Pennsylvania’s RACT 2 Air Quality Regulation is Official!
Reasonably Available Control Technology (RACT) is a Clean Air Act requirement for states like Pennsylvania with persistent Ozone nonattainment problems. States are required by U.S. EPA to implement RACT regulations to reduce emissions of nitrogen oxides (NOx) and volatile organic compounds (VOC), both of which are classified an ozone “precursor” pollutants. The rule is a follow-up to the “RACT 1” rule from the mid 1990’s that required a case-by-case evaluation of VOC and NOx control options and led to many sources (e.g., bakeries) in PA having to install pollution controls at great expense.
The long-awaited RACT 2 will impact power plants, cement plants, landfills, plants that operate large boilers or process heaters, and manufacturing operations that use large quantities of solvents or whose processes result in VOC emissions (e.g., cocoa roasters, iron foundries, polystyrene foam plants). The rule is expected to have significant cost impacts on these sources including stack testing requirements, installation/operation of continuous emissions monitoring systems (CEMS), retrofitting low-NOx burners in large boilers, and installation of add-on VOC control devices (e.g., oxidizers).
The rule requires PA sources to prepare a “RACT Proposal” identifying NOx and VOC emission reductions and compliance methods by October 24, 2016. Compliance must be achieved by January 1, 2017. If add-on pollution controls or low-NOx burner retrofits are required to meet the rule, sources can obtain an extension for up to 3 years after the January 1 compliance date.
Note that the rule only applies to major sources (> 100 tpy NOx or > 50 tpy VOC in most areas of PA except the Phila 5-county area where is is > 25 tpy for either) and therefore sources with “synthetic minor” or State Only Operating Permits will not be impacted. There are also several exemptions in the rule for source categories like printing, degreasing and surface coating and emissions-based exemptions for small VOC and NOx sources.