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J DEPARTMENT OF ENVIRONMENTAL QUALITY 4 

\1 DIVISION OF AIR QUALITY l 

Michael O. Leavitt 150 North 1950 West i Governor P.O. Box 144820 

Dianne R. Nielson, Ph.D. Salt Lake City, Utah 84114-4820 

Executi ve Direc{or (80 I) 536-4000 

(80 I) 536-4099 Fax Richard W. Sprott I(80l) 536-4414 T.D.D. DireClor 

www.ueq.state.uLus

April 18, 2002 

Mr. Richard R. Long 

Director, Air and Radiation Program 

Office of Partnerships and Regulatory Assistance 

USEPA Region VIII 

999 18th St., Suite 300 

(8P-AR) 

Denver, Colorado 80202-2466 

Dear Richard: 

In a continuing effort to re-develop the PMIO State Implementation Plan for Salt Lake and Utah 

Counties, and in an attempt to address the lapse of transportation conformity in Utah County, the 

Utah Division of Air Quality and EPA have agreed to structure the Utah County SIP revision, 

which i<; currently going through the state rulemaking process, and to address additional Utah 

a:::d Salt Lake County SIP issues identified in our di'i~ussiOIi:Il lit\cr a 31.[' re\ isivn cr 

maintt;na[j~e plan, as determined appropriate, for both Salt Ld<.e and C:ah Coumie". Th~ STi? 

revision or maintenance plan will be submitted by March 1, 2004. 

The Utah Division of Air Quality commits to work with EPA in good faith to devel0p 

approvable SIP revisions, which address the following issues: 

1.	 State at;thority as it relates to the discretion granted to the Executive Secretary of the 

Utah Air Quality Board. 

2.	 Variance provisions as provided in Utah law, Air Quality regulations and the SIP. 

3.	 UAM-Areo based modeling and analysis to address pollutants of concern in the SIP or 

maintenance plan. 

4.	 Stationary Source modeling for major sources and appropriate non-major sources to 

determine predicted impacts of emission limit established in the SIP or maintenance plan. 

5.	 Enforceable emission limits for sources in the SIP or maintenance plan, including
 

enforceable 24-hour emission limits for major sources in both Salt Lake and Utah
 
April 18, 2002 

Page 2 

Counties and emission limits (or surrogates for emission limits) for refinery process 

flaring and SRU maintenance downtime. 

6.	 Emissions inventory and modeling analysis for the non-attainment areas in Salt Lake and 

Utah Counties. 

7.	 New source review, emissions banking, and interpol!utant trading. (See EPA letter of 

May 10, 2001.) 

8.	 Unavoidable breakdown rules and consistency with the EPA September 20, 1999 policy 

regarding such breakdowns. 

9.	 Inclusion of annual growth rates in the SIP or maintenance plans. 

10. Justification for credits and growth rates for wood and coal burning in Utah County. 

11. Backhalf emissions measuring for PMlO emissions limit stack testing. 

12. General language clean up in PMIO SIP to assure SIP is consistent and read appropriately. 

13. Diesel IIM revision or program withdrawal. 

J.1. Emission budgets for PM 10 and NO;\. in Salt Lake pCltion of tlM1i)" sr... 

15. Emission inventory and modeling analysis for Automobile Emission Inspection and 

Maintenance Program changes, if any such changes are made in the SIP or maintenance 

plan. 

It is our intent to work with EPA to address these issues and develop an approvable SIP or 

maintenance plan.