Salt Lake Inland Port Clean Air Plan EPA Clean Ports Program Climate and Air Quality Planning

Quality Assurance Project Plan

August 18, 2025

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List of Acronyms

Acronym Definition

CPP Clean Ports Program

CAQP Climate and Air Quality Planning

DQI Data quality indicator

DQO Data quality objective

EI Environmental Information

EIO Environmental information operation

EPA Environmental Protection Agency

FAF Freight Analysis Framework

FPM Future Projection Method

NAAs Nonattainment areas

NOx Nitrogen oxide

O3 Ozone

PE Primary estimate

PM Project Manager

PM10 Particulate matter with an aerodynamic diameter less than or equal to 10 microns

PM2.5 Particulate matter with an aerodynamic diameter less than or equal to 2.5 microns

PO Project Officer

PTT Primary technical team

QA Quality assurance

QAM Quality Assurance Manager

QAPP Quality Assurance Project Plan

QC Quality Control

RC Reference Case

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Acronym Definition

RFP Request for Proposal

SLCIT Salt Lake City Intermodal Terminal

SLIPCAP Salt Lake Inland Port Clean Air Plan

SO2 Sulfur dioxides

TL Task Leader

TM Task Manager

UDAQ Utah Division of Air Quality

UDEQ Utah Department of Environmental Quality

UIPA Utah Inland Port Authority

U.S. United States

UP Union Pacific

VOC Volatile organic compounds

ZE Zero-Emission

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● A.1 Title Page

Quality Assurance Project Plan for Utah Clean Ports Program

Climate and Air Quality Planning Salt Lake Inland Port Clean Air Plan

Grant ID Number:

14155847

Prepared by:

Utah Inland Port Authority

60 E S Temple St #600 Salt Lake City, Salt Lake County, UT

84111

Prepared for:

US EPA, Region 8

Air Permitting & Grants Management Branch Air and Radiation Division, EPA Region 8

1595 Wynkoop Street Denver, CO

80202

Date prepared:

August 18, 2025

Period of Applicability:

January 15, 2025 - January 14, 2028

Scope:

Per EPA Quality Assurance Project Plan (QAPP) Standard revised April 3, 2024, work products that rely on Environmental Information Operations https://drive.google.com/file/d/1oMFj57h19eyNABjX7PpM8LFyFPyRTGCR/view?usp=drive_link

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● A.2 Approval Page

___________________________________________________ 08/18/2025 Mona Smith, Project Manager (PM) Date

Amy Brown Coffin, Quality Assurance Manager (QAM) Date

Sara Key, EPA Regional Project Officer (PO) Date EPA Region 8

____________________________________________________ Date Mary Goldade, EPA Regional Quality Assurance Manager (RQAM) or Delegated Approval Official (DAO) EPA Region 8

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QAPP Revision History Revision # Date Author Description of Change 0 08/18/2025 Mona Smith Original revised draft version

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● A.3 Table of Contents, Document Format, and Document Control

Table of Contents

Group A: Project Management and Information/Data Quality Objectives A.1 Title Page 3 A.2 Approval Page 4 A.3 Table of Contents, Document Format, and Document Control 6 A.4 Project Purpose, Problem Definition, and Background 7 A.5 Project Task Description 14 A.6 Information/Data Quality Objectives and Performance/Acceptance Criteria 20 A.7 Distribution List 25 A.8 Project Organization 27 A.9 Project QAM Independence 30 A.10 Project Organizational Chart and Communications 31 A.11 Personnel Training/Certification 33 A.12 Documents and Records 34 Group B: Implementing Environmental Information Operations B.1 Identification of Project Environmental Information Operations 36 B.2 Methods for Environmental Information Acquisition 44 B.3 Integrity of Environmental Information 46 B.4 Quality Control 47 B.5 Instruments/Equipment Calibration, Testing, Inspection, and Maintenance 51 B.6 Inspection/Acceptance of Supplies and Services 52 B.7 Environmental Information Management 53 Group C: Assessment and Oversight C.1 Assessments and Response Actions 55 C.2 Oversight and Reports to Management 57 Group D: Environmental Information Review and Usability Determination D.1 Environmental Information Review 59 D.2 Usability Determination 62 Appendices Appendix 1 List of Tables and Figures 64

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● A.4 Project Purpose, Problem Definition, and Background

The purpose of this project is to complete a baseline emissions inventory for port vehicles and equipment (drayage trucks, cargo-handling equipment, locomotives, and other non-road equipment) servicing the Salt Lake City Intermodal Terminal (SLCIT) and evaluate emission reduction strategies for the SLCIT, an eligible dry port for the United States (U.S.) Environmental Protection Agency’s (EPA’s) 2024 Clean Ports Program (CPP) and target area of this Climate and Air Quality Planning (CAQP) project.

To implement this project, the project team will define the problem by collecting Environmental Information (EI) for port activities at the SLCIT that impact local air quality. The project team will work with fleet owners and operators to complete a quantitative emissions inventory of port vehicles and equipment servicing the SLCIT to better understand overall emissions and relative contributions of different mobile source sectors at the SLCIT. The emissions inventory will be developed using the number of port vehicles and equipment operating at the SLCIT along with data on associated operational activity combined with appropriate emission factors.

