» If written and adopted, this rule would have required early sales of low RVP gasoline, probably 7.4 psi, in the NWF. » The Clean Air Act (CAA) requires reformulated gas (RFG) at 7.4 psi RVP one year after an ozone nonattainment area bumps up to severe nonattainment. We project RFG to be required for the summer gasoline season in 2029. If UDAQ pursued their consideration of adopting a low RVP requirement now, then 7.4 psi RVP would be required years earlier. » UPA prepared a white paper to educate UDAQ on the ramifications and difficulties of converting to low RVP gasoline on an earlier schedule. • Boiler Rule changes (NOx Emission Controls for Natural GasFired Boilers Greater Than 5.0 MMBtu): Final rule. » The boiler rule regulates boilers fired by natural gas in the five counties of the NWF and SWF. » UPA engaged heavily in this rule in 2022 and 2023 when it was finalized and again in 2024 when UDAQ made some changes. » UPA advocacy and written comments resulted in the removal of some problematic definitions and raising the CO limit to match the limit elsewhere outside of Utah. » Although the rule does not apply to the refineries because they use process gas rather than natural gas, UDAQ is contemplating adopting parts of this rule in changes for refinery NOx controls in the Serious PM2.5 SIP. • Serious PM2.5 State Implementation Plan (SIP): Proposed rule on hold by EPA until UDAQ resolves some EPA concerns with refinery emission limits. » The Salt Lake City PM2.5 nonattainment area (SLC) measured attainment several years ago, and EPA published a final DAAD in late 2020. » EPA also published a proposed redesignation to attainment in late 2020. Based on comments received, EPA expressed concerns about refinery limits for some emissions. » UPA and its member company refineries have engaged in several discussions with UDAQ to understand EPA concerns, have provided extensive additional data, and are continuing the dialogue toward updating the Serious PM2.5 SIP. • Moderate Ozone SIP for the NWF: Revision of the Final SIP to address the required 15% reduction of Volatile Organic Compounds (VOC). » The CAA requires that a Moderate ozone nonattainment area reduce VOC emissions by 15%. This must only be done once, on the first Moderate ozone SIP for an area. » The NWF does not have a prior approved 15% reduction, but the area did reduce VOC by more than 15% for the Moderate PM2.5 SIP. » UDAQ proposed a change to the moderate SIP already submitted to EPA in order to rely on the VOC reductions under the Moderate PM2.5 SIP. If approved by EPA, this will allow UDAQ to substitute NOx reductions in place of some of the required VOC reductions to meet the CAA requirement for emissions reductions at Moderate. » UPA submitted comments to UDAQ in support of the SIP change with suggestions to strengthen it. The SIP change will be considered by the Air Quality Board for approval to submit to EPA in November. • Serious Ozone SIP for the NWF: Preparing to draft rule changes. » UPA has engaged in dialogue with UDAQ to understand their path forward and to provide suggestions. We will remain engaged through SIP development over the next year. • UDAQ Rulemaking to Adopt EPA Emissions Guidelines OOOOc: Preparing to draft rules. » UPA is engaging with UDAQ to discuss areas of potential interest or concern in the rulemaking. After stakeholder meetings in October and November, UPA will submit written comments before the end of the year. • Lawn & Garden Rule: Proposed rule never put out for comment. » The Lawn & Garden rule could fulfill a significant portion of the required 15% VOC reduction for the Moderate ozone SIP for the NWF at a cost-effective dollar per ton of emissions reduced. » Some of the state’s leadership have expressed concerns about the rule, and UDAQ has not finalized the proposal at the Air Quality Board. » UPA has engaged in discussions to help education as to the need for this rule and the relatively low cost on a dollar per ton basis compared to other possible ways to get the same reductions. UDAQ has also kept this rule in their list of coming ozone serious SIP rules. Others • Extension of the Attainment Date and Determination of Attainment by the Attainment Date of the Uinta Basin Marginal Nonattainment Area Under the 2015 Ozone National Ambient Air Quality Standards: Proposed rule comment period closed. » Although not a UDAQ rule, this rulemaking would only apply for the Uinta Basin ozone nonattainment area (UB). » This rulemaking would approve the second extension to the Marginal attainment date and thus allow EPA to complete a determination of attainment by attainment date (DAAD). » The effect of a final DAAD would be to hold the UB at Marginal nonattainment and allow UDAQ to pursue a maintenance plan and redesignation to attainment. » UPA submitted written comments to EPA in support of the DAAD and is awaiting a final decision from EPA. • DEQ Waste Management and Radiation Control Division (WMRC) in October finalized a rule regulating the disposal of all oil and gas wastes. In 2018 the EPA notified the state that it had to change its definition of Solid Waste (which ironically includes predominately liquid wastes), and this triggered the need for oil and gas industry wastes to be regulated by DEQ rather than DOGM based on the state’s primacy status. This rule has taken several years to materialize and includes a number of changes, the most contentious was whether waste disposal cells for oil and gas wastes were required to have liners. UPA and other industry members advocated that liners should be required unless proven unnecessary on a site-specific basis, but the rule was ultimately approved without requiring liners. Going forward, WMRC will require land farms to convert to landfills and will be the regulator in charge of oil and gas waste disposal. 13 UPDATE
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