Utah continues to make significant progress toward understanding and addressing the causes of seasonal air pollution. Increased public awareness and legislative funding for research have provided important support for the Division of Air Quality (DAQ) in its ongoing efforts to reduce pollution, improve air quality, and protect public health.
Air Quality Research Projects
Legislative funding for air quality research has provided DAQ with the resources to investigate the complex conditions that lead to high pollution levels during winter inversions and summer ozone episodes. Better understanding of the unique conditions that lead to poor air quality helps DAQ craft effective regulations, target emission sources, and apply appropriate emission-control technologies. For example, legislative funding made it possible for DAQ to leverage federal, state, private-sector, and in-kind support of approximately $2 million for the upcoming Winter 2017 Fine Particulate Study in northern Utah. State seed money attracts researchers from across the country who bring equipment, personnel, and expertise to support Utah air-quality studies, maximizing the state’s return on investment for air-quality research.
DAQ led a number of research projects in 2016, including a program to determine the extent of leaks at oil industry storage tanks in the Uinta Basin, a study to investigate the chemical reactions behind the formation of fine particulate in the Salt Lake Valley during temperature inversions, research to identify the sources and chemical composition of hazardous air pollutants (HAPs), and a study on the contribution of wood burning to fine particulate levels during winter inversions.
STEPP Program (Uinta Basin)
A $150,000 appropriation from the Legislature funded the Storage Tank Emissions Pilot Project (STEPP), a collaborative effort between DAQ, the Bingham Research Center, and the Tri-County Health Department that uses innovative technology to track down leaks in storage tanks at oil and gas wells in the Uinta Basin. When the data is analyzed and presented to stakeholders this winter, discussions will focus on repair protocols that can be achieved through a collaborative process between industry and DAQ.
The large number of wells and the unique air-quality problems linked to volatile organic compound (VOC) emissions in the Basin offer an opportunity to find cost-effective ways to prevent VOC emissions through maintenance procedures. Since it would be impractical to visit more than 2,000 pieces of equipment associated with oil and gas production, DAQ is working with oil and gas producers and stakeholders to identify a representative sample of equipment that currently have VOC combustors and thief hatches (the likely source of the leaks) on their tanks. Researchers use infrared (IR) cameras, tablet-based Geographic Information System (GIS) equipment, and Google High-Resolution Imagery to help detect these leaks.
The STEPP project has facilitated a collaborative working relationship between DAQ and the oil and gas companies in the Basin. The inclusion of oil and gas producers in the process offers simple benefits, such as access to gated facilities and informal education opportunities to raise operator awareness about leaks in storage tanks.
“The … Basin’s air quality issues are a significant concern for the residents of the Uintah Basin … Speaking as one of the local governmental entities working on these issues, we are grateful for the collaborative relationship that exists between (DAQ) and our local Utah State University AQ research team. (The STEPP program) has identified what may be an issue, and it will result in valuable feedback to industry in a non-threatening manner to address concerns before future regulatory solutions are considered. This type of targeted approach, based upon solid science and focused on specific potential emission sources, is much more valuable in helping us improve our air quality while maintaining responsible economic development, as opposed to implementing sweeping general regulations … We are grateful for the funding the legislature gave to this project and for the collaborative process DAQ has used to fulfill the terms of the funding.” — Paul Hacking, Executive Director, Uintah Impact Mitigation Special Services District
Salt Lake Valley Winter 2015-2016 PM2.5 Study
Researchers from DAQ, the University of Utah, Utah State University, Weber State University, and the National Oceanic and Atmospheric Administration (NOAA) joined forces to conduct a study on wintertime particulate matter (PM) pollution in Salt Lake Valley between December 2015 and February 2016. The study looked at the ways chemical and meteorological processes combine to drive PM2.5 pollution episodes in Salt Lake Valley.
The study provided invaluable information on how pollutants vary spatially, including vertically; how they evolve with time; and the mechanisms that control the precursor chemistry that leads to particulate formation. Preliminary results suggest important connections between meteorology and chemistry, in particular the nitrate chemistry that occurs within the inversion layer and a potential downward mixing of particulate matter that may create elevated PM2.5 levels near the surface. Detailed analysis and more extensive vertical measurements of the species relevant to the fine particulate formation, including ammonia and nitric acid, are needed to better understand the chemical mechanism behind the formation of PM2.5.