The question to be answered by the project team involves using the EI collected from the baseline emissions inventory for the non-regulatory identification and assessment of effective emissions reduction strategies that provide the greatest potential for reducing adverse impacts of port operations at the SLCIT to local air quality.

The geographic domain of this project is confined to the SLCIT, located in the Utah Inland Port Authority (UIPA) jurisdictional area in the Northwest Quadrant of Salt Lake City, Utah. The SLCIT is located in PM2.5 (particulate matter with an aerodynamic diameter less than or equal to 2.5 microns) and ozone (O3) nonattainment areas (NAAs) in Salt Lake County, Utah, a county listed on the EPA CPP Disadvantaged Community County List. This area is also listed by EPA as having high ambient diesel particulate matter concentrations. The SLCIT opened in 2006 and is owned and managed by Union Pacific (UP). The SLCIT is a dry port where shipments from as far away as Montana are trucked to and from the UP’s intermodal trains. The Salt Lake City International Airport, locaUP railroad, and thousands of distribution centers and terminals create an important nexus of freight movement and commerce. Figure 1 shows the spatial boundaries of the site. The temporal boundaries of the site will include data from the years 2010 to 2025.

As the central point of the Western U.S., Utah boasts access to dry ports, intermodal hubs for warehousing and distribution, and is home to some of the country’s largest trucking companies, carriers, and suppliers. The previously mentioned distribution centers and terminals include United Parcel Service (UPS), FedEx Ground, Home Depot, Amazon, Walmart, and more. Diesel vehicles and equipment are at the center of these inland ports and are used to sort, prioritize, move cargo, and load/unload their daily deliveries. Thousands of delivery trucks and diesel equipment are consolidated in these locations at the same times every day, creating a heavy presence of diesel emissions. Goods movement is only expected to grow in the coming years as

Rev. 0 | 08/18/2025 UIPA | CAQP SLIPCAP QAPP Page 8 of 65 population is expected to double and state leaders work to position Utah for becoming a global logistics and distribution hub to the world through UIPA’s efforts.

As discussed further in Section 4 of this application, emissions from diesel vehicles and equipment negatively impact air quality and the health of Utah’s communities, especially the near-port communities in Salt Lake County. Nitrogen oxides (NOx) and direct PM emissions from diesel engines contribute to the ozone challenges the State experiences during the summer months and the PM2.5 challenges the State experiences during wintertime inversions. Reducing diesel emissions is important since areas throughout the state of Utah are in nonattainment for EPA’s national ambient air quality standards (NAAQS) for ozone and PM2.5, leading to statutory Clean Air Act (CAA) requirements as well as degraded quality of life for the residents of these areas. Utah’s meteorology and unique natural characteristics are also important factors in the buildup of pollution in its nonattainment areas.

Diesel emissions contribute to approximately 50% of total NOX in the Wasatch Front airshed. In a study conducted by the Utah Division of Air Quality (UDAQ), the agency evaluated on-road and non-road diesel emissions in the urbanized areas of the Northern Wasatch Front (NWF) where the SLCIT is located and determined that the majority of on-road diesel emissions comes from combination long-haul trucks (51.5% of on-road diesel emissions), and the majority of non-road diesel emissions comes from locomotives/railroad equipment (57.3% of non-road diesel emissions).

UIPA was established in 2018 by the Utah State Legislature and is a statewide organization that oversees inland port project areas, economic development activities, and logistics projects. The purpose of UIPA is to fulfill the statewide public purpose of working in concert with applicable state and local government entities, property owners and other private parties, and other stakeholders to encourage and facilitate development of land in UIPA project areas to maximize the long-term economic and other benefits for the state.

The Salt Lake City inland port jurisdictional area is mostly privately held and the UIPA was created to lead and implement sustainable logistics solutions that not only meet the needs of Utah’s growing population, but also protect the state’s precious natural resources. UDAQ has established two ambient air monitoring facilities around the inland port jurisdictional area in Salt Lake City to track pre-development and early development baseline data. These facilities include a sensor system consisting of monitors to measure levels of PM, ozone, and NOx.

However, a more holistic emission inventory and climate/air quality planning process is needed for the area.

Therefore, UIPA’s overall project approach for this CAQP application can be summarized as supporting robust climate and air quality planning activities in order to voluntarily reduce greenhouse gas (GHG) emissions and associated co-pollutants, create high-quality jobs, spur economic growth, and enhance the quality of life for Utahns, especially Salt Lake County’s near-port communities. As required, UIPA’s CPP project focused on the SLCIT will undertake: 1) a baseline emissions inventory process and other accounting practice activities and 2) community

Rev. 0 | 08/18/2025 UIPA | CAQP SLIPCAP QAPP Page 9 of 65 and stakeholder engagement activities. For the baseline emissions inventory, UIPA and its contractors will reference EPA’s Port Emissions Inventory Guidance. Potential data collection as a part of this process may include stakeholder interviews and surveys, truck counts/traffic studies, and emissions monitoring devices. While not required, UIPA also will pursue other planning activities including: 3) an emissions reduction strategy analysis and 4) Zero-Emission (ZE) feasibility assessment (including site design/engineering studies and a workforce impact analysis), because of how critical ZE technology can be to the long-term sustainability and success of the SLCIT and surrounding port area. Emission reduction strategy analysis may include scenario analysis (i.e., analysis of different approaches to reducing emissions) and stakeholder engagement as needed. As discussed further in other parts of this application, extensive near-port community engagement is also a key part of this proposal; UIPA’s community engagement efforts will help to identify and prioritize emissions sources to address.

