06-05150A

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BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE

DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

PLAN APPROVAL

Issue Date: Effective Date:

 In accordance with the provisions of the Air Pollution Control Act, the Act of January 8, 1960, P.L. 2119, as 

amended, and 25 Pa. Code Chapter 127, the Owner, [and Operator if noted] (hereinafter referred to as 

permittee) identified below is authorized by the Department of Environmental Protection (Department) to 

construct, install, modify or reactivate the air emission source(s) more fully described in the site inventory list. 

This Facility is subject to all terms and conditions specified in this plan approval. Nothing in this plan approval 

relieves the permittee from its obligations to comply with all applicable Federal, State and Local laws and 

regulations. 

The regulatory or statutory authority for each plan approval condition is set forth in brackets. All terms and 

conditions in this permit are federally enforceable unless otherwise designated as "State-Only" requirements. 

Plan Approval No. 06-05150A

Mailing Address:

Plant: BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE

400 CHESTERFIELD CTR STE 110

CHESTERFIELD, MO 63017-4800

Location: 06 Berks County

BERKS HOLLOW ENERGY ASSOC LLC

Responsible Official

Name:

Title:

Name:

Title:

Phone:

[Signature] _________________________________________

MICHAEL F VOGT

VICE PRESIDENT

BRADLEY J COOLEY

SR ENVIRONMENTAL ENG

(636) 534 - 3268

SIC Code: 4931 Trans. & Utilities - Electric And Other Services Combined

06949 Ontelaunee Township

WILLIAM R. WEAVER, SOUTHCENTRAL REGION AIR PROGRAM MANAGER

Owner Information

Plant Information

Name:

Phone:(636) 534 - 3238

Expiration Date:

Plan Approval Contact Person

Federal Tax Id - Plant Code: 45-4997110-1

COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

AIR QUALITY PROGRAM
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DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

Plan Approval Description

This application is for the construction of a natural gas-fired combined-cycle electric generation facility that is designed to generate 

up to 855 MW nominal, using 2 combustion turbine generators and 2 heat recovery steam generators that will provide steam to 

drive a single steam turbine generator. Each heat recovery steam generator will be equipped with a duct burner which may be 

utilized at time of peak power demands to supplement power output. The source is subject to PSD/NSR requirements. The 

proposed project will also include a natural gas –fired fuel gas heater, a natural gas-fired auxiliary boiler; a diesel engine-driven 

emergency generator; a diesel engine-driven firewater pump; a multi-cell evaporative cooling tower; and associated emission 

control systems, a cold cleaning degreaser, tanks, and other balance of plant equipment. This will be a Title V facility.
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SECTION A. Table of Contents

Section A. Facility/Source Identification 

Section B. General Plan Approval Requirements

Section C. Site Level Plan Approval Requirements

Section D. Source Level Plan Approval Requirements

Section E. Source Group Restrictions

Section F. Alternative Operating Scenario(s)

 #001

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Definitions

Future Adoption of Requirements

Plan Approval Temporary Operation

Content of Applications

Public Records and Confidential Information

Plan Approval terms and conditions.

Transfer of Plan Approvals

Inspection and Entry

Plan Approval Changes for Cause

Circumvention

Submissions

Risk Management

Compliance Requirement

 Table of Contents

 Plan Approval Inventory List

 C-I: Restrictions 

 C-II: Testing Requirements 

 C-III: Monitoring Requirements 

 C-IV: Recordkeeping Requirements

 C-V: Reporting Requirements 

 C-VI: Work Practice Standards 

 C-VII: Additional Requirements 

 C-VIII: Compliance Certification 

 C-IX: Compliance Schedule 

 D-I: Restrictions

 D-II: Testing Requirements

 D-III: Monitoring Requirements

 D-IV: Recordkeeping Requirements

 D-V: Reporting Requirements

 D-VI: Work Practice Standards

 D-VII: Additional Requirements

 Note: These same sub-sections are repeated for each source!

 E-I: Restrictions 

 E-II: Testing Requirements 

 E-III: Monitoring Requirements 

 E-IV: Recordkeeping Requirements

 E-V: Reporting Requirements 

 E-VI: Work Practice Standards 

 E-VII: Additional Requirements 

 F-I: Restrictions

 F-II: Testing Requirements

 F-III: Monitoring Requirements
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DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

SECTION A. Table of Contents

Section G. Emission Restriction Summary

Section H. Miscellaneous

 F-IV: Recordkeeping Requirements

 F-V: Reporting Requirements

 F-VI: Work Practice Standards

 F-VII: Additional Requirements
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PERMIT MAPS

CU

030

CU

031

STAC

S030

CNTL

C031A

CNTL

C031B

STAC

S031

FML

FML01

FML

FML01

SECTION A. Plan Approval Inventory List

030

031

032

033

101

102

103

110

C031A

C031B

C032A

C032B

FUEL PREHEATER

COMBINED CYCLE UNIT #1

COMBINED CYCLE UNIT #2

AUXILIARY BOILER

EMERGENCY GENERATOR (750 KW)

EMERGENCY FIREWATER PUMP (300 HP)

COOLING TOWER

COLD CLEANING MACHINE (DEGREASER)

SCR #1

OXIDATION CATALYST #1

SCR #2

OXIDATION CATALYST #2

 8.500

 3,046.000

 3,046.000

 40.000

 MMBTU/HR

 MMBTU/HR

 MMBTU/HR

 MMBTU/HR

 8.330

 2.980

 2.980

 39.300

 60.000

 16.000

 9.730

MCF/HR

MMCF/HR

MMCF/HR

MCF/HR

Gal/HR

Gal/HR

M Gal/HR

Natural Gas

Natural Gas

Natural Gas

Natural Gas

ULTRA LOW SULFUR DISTI

ULTRA LOW SULFUR DISTI

COOLING WATER

Source ID Source Name Capacity/Throughput Fuel/Material

FML01

FML02

FML03

NATURAL GAS PIPELINE

DIESEL FUEL TANK (2,000 GAL) FOR EMERGENCY 

GENERATOR

DIESEL FUEL TANK (500 GAL) FOR FIREWATER 

PUMP

S030

S031

S032

S033

S101

S102

Z103

Z110

FUEL PREHEATER STACK

COMBINED CYCLE #1 STACK

COMBINED CYCLE #2 STACK

AUXILIARY BOILER STACK

EMERGENCY GENERATOR STACK

EMERGENCY FIREWATER PUMP STACK

FUGITIVE: COOLING TOWER

FUGITIVE: DEGREASER
06-05150A

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PERMIT MAPS

CU

032

CU

033

PROC

101

PROC

102

PROC

103

PROC

110

CNTL

C032A

STAC

S033

STAC

S101

STAC

S102

STAC

Z103

STAC

Z110

CNTL

C032B

STAC

S032

FML

FML01

FML

FML01

FML

FML02

FML

FML03
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Definitions

Future Adoption of Requirements

Plan Approval Temporary Operation

Content of Applications

Public Records and Confidential Information

Words and terms that are not otherwise defined in this plan approval shall have the meanings set forth in Section 3 of 

the Air Pollution Control Act (35 P.S. § 4003) and 25 Pa. Code § 121.1.

The issuance of this plan approval does not prevent the future adoption by the Department of any rules, regulations or 

standards, or the issuance of orders necessary to comply with the requirements of the Federal Clean Air Act or the 

Pennsylvania Air Pollution Control Act, or to achieve or maintain ambient air quality standards. The issuance of this 

plan approval shall not be construed to limit the Department's enforcement authority.

This plan approval authorizes temporary operation of the source(s) covered by this plan approval provided the following 

conditions are met.

(a) When construction, installation, modification, or reactivation is being conducted, the permittee shall provide written 

notice to the Department of the completion of the activity approved by this plan approval and the permittee's intent to 

commence operation at least five (5) working days prior to the completion of said activity. The notice shall state when 

the activity will be completed and when the permittee expects to commence operation. When the activity involves 

multiple sources on different time schedules, notice is required for the commencement of operation of each source.

(b) Pursuant to 25 Pa. Code § 127.12b (d), temporary operation of the source(s) is authorized to facilitate the 

shakedown of sources and air cleaning devices, to permit operations pending the issuance of a permit under 25 Pa. 

