Salt Lake Area Source BACM Analysis
DRAFT: August 21, 2017Salt Lake Area Source BACMSalt Lake Area Source BACM AnalysisBACM Analysis ProcessOne of the requirements for a serious nonattainment area plan is to demonstrate thatthe plan includes the best available control measures (BACM) that can be feasibly andcost effectively implemented for all precursors. EPA defines BACM as being morestringent than reasonably available control measures (RACM), but less stringent thanthe lowest achievable emission rate (LAER), which does not take into consideration thecost effectiveness of implementing a particular control measure. The BACM analysiswas conducted based on: Literature review of EPA guidance documents and regulations including:o Control Techniques Guidelines (CTG)o Alternative Control Techniques (ACT)o New Source Performance Standards (NSPS) A comparison of existing rules to the CTG to assure that all appropriate CTG’shave been addressed in rulemaking Ozone Transport Commission (OTC) model rules A comparison of other serious nonattainment air districts rules for ozone and/orPM2.5 to UDAQ rules:ooooSan Joaquin Valley (SJ) – PM2.5South Coast Air District (SC) – PM2.5Ventura County, CA – ozoneSacramento Metro, CA – ozoneAdditional air district rules may also be reviewed if the air districts listed above donot have a comparable UDAQ rule. An evaluation of technological/economical feasibility for newly identified controlsor enhancement of existing controlsThe BACM analysis is based on a seasonally adjusted inventory. That is to say thatsource categories that do not occur in the winter are not included. Temporaladjustments are also made in the inventory. For example, exterior coating operationsare not performed during the winter-inversion periods.
DRAFT: August 21, 2017Salt Lake Area Source BACMDirect PM2.5 BACM AssessmentSource CategoryCombustion, Wood,All DevicesConstruction,BuildingsCommercial CookingMining & Quarrying,All ProcessesSource 2325231103Construction, RoadsBackyard BBQCommercial Cooking,Chain-DrivenCharbroilerCombustion, NaturalGas, ResidentialCombustion, NaturalGas, Commercial 102006210400421020052.41Construction, Buildings1.13Existing CA rules only apply to verylarge sources due to extreme cost (atleast 15K/ton) Prohibitive costwould shutter most sources.R307-309 FugitiveEmissions & FugitiveDustR307-309 FugitiveEmissions & 307-356 AppliancePilot Light0.0540 CFR 63 SubpartDDDDDR307-309 FugitiveEmissions & FugitiveDust40 CFR 63 SubpartDDDDDR307-312 AggregateProcessing Operations21020072104007281006010.32R307-303 CommercialCooking40 CFR 63 SubpartDDDDDCremation, Human1.030.77Statutory exemptionCombustion, OilCombustion, LPGCommentsR307-208 OutdoorWood BoilersR307-302 Solid FuelBurning Devices2810025LandfillsCombustion, NaturalGas, IndustrialUtah Existing Rulesand Federal Rules2014UncontrolledInventoryTons/winterWeek DayMACT requires PM reduction0.006MACT requires PM reduction0.003EPA-600/2-75-069-aGuidelines for Residential Oil-BurnerAdjustments Procedures to MinimizeAir Pollution0.001No known controlR307-201-3 VisibleEmissions Standards0.019.3 x 10-4Opacity Requirement6 x 10-4May also use PM collection systemsNo known control1.1 x 10-4Seven area source rules have been adopted that provide control of direct PM2.5. Most ofthese rules are also helpful in providing control for precursors, such as VOC’s. Thissection is dedicated to those control measures that provide the greatest control fordirect PM2.5. The rules discussed in this section are annotated in the table in bold print.
