Contrary to popular belief, industrial emissions, from things like refineries, mines, power plants, and waste facilities, are actually the smallest source of emissions in Utah. While the eyesore that industrial facilities can be makes them an easy target for public outcry, federal standards heavily regulate every facilities’ emissions. But this doesn’t mean that we can ignore industry emissions. We work with state regulatory offices to ensure that industry is doing all it can to control and lessen its emissions.
Our biggest concerns with industry emissions are industries’ transparency and compliance with federal and state standards. We address these things by reviewing industrial sources with experts, submitting technical comments to regulators, pushing for better transparency, and watchdogging large emitters and their compliance.
Subpart H review
The Subpart H review is part of the Serious State Implementation Plan. Subpart H specifically deals with industry sources by setting emission caps throughout the nonattainment area for every regulated facility. Taking into account the technological and economic feasibility of the industry’s best technologies (known as the best available control technology, or BACT) and assessments by each facility detailing what they are already doing, Subpart H will suggest caps and ways to reach them.
HEAL’s work comes in once the Subpart H suggestions, on caps and how to reach them, are complete, which they will be in the fall of 2018. We are consulting with a technical expert to determine whether the Subpart H suggestions go far enough to cut emissions. We will submit these technical comments to the Department of Air Quality to, hopefully, help them determine the best methods for getting our regions back into attainment.
Title V permit for Andeavor
Title V permits are a federal regulation, created by the Clean Air Act, on industrial facilities. The permit includes pollution control requirements from both federal and state regulations and reporting and modeling standards. Only facilities of a certain type and size are required to get this permit, and the Andeavor Refinery here in Utah falls under this category. Andeavor should have applied for this permit over 10 years ago but only recently filed it. HEAL reviewed their application and submitted comments on whether or not it was strong enough and where they should do more to report and control emissions. Andeavor’s Title V permit application is currently under review by the state and we are waiting for their analysis of the permit.