Code Chapter 127, Subchapter F (relating to operating permits) or Subchapter G (relating to Title V operating permits) 

or to permit the evaluation of the air contaminant aspects of the source.

(c) This plan approval authorizes a temporary operation period not to exceed 180 days from the date of commencement

of operation, provided the Department receives notice from the permittee pursuant to paragraph (a), above.

(d) The permittee may request an extension of the 180-day shakedown period if further evaluation of the air 

contamination aspects of the source(s) is necessary. The request for an extension shall be submitted, in writing, to the 

Department at least 15 days prior to the end of the initial 180-day shakedown period and shall provide a description of 

the compliance status of the source, a detailed schedule for establishing compliance, and the reasons compliance 

has not been established. This temporary operation period will be valid for a limited time and may be extended for 

additional limited periods, each not to exceed 180 days.

(e) The notice submitted by the permittee pursuant to subpart (a) above, prior to the expiration of the plan approval, shall

modify the plan approval expiration date on Page 1 of this plan approval. The new plan approval expiration date shall be

180 days from the date of commencement of operation.

The permittee shall maintain and operate the sources and associated air cleaning devices in accordance with good 

engineering practice as described in the plan approval application submitted to the Department.

(a) The records, reports or information obtained by the Department or referred to at public hearings shall be available to

the public, except as provided in paragraph (b) of this condition.

(b) Upon cause shown by the permittee that the records, reports or information, or a particular portion thereof, but not 

emission data, to which the Department has access under the act, if made public, would divulge production or sales 

figures or methods, processes or production unique to that person or would otherwise tend to affect adversely the 

SECTION B. General Plan Approval Requirements

[25 Pa. Code § 121.1]

[25 Pa. Code § 127.12b (a) (b)]

[25 Pa. Code § 127.12b]

[25 Pa. Code § 127.12(a) (10)]

[25 Pa. Code §§ 127.12(c) and (d) & 35 P.S. § 4013.2]
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 #006

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Plan Approval terms and conditions.

Transfer of Plan Approvals

Inspection and Entry

competitive position of that person by revealing trade secrets, including intellectual property rights, the Department will 

consider the record, report or information, or particular portion thereof confidential in the administration of the act. The 

Department will implement this section consistent with sections 112(d) and 114(c) of the Clean Air Act (42 U.S.C.A. § § 

7412(d) and 7414(c)). Nothing in this section prevents disclosure of the report, record or information to Federal, State or

local representatives as necessary for purposes of administration of Federal, State or local air pollution control laws, or 

when relevant in a proceeding under the act.

[Additional authority for this condition is derived from 25 Pa. Code Section 127.13]

(a) This plan approval will be valid for a limited time, as specified by the expiration date contained on Page 1 of this plan

approval. Except as provided in § § 127.11a and 127.215 (relating to reactivation of sources; and reactivation), at the 

end of the time, if the construction, modification, reactivation or installation has not been completed, a new plan 

approval application or an extension of the previous approval will be required.

(b) If construction has commenced, but cannot be completed before the expiration of this plan approval, an extension of 

the plan approval must be obtained to continue construction. To allow adequate time for departmental action, a request

for the extension shall be postmarked at least thirty (30) days prior to the expiration date. The request for an extension 

shall include the following:

 (i) A justification for the extension,

 (ii) A schedule for the completion of the construction

If construction has not commenced before the expiration of this plan approval, then a new plan approval application 

must be submitted and approval obtained before construction can commence.

(c) If the construction, modification or installation is not commenced within 18 months of the issuance of this plan 

approval or if there is more than an 18-month lapse in construction, modification or installation, a new plan approval 

application that meets the requirements of 25 Pa. Code Chapter 127, Subchapter B (related to plan approval 

requirements), Subchapter D (related to prevention of significant deterioration of air quality), and Subchapter E (related 

to new source review) shall be submitted. The Department may extend the 18-month period upon a satisfactory 

showing that an extension is justified.

(a) This plan approval may not be transferred from one person to another except when a change of ownership is 

demonstrated to the satisfaction of the Department and the Department approves the transfer of the plan approval in 

writing. 

(b) Section 127.12a (relating to compliance review) applies to a request for transfer of a plan approval. A compliance 

review form shall accompany the request.

(c) This plan approval is valid only for the specific source and the specific location of the source as described in the 

application.

(a) Pursuant to 35 P.S. § 4008, no person shall hinder, obstruct, prevent or interfere with the Department or its 

personnel in the performance of any duty authorized under the Air Pollution Control Act.

(b) The permittee shall also allow the Department to have access at reasonable times to said sources and associated 

air cleaning devices with such measuring and recording equipment, including equipment recording visual 

observations, as the Department deems necessary and proper for performing its duties and for the effective 

enforcement of the Air Pollution Control Act and regulations adopted under the act.

SECTION B. General Plan Approval Requirements

[25 Pa. Code § 127.12b]

[25 Pa. Code § 127.32]

[25 Pa. Code § 127.12(4) & 35 P.S. § 4008 & § 114 of the CAA]
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 #010

 #011

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Plan Approval Changes for Cause

Circumvention

Submissions

Risk Management

(c) Nothing in this plan approval condition shall limit the ability of the Environmental Protection Agency to inspect or 

enter the premises of the permittee in accordance with Section 114 or other applicable provisions of the Clean Air Act.

This plan approval may be terminated, modified, suspended or revoked and reissued if one or more of the following 

applies: 

(a) The permittee constructs or operates the source subject to the plan approval in violation of the act, the Clean Air Act, 

the regulations promulgated under the act or the Clean Air Act, a plan approval or permit or in a manner that causes air 

pollution. 

(b) The permittee fails to properly or adequately maintain or repair an air pollution control device or equipment attached 

to or otherwise made a part of the source. 

(c) The permittee fails to submit a report required by this plan approval. 

(d) The Environmental Protection Agency determines that this plan approval is not in compliance with the Clean Air Act 

or the regulations thereunder.

(a) The permittee, or any other person, may not circumvent the new source review requirements of 25 Pa. Code Chapter

127, Subchapter E by causing or allowing a pattern of ownership or development, including the phasing, staging, 

delaying or engaging in incremental construction, over a geographic area of a facility which, except for the pattern of 

ownership or development, would otherwise require a permit or submission of a plan approval application.

(b) No person may permit the use of a device, stack height which exceeds good engineering practice stack height, 

dispersion technique or other technique which, without resulting in reduction of the total amount of air contaminants 

emitted, conceals or dilutes an emission of air contaminants which would otherwise be in violation of this plan 

approval, the Air Pollution Control Act or the regulations promulgated thereunder, except that with prior approval of the 

Department, the device or technique may be used for control of malodors.

Reports, test data, monitoring data, notifications shall be submitted to the:

 Regional Air Program Manager

 PA Department of Environmental Protection

 (At the address given on the plan approval transmittal letter or otherwise notified)

(a) If required by Section 112(r) of the Clean Air Act, the permittee shall develop and implement an accidental release 

program consistent with requirements of the Clean Air Act, 40 CFR Part 68 (relating to chemical accident prevention 

provisions) and the Federal Chemical Safety Information, Site Security and Fuels Regulatory Relief Act (P.L. 106-40).

(b) The permittee shall prepare and implement a Risk Management Plan (RMP) which meets the requirements of 

Section 112(r) of the Clean Air Act, 40 CFR Part 68 and the Federal Chemical Safety Information, Site Security and Fuels

Regulatory Relief Act when a regulated substance listed in 40 CFR § 68.130 is present in a process in more than the 

listed threshold quantity at the facility. The permittee shall submit the RMP to the Environmental Protection Agency 

according to the following schedule and requirements:

 (1) The permittee shall submit the first RMP to a central point specified by the Environmental Protection Agency no 

later than the latest of the following:

SECTION B. General Plan Approval Requirements

[25 Pa. Code 127.13a]

[25 Pa. Code §§ 121.9 & 127.216]

[25 Pa. Code § 127.12c]

[25 Pa. Code § 127.12(9) & 40 CFR Part 68]
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Compliance Requirement

 (i) Three years after the date on which a regulated substance is first listed under § 68.130; or,

 (ii) The date on which a regulated substance is first present above a threshold quantity in a process.

