The Division of Air Quality (DAQ) protects Utah’s air through a variety of programs that protect, maintain, and enhance the air quality in the state. DAQ ensures the state’s compliance with the National Ambient Air Quality Standards (NAAQS) and visibility standards at its national parks, enacts rules pertaining to air-quality standards, develops plans to meet federal standards when necessary, issues preconstruction and operating permits to stationary sources, conducts research into Utah’s unique air-quality issues, and ensures compliance with state and federal air-quality rules.
Utah continues to make significant progress towards understanding and addressing the causes of seasonal air pollution. Increased public awareness and legislative funding for research have provided important support for 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. In addition, this state funding was critically important for leveraging federal, state, private-sector sponsorships, and in-kind support of approximately $2 million for the 2017 Utah Winter Fine Particulate Study.
DAQ led a number of research projects in 2017, including a multi-agency investigation into the factors contributing to the formation of fine particulates in the Utah’s nonattainment areas during temperature inversions, a program to provide small operators in the Uinta Basin with the use of an infrared camera to detect and fix volatile organic compound (VOC) leaks at their facilities, and an in-depth study on the contribution of wood burning to fine particulates during winter inversions.
Utah Winter Fine Particulate Study
Most of the fine particulate matter (PM2.5) present during inversions is created through secondary chemical reactions in the atmosphere. Precursor emissions that contribute to this secondary formation of PM2.5 include nitrogen oxides (NOx), volatile organic compounds (VOCs), sulfur dioxide (SO2), and ammonia (NH3). A complex interplay of chemical and meteorological factors drives the reactions that form PM2.5. Better understanding of the mechanisms behind these episodes and the pollutants most responsible for the formation of PM2.5 will help DAQ develop effective control strategies to reduce particulate levels.
Air-quality research to date has focused on ground-level and near-ground observations. The Utah Winter Fine Particulate Study (UWFPS), by contrast, used a specially equipped Twin Otter airplane to investigate the chemistry in the upper inversion layers. The light aircraft made daily flights, weather permitting, over the Wasatch Front and Cache Valley to survey chemical conditions. Researchers collected ground-based measurements at Smithfield and Logan in Cache Valley; the University of Utah and Hawthorne Elementary in Salt Lake Valley; and Lindon in Utah Valley. Scientists compared ground-based observations with data collected by the Twin Otter to increase their understanding of the complex interactions occurring between the chemical processes that form PM2.5 and the meteorological processes that mix PM2.5 and other pollutants within the inversion layer.
Scientists were particularly interested in answers to the following questions:
- What are the most important chemical mechanisms behind the formation of ammonium nitrate, the major component of PM2.5 during inversions?
- What are the sources of the chemical precursors?
- Are there emission “hotspots” in each valley, and if so, where are they?
- How does PM2.5 and its precursors vary during particular times of the day at ground level and in the upper atmosphere, and how do these variations impact pollution levels?
- What is the role of the Great Salt Lake or Utah Lake in the formation of PM2.5?
Answers to these questions will help DAQ scientists and policy planners better understand pollutant interactions in the atmosphere and target cost-effective regulatory controls.
Thanks to $130,000 in legislative seed money, DAQ was able to leverage $2 million of in-kind equipment, laboratory analysis, and scientific expertise from partner agencies and research institutions including the NOAA Earth System Research Laboratory (ESRL) and the Cooperative Institute for Research in Environmental Sciences (CIRES), University of Colorado Boulder, the Environmental Protection Agency (EPA), United States Department of Agriculture (USDA), University of Utah, University of Washington, University of Toronto, University of Minnesota, Utah State University, and Brigham Young University.
Preliminary observations from the research include the following:
- Consistent with previous ground-based studies, approximately 75 percent of the PM2.5 mass during high pollution events was dominated by ammonium nitrate.
- Oxides of nitrogen (NOx) were higher in more populated urban areas closer to local sources and lower in rural areas such as the Cache Valley.