DRAFT: August 21, 2017Salt Lake Area Source BACMR307-312 and R307-356 are discussed in other sections dedicated to the SOx and NOxprecursors.Utah Existing RulesR307-208 Outdoor Wood BoilersR307-302 Solid Fuel BurningDevicesR307-303 Commercial CookingR307-307 Road Salting &SandingR307-309 Fugitive Emissions &Fugitive DustR307-312 Aggregate ProcessingOperationsR307-356 Appliance Pilot LightControlProhibits sale of units innonattainment areasEstablishes an emissionstandard and allowableburning periodEmission controls forchain-driven charbroilersEmission controlEmission controlEmission controlProhibits sale of pilot lightsin the nonattainment areasParameterVOC,PM2.5,NOxVOC, PM2.5,NOx, SOxPM2.5, VOCPMPMSOx, PM2.5,NOxNOx, PM2.5,VOC, SOx,NH3PM2.5 Source Category AnalysisR307-208 Outdoor Wood Boilers: Prohibits the sale of new units in the nonattainmentarea and established a registry for units within the nonattainment area in existence priorto rule promulgation. Units on the Registry may be replaced with outdoor wood boilerswith an EPA Phase 2 qualified wood pellet outdoor wood boiler. New EPA Phase 2units may be sold in attainment areas.The rule also prohibits the burning of waste and hazardous materials, establishes a20% opacity limit and prohibits burning during restricted burning days.Federal Regulation or Guidance: EPA published the residential wood burning NSPSon February 3, 2015. The NSPS included a PM emission limit for outdoor wood boilershowever, the NSPS does not resolve the issues that may lead outdoor boilers to causenuisance emissions.Comparison of Other State Rules: Outdoor wood boilers have been banned in 16 towns in Connecticut – Rocky Hill,Granby, Tolland, Hebron, Woodbridge, South Windsor, Portland, Norfolk,Ridgefield, Haddam, Cheshire, West Hartford, Hamden, North Haven, NewFairfield and Avon. Manufacturers who wish to sell wood-fired hydronic heaters in Washington Statemust have the device tested using EPA Method 28 WHH or ASTM E2618 butusing Douglas fir test fuel; and submit test results to the State showing the deviceemits no more than 4.5 grams of fine particles per hour. This rate limit applies toboth the annual average emissions and the highest individual test run emissions.
DRAFT: August 21, 2017Salt Lake Area Source BACM Maine Department of Environmental Protection Chapter 150: Control ofEmissions from Outdoor Wood Boilers, establishes a particulate matter emissionlimit of 0.60 lbs/MMBtu heat input, setback and stack height limits.BACM Conclusion: Some Connecticut towns have also banned new sales. Theremaining state rules are less stringent than R307-208.Any replacement unit permitting under R307-208 would have to meet the NSPS. UDAQestimates that there are less than 50 outdoor wood burning units in the nonattainmentarea. This estimate is based on the number of people who attended the two publichearings held during the R307-208 public comment period.There are no opportunities beyond the current ban that would lead to further emissionreductions.R307-302 Solid Fuel Burning Devices: Residential fireplaces and wood stovescontribute PM emissions to the atmosphere. To minimize the amount of emissions fromthese devices, they are regulated by an opacity standard. When operated properly,these devices will produce visible emissions of less than 20% opacity from the chimneyor smoke stack. The proper operation of these devices is required to meet the visibleemission standard of 20% opacity during normal operation. The 20% opacity limitapplies at all times except for an initial start-up period of 15 minutes and a 15 minuteperiod in any three hour period for reloading the device.UDAQ issues mandatory no burn actions when PM2.5 levels build up to unhealthy levelsduring winter inversions. The no-burn period extends from November 1st to March 1st.R307-302 prohibit residents from burning wood or coal on no burn days. The Divisionreports current action levels twice a day to local media outlets such as newspapers, TV,and radio stations. The Division posts action levels on its Web site. Residents canregister to receive free e-mail air quality alerts or download the UtahAir app for Androids(Google Play) and iPhones (Apple Apps store, coming soon) to get the latestinformation on current conditions and air quality actions by county.
DRAFT: August 21, 2017Salt Lake Area Source BACMUDAQ Web Page ForecastNo solid fuel burning devices (including EPA certified units) are allowed to burn during amandatory action period unless the device was registered as a sole source of heatingfor the residence with the Division.Mandatory no burn days are called when the PM2.5 levels are forecasted to reach orexceed 25 µg/m3.The rule also includes prohibition on burning waste and hazardous materials.
