Utah’s Northern Wasatch Front EPA ozone non-attainment area status likely to go from marginal to moderate – triggering RACT requirements for major sources

December 1, 2020

The Utah Division of Air Quality (UDAQ) recently provided letters to major sources in the Northern Wasatch Front non-attainment area (all or part of Salt Lake, Davis, Weber, and Tooele counties) indicating that they anticipate the Environmental Protection Agency (EPA) will reclassify the Nonattainment Area from marginal to moderate according to a November 18, 2020 Trinity Consultants report.

     Utah ozone non-attainment areas.

This reclassification is anticipated based on recent monitoring data which indicates the Northern Wasatch Front nonattainment area will not attain the current ozone standard (0.070 ppm) by the required attainment date of August 3, 2021. This reclassification of the area to moderate will likely be required in early 2022.

This anticipated bump-up from marginal to moderate classification will trigger new control strategy requirements for major sources in the Northern Wasatch Front nonattainment area. Specifically, the Ozone Implementation Rule requires the State Implementation Plan (SIP) to include Reasonable Available Control Technology (RACT) measures for all major stationary sources in nonattainment areas classified as moderate or higher.

The exact dates for the submittal of SIP RACT and RACT implementation will be announced when EPA publishes the notice of reclassification in the federal register. However, based on the general timeline provided in the Ozone Implementation Rule, UDAQ anticipates the following schedule:

1. Bump up to moderate early 2022
2. Moderate SIP will be due to EPA in early 2023, within 12 months from the effective date of reclassification
3. RACT measures will have to be implemented as expeditiously as practicable but likely before the end of 2023

UDAQ has determined the BACT analysis conducted during the PM2.5 Serious SIP for NOx and VOC emission units will satisfy the requirements of a RACT analysis for the moderate ozone SIP. Therefore, UDAQ will not require major sources to submit a RACT analysis if they were previously evaluated as part of the PM2.5 Serious SIP.

Additionally, UDAQ anticipates preparing the modeling emissions inventory for point sources in mid-2021. This emission inventory data will incorporate RACT to existing equipment and any anticipated changes to the facility. UDAQ will work with major sources to prepare the emission inventory data for each affected facility that will be included in the model.

UDAQ plans to hold an informational meeting, electronically, in the near future for those likely to be impacted by this reclassification. It is anticipated that the Southern Wasatch Front will meet the current ozone standard by August 2021 deadline and will not be affected by the above changes.

What this means to you
The Utah Division of Air Quality (UDAQ) recently provided letters to major sources in the Northern Wasatch Front (all or part of Salt Lake, Davis, Weber, and Tooele counties) indicating that they anticipate the Environmental Protection Agency (EPA) will reclassify the Northern Wasatch Front Ozone Nonattainment Area from marginal to moderate. The upgrade to moderate requires the State Implementation Plan (SIP) to include Reasonable Available Control Technology (RACT) measures for all major stationary sources.

MIRATECH can help
Contact MIRATECH for stationary engine NOx CO and VOC emissions control in Utah.