A New Pennsylvania RACT Rulemaking is on the Way

The Pennsylvania Department of Environmental Protection (PADEP) has announced that they will be revising their Reasonably Available Control Technology (RACT) regulations in 25 Pa. Code Chapter 129 for control of major sources of nitrogen oxides (NOx) and volatile organic compounds (VOC). The original RACT regulations were effective in 1994 as a Federal requirement for Pennsylvania to demonstrate reasonable further progress (RFP) toward attaining the ozone National Ambient Air Quality Standard (NAAQS). Since PADEP was not successful in demonstrating to U.S. EPA that the existing RACT determinations were still sufficient, new regulations are required. Greater than 90% of the original RACT determinations were case-by-case determinations by PADEP. In this next round of RACT, PADEP will be proposing many additional presumptive RACT emission limits, but case-by-case approvals will still remain an option. However, if PADEP proposes presumptive emission limits for your source type, it will be very important to review the new proposed regulations and to provide comment on these presumptive limits. A specific timeline for this proposal has not been issued.