West Valley Air Toxics Study
DAQ, Brigham Young University, and the Neil Armstrong Academy partnered for a hazardous air pollutant (HAP) monitoring project in West Valley City. The study, funded by a $355,000 grant from the EPA, used state-of-the-art instruments to measure gaseous and particulate HAPs in real-time.
This study provided a high-quality, real-time resolution dataset that can be used to determine the impacts of polycyclic aromatic hydrocarbons (PAHs) and HAPs such as formaldehyde and acetaldehyde, on air quality in Salt Lake Valley during the winter and summer months. DAQ anticipates collecting a wide range of important information from the study, including:
- Identification of HAPs in West Valley that may be at levels above the health exposure threshold
- Evaluation of the relative contribution of different sources — such as local industries, wood-burning, and vehicles — on HAPs levels in the air
- Better understanding of the impacts of PAHs on air quality in the Salt Lake Valley
- Better estimates of exposure risks to the urban population from HAPs
- Improved community understanding of HAPs exposure risks and air quality issues
- Improved community involvement and action to reduce toxic air emissions
The study is an important step toward the reduction of HAPs emissions and human exposure to air toxics in the Salt Lake Valley, and an important opportunity to involve the community in the study and subsequent emission control strategies.
2015 Air Toxics Study
In 2013, DAQ analyzed HAPs data collected between 2003 and 2012 at the Bountiful monitoring site and determined there was a need to gather more data on the composition, trends, and distribution of HAPs along the Wasatch Front. Legislative funding in 2014 provided DAQ with the opportunity to conduct more frequent sampling and establish three monitoring sites in Bountiful, West Valley, and Lindon to collect additional data.
The study found that Bountiful has elevated concentrations of formaldehyde and methylene chloride, and West Valley City has elevated concentrations of lead. The elevated levels of formaldehyde and methylene chloride in Bountiful are likely from small, unregulated sources in the area, and elevated levels of lead in West Valley City are likely the result of previous and current mining and smelting operations in the area.
Because the data collected didn’t point conclusively to a specific source or sources, DAQ applied for and received funding from the EPA to undertake a follow-up study to gain more understanding about potential source(s) of these pollutants. DAQ scientists will use additional equipment to conduct intensive monitoring for two weeks in January 2017 and Summer 2017 to help pinpoint the source(s) or factors leading to elevated levels in the Bountiful area. DAQ will not conduct further testing in West Valley City since the concentrations of lead and exposure levels are far lower than the National Ambient Air Quality Standards (NAAQS), and analysis of the data indicates that the potential sources of lead in the air may be from industrial activities that no longer operate in the area.
Wintertime Wood-Smoke Contribution to PM2.5
The 2015 Legislature provided DAQ with $70,000 for a modeling study to determine the impact of a two-stage wood burning control program that would reduce emissions from wood-burning stoves while maximizing the number of days EPA-certified stoves and other devices could be used for home heating.
DAQ gathered an extended set of PM2.5 measurements and analyzed them for a specific compound — levoglucosan — that is a unique chemical marker of PM2.5 from wood burning. Data analysis of these measurements indicate that emissions from wood burning contribute an appreciable amount of pollution during winter inversions in the PM2.5 nonattainment areas in northern Utah, even during mandatory no-burn periods.
Division scientists ran an air quality model that simulated the reduction in PM2.5 from the replacement of the current stock of wood stoves and fireplaces with more efficient, clean-burning devices to analyze the impact of a two-stage wood-burn program on the buildup of pollutants before an inversion. A report on the final results of the simulation will be completed by March 2017.
The Clean Air Retrofit and Replacement Technology (CARROT) Program provided incentives to individuals and small businesses to reduce emissions from small-engine and heavy-diesel equipment. The $700,000 appropriated for FY 2016 was divided into three segments: the Grant Program, the School Bus Replacement Program, and the Lawn Equipment Discount and Exchange Program.
The Grant Program awarded over $100,000 in grants to four entities for projects that reduced emissions from heavy-duty diesel engines. Those projects included construction-equipment retrofits and idle-reduction technologies, replacement of diesel generators with new propane generators, and the replacement of farm equipment and a long-haul truck. These changes resulted in a nearly 13,000-ton reduction over the lifetime of the equipment.
The School Bus Replacement Program provided $300,000 to eight school districts for replacing old, polluting diesel school buses for new buses that achieve the cleanest emissions standards. These efforts will reduce emissions by 89 tons over the lifetime of these buses.