- As pollution episodes progress, NOx and ammonium nitrate increase in all three valleys.
Preliminary findings offer possible answers to some of the research questions:
1. Is primary ammonia or secondary nitrate the limiting factor in ammonium nitrate formation in the three basins?
Secondary nitrate appears to limit the process of ammonium nitrate formation, suggesting that controls leading to reductions in secondary nitrate would be effective at reducing PM2.5. Salt Lake and Utah Valleys are predominantly nitrate limited, but the Salt Lake Valley is the least nitrate limited during pollution episodes and is often more ammonium limited later in pollution episodes. This suggests that Utah and Salt Lake Valley are close to the equivalence point between nitrate limited and ammonium limited, and reductions in either nitrate and/or ammonia emissions can effectively lead to reductions in ammonium nitrates. Validation of this finding will require further investigation.
2. Do existing emissions inventories for ammonia and NOx match the spatial measurements recorded aboard the Twin Otter?
The observed high spatial variability of ammonia between the Cache, Utah, and Salt Lake valleys conflicts with the current inventory, which shows comparable ammonia emissions in the inventories for these counties. These data indicate a potential misrepresentation of the spatial distribution of ammonia sources in the inventory. Since the Wasatch Front appears to be less nitrate limited, better characterization of ammonia sources in this region will be critical. Observed distributions of nitrogen oxides, the precursors to secondary nitrate, are similar to those found in the emissions inventories and concentrated near the largest urban areas in the region.
3. What is the contribution of residential wood smoke to PM2.5?
Aircraft observations during high pollution episodes showed that carbon-containing compounds, one of the major emissions from wood smoke, contributed less than 20 percent to the final particulate mass. Other sources, such as vehicular emissions, can also contribute to these aerosols. The actual contribution of residential wood combustion to total PM 2.5 is uncertain and may vary spatially depending on the neighborhood and time of the day. Spatial and vertical variability need to be considered when interpreting near-surface, fixed-site observations to determine the residential wood combustion contribution to total PM 2.5 in a basin. Further analysis of the aircraft data for organic aerosols may serve to provide more quantitative estimates of the contribution of wood smoke to total PM2.5.
Continuing analysis of UWFPS study data and additional field studies should ideally include research on the following:
- Chemical mechanisms for ammonium nitrates and oxidants
- Quantification of key meteorological processes
- Variation of nitrate limitations during the evolution of pollution episodes
- Uncertainties in ammonia sources
- Uncertainties in wood-smoke contribution to fine particulate mass
- Better characterization of volatile organic compounds (VOCs)
- Emissions controls on diesel and other vehicles during the winter and the role of cold starts.
- Uncertainties in meteorological monitoring
– Steve Brown, National Oceanic and Atmospheric Administration, Co-Principal Investigator UWFPS
Wood Burn Study
The 2015 Legislature provided DAQ with $70,000 for a modeling study to determine the impact of a two-stage wood burning control program to 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, a unique chemical marker of PM2.5 from wood burning. Data analysis of these measurements indicates that emissions from wood burning continue to 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. Preliminary results showed an average drop of about 0.4 and 1.4 micrograms per cubic meter (µg/m3) in total PM2.5 on typical high pollution days following a conversion of wood-burning devices to EPA-certified and natural gas devices, respectively.
Success Story: ULend Program
In 2016, the Division of Air Quality (DAQ) received legislative funding for the Storage Tank Emissions Pilot Project (STEPP), a collaborative program that used an infrared (IR) camera to check for leaks in oil and gas tanks in the Uinta Basin. The research showed that volatile organic compound (VOC) leaks may make a significant contribution to elevated ozone levels during winter inversions. The 2017 Utah Legislature appropriated $200,000 in air-quality research money to fund the new ULend program, a camera-lending system that provides oil-and-gas operators with a practical way to reduce VOC leaks at their facilities.
