4 The record articles

Utah Emissions Reporting: Change is in the Air

Posted: June 22nd, 2020

Authors: Sean C. 

As Bob Dylan says, the times, they are a-changin’.  Amidst the COVID-19 concerns and considerations that are ongoing, the changes don’t stop there for those who operate in Utah.  The Utah Department of Environmental Quality (UDEQ) has proposed to update the air Emissions Inventory Rule at R307-150.  UDEQ has also provided a summary of the proposed rule changes.  The proposed updates fall into two categories: ozone nonattainment and procedural updates.  Each category of changes is discussed below.

The first set of changes revolves around the August 2018 designation from U.S. EPA that the counties of Davis, Weber, Salt Lake, Utah, and a portion of Tooele are in nonattainment with the National Ambient Air Quality Standards (NAAQS) for ozone.  The portion of Uinta Basin, located in Duchesne and Uintah Counties, at 6,500 feet above sea level or below was also designated as ozone nonattainment.  In order to obtain additional information about the sources contributing to the NAAQS nonattainment, UDEQ has proposed to require sources within the nonattainment area which have the potential to emit 25 tons per year of nitrogen oxides (NOX) or volatile organic compounds (VOC) to report NOX and VOC emissions annually.  NOX and VOC are the primary contributors for the formation of ground-level ozone.

The second set of changes is intended to improve the emissions reporting process and is more broadly applicable to the regulated community.  Emissions inventories are required to be submitted annually for large major stationary sources [i.e., major stationary sources with the potential to emit 2,500 tons or more of NOX, oxides of sulfur (SOX), or carbon monoxide (CO) or that has the potential to emit 250 tons or more of particulate matter either 10 micrometers or 2.5 micrometers or less in diameter (PM10 or PM2.5), VOC, or ammonia].  Title V sources that are not classified as large major sources must submit emissions inventories every three years.

Currently, Title V sources are required to submit either a summary only inventory or a detailed inventory, depending on the location of the source and/or the potential to emit from the source as outlined in R307-150-7.  The proposed changes would require all Title V sources required to submit an emissions inventory to submit a detailed inventory, regardless of location or potential to emit.  Facilities changing from a summary only inventory to a detailed inventory report will need to work with UDEQ to reconcile the inventory of emissions units.  UDEQ staff plan to work with the affected facilitates to complete the emissions unit inventory reconciliation in preparation for reporting year 2020 activity.

The proposed changes would become effective for reporting year 2020 (i.e., the first report under the amendments will be due April 15, 2021).  UDEQ intends to use the existing tools in place for the emissions inventories [i.e., the Statewide and Local Emission Inventory System (SLEIS), or the Centralized Air Emissions Reporting System (CAERS) for oil and gas sources] as the avenue for this submittal.  The changes were discussed at a Utah Air Quality Board meeting on June 3, 2020.  The rule is now under the public comment period, which ends on July 2, 2020 and for which a public hearing is scheduled on August 3, 2020.

Of course, we will continue to track the ch-ch-ch-ch-changes (thanks David Bowie!).  If you have any questions or need assistance, please contact me at scunningham@all4inc.com or (610) 422-1144.


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