The Lawn Equipment Discount and Exchange Program offered 944 electric mowers and 707 electric trimmers to individuals at a discounted price and provided an additional discount for those who exchanged a gas-powered model. The April 2016 discount and exchange event was a tremendous success: the registration system was overwhelmed by over 380,000 web hits in the first thirty minutes, and demand far exceeded the equipment available through legislative funding. These change-outs were the equivalent of removing 424 passenger cars from Utah roads.
“We arrived at about 8:45 to find everyone waiting and willing to process us through. We were in and out in less than 10 minutes! I was pleasantly surprised at the efficiency of this whole thing! I came home, put the units together and mowed my lawn! I love it! Thanks again for all you guys do! I’m just learning about ‘my part’ in all of this and look forward to more environment saving ideas! Thanks again to all of you involved in this! You are NOT the typical stereotyped government employees!” — Comment Posted to the DEQ Facebook Page
The legislature did not appropriate funds to continue the program in FY 2017.
Utah Clean Diesel Program
The Environmental Protection Agency (EPA) awarded $1.2 million to the Utah Clean Diesel Program for school bus replacements and idle-reduction technologies in the Canyons, Grand, Morgan, Jordan, and Tooele school districts. Salt Lake City and Momentum Recycling received funding to assist with heavy-duty diesel vehicle replacements, along with Calco Transportation for retrofitting short-haul trucks with diesel oxidation catalysts and idle-reduction technologies. In addition, a 2006 diesel shuttle bus that operates on Weber State University’s campus will be converted to all-electric. Over $12 million in state and federal grants have been awarded through the Utah Clean Diesel Program since 2008, resulting in over 46,346 tons of emissions reductions.
Environmental Protection Agency (EPA) Targeted Airshed Grant
In 2016, EPA awarded DAQ $5 million out of the $20 million available through its Targeted Airshed Grants program. The funding will help Provo and Logan meet federal air quality standards for wintertime particulate pollution. This grant money will fund two $2.5 million projects over a 5-year period:
- Replacement of up to 40 old school buses in Utah and Cache counties with cleaner vehicles
- Grants for qualifying vehicle owners to repair or replace vehicles that fail emissions testing in Cache County
PM2.5 State Implementation Plans (SIPs)
In 2013, a D.C. Circuit Court of Appeals ruling against EPA interpretation of the Clean Air Act (CAA) required the agency to publish a new schedule for PM2.5 State Implementation Plan (SIP) submissions. Utah had to resubmit its three PM2.5 plans and demonstrate that each area would either attain the standard by December 31, 2015, or that it would be impracticable to do so even after applying all reasonable control measures.
The State was unable to attain the PM2.5 standard under the National Ambient Air Quality Standards (NAAQS) by the 2015 deadline. On December 1, 2016, the EPA administrator signed a notice that the three nonattainment areas in Utah did not meet the PM2.5 standard by the deadline, and proposed that the areas be reclassified as “Serious” rather than “Moderate.” The Logan nonattainment area was on track to attain the standard by the 2015 deadline, but elevated PM2.5 levels during the last month of 2015 disqualified the area for an extension.
Under new SIP Requirement Rules issued by the EPA in July 2016, Utah must complete new SIP revisions for these three nonattainment areas by December 31, 2017, and demonstrate attainment of the PM2.5 standard by December 31, 2019. If the State shows that the 2019 deadline is impracticable, it can petition for an extension of up to five years, but an extension would require the SIP to employ Most Stringent Measures (MSM), which include any technologies that have been implemented in another state’s SIP or achieved in practice, regardless of cost.
Reclassification of Utah’s nonattainment areas to “serious” will impact point, area, and mobile sources.
Point sources specifically identified in the Moderate area SIPs will need to ensure that their controls meet Best Available Control Measures (BACM), including Best Available Control Technology (BACT). In Serious nonattainment areas, sources that emit 70 tons per year (tpy) or more of PM2.5 or any PM2.5 precursors — nitrogen oxides (NOx), volatile organic compounds (VOCs), sulfur dioxide (SO2), and ammonia — are subject to BACT. This 70 tpy threshold will affect more point sources than were identified in previous Moderate area SIPs, which had a 100 tpy cutoff. In addition, sources that meet or exceed the 70 tpy threshold for a single precursor will be reclassified as major sources subject to Title V permit regulations.
DAQ will reevaluate the area source rules enacted as part of the Moderate area SIPs to ensure that they represent the Best Available Controls rather than the Reasonably Available Controls required under Moderate area SIP planning.