The results of this CAQP effort will help inform the parallel ZE Technology Deployment effort led by UDAQ in their CPP application. UIPA anticipates that our combined CPP proposals will create transformational change across local freight operations because any adoption of ZE vehicles and equipment at the SLCIT would be the first-of-its-kind for Utah’s port areas, providing a viable example for other UIPA project areas as well.

By engaging in these activities, UIPA’s project will meet the CPP’s goals to:

● Build a foundation for the port to transition to fully ZE operations, positioning the port to serve as a catalyst for transformational change across local freight operations;

● Reduce mobile source pollution in near-port communities, especially disadvantaged communities; and

● Help ensure that meaningful community engagement and emissions reduction planning are port industry standard practices.

These activities will meet these goals as evidenced by the previous overview and the anticipated GHG and co-pollutant reductions, planned benefits to near-port/disadvantaged communities, and commitment to long-term sustainability of the project, etc., provided throughout the rest of this application.

As previously described, the project will be located in Salt Lake County which is in nonattainment for the 2015 8-hour ozone and 2006 PM2.5 standards. As previously described, the project will be located in Salt Lake County which is a disadvantaged community/area with air toxic concerns.

Additionally, provided in Figure 3 below is Diesel Particulate Matter Supplemental Environmental Justice Index information about UIPA’s Salt Lake City jurisdictional area (included within the boundary on the figure) where UP’s SLCIT is located.

The project team will estimate port-related emissions for the following pollutants:

● Nitrogen oxides (NOx)

● Particulate matter with an aerodynamic diameter less than or equal to 2.5 microns (PM2.5)

● Particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM10) https://www.epa.gov/ports-initiative/port-and-goods-movement-emission-inventories

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● Sulfur dioxide (SO2)

● Volatile organic compounds (VOC)

● Ozone (O3)

The sources to be included in this analysis include off-road mobile equipment and on-road vehicles such as drayage trucks, cargo-handling equipment, locomotives, and other non-road equipment servicing the SLCIT.

The project team will use methodologies and estimates consistent with the EPA’s Port Emissions Inventory Guidance: Methodologies for Estimating Port-Related and Goods Movement Mobile Source Emissions1 for all emissions estimates included in this baseline emissions inventory.

Emission reduction strategy analysis will include Reference Case (RC) scenario analysis (i.e., analysis of varying percentages of vehicle and equipment transition to ZE) and stakeholder engagement as needed. The RC analysis will evaluate unique emissions reduction strategies which may include a unique combination of strategies. The results of this analysis will help inform the parallel CPP ZE Technology Deployment effort led by the Utah Department of Environmental Quality (UDEQ) Utah Division of Air Quality (UDAQ). Where emissions reductions strategies are based on replacing older models with newer (more efficient) models based on substantially the same technology, emissions reductions will be based on datasheets provided by the manufacturer of the proposed (or evaluated) new technology.

When preparing the emissions inventory, quality assurance (QA) should include: data source verification, cross-checking calculations, using standardized and current EPA emission factors, documenting assumptions and methodologies, implementing data quality checks, and comparing results to historical activity trends or industry benchmarks to ensure accuracy and reliability of the estimates throughout the inventory development process. The Climate Pollution Reduction Grants Implementation grant QAPP template was used as a QA planning document. It was utilized as a template to develop UIPA’s QAPP.

The Clean Ports Program is part of the Inflation Reduction Act of 2022 and provided the EPA with funding for ZE port equipment and infrastructure as well as climate and air quality planning at U.S. ports. Reducing emissions and improving air quality are some of the goals outlined in the Clean Air Act. Reducing diesel emissions is important since areas throughout the State of Utah are in nonattainment for EPA’s national ambient air quality standards for ozone and PM2.5, leading to statutory Clean Air Act requirements as well as degraded quality of life for the residents of these areas. Utah’s meteorology and unique natural characteristics are also important factors in the buildup of pollution in its nonattainment areas.

1 U.S. EPA Office of Transportation and Air Quality Transportation and Climate Division, Port Emissions Inventory Guidance: Methodologies for Estimating Port-Related and Goods Movement Mobile Source Emissions, EPA-420-B-22-011, April 2022, https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P1014J1S.pdf

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● A.5 Project Task Description

Environmental information operations (EIOs) for this project will be completed during the period of applicability for this grant (14155847) under the following tasks that perform the following analyses and produce the following work products:

1. Identification of activity level data sources for the SLCIT,

2. Preparation of the baseline emissions inventory,

3. Development of emission reduction strategy analysis, and

4. Development of standardized documentation for the EI data sets.

Each task is further detailed in the following sections. The schedule for these tasks and associated work products is outlined below. The spatial boundary of this project includes the SLCIT while the temporal boundary includes 2020-2040.

