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ARTICLE · 19 DECEMBER 2022

PADEP Issues Emergency Rulemaking For Volatile Organic Compound Emissions In Conventional Oil And Gas Operations

McNees Wallace & Nurick
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On December 2, 2022, the Pennsylvania Department of Environmental Protection ("DEP") announced that its recent emergency rulemaking limiting volatile organic compound...

United StatesEnvironment
Terry Bossert
Terry Bossert
Errin McCaulley, Jr.
Errin McCaulley, Jr.
Sarah Hibbert
Sarah Hibbert
Scott Gould
Scott Gould
Brigid Landy Khuri
Brigid Landy Khuri

On December 2, 2022, the Pennsylvania Department of Environmental Protection ("DEP") announced that its recent emergency rulemaking limiting volatile organic compound ("VOC") emissions from conventional oil and gas sources had become final and effective as of that date ("VOC Rulemaking"). The VOC Rulemaking was subsequently published in the Pennsylvania Bulletin on December 10, 2022. Under the federal Clean Air Act ("CAA"), Pennsylvania has until December 16 to submit to the U.S. Environmental Protection Agency ("EPA") a plan implementing the VOC Rulemaking, including regulations covering VOC emissions for all required oil and gas sources.

The VOC Rulemaking adopts reasonably available control technology ("RACT") requirements and RACT emission limitations, and applies to owners or operators of the following conventional oil and gas VOC emissions sources:

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