Transportation-related conformity requirements will affect Metropolitan Planning Organizations (MPOs) in nonattainment areas. PM2.5-related emission goals known as Motor Vehicle Emission Budgets (MVEBs) will be included in each SIP. To receive federal funding, each MPO will need to demonstrate conformity with these MVEBs as part of the SIP’s transportation-planning requirements.
Ozone Standard Change
In October 2015, the EPA finalized a new 8-hour ozone standard that lowers the ozone standard from 75 parts per billion (ppb) to 70 ppb. DAQ was given one year to evaluate statewide air monitoring data to determine which areas meet the new standard.
DAQ completed its ozone area designation review and 5-factor analysis in September 2016 and recommended three ozone nonattainment areas for the governor’s consideration:
- Portions of Utah County currently nonattainment for PM2.5
- Portions of Weber, Davis, Tooele, and Salt Lake counties currently nonattainment for PM2.5
- Portions of the Uinta Basin that are 6,000 feet or lower in elevation and within jurisdictions subject to state air-quality regulations
The division recommended that Box Elder, Cache, Carbon, Garfield, San Juan, and Washington counties be designated as ozone attainment areas, and areas without monitoring data be designated as unclassifiable/attainment until sufficient monitoring data is collected.
Governor Herbert made a formal recommendation to EPA on behalf of the state based on this DAQ staff analysis. EPA is scheduled to publish the final designations and classifications in October 2017.
Utah, along with other western states, has elevated background ozone, often in rural areas far from manmade pollution sources. This background ozone comes from wildfires, stratospheric intrusions, and domestic and intercontinental ozone transport. The EPA has indicated that it will work closely with Utah to find ways to comply with the new standard while taking into account exceedances potentially caused by background ozone.
EPA’s finalization of the new ozone standard will affect emission-reduction strategies and controls for oil and gas operations in the Uinta Basin. In a September 29, 2016, letter to EPA Region 8 Regional Administrator, Governor Herbert recommended that portions of the Uinta Basin 6,000 feet or below in elevation and within areas subject to state air-quality jurisdiction be included in an ozone nonattainment area based on the new standard. EPA’s final designation and classification of the Basin ozone nonattainment area will determine the nature and extent of emission reductions, required control technologies, and the need for a State Implementation Plan (SIP) for ozone.
Multi-jurisdictional Air Quality Issues
Approximately two-thirds of currently producing oil and gas wells — ninety percent of the gas production and half of the oil production in the Uinta Basin — are located in Indian Country where the tribe and EPA have regulatory authority. Because EPA views the Uinta Basin as a single airshed and ozone nonattainment area, the design value for determining nonattainment-area classification is triggered by air-quality data from the monitor with the highest ozone values — in this case, the Ouray monitor in Indian Country. EPA’s final determination on the Basin’s nonattainment classification will affect state requirements for emission reductions, even though the State’s regulatory control covers only a small portion of the oil and gas operations in the airshed.
A good working relationship between DAQ and the Ute tribe is critical for addressing air-quality challenges, arriving at effective control strategies, and minimizing emissions in the proposed nonattainment area. To that end, DAQ has been working collaboratively with the tribe to tackle cross-jurisdictional air-quality issues that impact both entities. The tribe is now overseeing air-quality monitoring on tribal lands and contributing data for the area’s emission inventory. They have also expressed great interest in implementing a VOC leak-detection process to identify leaks in storage tanks at oil and gas wells on tribal lands.
In addition, the division is working with the tribe and EPA to flag air-quality data that may have been impacted by a “stratospheric intrusion episode” on June 8-9, 2015. Intrusion episodes occur when stratospheric ozone descends towards the earth’s surface and elevates ground-level ozone levels. Stratospheric intrusions can qualify for the exceptional event exclusion under EPA guidelines. Inclusion or exclusion of these data will impact the ozone values used to determine the Basin’s nonattainment classification.
EPA is moving forward with a Reservation-Specific Federal Implementation Plan (FIP) for ozone for the Uintah and Ouray Reservation. The FIP has been delayed by the need for a more robust cost analysis of the mitigation strategies. EPA has committed to ozone mitigation measures in the final FIP that will be equivalent to, but no stricter than, the State’s current air rules.
Air Quality Rules
DAQ is exploring the idea of moving from source-by-source permitting to a streamlined permit-by-rule approach for oil and gas sources. Advantages include expedited receipt of a permit upon registration, decreased cost, upfront regulatory certainty, and consistency of requirements across jurisdictions.