● Figure 1: UIPA’s Salt Lake Jurisdictional Area, one of UIPA’s twelve statewide inland port project areas, includes the UP-owned SLCIT and is located in the Northwest Quadrant of Salt Lake City, a geographical location that accommodates national trucking flows (shown in Figure 2) making Utah the "Crossroads of the West” for freight traffic and providing a life-line to critical transportation arteries for freight distribution coast to coast and between Canada and Mexico.

Now, Interstates 15, 80, 84, and 70 (and other freight routes) provide connections to Utah’s central transportation network, which serves as a strategic hub for highway, rail, and air freight in the Western U.S.

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● Figure 2: Estimated Freight Analysis Framework Flow for trucks passing through Utah on National Highway System, 2017.

● Figure 3: Northern Wasatch Front Ozone Nonattainment Area Diesel Particulate Matter state percentiles as shown by EPA’s Environmental Justice Screening and Mapping Tool, EJScreen

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● Figure 4: UIPA CPP CAQP SLIPCAP QAPP Proposed Schedule

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Task 1. Identify activity level data sources for the SLCIT.

The compiled data about the SLCIT and its operations will provide useful insight that will support the emissions inventory efforts as well as assessment of viable emissions reduction options within the spatial (SLCIT) and temporal (2020-2040) boundary of the site. The data will be compiled from existing data sources if possible. If this data is not available, then the data will be collected via surveys gathered from UP. This will include compiling and evaluating data which may include, but not be limited to the following sources:

● Current and historical industry indicators and activity data for the SLCIT spatial boundaries that are newer than 2020.

● Any publicly available global and U.S. or regional trade forecasts or freight movement trends expected to impact future SLCIT activity and associated emissions projections within the spatial boundaries (SLCIT) as well as between 2020-2040.

● Potential future changes in distribution patterns across the multiple modes at the SLCIT such as increasing numbers of shipping containers, expansions of rail and trucking, and implications for cargo distribution centers, warehouses, etc. within the spatial boundaries of the SLCIT. Future changes will include a temporal boundary of 2040.

● Any existing or planned future environmental, energy, operational systems management, or other programs that could inform the analysis of this project from the years 2020-2040 for the SLCIT spatial boundary

● Potential state, local, or private incentives and barriers to increasing technological and operational emission reduction strategies at the SLCIT spatial boundaries in the future up to 2040.

Task 1 Work Products:

1. Listing of all SLCIT activities to be included in baseline emissions inventory within the SLCIT spatial boundary and temporal boundary of 2020-2040.

2. Listing of available data sources or surrogates that show historical variations in SLCIT activities within the SLCIT boundary and from data sources that are from 2020 or newer.

3. Relevant schedules and anticipated activity-level impacts of non-project-related, planned, capital improvements that should be included in future emissions projections.

This will include a temporal boundary of 2020-2040 and a spatial boundary of the SLCIT.

4. A DRAFT emissions inventory framework that is compatible with available data resources on historical and future SLCIT spatial boundary activity data for a temporal boundary of the years 2020-2040. The DRAFT framework will be submitted to the Project Manager (PM), Quality Assurance Manager (QAM) Task Manager (TM), and all Task Leaders (TLs) for review, deliberations, and finalization prior to beginning work on subsequent tasks.

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Task 2. Prepare the Baseline Emissions Inventory.

The primary technical team (PTT) will use the following strategies to ensure that the SLCIT’s baseline emissions inventory reflects all SLCIT activities that can significantly impact local air quality within the spatial (SLCIT) and temporal boundaries (2020-2040) set.

The framework will be based on appropriate activity-level data inputs and the EPA’s latest emissions models, methods, and standards, as described in the most recent version of the EPA’s Port Emissions Inventory Guidance. All calculations that show significant emissions reductions must include the documentation of activity levels and equipment characteristics, including manufacturer data sheets for evaluated new equipment. If manufacturer data sheets are available for the old equipment being evaluated for replacement, these “old” sheets will also be included in the report or otherwise made available to both the PTT and the Quality Control (QC) team.

The PTT will evaluate different methodologies, activity data sources, and emissions data sources that are available for characterizing air emissions from port equipment servicing the SLCIT.

The PTT will also provide sufficient details as needed for assessing emission reduction strategies by providing comparable emissions calculations for the baseline and ensuring that baseline methodologies are compatible with the methodologies used for any future projections.

Task 2 Work Products:

1. Baseline emissions inventory using a framework approved by the Project Manager in consultation with the TM and all TLs for the spatial boundary of the SLCIT and the temporal boundary of data sources that are from 2020 or newer.

https://drive.google.com/file/d/1wbcKgumVSs0gUUiEmIk9tAaSO4Z8iBdi/view?usp=drive_link

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Task 3. Development of Emission Reduction Strategy Analysis.

