Emissions from Utah’s petroleum refineries are heavily regulated. The refineries have major source air permits with Best Available Control Technology, are subject to Title V permitting and comply with various EPA rules (e.g., rules for petroleum refineries, boilers, benzene waste, storage vessels, leak detection and repair, etc.). They also comply with Utah State Implementation Plans (SIPs) for prior air quality standards (now all attaining) and with Utah’s Moderate Ozone SIP for the NWF. In addition, the local petroleum refineries make and sell Tier 3 gasoline voluntarily for the area instead of applying credits generated elsewhere as allowed in EPA’s gasoline standards, thus reducing motor vehicle emissions. Modeling studies show that only about 25% of NWF ozone is caused by local emissions. Of that portion, almost half originates from motor vehicle and offroad mobile sources (examples include equipment for lawn and garden, construction, rail and airports). Large parts of NWF ozone come from international global sources, Utah biogenic sources and sources in the U.S. outside of Utah. The petroleum refineries supply only about 5% of local ozone-forming emissions. A t the end of the last administration, EPA finalized two adverse rulemakings for the state of Utah, one for the Northern Wasatch Front and one for the Uinta Basin (UB). If left in place, these rules would have costly and unnecessary impacts on our industry. In December, EPA completed a rulemaking that reclassified the Northern Wasatch Front (NWF) ozone nonattainment area, which includes all of Salt Lake City, its suburbs and the five petroleum refineries. This action will require significant new controls on emissions. EPA’s decision was flawed for a variety of reasons. The NWF has a long history of decreasing emissions of NOx and VOC, the two primary ozone precursor emissions to ozone formation in ambient air, but ozone has actually increased during this time. Figure 1. Ozone Design Value and Emission Trends (2011, 2014, 2017 and 2020) Northern Wasatch Front and Uinta Basin Ozone 11 UPDATE
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