DRAFT: August 21, 2017Salt Lake Area Source BACMFurther, the rule mandates that all solid fuel burning devices sold in the nonattainmentarea must meet the residential wood burning NSPS requirements. The exemptions inthe new NSPS are therefore not carried over into R307-302.Federal Regulation or Guidance: New Source Performance Standards for ResidentialWood Heaters applies emission rating for solid fuel combustion devices.Comparison of Other State Rules: SJ Rule 4901, Wood Burning Fireplaces and WoodBurning Heaters was evaluated and compared to R302-302. There are many similaritiesin the way the Rule 4901 and R307-302 are structured. The no burn thresholds are bothbased on forecasted PM2.5 levels. Rule 4901 no burn threshold is a range in which thelow point is set at 20 μg/m3 with an allowable exemption for EPA certified wood stovesthat have been inspected and registered with SJ. The no burn threshold in R307-302 isset at 25 µg/m3 but there is no exemption for any wood stoves therefore, R307-302 ismore stringent in that regard.R307-302 permits a real estate transfer containing a non EPA certified stove within aresidential dwelling that was installed prior to March 6, 2014 so long as the unit remainsintact within the real property of sale. Rule 4901 does not permit real estate transfercontaining a wood stove unless the wood stove is an EPA Phase II or better under acurrent NSPS, is a pellet stove exempt from EPA certification or is rendered inoperable.Rule 4901 is more stringent in this regard.BACM Conclusion: Overall, R307-302 is more stringent because there is noexemption from the NSPS, nor does it exempt EPA certified stoves.An area of improvement to R307-302 may be to consider a requirement to remove nonEPA certified stoves during real estate transactions, although that is likely beyondBACM.R307-303 Commercial Cooking: R307-303 was promulgated as RACT for chain-drivencharbroilers, which are predominately found in large fast food restaurant chains. Othercooking methods using underfire charbroilers and flat griddles account for more of thePM2.5 emissions from commercial cooking, but were notincluded in R307-303 because current control technologyoptions are limited for these types of cooking and carryextreme cost. Emission control cost to control underfirecooking range from approximately 10-40K/ton, depending onthe selected technology with capital cost that range from 3070K (SC restaurant emission analysis study, August 2009).Chain-driven CharbroilerFederal Regulation or Guidance: NoneComparison of Other State Rules: Bay Area Air Quality Management District Regulation 6, Rule 2, CommercialCooking Equipment. This rule applies to chain-driven charbroiler in a restaurant
DRAFT: August 21, 2017Salt Lake Area Source BACMthat purchases 500 pounds of beef or more per week or an under-firedcharbroiler in a restaurant that purchases 1,000 pounds of beef or more perweek and an aggregate grill surface area of ten square feet or more. The ruletargets PM10 emission reduction.R307-303 is intended to reduce direct PM2.5 and VOC and applies to allcommercial chain-driven charbroilers. Consequently, R307-303 is more stringentas it relates to this SIP. SC Rule 1138, Control of Emissions from Restaurant Operations.This rule is intended on controlling PM10 and VOC emissions. Rule 1138 requiresall chain-driven charbroilers that are used to cook 400 pounds or more meat perweek must install a catalytic oxidizer.R307-303 is more stringent than Rule 1138 because it applies to all chain-drivencharbroilers. Ventura County Rule 74.25, Restaurant Cooking Operations.The rule requires the same level of control as R307-303 but provides exemptionsthat are not included in R307-303; therefore, R307-303 is more stringentBACM Conclusion: There are no current opportunities for additional program revisionsthat would lead to further emission reductions.R307-307 Road Salting & Sanding: The purpose of this rule is to establish emissioncontrol for winter time road salting. This is an existing rule that was part of the PM10 SIP(Section IX, Part A, Page 57) that was approved by EPA on December 6, 1999 (64 FR68031). A RACT analysis was conducted as part of that SIP. The rule was amended byexpanding the applicability to include PM2.5 nonattainment areas as part of themoderate PM2.5 SIP. The actual PM emission reduction is unknown however, pastUDAQ studies have indicated that road salt plays a minimal role related to this SIP.Consequently, no further analysis is warranted.R307-309 Fugitive Emissions & Fugitive Dust: Establishes minimum work practices andemission standards for sources of fugitive emissions and dust. The rule applies to allconstruction and soil disturbance for areas greater than ¼ acre, requires BMP’s formining, sand & gravel processes and other types of fugitive dust generating activities.Sources must file a dust control plan using the DAQ form (online dust plan developmenttool) before commencing dust generating activities.Federal Regulation or Guidance: None