This task will focus on evaluating future year viable control options to reduce SLCIT-related emissions. Work products from Tasks 1 and 2 will be used to develop five similar but distinct analyses to enable comparisons of the emissions reductions, costs, and local air quality benefits of five distinct RC options (0%, 25%, 50%, 75%, and 100%) for SLCIT equipment replacements. In addition to completing five stand-alone analyses, the Task 3 leader will produce a one-page summary table to facilitate quick comparison of all five RC options. This work will be done for the spatial boundaries of the SLCIT as well as the temporal boundaries of data from 2020 or newer and a future temporal boundary of 2040.

Task 3 Work Products:

1. Five separate analyses documenting review of the five reduced-emissions RC scenarios that each address the following aspects to be considered during option selection (these will show estimations for up to the year 2040 and within the spatial boundaries of the

SLCIT):

a. Total estimated reductions by pollutant for all pollutants reduced in any of the five RCs. This requirement must be formatted to facilitate comparisons by pollutant across all RCs and will have the spatial and temporal boundaries of the SLCIT and up to the year 2040 based on data that is from 2020 or newer.

b. Total estimated cost of new equipment with associated vendor estimates attached considering spatial boundaries for the SLCIT and the temporal boundaries of 2020-2040.

c. Total estimated downtime of any port operation required for implementation with concurrence from senior SLCIT operations official for the SLCIT spatial boundary and up to the year 2040.

d. Summary of annual and seasonal ambient air quality improvements and associated attainment status of each pollutant showing reductions in strategy selection analyses up to the year 2040 and within the SLCIT spatial boundary.

2. One-page summary table comparing each of the five RC options to the baseline inventory and, upon selection, a one-page summary of the rationale for selecting the RC option approved by UP. This will include the spatial boundary of the SLCIT and data or estimations for the years 2020-2040.

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Task 4. Document EI Data Sets.

This task will focus on compiling the reports developed in the earlier tasks into a single, comprehensive report that clearly documents the activities implemented in a transparent and concise manner allowing for independent replication of the procedures used. The Task 4 Leader is responsible for ensuring each of the primary work products under Tasks 1-3 reflect the same emissions activities, the same framework for activity data and emissions calculations, and the same conventions for comparing RC attributes. This will include the SLCIT spatial boundary and the temporal boundaries of data newer than from the year 2020 and predictions within the year 2040.

Task 4 Work Products:

1. DRAFT compilation of all work products using a standard framework and format for review by all TLs. This will include the SLCIT spatial boundary and the temporal boundaries of data newer than from the year 2020 and predictions within the year 2040.

2. Final compilation of all work products using a standard framework and format for review by all TLs including an approval sheet and signatures by all TLs, the PM, and the QAM.

This will include the SLCIT spatial boundary and the temporal boundaries of data newer than from the year 2020 and predictions within the year 2040.

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● A.6 Information/Data Quality Objectives and Performance/Acceptance Criteria

The following DQOs are for existing information and secondary information that may be gathered throughout the project. The following primary data quality objectives (DQOs) and data quality indicators (DQIs) of this project are aligned with the EI sets and EIOs that are required to reliably achieve the project’s purpose of comparing data sets and identifying the most effective strategy for reducing the air quality impacts of port operations:

DQO 1. The listings of emissions sources, activity data, and pollutants in each of the sets of EI (baseline and RC reduced-emissions projections) used for the options analyses must be comprehensive (i.e., cover all relevant SLCIT operations). This will be measured by comparing the listing of used sources to the listing of all sources.

DQO 2. The activity data must be available in a primary form or in conjunction with other primary data sources to allow disaggregation of shared energy supplies to each discrete activity on the Master List. DQIs such as the accuracy and precision of such data sources will be regularly assessed during data collection and reporting periods. For precision, measurements from data sources of the same property that have substantially similar conditions will be expected to be in agreement with each other. If this is not apparently true, data sources will be checked to ensure there is an understanding of why similar conditions led to different outcomes and why the measure of agreement among repeated measurements of the same property under identical, or substantially similar conditions, was not true. To ensure accuracy and a lack of bias in the data collection process, the overall agreement of measurements to any known values will be measured. Additionally, the sensitivity of such data sources will be regularly assessed during data collection and reporting periods. Differences in the measurement responses represented at different levels of the variable of interest will be expected. If these differences do not occur, the sensitivity or detection limit capability of the method of data collection or instruments from the data sources will be researched and ensured to be encompassing of accurate data and able to detect and discriminate between measurement responses representing different levels of the variable of interest.

DQO 3. The activity data for a discrete, listed activity must be representative of all sources included under that activity, and the operating year(s) when the activity data was recorded must be representative of normal SLCIT operations and the facilities in service during the baseline period. Such representativeness for the use of activity data for groups of dissimilar equipment (e.g., activities served by both older diesel engines and newer diesel engines) may also be captured through available manufacturer

Rev. 0 | 08/18/2025 UIPA | CAQP SLIPCAP QAPP Page 20 of 65 data sheets or engine-specific fuel consumption logs and will be assessed using the following approach:

a. The data quality rating of “A” under Table 1-1 will be assigned to all activity data for engines supported by manufacturer’s data sheets or fuel consumption records.

