Regulatory Update — Spotlight on Air Given our state’s ozone challenges, UPA has been working collaboratively with our regulators anticipating rulemaking in support of a forthcoming State Implementation Plan (SIP), both for the Wasatch Front and the Uintah Basin. In the Basin, while the outcome of this winter is not yet determined, it serves as the critical fork in the road to either a path/redesignation of the standard or a “bump” from marginal to moderate nonattainment status. We will need to ensure that we can continue to reduce VOC and NOx emissions in either case. To that end, the Utah Division of Air Quality (DAQ) is in the process of proposing rules, likely to be presented to the Air Quality Board in March to kick off formal rulemaking, with a target to be effective Jan. 1, 2023, focused on the following (note that this is a high-level summary, not a comprehensive outline of the draft proposal): • R307-506-Storage Vessels: ❒ Removes the exemption from the rule for sites with an Approval Order (AO) ❒ Lowers the applicability threshold for crude oil from 8,000 to 3,200 barrels ❒ Requires controls for applicable tanks “at all times” ❒ Changes to emergency relief storage vessels, including reducing the time period for the vessel to be emptied from 15 days to 48 hours after it receives fluids ❒ Adds pressure relief devices to required monthly inspections and repairs • R307-508-VOC Control Devices: ❒ Removes the exemption from the rule for sites with an AO ❒ Requires operations to meet manufacturer specifications or equivalent ❒ Requires air pollution control equipment to be adequately designed and sized to achieve the control efficiency and reasonably foreseeable fluctuations, including separator dumps • R307-509-Leak Detection and Repair: ❒ Removes the exemption from the rule for sites with an AO ❒ Adds requirements for fugitive emissions surveys with very specific timing of surveys as well as requiring a survey be performed within seven days of a well site becoming operational after being shut-in or temporarily abandoned • R307-511-Associated Gas Flaring: ❒ Removes the exemption from the rule for sites with an Approval Order (AO) ❒ Clarifies recordkeeping requirements for flaring 16 UPDATE
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