 (2) The permittee shall submit any additional relevant information requested by the Department or the Environmental 

Protection Agency concerning the RMP and shall make subsequent submissions of RMPs in accordance with 40 CFR 

§ 68.190.

 (3) The permittee shall certify that the RMP is accurate and complete in accordance with the requirements of 40 CFR 

Part 68, including a checklist addressing the required elements of a complete RMP.

(c) As used in this plan approval condition, the term "process" shall be as defined in 40 CFR § 68.3. The term 

"process" means any activity involving a regulated substance including any use, storage, manufacturing, handling, or 

on-site movement of such substances or any combination of these activities. For purposes of this definition, any group 

of vessels that are interconnected, or separate vessels that are located such that a regulated substance could be 

involved in a potential release, shall be considered a single process.

A person may not cause or permit the operation of a source subject to § 127.11 (relating to plan approval 

requirements), unless the source and air cleaning devices identified in the application for the plan approval and the 

plan approval issued to the source, are operated and maintained in accordance with specifications in the application 

and conditions in the plan approval issued by the Department. A person may not cause or permit the operation of an air 

contamination source subject to this chapter in a manner inconsistent with good operating practices.

SECTION B. General Plan Approval Requirements

[25 Pa. Code § 127.25]
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I. RESTRICTIONS.

Emission Restriction(s).

 # 001 [25 Pa. Code §123.1]

Prohibition of certain fugitive emissions

(a) No person may permit the emission into the outdoor atmosphere of fugitive air contaminant from a source other than 

the following:

 (1) Construction or demolition of buildings or structures.

 (2) Grading, paving and maintenance of roads and streets.

 (3) Use of roads and streets. Emissions from material in or on trucks, railroad cars and other vehicular equipment are 

not considered as emissions from use of roads and streets.

 (4) Clearing of land.

 (5) Stockpiling of materials.

 (6) Open burning operations.

 (7) Not applicable

 (8) Not applicable 

 (9) Sources and classes of sources other than those identified in paragraphs (1)-(8), for which the operator has 

obtained a determination from the Department that fugitive emissions from the source, after appropriate control, meet the 

following requirements:

 (i) the emissions are of minor significance with respect to causing air pollution; and

 (ii) the emissions are not preventing or interfering with the attainment or maintenance of any ambient air quality 

standard.

(b) An application form for requesting a determination under either subsection (a)(9) or 129.15(c) is available from the 

Department. In reviewing these applications, the Department may require the applicant to supply information including, but 

not limited to, a description of proposed control measures, characteristics of emissions, quantity of emissions, and 

ambient air quality data and analysis showing the impact of the source on ambient air quality. The applicant shall be 

required to demonstrate that the requirements of subsections (a)(9) and (c) and 123.2 (relating to fugitive particulate 

matter) or of the requirements of 129.15(c) have been satisfied. Upon such demonstration, the Department will issue a 

determination, in writing, either as an operating permit condition, for those sources subject to permit requirements under 

the act, or as an order containing appropriate conditions and limitations.

(c) A person responsible for any source specified in subsections (a)(1) -- (7) or (9) shall take all reasonable actions to 

prevent particulate matter from becoming airborne. These actions shall include, but not be limited to, the following:

 (1) Use, where possible, of water or chemicals for control of dust in the demolition of buildings or structures, 

construction operations, the grading of roads, or the clearing of land.

 (2) Application of asphalt, oil, water or suitable chemicals on dirt roads, material stockpiles and other surfaces which 

may give rise to airborne dusts.

 (3) Paving and maintenance of roadways.

 (4) Prompt removal of earth or other material from paved streets onto which earth or other material has been transported

by trucking or earth moving equipment, erosion by water, or other means.

(d) Not applicable

SECTION C. Site Level Plan Approval Requirements
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 # 002

 # 003

 # 004

 # 005

 # 006

 [25 Pa. Code §123.2]

 [25 Pa. Code §123.31]

 [25 Pa. Code §123.41]

 [25 Pa. Code §123.42]

 [25 Pa. Code §127.12b]

Fugitive particulate matter

Limitations

Limitations

Exceptions

Plan approval terms and conditions.

A person may not permit fugitive particulate matter to be emitted into the outdoor atmosphere from a source specified in 

123.1(a)(1) -- (9) (relating to prohibition of certain fugitive emissions) if such emissions are visible at the point the 

emissions pass outside the person's property.

(a) Limitations are as follows:

 (1) If control of malodorous air contaminants is required under subsection (b), emissions shall be incinerated at a 

minimum of 1200F for at least 0.3 seconds prior to their emission into the outdoor atmosphere.

 (2) Techniques other than incineration may be used to control malodorous air contaminants if such techniques are 

equivalent to or better than the required incineration in terms of control of the odor emissions and are approved in writing 

by the Department.

(b) A person may not permit the emission into the outdoor atmosphere of any malodorous air contaminants from any 

source in such a manner that the malodors are detectable outside the property of the person on whose land the source is 

being operated.

(c) Not applicable

A person may not permit the emission into the outdoor atmosphere of visible air contaminants in such a manner that the 

opacity of the emission is either of the following:

 (1) Equal to or greater than 20% for a period or periods aggregating more than three minutes in any 1 hour.

 (2) Equal to or greater than 60% at any time.

The limitations of 123.41 (relating to limitations) shall not apply to a visible emission in any of the following instances:

 (1) when the presence of uncombined water is the only reason for failure of the emission to meet the limitations.

 (2) When the emission results from the operation of equipment used solely to train and test persons in observing the 

opacity of visible emissions.

 (3) When the emission results from sources specified in 123.1(a)(1) -- (9) (relating to prohibition of certain fugitive 

emissions).

 (4) Not applicable

(a) The facility shall not permit the emission into the outdoor atmosphere of any single HAP (formaldehyde) in excess of 4.8

tpy based on a 12-month rolling total. [Compliance with the formaldehyde limit will show compliance with the total facility 

HAP limit based on EPA stating it is appropriate to use formaldehyde as a surrogate for all organic HAP emissions.]

(b) The facility shall not permit the emission into the outdoor atmosphere of total HAP in excess of 11.3 tpy based on a 12-

month rolling total.

(c) The facility shall not permit the emission into the outdoor atmosphere of PM-2.5 in excess of 99.99 tpy based on a 12-

month rolling total. [This condition was requested by the permittee so the facility would remain NSR minor.]

SECTION C. Site Level Plan Approval Requirements
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(d) The facility shall not permit the emission into the outdoor atmosphere of SO2 in excess of 39.67 tpy based on a 12-

month rolling total based on fuel sulfur content and amount of fuel burned. [This condition was requested by the permittee 

so the facility would remain NSR/PSD minor.]

 # 007

 # 008

 # 009

 # 010

 # 011

 # 012

 [25 Pa. Code §123.43]

 [25 Pa. Code §127.12b]

 [25 Pa. Code §127.12b]

 [25 Pa. Code §127.12b]

 [25 Pa. Code §135.5]

 [25 Pa. Code §127.12b]

Measuring techniques

Plan approval terms and conditions.

Plan approval terms and conditions.

Plan approval terms and conditions.

Recordkeeping

Plan approval terms and conditions.

Visible emissions may be measured using either of the following:

 (1) A device approved by the Department and maintained to provide accurate opacity measurements.

 (2) Observers, trained and qualified to measure plume opacity with the naked eye or with the aid of any devices approved 

by the Department.

The permittee shall perform monitoring of the facility at least once per operating day for the presence of visible emissions, 

fugitive emissions, and malodors. The permittee shall take immediate corrective action to eliminate any emissions that are

out of compliance. For determining visible emissions, a visual observation of the stack shall be used to determine whether 

or not there is a visible emission. If during this observation a visible emission is detected, a Method 9 reading shall be 

performed to determine compliance. Method 22 shall be used for determining fugitive emissions.

The permittee shall monthly calculate and record the quantity of PM-2.5 and the quantity of SO2 emitted in the previous 

month and in the most recent 12-month period. These records shall be available to the department on request.

(a) The facility shall keep adequate records to show compliance with the facility HAP emission limitations. Records shall 

be kept on a monthly basis and a 12-month rolling total basis.

(b) The facility shall keep records of the daily facility monitoring indicating, at a minimum, that required monitoring was 

performed.