Product leaks at oil-and-gas facilities can be difficult to detect. Infrared (IR) cameras offer a proven technology for locating hard-to-find leaks, but the cameras can be prohibitively expensive for small operators. The legislative appropriation provided DAQ with the funds to purchase an IR camera and provide training for companies to become certified in optical gas-imaging (OGI). After certification, those companies can borrow the IR camera to check for leaks at their sites. The program benefits operators in a number of ways:
- While many leaks at oil and gas operations are relatively easy to repair, they can be difficult to see. An IR camera helps operators locate fugitive VOC emissions that are not normally visible to the naked eye.
- Operators can inspect their own sites with an IR camera to identify and repair leaks. This proactive approach minimizes leaks that have the potential to become a compliance issue.
- DAQ will be able to use the information provided by program participants to increase its understanding of the source(s) and frequency of leaks. Repair data will help ensure that DEQ regulations target fugitive VOC emissions in an appropriate, cost-effective manner.
DAQ kicked off its outreach campaign for the ULend program during presentations to stakeholders at the Uinta Basin Energy Summit, the Division of Oil Gas and Mining (DOGM) Collaborative Meeting, and the Utah Petroleum Association meeting. Operators from several companies have already received their optical gas imaging (OGI) IR camera certification through the ULend program.
DEQ developed a comprehensive webpage on the program, and the Utah State University Bingham Research Center created an electronic camera checkout system to make it easy for participants to check out a camera. Additional camera training for ULend participants will be offered locally in the Uinta Basin through the Bingham Research Center.
The ULend program is a great example of what can be accomplished when industry and government work together. DAQ has partnered with the USU Bingham Research Center and the Tri-County Health Department for this project, with additional support from the Utah Clean Air Partnership (UCAIR). These kinds of cooperative efforts help DAQ develop innovative and effective ways to reduce the area’s VOC emissions. Fewer emissions mean lower ozone levels and better air quality for Basin residents at a lower cost to operators.
PM2.5 State Implementation Plans (SIPs)
A State Implementation Plan (SIP) is a state plan to reduce air pollution in areas that do not meet National Ambient Air Quality Standards (NAAQS). Each state is responsible for developing plans to demonstrate how the NAAQS will be achieved, maintained, and enforced. The plans and rules associated with them are enforced by the state, and, after federal approval, they are also federally enforceable. These plans are the framework for each state’s program to protect the air.
In 1997, the EPA strengthened the 24-hour standard for PM2.5, lowering it from 65 micrograms per cubic meter (µg/m3) to 35µg/m3. Prior to this change, Utah was in compliance with the 24-hour standard. The new standard went into effect in December 2006. In November 2009, the EPA determined that three areas in Utah were unable to meet the revised 24-hour PM2.5 standard, which required the state to prepare State Implementation Plans (SIPs) for each nonattainment area. These plans ultimately became Utah’s Moderate Area SIPs.
In 2013, a D.C. Circuit Court of Appeals ruling against Environmental Protection Agency (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 Moderate 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 revised plans for both the Salt Lake City and Provo nonattainment areas showed that it would be impracticable to attain the standard by the end of 2015. The Logan SIP demonstrated that attainment could be achieved by 2015.
The EPA made its determinations for each nonattainment area in May 2017. The agency found that neither the Salt Lake City nor the Provo area had demonstrated attainment by December 2015. This finding effectively reclassified both areas from Moderate to Serious as of June 9, 2017. EPA’s action did not include reclassification for the Logan PM2.5 nonattainment area. The agency has indicated that it will address the Logan area in a subsequent rule-making.
Under new SIP Requirement Rules issued by the EPA on August 24, 2016, Utah must complete new SIP revisions for the Salt Lake and Provo 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 feasible technologies that have been implemented in another state’s SIP or achieved in practice, regardless of cost.
The reclassification of two of Utah’s nonattainment areas to Serious impacts point, area, and mobile sources.