b. The data quality rating of “B” under Table 1-1 will be assigned to any engine activity data that is not based on an engine-specific manufacturer’s data sheet but where the engine’s activity data are derived from the engine’s certification plate and the plate is substantially the same certification level and output rating as an engine accompanied by the manufacturer’s data sheet.

c. The data quality rating of “C” will be assigned to any engine activity data that is not based on an engine-specific manufacturer’s data sheet but where the engine’s activity data are derived from the engine’s certification plate and the plate is not substantially the same certification level but has a similar output rating as an engine accompanied by the manufacturer’s data sheet. Fuel consumption is derived from comparison of the engine’s certification plate output rating versus the most similar engine with a different certification level but similar output rating and the manufacturer’s data sheet.

d. The data quality rating of “D” will be assigned to any engine that does not have the engine-specific manufacturer’s data sheet where no similar engines are identified, and the fuel consumption estimate is based strictly on the engine’s certification plate’s output rating.

e. A data quality rating of “E” will be applied to any engine that does not have a certification output plate indicating the output rating of the engine.

DQO 4. The emissions estimating methodologies for different activities must be comparable, and technical staff should characterize (using Table 1) and publish the uncertainty of each activity-specific methodology to ensure that technical staff tasked with comparing reductions by activity can consider the uncertainty in each estimate included in the comparison. Comparability of data produced with different methodologies will be assessed by the difference between the Table 1 rankings. Acceptable comparisons are A-A, A-B, A-C, B-B, B-C, B-D, C-C, C-D, and D-D.

DQO 5. The activity data must be complete and reflective of all the equipment listed under each activity. Any missing activity data must be disclosed to the PM and QAM, and the PM or their delegate must develop a data substitution protocol for review and approval by the QAM when more than 10 percent of the activity data is missing for the baseline year. The quantity of missing data (i.e., completeness) is

Rev. 0 | 08/18/2025 UIPA | CAQP SLIPCAP QAPP Page 21 of 65 a key characteristic. If less than 10 percent of the activity data for a year is missing, the activity data set is acceptable.

The compiled data under each of the sets of EI (baseline and RC projections) will be evaluated relative to this specific project's data quality objectives. This evaluation will include: all data compiled for the project including SLCIT mobile sources and any additional data needed to develop the emissions reduction RC scenarios. All compiled primary data will be ranked based on the criteria in the table below:

● Table 1: Primary Data Quality Ranking Score

Rank Quality Source

A Highest Federal and state agencies and laboratories

B Second Independent journal articles, academic studies, and manufacturer product literature: peer-reviewed

C Third NGO studies, trade journal articles, and conference proceedings:

peer-reviewed

D Fourth Conference proceedings and other trade literature:

non-peer-reviewed

E Lowest Individual estimates

These rankings will be recorded on the project QA Documentation Sheets.

Primary Data Needs

Primary data that quantifies rail, truck, and cargo handling equipment characteristics and operations is the priority for this work. Any primary data used in this study must be the highest quality data publicly available derived from unbiased data sources and should be appropriate and representative for analysis of this emissions inventory. Anticipated primary data include but are not limited to:

● annual odometer readings by source type (onroad)

● annual hours of use by source type (nonroad)

● engine specifications

● fuel usage

● levels of operation

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Secondary Data Needs

Given the nature of this study, collecting and using primary data that quantify rail, truck, and cargo handling equipment characteristics and operations will be given priority over secondary data sources. This project may need to collect and use aggregated data for purposes other than the purposes for which those aggregated data were originally developed. Such data is known as secondary data. The project team will attempt to minimize the use of secondary data where possible. But it may be necessary to compile secondary data elements such as:

● EPA emission factors

● equipment type

● equipment expected lifespan

● fuel type

● rated engine power

● retrofit devices or other emission mitigation measures employed (if applicable)

● aggregated data used for future year projections

● control profiles that quantify anticipated emission reduction and fuel savings

● temperature and relative humidity

● fuel formulation and supply

● inspection and maintenance coverage

● Stage II refueling program presence and efficiency

● vehicle miles traveled and population

● average vehicle speed distributions by source type (vehicle/equipment)

● annual hours of usage by source type, with temporal allocations

Approach for Evaluating Project Objectives

Data gathered for Tasks 1 and 2 will be evaluated relative to the DQOs 1-5 and primary data quality ranking scores noted in Table 1 to ensure that data are appropriate for use in this study and represent the highest quality currently available. This will ensure that the study will generate information suitable for a variety of uses.

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During the data gathering phase of this project, information about how the data were originally identified and collected will be documented, including:

● Source of the data (e.g. federal and state agencies, consultants, shipping lines, railroad companies, fleet operators, etc.)

● Whether the data identify locomotive, vehicle or cargo handling equipment used for SLCIT activities, this would include:

○ equipment/engine characteristics

○ operations

○ fuel/energy usage data

○ emissions factors

○ load factors

○ temporal data elements

○ spatial elements

○ relevant regulations

○ previous and planned equipment retrofit and early retirement programs

○ anticipated changes to the SLCIT, nearby railroads, yards, trucking terminals and warehouses

○ control options

For many cases, the most appropriate representation of the data will not be a single data value, but a range of acceptable values. Such information is particularly important when evaluating the quality of the data because it helps quantify variance and uncertainty. Data value ranges will be retained and provided as a data quality indicator.