DRAFT: August 21, 2017Salt Lake Area Source BACMBACM Analysis:DAQ conducted a thorough analysis of the UDAQ fugitive dust program that included: A review of other arid western non-attainment air district fugitive dust rules Options described in the WRAP Fugitive Dust Handbook Internal UDAQ engineering and inspectors insights.The following table provides a summary of the analysis.RequirementUtahNevadaWashoeCounty, NVClarkCounty,NVMaricopa,AZSouthCoast, CASanJoaquinValley, CAConstruction & Excavation(acreage)0.255 construction1 acre soilclearing10.250.1510 res./5nonres.Demolition 1,000 Sq.Ft. 5 acres or100 cu. Yd.5 acres or100cu. Yd.Trenching---100 ft.---Bulk Materials Transport Carryout and Trackout - Open Areas Disturbance - Unpaved Vehicle &Equipment Traffic Areas Material Handling Storage Piles Mineral ProcessingOperations - 10 -20%20%000 -20%0 – 20%Additional activity specificrequirements - -Wind EventRequirements - ModerateUnclassifiableMaintenanceSeriousOpacity limits (%)(property boundary –onsite)PM10 ClassificationModerateModerate20%AttainThe outcomes of the analysis indicate that there are similarities between R307-309 andother state rules, especially the Clark County rule because it also requires use ofestablished fugitive control best management practices (BMP’s).
DRAFT: August 21, 2017Salt Lake Area Source BACMThe most significant rule revision to R307-309 was the development and requirement ofBMPs. Two BMPs are required of every plan, BMP 09 and 19 on the following table.These were determined to be most problematic for both air and stormwater due to soildisturbance projects. The following table shows the BMPs in the rule that address allfugitive dust source types.BMPProject Activity01Backfilling filling area previously excavated or trenched.02Blasting soil & rock, explosive blasting of soil and rock – drilling and blasting.03Clearing & grubbing, clearing and grubbing for site preparation and vacant land cleanup.04Clearing forms, foundations, slab clearing and cleaning of forms, foundations and slabs prior to pouring concrete.05Crushing of construction and demolition debris, rock and soil. Screening of rock, soil or construction debris.06Cut and/or fill cut and/or fill soils for site grade preparation.07Demolition – implosion, Implosive demolition of a structure, using explosives.08Demolition - mechanical/manual demolition of walls, stucco, concrete, freestanding structures, buildings and otherstructures.09Disturbed Soil THIS ACTIVITY MUST BE SELECTED FOR ALL PROJECTS.10Disturbed land - long term stabilization and erosion control of large tracts of disturbed land that will not have continuingactivity for more than 30 days.11Dust suppressants - selection and use of chemical and organic dust suppressing agents and other chemicalstabilizers.12Hauling materials.13Mining and reclamation operations.14Paving/subgrade preparation for paving streets, parking lots, etc.15Sawing/cutting material, sawing or cutting materials concrete, asphalt, block or pipe.16Staging areas, equipment storage, vehicle parking lots, and material storage areas.17Stockpiles materials (storage), other soils, rock or debris, for future use or export.18Tailings piles, ponds and erosion control.19Trackout Prevention and Cleanup THIS ACTIVITY MUST BE SELECTED FOR ALL PROJECTS.20Traffic - unpaved routes and parking, construction related traffic on unpaved interior and/or access roads and unpavedemployee/worker parking areas.21Trenching with track or wheel mounted excavator, shovel, backhoe or trencher.22Truck loading with materials including construction and demolition debris, rock and soil.Check AllThat ApplyXXBACM Conclusion: There are no current opportunities for additional program revisionsthat would lead to further emission reductions.