Source owners or operators shall maintain and make available upon request by the Department records including 

computerized records that may be necessary to comply with § § 135.3 and 135.21 (relating to reporting; and emission 

statements). These may include records of production, fuel usage, maintenance of production or pollution control 

equipment or other information determined by the Department to be necessary for identification and quantification of 

potential and actual air contaminant emissions. If direct recordkeeping is not possible or practical, sufficient records shall 

be kept to provide the needed information by indirect means.

The permittee shall report, within 24 hours, each malfunction that poses an imminent and substantial danger to the public 

II.

III.

IV.

V.

TESTING REQUIREMENTS.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

REPORTING REQUIREMENTS.

No additional testing requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements).

SECTION C. Site Level Plan Approval Requirements
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 # 013

 # 014

 # 015

 [25 Pa. Code §135.21]

 [25 Pa. Code §135.3]

 [25 Pa. Code §135.4]

Emission statements

Reporting

Report format

health and safety or the environment or which it should reasonably believe may result in citizen complaints to the 

Department that occurs at this facility. For purposes of this condition, a malfunction is defined as any sudden, infrequent, 

and not reasonably preventable failure of air pollution control equipment, process equipment or a process to operate in a 

normal or usual manner that may result in an increase in the emissions of air contaminants.

(a) Except as provided in subsection (d), this section applies to stationary sources or facilities:

 (1) Located in an area designated by the Clean Air Act as a marginal, moderate, serious, severe or extreme ozone 

nonattainment area and which emit oxides of nitrogen or VOC.

 (2) Not located in an area described in subparagraph (1) and included in the Northeast Ozone Transport Region which 

emit or have the potential to emit 100 tons or more oxides of nitrogen or 50 tons or more of VOC per year.

(b) The owner or operator of each stationary source emitting oxides of nitrogen or VOCs shall provide the Department with 

a statement, in a form as the Department may prescribe, for classes or categories of sources, showing the actual 

emissions of oxides of nitrogen and VOCs from that source for each reporting period, a description of the method used to 

calculate the emissions and the time period over which the calculation is based. The statement shall contain a certification 

by a company officer or the plant manager that the information contained in the statement is accurate.

(c) Annual emission statements are due by March 1 for the preceding calendar year and shall provide data consistent with 

requirements and guidance developed by the EPA. The guidance document is available from: United States Environmental 

Protection Agency, 401 M. Street, S.W., Washington, D.C. 20460. The Department may require more frequent submittals if 

the Department determines that one or more of the following applies:

 (1) A more frequent submission is required by the EPA.

 (2) Analysis of the data on a more frequent basis is necessary to implement the requirements of the act.

(d) Subsection (a) does not apply to a class or category of stationary sources which emits less than 25 tons per year of 

VOCs or oxides of nitrogen, if the Department in its submissions to the Administrator of the EPA under section 182(a)(1) or 

(3)(B)(ii) of the Clean Air Act (42 U.S.C.A. 7511a(a)(1) or (3)(B)(ii)) provides an inventory of emissions from the class or 

category of sources based on the use of the emission factors established by the Administrator or other methods 

acceptable to the Administrator. The Department will publish in the Pennsylvania Bulletin a notice of the lists of classes or 

categories of sources which are exempt from the emission statement requirement under this subsection.

(a) A person who owns or operates a source to which this chapter applies, and who has previously been advised by the 

Department to submit a source report, shall submit by March 1 of each year a source report for the preceding calendar year.

The report shall include information for all previously reported sources, new sources which were first operated during the 

preceding calendar year and sources modified during the same period which were not previously reported.

(b) A person who receives initial notification by the Department that a source report is necessary shall submit an initial 

source report within 60 days after receiving the notification or by March 1 of the year following the year for which the report is 

required, whichever is later.

(c) A source owner or operator may request an extension of time from the Department for the filing of a source report, and 

the Department may grant the extension for reasonable cause.

Source reports shall contain sufficient information to enable the Department to complete its emission inventory. Source 

reports shall be made by the source owner or operator in a format specified by the Department.

SECTION C. Site Level Plan Approval Requirements
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DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

 # 016 [25 Pa. Code §129.14]

Open burning operations

(a) Air basins. No person may permit the open burning of material in an air basin.

(b) Outside of air basins. No person may permit the open burning of material in an area outside of air basins in a manner 

that: 

 (1) The emissions are visible, at any time, at the point such emissions pass outside the property of the person on whose

land the open burning is being conducted. 

 (2) Malodorous air contaminants from the open burning are detectable outside the property of the person on whose land 

the open burning is being conducted. 

 (3) The emissions interfere with the reasonable enjoyment of life or property. 

 (4) The emissions cause damage to vegetation or property. 

 (5) The emissions are or may be deleterious to human or animal health. 

(c) Exceptions: The requirements of subsections (a) and (b) do not apply where the open burning operations result from:

 (1) A fire set to prevent or abate a fire hazard, when approved by the Department and set by or under the supervision of a

public officer.

 (2) A fire set for the purpose of instructing personnel in fire fighting, when approved by the Department.

 (3) A fire set for the prevention and control of disease or pests, when approved by the Department.

 (4) Not applicable

 (5) Not applicable

 (6) A fire set solely for recreational or ceremonial purposes.

 (7) A fire set solely for cooking food.

(d) Clearing and grubbing wastes. The following is applicable to clearing and grubbing wastes:

 (1) As used in this subsection the following terms shall have the following meanings:

Air curtain destructor -- A mechanical device which forcefully projects a curtain of air across a pit in which open burning is 

being conducted so that combustion efficiency is increased and smoke and other particulate matter are contained.

Clearing and grubbing wastes -- Trees, shrubs, and other native vegetation which are cleared from land during or prior to 

the process of construction. The term does not include demolition wastes and dirt laden roots.

 (2) Subsection (a) notwithstanding, clearing and grubbing wastes may be burned in a basin subject to the following 

requirements:

 (i) Air curtain destructors shall be used when burning clearing and grubbing wastes.

 (ii) Each proposed use of air curtain destructors shall be reviewed and approved by the Department in writing with 

respect to equipment arrangement, design and existing environmental conditions prior to commencement of burning. 

Proposals approved under this subparagraph need not obtain plan approval or operating permits under Chapter 127 

(relating to construction modification, reactivation and operation of sources).

VI. WORK PRACTICE REQUIREMENTS.

SECTION C. Site Level Plan Approval Requirements
06-05150A

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BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE

DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

 # 017

 # 018

 [25 Pa. Code §121.7]

 [25 Pa. Code §127.12b]

Prohibition of air pollution.

Plan approval terms and conditions.

 (iii) Approval for use of an air curtain destructor at one site may be granted for a specified period not to exceed 3 

months, but may be extended for additional limited periods upon further approval by the Department.

 (iv) The Department reserves the right to rescind approval granted if a determination by the Department indicates that 

an air pollution problem exists.

 (3) Not applicable

 (4) During an air pollution episode, open burning is limited by Chapter 137 (relating to air pollution episodes) and shall 

cease as specified in such chapter.

No person may permit air pollution as that term is defined in the Air Pollution Control Act (35 P.S. Section 4003).

(a) Nothing in this plan approval shall relieve the owner or operator from complying with any local zoning ordinances.

(b) Emission Reduction Credit Requirements

1. The permittee shall not operate the source(s) until the required emission reduction credits are provided to and 

processed through the ERC registry in accordance with 25 PA Code 127.206(d)(1) and the Department certifies the 

required emissions reductions.

2. The permittee shall secure NOx and VOC ERCs. ERCs shall be properly generated and certified by the Department. 

Upon transfer, the permittee shall provide the Department with documentation clearly specifying the details of the ERC 

transaction. The facility NOx PTE is based on 1.01 tpy for the Auxiliary Boiler, 0.53 tpy for the Emergency Generator, 0.10 tpy 

for the Emergency Fire Pump, 1.30 tpy for the fuel gas heater, and the NOx PTE for the Combined Cycle Units. The facility 

VOC PTE is based on 0.14 tpy for the Auxiliary Boiler, 0.03 tpy for the Emergency Generator, 0.04 tpy for the Emergency Fire 

Pump, 0.19 tpy for the fuel gas heater, and the VOC PTE for the Combined Cycle Units. The NOx and VOC PTE for the GE 

7FA is 262.37 tpy and 187.70 tpy resulting in a facility NOx and VOC PTE of 265.31 tpy and 188.09 tpy. The NOx and VOC 

PTE for the Siemens F is 263.20 tpy and 140.47 tpy resulting in a facility NOx and VOC PTE of 266.14 tpy and 140.87 tpy. 