Point sources emitting, or having the potential to emit, at least 70 tons per year (tpy) of PM2.5 or any of its precursors had to undergo an updated review to ensure all controls meet Best Available Control Measures (BACM), including Best Available Control Technology (BACT). DAQ will identify best available controls to limit emissions of direct particulate matter (PM2.5), nitrogen oxides (NOx), sulfur dioxide (SO2) and volatile organic compounds (VOCs) and draft new SIP limits based upon those controls and control techniques. Potential control strategies for ammonia may or may not be required. DAQ will evaluate the efficacy of ammonia controls with respect to reducing PM2.5 through the air-quality model for the SIP.
DAQ solicited a BACT analysis from each major point source in the PM2.5 nonattainment areas. The division will evaluate these reports to ensure completeness and concurrence and include its analysis in the technical support document (TSD) for the Serious SIPs. These reports and evaluations will also be posted on the DEQ website as work progresses.
DAQ developed and reviewed area-source rules for the Moderate SIP to ensure they met reasonably available control measure (RACM) requirements. As part of the Serious SIP, the division has re-evaluated these rules to ensure they meet the more stringent BACM requirements and modified them where appropriate. Numerous area-source rules are currently included in the Serious SIP. The division has conducted draft area-source BACM analyses for the Salt Lake, Provo, and Logan nonattainment areas and posted these analyses on its website.
Success Story: Volatile Organic Compound (VOC) Rules
DAQ has focused on reducing volatile organic compounds (VOCs) — precursors to fine particulates — to improve air quality and meet State Implementation Plan (SIP) requirements to reduce PM2.5 emissions in nonattainment areas in Utah. Over the past few years, DAQ has successfully reduced VOCs in consumer and industrial products.
During the 2017 VOC rulemaking process, Joel Karmazyn, the DAQ scientist charged with developing these rules, visited individual area sources affected by the proposed rules and talked with businesses about possible impacts to their operations. These discussions helped refine the proposed rules to meet regulatory objectives while taking into consideration real-world solutions for specific industries.
For example, Hill Air Force Base (HAFB) uses hundreds, if not thousands, of solvents defined as VOCs for a variety of processes. HAFB has made a concerted effort to replace traditional solvents with more environmentally friendly chemicals. But there’s a hitch — even environmentally friendly chemicals still use VOCs. These products have very low vapor-pressure VOCs, so they don’t evaporate easily like traditional solvents, leading to lower VOC emissions. Unfortunately, the regulatory structure does not discriminate between high and low vapor VOCs; they are all treated as equally undesirable.
Mr. Karmazyn worked closely with HAFB to find ways to work within its existing regulatory structure to permit the use of very low vapor-pressure VOCs. Industry as a whole heartily supported this new approach, and the Air Quality Board recently adopted these changes. DAQ believes this kind of collaboration helps the division develop common-sense rules that reduce emissions while taking into account alternatives that achieve the same outcomes.
Dr. Erik Dettenmaier, HAFB Air Quality Environmental Manager stated that:
Mr. Karmazyn should be commended on his efforts at updating area-source rules to address the Serious SIP. Ideally, rules should strive to align the needs for real emission reductions while acknowledging the needs of various stakeholders; in the case of Hill Air Force Base, our need to ensure our national security. Throughout the rule making process, Mr. Karmazyn made it a priority to strike that balance demonstrated in the extensive stakeholder engagement that he fostered. Mr. Karmazyn’s actions allowed for the development and incorporation of several industry ideas that encouraged and incentivized voluntary reductions. Examples of these incentives include research and development allowances and the use of the most emissions efficient and size-appropriate methodologies for a given process. Mr. Karmazyn’s (efforts) minimized tax payer expense while reducing environmental impacts, with progressive implementation dates and applicability thresholds that acknowledged realities on the ground.”
Joel Karmazyn also expressed praise for the environmental team at HAFB.