DRAFT: August 21, 2017Salt Lake Area Source BACMVOC BACM AssessmentSource CategorySurface Coatings, ArchitecturalSolvent, Consumer UseHousehold ProductsSolvent, Consumer UsePersonal Care ProductsPesticide Solvent DegreasingSolvent, Consumer Use AutoAftermarketCombustion, Wood, AllDevicesSolvent, Consumer UseCoatingsSolvent, Consumer UseAdhesive & SealantsSolvent, Consumer UseCoatingsSurface Coatings, HighPerformance Maintenance andTransportationSolvent, Graphic ArtsSurface Coatings, urface Coatings, WoodFurniture and FixturesUtah ExistingRules/Statute andFederal RulesR307-361 ArchitecturalCoatingsR307-357 ConsumerProductsR307-357 ConsumerProductsSurface Coatings, MetalFurniture4.314.353.302.63R357 ConsumerProductsR307-357 ConsumerProductsR307-357 ConsumerProductsR307-350 MiscellaneousMetal Parts & ProductsCoating2.302.302.302.18R307-351 Graphic Arts1.23R307-354 Auto BodyRefinishingR307-343 EmissionsStandards for WoodFurniture ManufacturingOperationsBakery Yeast24010254.85R307-302 Solid FuelBurning Devices40 CFR 49 Subtitle B25010602015.33R307-304 SolventCleaningR307-335 DegreasingR307-357 ConsumerProducts2302050000Fuel Gas/Gasohol UnderGround Storage Tank5.38R307-357 ConsumerProducts2505040120Fuel Gas/Gasohol PipelinesCommentsDAQ enforces FederalUST regulationsR307-346 MetalFurniture Week Day1.151.13U.S. Dept. ofTransportation isresponsible for pipelinesafety and spill preventionEstimated to cost at least 19,000/ton, requiresdouble-walled stainlesssteel stack plus catalyticoxidation of ethanol. Highcapitol cost would require arule with high applicabilitythreshold that wouldpreclude regulating mostbakeries that comprisethese emissions.1.100.850.840.78
DRAFT: August 21, 2017Salt Lake Area Source BACMSource CategoryResidential & CommercialPortable Gas CansEvaporation/Spillage etc.Fuel Gas/Gasohol Bulk PlantsFuel Gas/Gasohol Bulk PlantsCombustion, Natural Gas,ResidentialLeaking Underground StorageTanksCutback Asphalt PavingSurface Coatings, MetalContainersFuel Gas/Gasohol Stage 1Surface Coatings, Paper, Film,and 262003LandfillsCommercial CookingCombustion, Natural Gas,Commercial & Institutional2103006Surface Coatings, Machinery240100800Surface Coatings, AircraftSurface Coatings, FactoryFinished WoodFuel Gas/Gasohol Tank TruckTransportCombustion, Natural .69Title 19 Chapter 6 Part4 Underground StorageTank ActR307-341 CutbackAsphaltR307-352 MetalContainers, Closure &Coil CoatingR307-328 GasolineTransfer and StorageR307-344 Paper, Film &Foil CoatingR307-221 EmissionStandards: EmissionControls for ExistingMunicipal Solid WasteLandfills0.620.380.320.250.160.14Current rules only apply tovery large sources due toextreme cost (at least 15K/ton) Prohibitive costwould shutter mostsources.R307-356 AppliancePilot LightR307-350 MiscellaneousMetal Parts & ProductsCoatingR307-361 ArchitecturalCoatings25010800500.140.140.130.12Not technically feasible forjet fuel due to low vaporpressure (0.125 psi)R307-355 Control ofEmissions fromAerospace Manufacture& Rework FacilitiesR307-349 Flat WoodPanel CoatingR307-328 GasolineTransfer and StorageR307-312 AggregateProcessing Operations2014UncontrolledInventoryTons/winterWeek Day0.72R307-328 GasolineTransfer and StorageR307-328 GasolineTransfer and StorageR307-356 AppliancePilot LightFuel, Jet, Stage 12401075000Comments40 CFR Part 59, SubpartF, Control of Evap.Emission from New & Inuse Portable 32002401055000Surface Coatings, TrafficMarkingsUtah ExistingRules/Statute andFederal Rules0.090.080.050.050.04
DRAFT: August 21, 2017Salt Lake Area Source BACMSource CategorySurface Coatings, ElectricalSourceCategoryCode2401065000Backyard BBQ2810025000Commercial Cooking, ChainDriven Charbroiler2302002100263002Sewer Treatment in PubliclyOwned Treatment Works(POTW)Utah ExistingRules/Statute andFederal RulesR307-348 Magnet WireCoating250108012401085000Surface Coatings, OtherSpecial PurposeSurface Coatings, OtherSpecial Purpose240120024012002401080000Surface Coatings, MarineAll major POTW’s meetBest Available Technology0.03Not technically feasible forjet fuel due to low vaporpressure (0.125 psi)0.020.0020.010.010.01Solvent