There may be cases where information related to this project's data quality objectives is not available from the data source; these data will be flagged in the QA Documentation Sheets and discussed with the TM and PM to determine whether the data are acceptable for inclusion in this analysis.

The quality assessment of the compiled data will be recorded in the QA Documentation Sheets, including the quality ranking score (Table 1) as well as comments or issues identified by the TLs, TM, or the PM. It will also be noted whether the data meet the project's data quality objectives and whether the appropriate data entry and calculation checks have been made. These QA Documentation Sheets will be included in the project report.

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● A.7 Distribution List

The original Quality Assurance Project Plan (QAPP), and any subsequent revisions, will be distributed to the personnel presented below. Additionally, this QAPP will be provided to any unlisted staff who are assigned to perform work under this project. A secured copy of this QAPP and any subsequent revisions will be maintained in the project files located on UIPA’s shared drive at <https://drive.google.com/drive/folders/1mo819nNdoskIcRaZUkXTJzC5i5zAhuAX>.

● Table 2: Distribution List

Name Role Organization Email Address/Location

Mona Smith Project Manager (PM)

Utah Inland Port Authority smsmith@utah.gov 60 E S Temple St #600, Salt Lake City, UT 84111

Ben Hart Senior Manager

Utah Inland Port Authority blh@utah.gov 60 E S Temple St #600, Salt Lake City, UT 84111

Amy Brown-Coffin

Quality Assurance Manager

(QAM)

Utah Inland Port Authority abrowncoffin@utah.

gov

60 E S Temple St #600, Salt Lake City, UT 84111

Michelle Bohnen

Task Manager

(TM)

Utah Inland Port Authority michellebohnen@uta h.gov

60 E S Temple St #600, Salt Lake City, UT 84111

Sara Key EPA Project Officer (PO) & Delegated Approving Official

EPA Region 8 key.sara@epa.gov 1595 Wynkoop Street, Denver, CO 80202

Mary Goldade

EPA Regional Quality Assurance Manager

(RQAM)

EPA Region 8 goldade.mary@epa.

gov

1595 Wynkoop Street, Denver, CO 80202

Thad Call Collaborating Entity

Union Pacific tacall@up.com 1045 S 5500 W, Salt Lake City, UT 84104 https://drive.google.com/drive/folders/1mo819nNdoskIcRaZUkXTJzC5i5zAhuAX

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Amariah Gibbs

Collaborating Entity

Utah Division of Air Quality amariahgibbs@utah.

gov

195 N 1950 W, Salt Lake City, UT 84116

Contractor Name

Task Leaders (TLs)

Contractor Organization

Contractor Email Contractor Address/Location

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● A.8 Project Organization

The Primary Quality Assurance Organization is UIPA. The primary personnel responsible for implementation of this project are UIPA’s assigned Environmental & Sustainability Director (Project Manager, Mona Smith), Chief Risk & Compliance Officer (QAM, Amy Brown Coffin), Emissions Inventory Analyst (Task Manager, Michelle Bohnen), the EPA regional QAM and EPA Project Officer (PO, Sara Key), and the assigned Task Leaders (TLs, names to be determined) for the described tasks. The Senior Manager (Executive Director, Benjamin Hart) has executive leadership and approval authority for the organization conducting the EIOs (UIPA).

Position-specific duties are outlined briefly in this section.

The UIPA Environmental & Sustainability Director will serve as the Project Manager (PM), providing senior-level oversight as needed and leading the Task Manager’s (TM) coordination with the PTT. The PM is responsible for the project’s technical and financial performance as well as maintaining communications with the EPA’s PO to ensure mutual understanding of grant requirements, EPA expectations, and conformity with EPA quality procedures. The PM will manage oversight of and conduct all primary project activities, including the planning of required training for technical staff; allocation of resources to specific tasks; and ensuring that data quality procedures are incorporated into all aspects of the primary work to ensure all draft deliverables conform to acceptance criteria prior to submitting draft work products to the project QAM for independent review. The PM is also responsible for developing, conducting, and/or overseeing QA plans and measures integrated into the primary tasks and during the hand-off of work products between the PTT and the TM, as necessary. The PM will review any corrective actions identified by PTT members or by QC staff, authorize specific PTT member(s) to implement the corrective action, and provide direction to the PTT member(s) in the approach for the corrective action. The PM is responsible for day-to-day oversight as necessary to ensure project activities are consistent with the approved QAPP, and to ensure that all work products under this project are consistent with the specified type, quantity, and quality in the approved QAPP. Finally, the PM is responsible for developing a training plan for the PTT and QC staff as necessary to ensure assigned staff have the requisite knowledge and skills to implement assigned tasks.

The UIPA Emissions Inventory Analyst will serve as the TM for the team conducting the EIOs and is the individual responsible for maintaining the QAPP. The TM works with TLs assigned by the selected contractor for the baseline emissions inventory and emissions reduction strategy analysis for each technical task to develop instructions to complete the specific responsibilities for each assigned task. Additionally, the TM is responsible for analyzing, developing, and overseeing the implementation of the baseline emissions inventory process. They will develop and implement methods and techniques for the collection, analysis, and evaluation of the air quality study and plans to create and prepare written documents, technical reports, findings, recommendations, and work products assessing and summarizing the results of CAQP activities.

