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On May 23, 2020, the Pennsylvania Department of Environmental Protection (PADEP) published the draft RACT regulations for the control of volatile organic compound emissions from the oil and gas industry in the PA Bulletin. The Draft RACT regulation is based in part on the 2016 control technique guidelines (CTGs) published by EPA for the industry. PADEP has develop regulations for existing sources that achieve equivalent or greater VOC emission reductions than the comparable CTG requirement. The draft regulation pertains to the following operations and equipment at natural gas production operations (both conventional and unconventional wells), compressor stations, and processing plants:

  • Reciprocating compressors;
  • Centrifugal compressors;
  • Storage vessels;
  • Fugitive emissions components;
  • Natural gas driven pneumatic controllers; and
  • Natural gas driven diaphragm pumps.

The proposed emission controls for the subject equipment generally match the emission thresholds and control requirements for NSPS Subpart OOOOa, PADEP's Exemption 38, and/or PADEP's General Permits (i.e., GP-5/5A), which are as stringent or more stringent that the CTGs. The compliance date for the draft rule will be one year from the date of publication of the final rule.

Public comments can be submitted to the Department via eComment. The last day to submit your public comment to the department is on July 27, 2020 11:59 pm. For questions on the proposed rule, or for more information on how it might impact your existing operations, please contact Trinity's Philadelphia office at 610.280.3902 or Trinity's Pittsburgh office at 724.935.2611.