DAQ implemented four retrofit rules in 2015 to reduce emissions from older oil and gas equipment operating in the Basin. These regulations implement best practices that are known to cut emissions from existing sources, including:
- General provisions that minimize volatile organic compound (VOC) emissions
- Replacement of high-bleed pneumatic controllers with low-bleed devices
- Auto-igniting flares at oil and gas production sites
- Bottom-loading or submerged filling for tank trucks
By designating best operating practices for the oil and gas industry and instituting cost-effective emission control requirements, DAQ ensures that existing oil and gas sites in the Basin operate in a clean, efficient manner.
DAQ has been working on improvements to Uinta Basin coordination and compliance, including an online inventory tool and tablet-based GIS application for navigating the Uinta Basin oil fields and accessing air quality permit and Division of Oil, Gas, and Mining (DOGM) information in real-time. The Ute tribe is interested in adopting this technology for their use in their air jurisdictions in the Basin.
Utah’s Regional Haze (RH) State Implementation Plan (SIP) was developed to protect the vistas of Class 1 areas, including Utah’s five national parks, from regional haze. In 2013, the EPA approved the majority of the RH SIP dealing with emission reductions for sulfur dioxide (SO2), but disapproved the SIP’s best available retrofit technology (BART) determinations for nitrogen oxides (NOx) and particulate matter (PM) for Units 1 and 2 at PacifiCorp’s Hunter and Huntington plants.
Working closely with EPA, DAQ revised the Regional Haze SIP to demonstrate that an alternative to BART for nitrogen oxides (NOx) would achieve greater reasonable progress than BART. Combined emissions of NOx, SO2, and PM in the Alternative to BART RH SIP would be lower than achieved by the most stringent technology available to reduce NOx from sources subject to BART. Visibility modeling showed that the alternative would provide visibility improvement on a greater number of days and greater average improvement with reductions achieved earlier than required by rule.
On June 1, 2016, the EPA issued a partial approval, partial disapproval of Utah’s regional haze plan. The decision includes a Federal Implementation Plan (FIP) requiring installation of selective catalytic reduction (SCR) equipment at PacifiCorp’s Hunter and Huntington plants to further reduce NOx emissions. DAQ has filed an appeal of the EPA’s decision in the Tenth Circuit Court and applied for an administrative stay of implementation of the decision, stating that the costly $700 million in upgrades will have imperceptible benefits to air quality in the region.
Continuous Improvement/SUCCESS Framework
DAQ is committed to continuous improvement to improve performance and implement innovations that advance quality, efficiency, and effectiveness. Listed below are a few of the ongoing continuous improvement/SUCCESS Framework process improvements within DAQ.
Statewide Oil and Gas Inspections
DAQ has adopted process improvements to its inspection program to increase statewide compliance with oil and gas regulations. Improvements include:
- Prioritizing inspections on the basis of risk and compliance history.
- Mapping facility locations so that inspections can be grouped to maximize field work time and minimize travel time.
- Using tablets for travel (maps of locations) and inspection notes, eliminating duplication of effort, and cutting the time spent transcribing and inputting notes back at the office.
- Using an infrared camera to detect leaks at tank batteries during inspections.
Oil and Gas Permitting
The division has adopted process improvements to its permitting program to reduce the time between receiving a completed oil and gas permit application and permit issuance. Improvements include:
- Using a General Approval Order (GAO) process to streamline permitting for qualifying facilities.
- Holding pre-meetings before a permittee submits a Notice of Intent (NOI) to answer questions and ensure permit applications are complete before submission.
DAQ has improved its permitting process to reduce the number of Title V permits extended beyond their five-year term. After five years, the source is allowed to operate according to the existing permit conditions under “application shield” provisions, as long as the facility has applied for a permit renewal in an appropriate and timely manner. In 2009, permits beyond the five-year term soared to 35. Since then, DAQ has been able to substantially reduce that number, and currently has the lowest number of permits beyond the five-year term in EPA Region 8.
New Source Review Permits
DAQ has adopted process improvements to its permitting program to reduce the time between receiving a completed new source review permit application and permit issuance. Improvements include:
- Holding pre-meetings before a permittee submits a Notice of Intent (NOI) to answer questions and ensure permit applications are complete before submission.
- Providing guidance documents online to assist permittees in filling out the permit application.
- Starting the permit time clock when a complete application is received, not before.