dry cleaners useno transfer machines thateliminate vapor loss duringtransfer from washing todrying. Additional built-incontrols includerefrigerated condensers.Some units also includebuilt-in stills to furtherrecover vapors. No furthercontrols would be feasible.Only controls developedfor LPG combustion are toreduce NOx emissions(EPA AP 42, Section 1.5)Solvent, Dry Cleaning210200721040070.030.03R307-350 MiscellaneousMetal Parts & ProductsCoatingR307-353 Plastic PartsCoatingsR307-350 MiscellaneousMetal Parts & ProductsCoatingR307-350 MiscellaneousMetal Parts & ProductsCoatingR307-353 Plastic PartsCoating2420Combustion, LPG0.04Statutory exemptionR037-303 CommercialCookingClean Water Act: allPOTW’s have to reportto EPA VOCconcentrations indischarges.Fuel, Jet, Stage 2Surface Coatings, erWeek Day0.010.01Fires, Structural281005Uncontrollable0.005Fires, Vehicle281005Uncontrollable0.0052401060000Surface Coatings, AppliancesTank Cleaning24611621040042102005Combustion, Oil28100601Cremation, HumanCombustion, Kerosene2103011000R307-347 LargeAppliance SurfaceCoatingR307-304 SolventCleaning0.0024.7 x 10-4EPA-600/2-75-069-aGuidelines for ResidentialOil-Burner AdjustmentsProcedures to Minimize AirPollutionCatalytic oxidizer controlcost would readily exceed 15,000/tonNo known control3.2 x 10-43.2 x 10-51.8 x 10-5
DRAFT: August 21, 2017Salt Lake Area Source BACMVOC Source Category AnalysisR307-221 Emission Standards: Emission Controls for Existing Municipal Solid WasteLandfills: The rule is intended to meet federal requirements noted below. Large landfillsmust reduce non-methane organic compounds by 98%.Federal Regulation or Guidance: 42 U.S.C. 7411(d) and 40 CFR 60.30c – 60.36c.There are no further rule enhancements.R307-304 Solvent Cleaning: R307-304 was adopted in 2017, which was originally partof the degreasing rule R307-335. UDAQ amended R307-335 by removing the IndustrialSolvent Cleaning sections R307-335-7 and 8 from R307-335. UDAQ believes that wecan achieve greater VOC emission control by including the former industrial solventcleaning sections into a new solvent use rule. The requirements for R307-335-7 werederived from the EPA guidance for industrial solvent cleaning (EPA 453/R-06-001). EPArecommends that states set industrial solvent cleaning rule applicability at 15 lbs. ofVOCs/day or approximately 720 gallons of solvent/yr. R307-304 provides a lowerapplicability threshold for gallons of solvent used than R307-335-7. R307-304 applies toall industrial solvent usage of 55 gallons or more in any 12 month period.Federal Regulation or Guidance: Control Techniques Guidelines for IndustrialCleaning Solvents.Comparison of Other State Rules: UDAQ’s analysis of various state and air districtrules that regulate industrial solvent cleaning indicates that most apply aqueous-basedsolvent cleaning limits based on density, which greatly limits solvent options. SJ Rule 4663, Organic Solvent Cleaning, Storage, and Disposal.Requires aqueous-based solvent cleaning with an applicability set at 55 gallonsor more of solvent products in any consecutive12 month period. Rule 4663 is themost stringent rule that UDAQ could identify that solely regulates industrialcleaning activities. SC Rule 1171 Solvent Cleaning Operations.The rule casts a wider net by including cleaning of many source types, includingcoating operations. SJ regulates coating sources and their cleaning requirementsin separate coating rules, therefore Rule 1171 is not directly comparable toR307-304. Sacramento Rule 466, Solvent Cleaning.This rule is similar to SJ Rule 4663.BACM Conclusion: The R307-304 rule applicability of 55 gallons in a calendar year(0.15 gallon/day) essentially regulates most industrial solvent cleaning and usage within