The permittee shall obtain the following NOx and VOC ERCs based on the facility NOx and VOC PTE times the offset of 

1.15:

 (a) GE 7FA: NOx – 305.1 tons and VOC – 216.3 tons

 (b) Siemens F: NOx – 306.1 tons and VOC 162.0 tons

3. If the amount of required emission reduction credits increases, the company shall secure emission offsets according to

a schedule determined by the Department.

4. The ERCs shall be obtained in accordance with the requirements of 25 PA Code 127.208.

VIII. COMPLIANCE CERTIFICATION.

IX. COMPLIANCE SCHEDULE.

 No compliance milestones exist.

VII. ADDITIONAL REQUIREMENTS.

SECTION C. Site Level Plan Approval Requirements

No additional compliance certifications exist except as provided in other sections of this plan approval including Section B 

(relating to Plan Approval General Requirements).
06-05150A

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BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE

DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

Source ID: 030 Source Name: FUEL PREHEATER

Source Capacity/Throughput: 

I. RESTRICTIONS.

 # 001

 # 002

 # 003

 # 004

 [25 Pa. Code §123.11]

 [25 Pa. Code §123.22]

 [25 Pa. Code §127.12b]

 [25 Pa. Code §127.12b]

Combustion units

Combustion units

Plan approval terms and conditions.

Plan approval terms and conditions.

The permittee shall limit the emissions of particulate matter to 0.4 pounds per million BTU of heat input or less.

No person may permit the emission into the outdoor atmosphere of sulfur oxides, expressed as SO2, from any combustion

unit, at any time, in excess of the rate of 3 pounds per million BTU of heat input over any 1-hour period. 

[25 PA Code 123.22(c)(1)]

In accordance with the plan approval application the Department designates as Best Available Control Technology (BACT) 

the following limits on the emissions to atmosphere from the fuel gas heaters:

a. Nitrogen Oxides (NOx) as NO2 - 0.035 lb/mmBtu based on vendor data

b. Carbon Monoxide (CO) - 0.05 lb/mmBtu based on vendor data

c. Particulate Matter (PM/PM-10) - 0.007 lb/mmBtu based on AP-42 factors

d. Volatile Organic Compounds (VOC) - 0.005 lb/mmBtu based on AP-42 factors

e. Sulfur Dioxide (SO2) - 0.0021 lb/mmBtu for natural gas with maximum sulfur content of 0.68 grain/100 dscf

f. Sulfuric Acid (H2SO4) - 0.00048 lb/mmBtu for natural gas with maximum sulfur content of 0.68 grain/100 dscf

The permittee is limited to firing only natural gas in this source.

Emission Restriction(s).

Fuel Restriction(s).

 # 005 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

The permittee shall install and maintain the necessary meter(s) to determine and to record amount of fuel usage.

GHG

PM2.5

Conditions for this source occur in the following groups:

FML

FML01

CU

030

STAC

S030

 8.500 MMBTU/HR

 8.330 MCF/HR Natural Gas

No additional testing requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements) and/or Section E (Source Group Restrictions).

II.

III.

TESTING REQUIREMENTS.

MONITORING REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
06-05150A

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BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE

DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

No additional record keeping requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional reporting requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional work practice requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional requirements exist except as provided in other sections of this plan approval including Section B (Plan Approval 

General Requirements) and/or Section E (Source Group Restrictions).

IV.

V.

VI.

VII.

RECORDKEEPING REQUIREMENTS.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

ADDITIONAL REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
06-05150A

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BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE

DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

Source ID: 031 Source Name: COMBINED CYCLE UNIT #1

Source Capacity/Throughput: 

I. RESTRICTIONS.

CAIR

CCU

CEM

GHG

PM2.5

STARTUP & SHUTDOWN

SUBPART KKKK

Conditions for this source occur in the following groups:

No additional requirements exist except as provided in other sections of this plan approval including Section B (Plan Approval

General Requirements) and/or Section E (Source Group Restrictions).

FML

FML01

CU

031

CNTL

C031A

CNTL

C031B

STAC

S031

 3,046.000 MMBTU/HR

 2.980 MMCF/HR Natural Gas

No additional testing requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional monitoring requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional record keeping requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional reporting requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional work practice requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional requirements exist except as provided in other sections of this plan approval including Section B (Plan Approval 

General Requirements) and/or Section E (Source Group Restrictions).

II.

III.

IV.

V.

VI.

VII.

TESTING REQUIREMENTS.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

ADDITIONAL REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
06-05150A

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BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE

DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

Source ID: 032 Source Name: COMBINED CYCLE UNIT #2

Source Capacity/Throughput: 

I. RESTRICTIONS.

CAIR

CCU

CEM

GHG

PM2.5

STARTUP & SHUTDOWN

SUBPART KKKK

Conditions for this source occur in the following groups:

No additional requirements exist except as provided in other sections of this plan approval including Section B (Plan Approval

General Requirements) and/or Section E (Source Group Restrictions).

FML

FML01

CU

032

CNTL

C032A

CNTL

C032B

STAC

S032

 3,046.000 MMBTU/HR

 2.980 MMCF/HR Natural Gas

No additional testing requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional monitoring requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional record keeping requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional reporting requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional work practice requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements) and/or Section E (Source Group Restrictions).

No additional requirements exist except as provided in other sections of this plan approval including Section B (Plan Approval 

General Requirements) and/or Section E (Source Group Restrictions).

II.

III.

IV.

V.

VI.

VII.

TESTING REQUIREMENTS.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

ADDITIONAL REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
06-05150A

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BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE

DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

Source ID: 033 Source Name: AUXILIARY BOILER

Source Capacity/Throughput: 

I. RESTRICTIONS.

 # 001

 # 002

 # 003

 [25 Pa. Code §127.12b]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.42c]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.43c]

Plan approval terms and conditions.

Standard for sulfur dioxide.

Standard for particulate matter.

The emissions shall not exceed the following:

1. PM/PM10/PM2.5: 0.005 lb/mmbtu or 0.46 tpy based on a 12-month rolling total

2. NOx: 0.011 lb/mmbtu or 1.01 tpy based on a 12-month rolling total

3. CO: 0.036 lb/mmbtu or 3.31 tpy based on a 12-month rolling total

4. VOC: 0.0015 lb/mmbtu or 0.14 tpy based on a 12-month rolling total

5. SOx: 0.0021 lb/mmbtu or 0.19 tpy based on a 12-month rolling total

6. H2SO4: 0.00048 lb/mmbtu or 0.04 tpy based on a 12-month rolling total

Not applicable

Not applicable

Emission Restriction(s).

 # 004

 # 005

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.44c]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.45c]

Compliance and performance test methods and procedures for sulfur dioxide.

Compliance and performance test methods and procedures for particulate matter.

Not applicable

Not applicable

Subpart Dc - Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units

Subpart Dc - Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units

GHG

PM2.5

Conditions for this source occur in the following groups:

Subpart Dc - Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units

Subpart Dc - Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units

FML

FML01

CU

033

STAC

S033

 40.000 MMBTU/HR

 39.300 MCF/HR Natural Gas

II. TESTING REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
06-05150A

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BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE

DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

 # 006

 # 007

 # 008

 # 009

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.46c]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.47c]

 [25 Pa. Code §127.12b]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.48c]

Emission monitoring for sulfur dioxide

Emission monitoring for particulate matter.

Plan approval terms and conditions.

Reporting and recordkeeping requirements.

Not applicable

Not applicable

(a) All recordkeeping shall commence upon startup of the source and shall be kept for a period of 5 years and made 

available to the Department upon request.

(b) The company shall maintain a log of all preventative maintenance inspections of the source. The inspection logs, at a 

minimum, shall contain the dates of the inspections, the name of the person performing the inspection, any mechanical 

repairs and/or adjustments, any potential problems or defects that were encountered, and the steps taken to correct them.