Dr. Dettenmaier and Megan Evans, HAFB Staff Scientist, should equally share the credit for this success, because they were both open to new approaches to reduce emissions while meeting their mission to service the military aircraft without jeopardizing national security. The Hill team brought forth a number of novel ideas that I was able to mold into a regulatory framework.”
Mobile source controls already include Tiers 2 and 3 of the federal motor-vehicle-control program, as well as vehicle inspection and maintenance (I/M) programs. Transportation-related conformity requirements will become part of the Serious Area SIPs and affect Metropolitan Planning Organizations (MPOs) in their respective 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.
DAQ has completed many of the necessary technical elements for the SIPs, including a validated air-quality model, a base-year emissions inventory, and draft emission inventories. The draft emission inventories will become final once DAQ quantifies the air-quality benefits of the BACT/BACM requirement for Serious SIPs.
Staff completed their review of current area-source rules to ensure the rules meet BACM. In many cases, rules were modified to apply to more sources or to tighten restrictions. These efforts allowed staff to quantify emission reductions from these measures into the emission projections for area sources. Inventory projections for on-road and off-road mobile sources are essentially complete.
Quantifying emissions for BACT for stationary sources, however, has proven to be more challenging. DAQ needs more time to determine if emission reductions from BACT will meet SIP requirements by the December 31, 2019, deadline. Since the division cannot yet demonstrate attainment in 2019, it will not be able to meet the December 2017 deadline for submission of the Salt Lake and Provo Serious SIPs.
DAQ will continue to work with stakeholders to refine emission-control strategies and incorporate data from 2017 into the SIP’s design values to determine if these data will bring the areas into attainment within the statutory timeframe. The CAA requires EPA to make a “completeness” finding six months after the deadline — in this case, June 2018. The completeness finding ensures that the SIP contains all the elements necessary for its approval. DAQ plans to work closely with EPA and the Air Quality Board to meet the June 2018 deadline.
Preliminary modeling results for BACT show that the Salt Lake nonattainment area would still be over the standard in 2019, and possibly even 2024, based on monitoring data from the Rose Park and Hawthorne air-quality monitors. Since Provo only has two stationary sources, DAQ has decided to separate the Salt Lake and Provo SIPs and fast-track the Provo plan. The division is finishing up the BACT work on those two sources in Provo, which means it can complete emission inventory projections for Provo and run the model soon. DAQ expects it will be possible to show attainment for the Provo nonattainment area by 2019.
Success Story: Employer Based Trip Reduction (EBTR)
DAQ hosted a series of meetings in 2017 to provide companies and employees with vehicle trip-reduction strategies and other mobile-related emissions measures. Implementation of these measures can help companies:
- Reduce their contribution to poor air quality.
- Provide benefits to their employees.
- Reduce company costs associated with transportation.
Since vehicle emissions are responsible for the majority of the ozone and PM2.5 in Utah, DAQ is pleased that many companies throughout the state are taking voluntary steps to reduce their vehicle emissions. The EBTR series serves as a way to help employers identify vehicle emission-reduction strategies that work for their companies.
The webinars have been well-attended, and DAQ plans to continue the series beginning March 2018. During the first webinar in 2017, an EBTR Symposium, employers and government leaders shared strategies to reduce vehicle emissions. Presenters included leaders from the Governor’s Office of Economic Development, the Sustainability Office at the University of Utah, the Sustainability Program with Salt Lake City, Kennecott, Hill Air Force Base, the State of Utah Resource Stewardship Coordinator’s Office, the Utah Department of Transportation, and Intermountain Healthcare.
Other 2017 webinar topics included:
- The Utah Transit Authority’s Vanpool and ECOPass programs
- Active Transportation
- Choosing a Clean Vehicle Fleet
The EBTR Webinar Series has been timely and excellent in providing information, making connections, and understanding what is happening at other businesses and organizations. It has been a great platform for learning from others about their experiences and new possibilities. I look forward to future presentations.”