They will prepare, analyze, and plan information and data as input for assessing emission

Rev. 0 | 08/18/2025 UIPA | CAQP SLIPCAP QAPP Page 27 of 65 reduction strategies, decisions, management plans, and assessments through supporting documents such as graphs and statistical summaries. They will work in concert and collaboration with the TLs to report progress, coordinate activities, ensure program milestones are met, collect and prepare operational activity data of port vehicles and equipment servicing the SLCIT, and ensure that appropriate procedures and controls are in place. Note that some TLs are contractors or sub awardees, for which contracts are still yet to be awarded. Each TL is responsible for the day-to-day technical activities under their assigned task, including planning, reporting, and controlling of technical and financial resources allocated to the task by the PM.

Accordingly, the TM is primarily responsible for working with each TL to implement the quality measures integral to the primary work and coordinating with other TLs as necessary to ensure the draft work products are consistent and comparable across all tasks as required by this QAPP.

For each major deliverable under each task, the assigned TL will review all QA-related plans and reports and is responsible for transmitting the draft deliverable and the primary QA documentation to the QAM (or delegate) for independent QC review and approval. Each TL is responsible for ensuring that the primary QA procedures are implemented at the task level. TLs are also responsible for maintaining the official, approved, task-level QAPP content. Each TL will discuss with the TM and PM any concerns about data quality identified during the primary technical activities and during internal reviews among TLs and PTT members during development of the draft deliverables. In the event of a severe data quality issue, any member of the PTT, the TM, the PM, or the QAM can issue an order to halt data collection until corrective actions have been implemented as needed.

Every PTT member is authorized to propose to the TLs, TM, or PM any revisions to task-level QAPP content considered by the PTT member as necessary to resolve observed quality issues.

However, only the PM is authorized to revise the QAPP. The PM must obtain concurrence from the QAM (or delegate) to implement any revisions to the approved QAPP considered necessary by the PTT to identify, resolve, or preclude problems or to amend task-level plans, as necessary.

In addition, each TL will work with the TM, PM, and the QAM to identify and implement quality improvements both during the primary work and in response to any findings on draft deliverables reviewed by the QC Team. The PM is responsible for ensuring the consistency of similar or related QA measures across tasks, and the TM is responsible for overseeing task-level work performed by the TLs and the PTT and for providing assurance that all required QA/QC procedures are being implemented in accordance with the approved QAPP.

Tasks 1 and 2 are expected to proceed concurrently. Task 3 is expected to proceed through identification of the data source for estimates of future year SLCIT activity levels, but development of emissions estimating frameworks and methodologies under Task 3 will not proceed until the frameworks and methods for the baseline inventory have been drafted and approved by the PM under Tasks 1 and 2.

The PM will maintain close communications with the TM and each TL and ensure any difficulties encountered or proposed changes at the task level are reviewed for implications on other similar or related tasks. The PM is also responsible for communicating progress or difficulties

Rev. 0 | 08/18/2025 UIPA | CAQP SLIPCAP QAPP Page 28 of 65 encountered (across all tasks) to the EPA PO, who provides the EPA’s primary oversight function for this project at EPA Region 8 and is responsible for review and approval of this QAPP and any future revisions. The PM (with support from the TM, TLs, and other PTT members) will be responsible for consulting with the EPA PO, on planning, scheduling, and implementing the QA/QC for all project deliverables and obtaining required EPA approvals.

The UIPA Chief Risk & Compliance Officer will serve as the project QAM, leading the QC efforts responsible for measuring all draft work products (prepared by the PTT) versus the acceptance criteria established in this QAPP. The QAM has oversight authority and responsibilities for planning, documenting, coordinating, and assessing the QAPP for effectiveness. The project QAM is independent of the PTT and will not be involved in generating the data or conducting any EIOs related to the draft work products. The Senior Manager has the responsibility of providing resources (knowledgeable personnel, funding, materials, supplies, and time).

The role of UDAQ (Amariah Gibbs) is to serve as a Collaborating Entity on the project. They will be a key partner to support emissions inventory and emissions reduction strategy analysis activities as well as coordination over complementary initiatives. The examples of their planned support activities include overseeing the parallel CPP ZE Technology Deployment grant, providing expertise when needed for the proposed development of an emissions inventory, providing expertise when needed for emission reduction strategy analysis, and engaging with near-port communities and other stakeholders.

The role of Union Pacific (Thad Call) will be to serve as a collaborating entity on the project. UIPA will collaborate with them and private fleet operators to complete the required baseline emissions inventory for port vehicles or equipment (locomotives, drayage trucks, cargo-handling equipment, and other non-road equipment) servicing the SLCIT.

The role of PacifiCorp (James Campbell) will be to serve as a Collaborating Entity. UIPA has already begun discussions with PacifiCorp, the local utility, about the proposed project and discussed high-level details. Their role will be to support assessment of ZE technology feasibility, including planning, site design, and engineering studies as needed.