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### J DEPARTMENT OF ENVIRONMENTAL QUALITY 4 \1 DIVISION OFAIR QUALITY 

### l Michael O. Leavitt 150 North 1950West 

# i Governor P.O. Box 144820 Dianne R. Nielson, Ph.D. Salt Lake City, Utah 84114-4820 Executive Direc{or (80I) 536-4000 (80I) 536-4099 Fax Richard W. Sprott 

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(80l) 536-4414 T.D.D. DireClor www.ueq.state.uLus April 18, 2002

Mr. Richard R. Long Director, Air and Radiation Program Office ofPartnerships 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 PM IO State Implementation Plan for Salt Lake and Utah Counties, and in an attempt to address the lapse oftransportation conformity in Utah County, the Utah Division ofAir 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 SaltLd<.e and C:ah Coumie".**Th~** STi? revision or maintenance plan will be submitted by March 1, 2004. The Utah Division ofAir 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 ofthe 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 ofconcern in the SIP or maintenance plan. 4. Stationary Source modeling for major sources and appropriate non-major sources to determine predicted impacts ofemission 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 UtahApril 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 ofannual growth rates in the SIP or maintenance plans. 10. Justification for credits and growth rates for wood and coal burning in Utah County. 11. Backhalfemissions 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 orprogram withdrawal. 

### J.1. Emission budgets for PM 10 and NO;\. in SaltLake 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.