Steven Bergstrom, Director, Office of Sustainability, Intermountain Healthcare
Ozone Standard Change
In October 2015, the EPA finalized a new 8-hour ozone standard that lowered 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 five-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 at or below 6,000 feet in elevation and within jurisdictions subject to state air-quality regulation
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 are collected. Governor Herbert made a formal recommendation to EPA on behalf of the state based on this DAQ staff analysis.
In June 2017, EPA determined there was insufficient information to complete area designations and extended the deadline by one year for states to submit their ozone measurements to the agency. EPA reversed course a few months later, and on August 2, 2017, announced it would, in fact, not seek a delay in the implementation of the 2015 ozone standard.
On November 6, 2017, EPA issued a notice with initial air-quality designations for the 8-hour 2015 ozone standard. The agency determined that most areas in the country were either in attainment or unclassifiable. Per DAQ’s recommendation, Beaver, Emery, Garfield, Iron, Kane, Millard, Piute, San Juan, Sevier, Washington, and Wayne counties were designated attainment/unclassifiable for the standard. EPA will issue designations for other areas of the country in a separate, future action.
Utah, along with other western states, has elevated background ozone, often in high-elevation, rural areas far from manmade pollution sources. This background ozone comes from wildfires, stratospheric intrusions, and domestic and intercontinental ozone transport. 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.
On November 6, 2017, EPA designated the counties in the nation that achieved attainment of the 2015 ozone standard. These designations included 11 of Utah’s 29 counties but did not include counties in the Uinta Basin. DAQ anticipates a designation of nonattainment for areas in the Basin, but does not know when that will occur, what the boundaries will be, and the nonattainment classification. The uncertainty around the timing of the designation and classification makes it difficult to plan for future regulatory actions. DAQ continues to focus on gathering data from various studies and moving forward with rules for the oil and gas industry to support its understanding of emission sources and their locations.
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 volatile organic compound (VOC) leak-detection process to identify leaks in storage tanks at oil and gas wells on tribal lands and have purchased an IR camera to do so.
The current design value for 2014-2016 for the peak monitor in the Basin located at Ouray is 80 ppb, lowered from a value of 81 ppb due to EPA’s acceptance of the exceptional-event exclusion request by the Tribe for a “stratospheric intrusion episode” that occurred on June 8-9, 2015. (Intrusion episodes occur when stratospheric ozone descends towards the earth’s surface and elevates ground-level ozone levels). This 80 ppb design value would place the Basin in the “marginal” nonattainment classification status. This is the lowest classification and has few regulatory requirements, but it gives DAQ only three years to achieve attainment of the standard.
If the designation delay extends into 2018, ozone monitoring data from 2017 may be included in the assessment for designation, which would raise the design value for the Ouray monitor to 89 ppb and raise the classification to a “moderate.” A moderate classification increases the mandatory regulatory requirements and requires the development of a State Implementation Plan (SIP).
EPA is moving forward with a Reservation-Specific Federal Implementation Plan (FIP) for ozone for the Uintah and Ouray Reservation. The FIP was delayed by the change in EPA administration and time requested by the new administration to evaluate all agency actions. EPA is now working on development of a FIP and will evaluate Utah rules to establish minimum-equivalent requirements for sources under federal jurisdiction. EPA’s goal is to establish a level playing field for oil/gas sources in the Basin by making the FIP requirements equal to the State’s requirements for the same sources.
Air Quality Rules
DAQ has proposed rules for oil and gas sources to replace source-by-source permitting with a streamlined permit-by-rule approach. These rules also establish a registration process for all oil and gas sources in the state and their inclusion in the triennial emissions inventory. The registration rule will apply statewide and ensure DAQ has essential information on oil and gas sources, their emissions, and the equipment and controls they have. This registration process will address concerns regarding the existence of de minimis sources and the appropriate application of the small-source exemption.