(c) The company shall maintain a log of the following, at a minimum, from the operational inspections:

1. Completion of inspection - daily defined as at least once per calendar day, while the source is operating or as approved 

by the Department in the work practice inspection protocol.

(d) The permittee shall comply with the recordkeeping and certification requirements in accordance with 40 CFR 

§§60.46c(e), 60.42c(h) and 60.48c(f)(1). Reports shall be submitted on a semi-annual basis unless no excess emissions 

occurred. If there are no excess emissions, the permittee shall semi-annually report that no excess emissions occurred 

during the semi-annual reporting period (this does not apply to gas-fired units).

(e) The permittee shall maintain daily fuel consumption records in accordance with 40 CFR §60.48c(g).

The following conditions are related to the GHG Tailoring Rule (40 CFR 51, 52 and 98)

(f) The facility shall maintain sufficient records to adequately demonstrate compliance with the emission limitations 

associated with the GHG rule.

(a) The owner or operator of each affected facility shall submit notification of the date of construction or reconstruction and 

actual startup, as provided by § 60.7 of this part. This notification shall include:

(1) The design heat input capacity of the affected facility and identification of fuels to be combusted in the affected facility.

(2) If applicable, a copy of any federally enforceable requirement that limits the annual capacity factor for any fuel or mixture 

of fuels under § 60.42c, or § 60.43c.

(3) The annual capacity factor at which the owner or operator anticipates operating the affected facility based on all fuels 

fired and based on each individual fuel fired.

(4) Notification if an emerging technology will be used for controlling SO2 emissions. The Administrator will examine the 

description of the control device and will determine whether the technology qualifies as an emerging technology. In making 

Subpart Dc - Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units

Subpart Dc - Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units

Subpart Dc - Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units

III.

IV.

V.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

REPORTING REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
06-05150A

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BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE

DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

 # 010 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

this determination, the Administrator may require the owner or operator of the affected facility to submit additional 

information concerning the control device. The affected facility is subject to the provisions of § 60.42c(a) or (b)(1), unless and

until this determination is made by the Administrator.

(b) Not applicable

(c) Not applicable

(d) Not applicable

(e) Not applicable

(f) Fuel supplier certification shall include the following information:

(1) Not applicable

(2) Not applicable

(3) Not applicable

(4) For other fuels:

 (i) The name of the supplier of the fuel;

 (ii) The potential sulfur emissions rate or maximum potential sulfur emissions rate of the fuel in ng/J heat input; and

 (iii) The method used to determine the potential sulfur emissions rate of the fuel.

(g)(1) Except as provided under paragraphs (g)(2) and (g)(3) of this section, the owner or operator of each affected facility 

shall record and maintain records of the amount of each fuel combusted during each operating day.

(2) As an alternative to meeting the requirements of paragraph (g)(1) of this section, the owner or operator of an affected 

facility that combusts only natural gas, wood, fuels using fuel certification in § 60.48c(f) to demonstrate compliance with the 

SO2 standard, fuels not subject to an emissions standard (excluding opacity), or a mixture of these fuels may elect to record

and maintain records of the amount of each fuel combusted during each calendar month.

(3) Not applicable

(h) Not applicable

(i) All records required under this section shall be maintained by the owner or operator of the affected facility for a period of 

two years following the date of such record.

(j) The reporting period for the reports required under this subpart is each six-month period. All reports shall be submitted to

the Administrator and shall be postmarked by the 30th day following the end of the reporting period.

(a) The permittee shall perform a daily operational inspection of the source until such time as the Department approves a 

work practice inspection protocol submitted by the permittee. After Departmental approval, the permittee shall perform 

periodic inspections of the significant source equipment and emission controls in accordance with the approved work 

practice inspection protocol.

(b) The permittee shall install and maintain the necessary meter(s) to determine and to record amount of fuel usage.

VI. WORK PRACTICE REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
06-05150A

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DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

 # 011

 # 012

 [25 Pa. Code §127.12b]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.40c]

Plan approval terms and conditions.

Applicability and delegation of authority.

(c) The permittee shall maintain and operate the source in accordance with the manufacturer's specifications, the 

manufacturer's preventative maintenance schedule, and good air pollution control practices. The facility shall maintain a 

copy of the manufacturer's preventative maintenance schedule on-site.

(a) The source is subject to 40 CFR 60 Subpart Dc Standards of Performance for Small Industrial-Commercial-Institutional 

Steam Generating Units.

(b) Any information required to be submitted as part of this plan approval should be submitted to the attention of Air Quality 

Program Manager, Air Quality Program, Southcentral Regional Office, 909 Elmerton Avenue, Harrisburg, PA 17110.

(c) In accordance with 40 CFR 60.4 copies of all requests, reports, applications submittals and other communications shall 

be forwarded to both EPA and the Department at the addresses listed below unless otherwise noted.

Air Quality Program Manager

Pa DEP

Air Quality Program

Southcentral Regional Office

909 Elmerton Avenue, Harrisburg, PA 17110.

Director

Air Toxics and Radiation

US EPA, Region III

1650 Arch Street

Philadelphia, PA 19103-2029

(d) Issuance of an Operating Permit is contingent upon satisfactory compliance with the plan approval conditions, upon the 

control device being installed, tested, and operated as stated within the application, and upon satisfactory demonstration 

that the emissions from the source will not be in violation of applicable Rules and Regulations of the Department.

(a) Except as provided in paragraphs (d), (e), (f), and (g) of this section, the affected facility to which this subpart applies is 

each steam generating unit for which construction, modification, or reconstruction is commenced after June 9, 1989 and 

that has a maximum design heat input capacity of 29 megawatts (MW) (100 million British thermal units per hour (MMBtu/h))

or less, but greater than or equal to 2.9 MW (10 MMBtu/h).

(b) In delegating implementation and enforcement authority to a State under section 111(c) of the Clean Air Act, § 

60.48c(a)(4) shall be retained by the Administrator and not transferred to a State.

(c) Steam generating units that meet the applicability requirements in paragraph (a) of this section are not subject to the 

sulfur dioxide (SO2 ) or particulate matter (PM) emission limits, performance testing requirements, or monitoring 

requirements under this subpart (§§ 60.42c, 60.43c, 60.44c, 60.45c, 60.46c, or 60.47c) during periods of combustion 

research, as defined in § 60.41c.

(d) Any temporary change to an existing steam generating unit for the purpose of conducting combustion research is not 

considered a modification under § 60.14.

(e) Affected facilities ( i.e. heat recovery steam generators and fuel heaters) that are associated with stationary combustion 

turbines and meet the applicability requirements of subpart KKKK of this part are not subject to this subpart. This subpart 

will continue to apply to all other heat recovery steam generators, fuel heaters, and other affected facilities that are capable 

of combusting more than or equal to 2.9 MW (10 MMBtu/h) heat input of fossil fuel but less than or equal to 29 MW (100 

Subpart Dc - Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units

VII. ADDITIONAL REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
06-05150A

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DEP Auth ID: 965778 PROPOSED 10/04/2013 10:42 AM

 # 013 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.41c]

Definitions.

MMBtu/h) heat input of fossil fuel. If the heat recovery steam generator, fuel heater, or other affected facility is subject to this 

subpart, only emissions resulting from combustion of fuels in the steam generating unit are subject to this subpart. (The 

stationary combustion turbine emissions are subject to subpart GG or KKKK, as applicable, of this part.)

(f) Any affected facility that meets the applicability requirements of and is subject to subpart AAAA or subpart CCCC of this 

part is not subject to this subpart.

(g) Any facility that meets the applicability requirements and is subject to an EPA approved State or Federal section 

111(d)/129 plan implementing subpart BBBB of this part is not subject to this subpart.

(h) Affected facilities that also meet the applicability requirements under subpart J or subpart Ja of this part are subject to the

PM and NOX standards under this subpart and the SO2 standards under subpart J or subpart Ja of this part, as applicable.

(i) Temporary boilers are not subject to this subpart.

As used in this subpart, all terms not defined herein shall have the meaning given them in the Clean Air Act and in subpart A

of this part.

