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Title V Permit Writer's Tips - Pennsylvania DEP Streamlining Example and Technical Justification

According to staff members in the United States Environmental Protection Agency - Region III - Air, Radiation, and Toxics Division, the current State Implementation Plan (SIP) limitation for SO2 emissions from a combustion unit is 4.0 pounds per million Btu of heat input at any time. The current SO2 limit for combustion units from 25 Pa. Code 123.22(a)(1) states that the limitation is 4.0 pounds per Million Btu of heat input over any 1-hour period.

Since the Department may have difficulty with enforcing the current SIP limit since it is no longer in the Pennsylvania Code, the Department wishes to forgo including the SIP version of the SO2 requirement in Title V Operating Permits under the streamlining provisions of the U.S. EPA White Paper #2. The Department believes that the requirements are equivalent and that the proposed streamlining is allowed by the White Paper.

In determining the equivalency of the requirements, the Department looked at the applicable monitoring, recordkeeping, testing, and reporting requirements for each limitation. A review of the current SIP limitation shows that there are no associated monitoring, recordkeeping, and reporting requirements associated with that limitation. Any testing to demonstrate compliance with that limitation would occur using the test methods in U. S. EPA Reference Method 6. EPA Method 6 requires the testing to be conducted over a one hour period. A review of the current Pa. Code version of the requirement also showed that there are no regulatory requirements for monitoring, recordkeeping, and reporting. 25 Pa. Code 139.13 states that any testing completed to demonstrate compliance with the current Pa. Code version would be completed in accordance with the procedures specified in 25 Pa. Code 139.4(5). 25 Pa. Code 139.4(5) is the citation for the Department’s Source Testing Manual. Chapter 5.0 of the Source Testing Manual, (relating to Sulfur Compound Testing) states that "Sampling and analytical procedures should follow the provisions contained in EPA Method 6 with the exceptions that the glass wool and contents of the isopropanol midget bubbler are not discarded as specified in the method. The glass wool and the isopropanol solution must be analyzed for SO3/SO4….The SO3/SO4 fraction is then added to the SO2 fraction to produce the total oxides of sulfur, expressed as SO2." Since the Departmental test method also includes the SO3/SO4 fraction in the final results, the results would indicate a higher emission rate than using the EPA Method 6. Therefore, the Department’s test method is more strict than just using EPA Method 6.

Since the Department’s test method used to demonstrate compliance with the current 25 Pa. Code 123.22(a)(1) is more strict than just using EPA Method 6, which would be used to demonstrate compliance with the current SIP version of the requirement, and the testing times (one hour) are the same for each test method, the Department believes that the current version of 25 Pa. Code 123.22(a)(1) (4.0 pounds/MMBtu over any 1-hour period) is at least equivalent to, if not more strict, than the current SIP approved version of the requirement (4.0 pounds/MMBtu at any time).

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