This emission inventory will provide the information necessary to continue to model air-quality impacts and potential exceedances of the National Ambient Air Quality Standards (NAAQS) from oil and gas operations. Advantages of the permit-by-rule include:
- Expedited receipt of a permit upon registration
- Decreased cost
- Upfront regulatory certainty
- Consistency of requirements across jurisdictions
The public comment period for these rules ended in November 2017. DAQ is currently responding to the comments received and anticipates presenting rules for adoption at the January 2018 Air Quality Board Meeting.
Coordination and Compliance
DAQ has been working hard to improve Uinta Basin coordination and compliance, including an online inventory tool and tablet-based GIS application to navigate the Uinta Basin oil fields efficiently and access air-quality permits and Division of Oil, Gas, and Mining (DOGM) information in real-time.
DAQ worked with the Tri-County Health Department and the Bingham Research Center through the Storage Tank Emissions Pilot Project (STEPP) project to evaluate several hundred oil and gas well sites and identify potential leaks from storage tanks. This successful collaboration between the agencies and the regulated community helped operators understand and locate emissions coming from storage tanks and fix the leaks found. The Ute tribe is interested in adopting the infrared (IR) camera technology used in the STEPP project as well, offering DAQ an opportunity to partner with the Tribe to address and remedy fugitive VOC emissions from oil and gas facilities on tribal lands.
Utah’s Regional Haze 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 Regional Haze 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 Regional Haze 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 included 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 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.
In July 2017, EPA Administrator Pruitt sent a letter to Governor Gary Herbert stating that the agency intended to reconsider its previous decision on the 2015 Regional Haze SIP. According to the EPA, this reconsideration was based on new evidence not available at the time of the 2016 decision, including data from additional visibility modeling, the seasonality of visibility improvements relative to visitation at the Class I areas affected by the Utah coal plants, and the timing of emission reductions.
In September 2017, the U.S. 10th Circuit Court of Appeals granted a stay to prevent the EPA’s final order from taking effect. DAQ and EPA have committed to work together to find common-sense solutions for achieving reasonable progress towards reducing regional haze.
Volkswagen (VW) Settlement
In 2015, the Environmental Protection Agency (EPA) issued a Notice of Violation against Volkswagen (VW) for installing “defeat devices” that falsified emission-certification results in VW, Audi, and Porsche diesel passenger vehicles. While the vehicles complied with federal limits during certification testing, they emitted up to 40 times the federal NOx limit under normal driving conditions.
VW ultimately admitted to secretly installing “cheat” software in some of its model year 2009-2016 diesel vehicles. Approximately 500,000 vehicles with 2.0-liter diesel engines and 80,000 vehicles with 3.0-liter engines were fitted with the illegal software.
Utah is set to receive approximately $35 million from a nationwide settlement with VW for violations of the Clean Air Act. Utah’s portion will help offset excess nitrogen oxides (NOx) emissions from the approximately 7,000 VW, Audi, and Porsche vehicles in the state affected by the automaker’s violations.
DEQ determined that these excess NOx emissions contributed an estimated 230.1 tons per year to Utah airsheds. Approximately 70 percent of the affected vehicles are registered in the seven counties designated as nonattainment for particulate matter (PM2.5) under the National Ambient Air Quality Standards.
Governor Herbert designated the Department of Environmental Quality (DEQ) as the lead agency to administer these monies. DEQ’s responsibilities as lead agency include the development of an Environmental Mitigation Plan (EMP).
The VW settlement identified certain categories of vehicles and equipment that are eligible for funding under the agreement, some of which do not exist in Utah. Utah’s EMP will determine which of the remaining categories the state will target for that funding. These categories include large, local freight trucks; medium, local freight trucks; freight switcher locomotives; airport ground support equipment; very large forklifts; and school, shuttle, and transit buses. The settlement also allows the state to use up to 15 percent of its allocation for certain light-duty, zero-emission vehicle supply equipment and light-duty, hydrogen-fuel-cell vehicle supply equipment. Utah can also use the funds as part of its non-federal voluntary match for Diesel Emission Reduction Act (DERA) projects.
