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DEP’s RACT III Determinations Results in New Emission Controls at Beaver Co. Compressor Station

The state Department of Environmental Protection (DEP) recently published notice of what may be the first Reasonably Available Control Technology - or RACT III - determination for a site in southwestern Pennsylvania under DEP’s jurisdiction - one that will lead to emissions reductions in Beaver County.

Specifically, DEP determined that the Pike Compressor Station in Beaver County is required to control emissions of volatile organic compounds (VOCs) from rod packing operations with a combustor and emissions of VOCs from compressor blowdowns and startups with an enclosed flare.

Based on the Pike Compressor Station’s existing Title V Operating Permit, it appears that such emissions were previously not controlled.

We have blogged about the RACT requirement before, but to review: The RACT requirement instructs the states to determine whether major sources of VOCs and oxides of nitrogen (NOx) are using all reasonably available control technology to limit their emissions of NOx and VOCs.

NOx and VOCs are the two principal precursors to the formation of ground-level ozone pollution. And the concern about ground-level ozone is that it can trigger a variety of health problems including chest pain, coughing, throat irritation, and congestion. It can worsen bronchitis, emphysema, and asthma. Ozone also can reduce lung function and inflame the lining of the lungs. Repeated exposure may permanently scar lung tissue.

If such sources of ozone are not implementing RACT, the states must require them to do so, even if they were properly permitted when they began operating and have continued to operate within all applicable limits.

New RACT determinations are required under the Clean Air Act every time a National Ambient Air Quality Standard (NAAQS) for ozone or NOx is revised. Because this is the third time new RACT rules have been required, the new rules are referred to as RACT III.

The first round of RACT determinations followed the imposition of the RACT requirement by the 1990 Amendments to the Clean Air Act and was implemented in the late 1990s and early 2000s. RACT II determinations, which were completed just last year, followed the revision of the NAAQS for ozone in 2008 (yes, there really was a 14-year lag!). RACT III follows the latest revision of the ozone standard, which occurred in 2015.

Generally, the Clean Air Act requires RACT determinations only for major sources in areas that do not attain the NAAQS for ozone. However, all areas of Pennsylvania are deemed to be nonattainment for the purpose of implementing RACT, because Pennsylvania is included in the “Ozone Transport Region” established by the Clean Air Act. As a result, all major sources of NOx and VOCs in Pennsylvania will be required to comply with RACT III emission limits.

DEP’s RACT III determination for the Pike Compressor Station is one of many that will be made in the upcoming months (and years); however, not all of them will result in new controls as this one did. We will keep you updated as DEP’s RACT III determinations continue.

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