Annual capacity factor means the ratio between the actual heat input to a steam generating unit from an individual fuel or 

combination of fuels during a period of 12 consecutive calendar months and the potential heat input to the steam generating

unit from all fuels had the steam generating unit been operated for 8,760 hours during that 12-month period at the 

maximum design heat input capacity. In the case of steam generating units that are rented or leased, the actual heat input 

shall be determined based on the combined heat input from all operations of the affected facility during a period of 12 

consecutive calendar months.

Coal means all solid fuels classified as anthracite, bituminous, subbituminous, or lignite by the American Society of Testing

and Materials in ASTM D388 (incorporated by reference, see § 60.17), coal refuse, and petroleum coke. Coal-derived 

synthetic fuels derived from coal for the purposes of creating useful heat, including but not limited to solvent refined coal, 

gasified coal not meeting the definition of natural gas, coal-oil mixtures, and coal-water mixtures, are also included in this 

definition for the purposes of this subpart.

Coal refuse means any by-product of coal mining or coal cleaning operations with an ash content greater than 50 percent 

(by weight) and a heating value less than 13,900 kilojoules per kilogram (kJ/kg) (6,000 Btu per pound (Btu/lb) on a dry basis.

Combined cycle system means a system in which a separate source (such as a stationary gas turbine, internal combustion

engine, or kiln) provides exhaust gas to a steam generating unit.

Combustion research means the experimental firing of any fuel or combination of fuels in a steam generating unit for the 

purpose of conducting research and development of more efficient combustion or more effective prevention or control of air 

pollutant emissions from combustion, provided that, during these periods of research and development, the heat generated

is not used for any purpose other than preheating combustion air for use by that steam generating unit ( i.e. , the heat 

generated is released to the atmosphere without being used for space heating, process heating, driving pumps, preheating

combustion air for other units, generating electricity, or any other purpose).

Conventional technology means wet flue gas desulfurization technology, dry flue gas desulfurization technology, 

atmospheric fluidized bed combustion technology, and oil hydrodesulfurization technology.

Distillate oil means fuel oil that complies with the specifications for fuel oil numbers 1 or 2, as defined by the American 

Society for Testing and Materials in ASTM D396 (incorporated by reference, see § 60.17), diesel fuel oil numbers 1 or 2, as 

defined by the American Society for Testing and Materials in ASTM D975 (incorporated by reference, see § 60.17), kerosine, 

as defined by the American Society of Testing and Materials in ASTM D3699 (incorporated by reference, see § 60.17), 

biodiesel as defined by the American Society of Testing and Materials in ASTM D6751 (incorporated by reference, see § 

60.17), or biodiesel blends as defined by the American Society of Testing and Materials in ASTM D7467 (incorporated by 

Subpart Dc - Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units

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reference, see § 60.17).

Dry flue gas desulfurization technology means a SO2 control system that is located between the steam generating unit and 

the exhaust vent or stack, and that removes sulfur oxides from the combustion gases of the steam generating unit by 

contacting the combustion gases with an alkaline reagent and water, whether introduced separately or as a premixed slurry 

or solution and forming a dry powder material. This definition includes devices where the dry powder material is 

subsequently converted to another form. Alkaline reagents used in dry flue gas desulfurization systems include, but are not 

limited to, lime and sodium compounds.

Duct burner means a device that combusts fuel and that is placed in the exhaust duct from another source (such as a 

stationary gas turbine, internal combustion engine, kiln, etc.) to allow the firing of additional fuel to heat the exhaust gases 

before the exhaust gases enter a steam generating unit.

Emerging technology means any SO2 control system that is not defined as a conventional technology under this section, 

and for which the owner or operator of the affected facility has received approval from the Administrator to operate as an 

emerging technology under § 60.48c(a)(4).

Federally enforceable means all limitations and conditions that are enforceable by the Administrator, including the 

requirements of 40 CFR parts 60 and 61, requirements within any applicable State implementation plan, and any permit 

requirements established under 40 CFR 52.21 or under 40 CFR 51.18 and 51.24.

Fluidized bed combustion technology means a device wherein fuel is distributed onto a bed (or series of beds) of limestone

aggregate (or other sorbent materials) for combustion; and these materials are forced upward in the device by the flow of 

combustion air and the gaseous products of combustion. Fluidized bed combustion technology includes, but is not limited 

to, bubbling bed units and circulating bed units.

Fuel pretreatment means a process that removes a portion of the sulfur in a fuel before combustion of the fuel in a steam 

generating unit.

Heat input means heat derived from combustion of fuel in a steam generating unit and does not include the heat derived 

from preheated combustion air, recirculated flue gases, or exhaust gases from other sources (such as stationary gas 

turbines, internal combustion engines, and kilns).

Heat transfer medium means any material that is used to transfer heat from one point to another point.

Maximum design heat input capacity means the ability of a steam generating unit to combust a stated maximum amount of 

fuel (or combination of fuels) on a steady state basis as determined by the physical design and characteristics of the steam 

generating unit.

Natural gas means:

(1) A naturally occurring mixture of hydrocarbon and nonhydrocarbon gases found in geologic formations beneath the 

earth's surface, of which the principal constituent is methane; or

(2) Liquefied petroleum (LP) gas, as defined by the American Society for Testing and Materials in ASTM D1835 (incorporated

by reference, see § 60.17); or

(3) A mixture of hydrocarbons that maintains a gaseous state at ISO conditions. Additionally, natural gas must either be 

composed of at least 70 percent methane by volume or have a gross calorific value between 34 and 43 megajoules (MJ) per

dry standard cubic meter (910 and 1,150 Btu per dry standard cubic foot).

Noncontinental area means the State of Hawaii, the Virgin Islands, Guam, American Samoa, the Commonwealth of Puerto 

Rico, or the Northern Mariana Islands.

Oil means crude oil or petroleum, or a liquid fuel derived from crude oil or petroleum, including distillate oil and residual oil.

SECTION D. Source Level Plan Approval Requirements
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Potential sulfur dioxide emission rate means the theoretical SO2 emissions (nanograms per joule (ng/J) or lb/MMBtu heat 

input) that would result from combusting fuel in an uncleaned state and without using emission control systems.

Process heater means a device that is primarily used to heat a material to initiate or promote a chemical reaction in which 

the material participates as a reactant or catalyst.

Residual oil means crude oil, fuel oil that does not comply with the specifications under the definition of distillate oil, and all 

fuel oil numbers 4, 5, and 6, as defined by the American Society for Testing and Materials in ASTM D396 (incorporated by 

reference, see § 60.17).

Steam generating unit means a device that combusts any fuel and produces steam or heats water or heats any heat 

transfer medium. This term includes any duct burner that combusts fuel and is part of a combined cycle system. This term 

does not include process heaters as defined in this subpart.

Steam generating unit operating day means a 24-hour period between 12:00 midnight and the following midnight during 

which any fuel is combusted at any time in the steam generating unit. It is not necessary for fuel to be combusted 

continuously for the entire 24-hour period.

Temporary boiler means a steam generating unit that combusts natural gas or distillate oil with a potential SO2 emissions 

rate no greater than 26 ng/J (0.060 lb/MMBtu), and the unit is designed to, and is capable of, being carried or moved from 

one location to another by means of, for example, wheels, skids, carrying handles, dollies, trailers, or platforms. A steam 

generating unit is not a temporary boiler if any one of the following conditions exists:

(1) The equipment is attached to a foundation.

(2) The steam generating unit or a replacement remains at a location for more than 180 consecutive days. Any temporary 

boiler that replaces a temporary boiler at a location and performs the same or similar function will be included in calculating 

the consecutive time period.

(3) The equipment is located at a seasonal facility and operates during the full annual operating period of the seasonal 

facility, remains at the facility for at least 2 years, and operates at that facility for at least 3 months each year.

(4) The equipment is moved from one location to another in an attempt to circumvent the residence time requirements of 

this definition.

Wet flue gas desulfurization technology means an SO2 control system that is located between the steam generating unit 

and the exhaust vent or stack, and that removes sulfur oxides from the combustion gases of the steam generating unit by 

contacting the combustion gases with an alkaline slurry or solution and forming a liquid material. This definition includes 

devices where the liquid material is subsequently converted to another form. Alkaline reagents used in wet flue gas 

desulfurization systems include, but are not limited to, lime, limestone, and sodium compounds.