DRAFT: August 21, 2017Salt Lake Area Source BACMthe nonattainment area that are not already regulated under industry specific coatingrules.The use of vapor pressure instead of a density based limit offers more solvent optionswhile reducing evaporative losses, therefore is a preferred approach to limit VOCemissions.No further reduction opportunities were identified for R307-304.R307-328 Gasoline Transfer and Storage: Establishes emission controls for gasolinevapors during filling of gasoline cargo tank and storage tanks state-wide. The rule isbased on the federal stage I vapor recovery guidance.Federal Regulation or Guidance: Control of Hydrocarbons from Tank Truck GasolineLoading Terminals.Comparison of Other State Rules and BACM Conclusion: SJ Rule 4621, GasolineTransfer into Stationary Storage Containers, Delivery Vessels, and Bulk Plants wasreviewed and no further emission reduction opportunities were found.R307-335 Degreasing: Provides VOC emission control for large degreasing equipment.The rule was based on the EPA degreasing CTG. Large degreasing equipment havebeen phased out over the years such that we believe there are few left to regulate.Federal Regulation or Guidance: Control of Volatile Organic Emissions from SolventMetal Cleaning.Comparison of Other State Rules and BACM Conclusion: SJ Rule 4662,Sacramento Rule 454 and Ventura Rule 74.6.1 were reviewed and no further reductionopportunities were identified.R307-341 Cutback Asphalt: Cutback asphalt is a bituminous coating that has beenthinned with a petroleum distillate so that it may be applied without heat or low heat.Cutback is used during winter months to conduct road repair when asphaltmanufacturing plants are not operating. R307-341 limits the oil distillate content to 7%.Cutback is normally formulated with 10-40% of petroleum distillate in order to reducethe viscosity so that it is malleable.Federal Regulation or Guidance: Control of Volatile Organic Emissions from Use ofCutback Asphalt.
DRAFT: August 21, 2017Salt Lake Area Source BACMComparison of Other State Rules: The Colorado Department of Public Health and Environment Regulation Number7 XI permits the use of cutback asphalt during winter months without limiting theorganic content. SJ Rule 4641, Cutback, Slow Cure, and Emulsified Asphalt, Paving andMaintenance Operations permits up to 5% organic compounds.BACM Conclusion: UDAQ consulted with Asphalt Emulsion Industries, a manufacturerof cutback, to determine whether it is feasible to reduce the petroleum distillate to 5%. Arepresentative of the company stated that while special formulations down to 5% can bemade, they do not recommend doing so for safety reasons. When the organic content islowered to that extent, the product must be heated to 160 degrees Fahrenheit toincrease the malleable, which can result in product fuming and possible flaming.Consideration must also be given to local winter time temperatures and its influence onproduct malleability. Consequently, there is no further emission reduction opportunity.R307-342 Adhesive and Sealants: UDAQ adopted the most current Ozone TransportCommission (OTC) model rule. The model rule achieves VOC reductions through twobasic components: sale and manufacture restrictions that limit the VOC content ofspecified adhesives, sealants and primers sold in the state; and use restrictions thatapply primarily to commercial/industrial applications.A reasonably available control technology determination prepared by the California AirResources Board (CARB) in 1998 forms the basis of this model rule. In the years 19982001, the provisions of the CARB determination were adopted in regulatory form invarious air pollution control districts in California including the Bay Area, VenturaCounty, Sacramento Metropolitan and San Joaquin Valley.Federal Regulation or Guida
low point is set at 20 μg/m3 with an allowable exemption for EPA certified wood stoves that have been inspected and registered with SJ. The no burn threshold in R307-302 is set at 25 µg/m3 but there is no exemption for any wood stoves
6 SALT LAKE CITY PLAN SALT LAKE 81 EVENTS 3,035 COMMENTS RECEIVED 43 LOCATIONS CITYWIDE During 2012 and 2013, the Plan Salt Lake team undertook an extensive public engagement eff ort to identify what Salt Lake City residents and visitors value, and gather input on what the future vision for Salt Lake City should be. The team attended 81 .
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