Submitted April 6, 2020. Pennsylvania is in the Ozone Transport Region (OTR). EPA proposed to approve Pennsylvania’s submittal to address reasonably available control technology (RACT) for source categories covered by a Control Techniques Guideline (CTG). The comment letter makes two arguments:

• Generally, the submittal relied on the recommendations in the CTG without apparent analysis to ensure the recommendations remain RACT.
• For natural gas processing plants, RACT at a minimum would require the leak detection and repair (LDAR) program found in 40 CFR part 60, subpart VVa.