DSHW-2024-008263

Deq submit <[e-mail]>
Fwd: UPA Comments re Utah Solid Hazardous Waste Rules R315-321
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JaLynn Knudsen <[e-mail]>Fri, Sep 6, 2024 at 1:00 PM
To: Deq submit <[e-mail]>
Solid Waste Public Comment Proposed E&P Rules
---------- Forwarded message ---------
From: Jennette King <[e-mail]>
Date: Friday, August 30, 2024 at 3:47:28 PM UTC-6
Subject: UPA Comments re Utah Solid Hazardous Waste Rules R315-321
To: [e-mail] <[e-mail]>
Cc: Rikki Hrenko-Browning <[e-mail]>, Gage Zobell <[e-mail]>, Nate
Robinson <[e-mail]>, Gary Coates <[e-mail]>
RE: Utah Petroleum Associaon Comments on Utah Solid and Hazardous Waste Rules R315-321, Class VII
Exploraon and Producon Waste Facility Requirements, and R315-322, Solid Waste Surface
Impoundment Requirements
To Whom It May Concern:
Please see the UPA Comment letter regarding the above mentioned proposed rule attached below. We appreciate your
kind attention.
Please acknowledge receipt of this letter by replying to this email. Thank you.
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UPACommentLetter_DWMRC_EPWasteRules_8.30.24.pdf
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9/6/24, 2:49 PM State of Utah Mail - Fwd: UPA Comments re Utah Solid Hazardous Waste Rules R315-321
https://mail.google.com/mail/b/AEoRXRRuo6JTPlU8mJix1Az3qAiU-Jb5OCPNar1NwtRtu8mnl5V0/u/0/?ik=adf9d5e615&view=pt&search=all&permthid…1/1

August 30, 2024

Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
P.O. Box 144880
Salt Lake City, UT 84114-4880
[e-mail]

RE: Utah Petroleum Association Comments on Utah Solid and Hazardous Waste Rules R315 -
321, Class VII Exploration and Production Waste Facility Requirements, and R315 -322, Solid
Waste Surface Impoundment Requirements

To Whom It May Concern,

The Utah Petroleum Association (“UPA”) appreciates the opportunity to respond to the Utah
Department of Environmental Quality, Division of Waste Management and Radiation Control
(“DWMRC”) request for public comments regarding its proposed rule and policy u pdates
pertaining to the regulatory framework and management of those wastes generated from the
exploration and production of crude oil and natural gas throughout the state of Utah, namely
Utah Solid and Hazardous Waste Rules R315-321, Class VII Exploration and Production Waste
Facility Requirements, and R315-322, Solid Waste Surface Impoundment Requirements, (the
“Proposed Rule”). UPA is a statewide petroleum trade association representing companies
involved in all facets of Utah’s oil and gas industry. Consequently, UPA has a compelling interest
and stake in the Proposed Rule.
UPA is concerned that the Proposed Rule would allow unlined oilfield landfills or scenarios
where a synthetic liner is not required. We believe that not having a synthetic liner should be
an allowance only approved after an extensive evaluation of subsurface conditions that
demonstrates liner equivalence. To approve solid waste disposal landfills without a synthetic
liner and without demonstration of equivalency creates an unnecessary risk for producers that
have cradle to grave liability for their wastes. It is the industry standard to use synthetic liners
for these types of disposal facilities and we encourage the DWMRC to be balanced but forward-
thinking in regulating the industry’s standard of care.

We appreciate your consideration of these comments as you move to final consideration and
adoption of this Proposed Rule.

Sincerely,

Rikki Hrenko-Browning
President, Utah Petroleum Association