DAQ invited the public to provide input on the EMP. The division will use this information to help guide the development of the final EMP expected to be completed the first half of 2018.
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.
EPA Targeted Airshed Grant
In 2016, EPA awarded DAQ $5 million out of $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. The grant money will fund two $2.5 million projects over a five-year period.
DAQ will use the grant to replace 33 school buses in Cache and Utah counties and fund a Vehicle Repair and Replacement Assistance Program in Cache County to help qualifying owners repair or replace vehicles that fail emissions testing. Each award was for $2,447,250.
The anticipated lifetime emission reduction from the school bus replacement program is 130.66 tons of nitrogen oxides (NOx) and 10.76 tons of particulate matter (PM2.5). The anticipated lifetime emission reduction from the Vehicle Repair and Replacement Assistance Program is 99.69 tons of non-methane organic gas (NMOG) and NOx, and 0.51 tons of PM.
Success Story: Clean Car Clinic
One of the education and outreach components of the Vehicle Repair and Replacement program is a biannual Clean Car Clinic in Franklin County, Idaho, an area bordering Cache County that is part of the Logan nonattainment area.
The clinics, hosted by the Bear River Health Department, are open to Franklin County residents. Car owners are encouraged to complete a voluntary emissions inspection on their vehicle at the event. If the vehicle fails the inspection, the program provides owners with the opportunity to receive incentives to repair or replace their dirty vehicles.
The first Clean Car Clinic was held in Franklin County Clean Car Clinic on October 27, 2017.
Nine vehicles were tested during the event. DAQ air-quality scientists were available to talk with a number of individuals who did not bring their vehicle to the event and explain the program and the air-quality impacts from dirty vehicles. DAQ issued three repair vouchers and two replacement vouchers out of the nine vehicles tested. One participant even worked with West Motor Company to select a newer vehicle while the event was taking place.
Bear River Health Department, in cooperation with the Utah Division of Air Quality, was able to implement a Vehicle Repair and Replacement Assistance Program this year. This program was made possible because of the relationship we have with DAQ. We appreciate the time and effort put in by DAQ staff, especially Mat Carlile and Joe Thomas, on behalf of the health department and those we serve.”
-Joshua Greer, LEHS, Bear River Health Department
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.
Continuous Improvement Spotlight: Air Quality Permitting
Over the past few years, the Division of Air Quality (DAQ) has adopted process improvements to its permitting program to reduce the time between receiving a permit application and issuing a permit. But the Permitting Branch wanted to go one step further: reduce the number of permits taking more than 180 days to complete.
The DAQ Continuous Improvement (CI) team surveyed the Branch and air pollution sources to identify problematic areas — big or small — in permitting. The survey results revealed a clear consensus around ways the Permitting Branch could boost its performance. Staff identified three key areas for improvement:
- Completeness of permit applications
- Educate/incentivize sources to submit permit applications that contain all the required information.
- Talk with sources to get feedback on “what works and doesn’t work” in the permitting process.
- Editing and review processes
- Improve processes to interface better with the air-quality TEMPO database.
- Use the TEMPO tool more effectively to improve workflow.
- Permit peer-review process
- Clarify the elements of the peer-review process to improve efficiency and effectiveness
- Clarify the timing of the peer- and source-review to streamline the review process.
These improvements will eliminate wasteful steps and create a more efficient permitting process.
The CI team is currently tackling application completeness. The complexity of the air-permitting process and the uncertainty of the level of detail required from air pollution sources to meet application requirements are the major roadblocks to submitting complete applications. The team has identified a number of solutions to clarify the requirements, including:
- Checklist development
- Easily accessible guidelines for sources seeking permits
- Training programs for sources and staff
Ongoing Continuous Improvement Projects
Statewide Oil and Gas Inspections
DAQ 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 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 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 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.