Guidance forGrowthFactors, Projections, and Control Strategies forthe 15 PercentRate-of-Progress Plan", outlines criteria for the use ofactual 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 theprocesses carried out at the source. The 1994 attainment emissions inventory is based on actualemissions. Allowableemissions arebased on theregulatoryelementofthesource's operatingpermit, 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 calculatedfor 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 Orderis not pending), the projected emissions may be based on actual emissions. Actual emissions may also be used for sources orsource 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 ora new Approval Order, the projections are tobe 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 majorpoint sources wereevaluatedto detenninewhetheractual orallowableemissions, orsome combination ofthe two, should be used. Evidence ofthose evaluations is provided in the TSD in the fonn ofletters 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 ofemissions selected for use in projections is contained in the TSD. Employment growth factors from the State ofUtah Economic & Demographic Projections 1994 are used to projectpoint source emissions. The growth factors begin in 1995 and are incorporated into the projected emissions until a source is predicted to reach 100% ofits NO, allowable limit, if a limit exists. Once the limit is reached, emissionsareprojected toremain flat. VOCprojectedemissions changein proportion with NO, projected emissions. Kennecott Utah Copper is an exception, because NO, emissions are affected by new NO,RACTrequirementsthatdo not affectthe otherpollutants. In this case, NO, projectionsdecrease, while VOC increases. The projected VOC and NO. emissions are demonstrated to remain below the 1994 attainment year emissions level. The accuracy oftheseprojections is reinforcedby the maintenance ofexistingrules (R307­ 325:341) which continue to apply to sources in SaltLake 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 attainmentyear and projectionyearVOC and NO,daily emissionsfor individualpoint 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.

icalSupportDocument, 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 summerweekday vehicle miles oftravel (VMT) within SaltLakeand Davis

. s. Thepeak ozoneday emissions are aggregated by county for eachpollutant. The details ofhow theemissl 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 RequirementRelating to Contingency Measures: Section 175A of theAct requires that areas seeking redesignationfrom nonattainment to attainment develop contingency measures that include state commitments to implement additional control measures in response tofuture violations of the NAAQS. (1) Purpose ofContingency Planning Section 175A ofthe Act requires that maintenance plans include VOC and NO. control measures necessary to assure prompt action to correct any violation ofthe 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 SIPfor 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. Thepurpose ofthese 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 ofthe area to nonattainment. It should also be noted that the pollutant ofconcern is ozone, for which VOCs and oxides ofnitrogen are precursors. The State collected information based on discussions and information from industry, metropolitan planning organizations, EPA and other states regarding the magnitude ofVOC and NO. emission reductions from various control strategies. The**eff~ctiveness** and viability ofpossible control measures were compared. Some controls interact with other controls thereby decreasing the overall effectiveness. Estimates ofthe emission reductions expected from implementation ofmobile 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 ofcontrols. 2) Determination ofContingency Action Level On July 18, 1 Environmental Protection Agency replaced the one-hour ozone standard, which is the basis ofthis 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· gerbe auto triggered by a violation ofthe one-hour ozone standard bec standard has been revoked in Uta

. emoval ofthe automatic trigger for continge easures is consistent with EPA guidance entitled "Guidanc lementing the I-Hour 

## o and Pre-Existing PM IO 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 ofthe 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 NO x R307-403-6 contains more stringent offset requirements for VOC and NO x 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 50tons. In addition, the offset ratio is increased from 1.15:1 to 1.2:1 to require increased reductions ofVOC and NO in SaltLake 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 ofhierarchy specified by the Clean AirAct, Section 182. The SaltLakelDavis County nonattainment area for ozone is presently classified as a "moderate" area. Specific costs for implementation ofthis 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 VaporRecovery Technical SupponDocument. Volume 19, Tab 19.3 The Air Quality Board has adopted R307-332, "Stage II Vapor Recovery Systems," which would require installation ofStage II vapor recovery systems in Davis and Salt Lake Counties ifStage II is triggered as a contingency measure. The schedule for implementation ofStage II after the contingency has been triggered is contained in R307-332. The following condition applies to this contingency measure: PressureTest 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 ofStage 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. Ifthe 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 50Stage 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 ofStage 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 ofgasoline and a known human carcinogen, 

### (c) More StringentLow-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 orreplacementburners to meet low NOx burner emission levels, would be expanded to include all existing sources in SaltLake and Davis Counties. Within 2 months ofthe contingency trigger date, existing sources that have not installed low NOx burners would be required to submit a schedule either for replacement oftheir burners, or for controls resulting from application ofan equivalent technology. A source may request an exemption if replacement ofthe 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 ofthe Employer-Based Trip Reduction (ETR) Program is to introduce and implement strategies designed to reduce the amount ofmeasurable 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 ofvehicle-related pollution in SaltLake 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. Therule may be extended to include all employers with 100 or more employees at a work site ifit is determined necessary to maintain the national ambient airquality 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 ofthe program, 13 of26 government agencies submitting trip reduction plans exceeded the first-year target. Wasatch Front Regional Council prepared estimates ofemission reductions that could be obtained by the years 2005 and 2015 ifTrip Reduction Programs were implemented. See Table 12. The State recognizes thatemission 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 SummerNO SummerVOC x 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/ContinuedMaintenance: The maintenanceplan must indicate how the state will track theprogress and the Maintenance Plan.


### (1) Tracking System for Verification ofEmission Inventory Continued maintenance ofthe ozone standard in Salt Lake and Davis Counties depends in large measure upon the ability ofthe 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 ofVOC 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 ofthis would be results obtained from auto body painting workshops and inventories. (d) The State will coordinate the efforts ofthe 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 ofarea 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 ofall 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 ofthe 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 ofthis evaluation will be submitted to EPA by October 1st ofeach 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 ofthe national primary ambient ozone standard, or to take advantage ofimproved or more expeditious methods ofmaintaining 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 ormaintain the national ambient ozone standard, or every eight years in compliance**~ith** Section 

### 175A ofthe Act.


### (4) Provision for Prohibiting Emissions That Interfere With AttainmentIn OtherStates 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