PM2.5 Serious Non-Attainment State Implementation Plan – Next Steps



On November 2, 2016, the Utah Division of Air Quality (UDAQ) held a meeting to discuss the PM2.5 Serious Non-Attainment Area Designation and potential impacts to sources.  UDAQ staff provided information regarding the new applicable regulations, and described the actions the UDAQ will be obligated to take to meet the new requirements.  A summary white paper was prepared by Trinity and UDAQ slides were developed and can be found here.

The next steps for sources subject to these requirements are as follows:

Next Steps

  1. USEPA will issue a letter to UDAQ establishing the Provo, Salt Lake and Logan Non-Attainment Areas as Serious non-attainment for PM2.5 and its precursors.
  2. UDAQ will send a letter to major sources that a Best Available Control Technology (BACT) and Best Available Control Measures (BACM) analysis is required to be completed.
  3. Each major source evaluates its processes, existing and available industry specific emission controls, emission limits, and prepares a BACT/BACM analysis for submittal to UDAQ.
  4. Discussion, negotiation, and finalization of a BACT/BACM review with UDAQ and associated revisions to approval order.
  5. UDAQ will establish State Implementation Plan (SIP) limits for each major source.
  6. Each source will be required to apply for Title V permit within 1 year of re-designation of the non-attainment area.

Trinity continues to work with clients on PM2.5 SIP related planning including but not limited to:

  • Preliminary evaluation of control technology analysis, so sources can make strategic plans and communicate with upper management.
  • Avoiding major source status through modifications of existing approval order with implementation enforceable conditions.
  • Anonymous contact with UDAQ to gain insight into requirements, timeline, and their approach.

Trinity has significant experience in developing BACT/BACM analyses through multiple industries and has been working with sources and speaking to UDAQ on a continual basis to understand their approach as they develop a plan to bring the area into attainment.