Wet scrubber system means any emission control device that mixes an aqueous stream or slurry with the exhaust gases 

from a steam generating unit to control emissions of PM or SO2 .

Wood means wood, wood residue, bark, or any derivative fuel or residue thereof, in any form, including but not limited to 

sawdust, sanderdust, wood chips, scraps, slabs, millings, shavings, and processed pellets made from wood or other 

forest residues.

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Source ID: 101 Source Name: EMERGENCY GENERATOR (750 KW)

Source Capacity/Throughput: 

I. RESTRICTIONS.

 # 001

 # 002

 [25 Pa. Code §127.12b]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4202]

Plan approval terms and conditions.

What emission standards must I meet for emergency engines if I am a stationary CI internal combustion engine 

manufacturer?

(a) The emissions shall not exceed the following:

1. PM/PM10/PM2.5: 0.33 lb/hr or 0.017 tpy based on a 12-month rolling total [Compliance with this requirement will show 

compliance with 25 PA Code 123.13]

2. NOx: 10.6 lb/hr or 0.53 tpy based on a 12-month rolling total

3. CO: 5.79 lb/hr or 0.29 tpy based on a 12-month rolling total

4. VOC: 0.63 lb/hr or 0.03 tpy based on a 12-month rolling total

5. SOx: 0.011 lb/hr or 0.00055 tpy based on a 12-month rolling total [Compliance with this requirement will show 

compliance with 25 PA Code 123.21]

6. H2SO4: 0.0025 lb/hr or 0.00013 tpy based on a 12-month rolling total

(b) The permittee may not allow the emission into the outdoor atmosphere of visible air contaminants in such a manner 

that the opacity of the emission is either of the following:

1. Equal to or greater than 15% for a period or periods aggregating more than three (3) minutes in any hour.

2. Equal to or greater than 50% at any time.

(a) Stationary CI internal combustion engine manufacturers must certify their 2007 model year and later emergency 

stationary CI ICE with a maximum engine power less than or equal to 2,237 KW (3,000 HP) and a displacement of less 

than 10 liters per cylinder that are not fire pump engines to the emission standards specified in paragraphs (a)(1) through 

(2) of this section.

(1) Not applicable

(2) For engines with a maximum engine power greater than or equal to 37 KW (50 HP), the certification emission standards

for new nonroad CI engines for the same model year and maximum engine power in 40 CFR 89.112 and 40 CFR 89.113 

for all pollutants beginning in model year 2007.

Emission Restriction(s).

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

GHG

PM2.5

Conditions for this source occur in the following groups:

FML

FML02

PROC

101

STAC

S101

 60.000 Gal/HR ULTRA LOW SULFUR DISTILLAT

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 # 003

 # 004

 # 005

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4204]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4205]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4217]

What emission standards must I meet for non-emergency engines if I am an owner or operator of a stationary CI 

internal combustion engine?

What emission standards must I meet for emergency engines if I am an owner or operator of a stationary CI internal 

combustion engine?

What emission standards must I meet if I am an owner or operator of a stationary internal combustion engine using 

special fuels?

[89.112 Table: kW > 560 Tier 2 2006: NMHC + NOx: 6.4; CO: 3.5; PM: 0.2 Emission limits are in g/kW-hr]

[89.113: Opacity must not exceed: (1) 20 percent during the acceleration mode; (2) 15 percent during the lugging mode; and

(3) 50 percent during the peaks in either the acceleration or lugging modes.]

(b) Not applicable

(c) [Reserved]

(d) Not applicable

(e) Not applicable

(f) Not applicable

(g) Not applicable

(h) Notwithstanding the requirements in paragraphs (a) through (f) of this section, stationary CI internal combustion engine 

manufacturers are not required to certify reconstructed engines; however manufacturers may elect to do so. The 

reconstructed engine must be certified to the emission standards specified in paragraphs (a) through (f) of this section that 

are applicable to the model year, maximum engine power and displacement of the reconstructed emergency stationary CI 

ICE.

Not applicable

(a) Not applicable

 

(b) Owners and operators of 2007 model year and later emergency stationary CI ICE with a displacement of less than 30 

liters per cylinder that are not fire pump engines must comply with the emission standards for new nonroad CI engines in §

60.4202, for all pollutants, for the same model year and maximum engine power for their 2007 model year and later 

emergency stationary CI ICE.

(c) Not applicable

 

(d) Not applicable

(e) Owners and operators of emergency stationary CI ICE with a displacement of less than 30 liters per cylinder who 

conduct performance tests in-use must meet the NTE standards as indicated in § 60.4212.

(f) Not applicable

Not applicable

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

SECTION D. Source Level Plan Approval Requirements
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 # 006

 # 007

 # 008

 [25 Pa. Code §127.12b]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4207]

 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

What fuel requirements must I meet if I am an owner or operator of a stationary CI internal combustion engine subject 

to this subpart?

Plan approval terms and conditions.

The emergency generator shall fire only ultralow sulfur diesel fuel (sulfur content less than 15 parts per million by weight).

(a) Not applicable

 

(b) Beginning October 1, 2010, owners and operators of stationary CI ICE subject to this subpart with a displacement of 

less than 30 liters per cylinder that use diesel fuel must purchase diesel fuel that meets the requirements of 40 CFR 

80.510(b) for nonroad diesel fuel. [From 40 CFR 80.510(b): Sulfur content: 15 parts per million (ppm) maximum for NR or 

500 ppm maximum for LR; Cetane index or aromatic content, as follows: (i) A minimum cetane index of 40; or (ii) A 

maximum aromatic content of 35 volume percent]

(c) [Reserved]

(d) Not applicable

(e) Not applicable

(a) The annual operation during testing shall not exceed 100 hours per year.

(b) The duration of each test shall not exceed 30 minutes.

(c) The emergency generator and the emergency firewater pump shall not be tested simultaneously (within the same hour).

(d) The emergency generator and the emergency firewater pump shall not be tested during (within the same hour as) 

startup or shutdown of the combustion turbines.

Fuel Restriction(s).

Operation Hours Restriction(s).

 # 009 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4212]

What test methods and other procedures must I use if I am an owner or operator of a stationary CI internal combustion 

engine with a displacement of less than 30 liters per cylinder?

Owners and operators of stationary CI ICE with a displacement of less than 30 liters per cylinder who conduct performance 

tests pursuant to this subpart must do so according to paragraphs (a) through (e) of this section.

(a) The performance test must be conducted according to the in-use testing procedures in 40 CFR part 1039, subpart F, for 

stationary CI ICE with a displacement of less than 10 liters per cylinder, and according to 40 CFR part 1042, subpart F, for 

stationary CI ICE with a displacement of greater than or equal to 10 liters per cylinder and less than 30 liters per cylinder.

(b) Exhaust emissions from stationary CI ICE that are complying with the emission standards for new CI engines in 40 CFR 

part 1039 must not exceed the not-to-exceed (NTE) standards for the same model year and maximum engine power as 

required in 40 CFR 1039.101(e) and 40 CFR 1039.102(g)(1), except as specified in 40 CFR 1039.104(d). This requirement 

starts when NTE requirements take effect for nonroad diesel engines under 40 CFR part 1039.

(c) Exhaust emissions from stationary CI ICE that are complying with the emission standards for new CI engines in 40 CFR 

89.112 or 40 CFR 94.8, as applicable, must not exceed the NTE numerical requirements, rounded to the same number of 

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

II. TESTING REQUIREMENTS.

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 # 010

 # 011

 # 012

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4213]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4209]

 [25 Pa. Code §127.12b]

 What test methods and other procedures must I use if I am an owner or operator of a stationary CI internal combustion

engine with a displacement of greater than or equal to 30 liters per cylinder?

What are the monitoring requirements if I am an owner or operator of a stationary CI internal combustion engine?

Plan approval terms and conditions.

decimal places as the applicable standard in 40 CFR 89.112 or 40 CFR 94.8, as applicable, determined from the following 

equation in 40 CFR 60.4212(c). Alternatively, stationary CI ICE that are complying with the emission standards for new CI 

engines in 40 CFR 89.112 or 40 CFR 94.8 may follow the testing procedures specified in § 60.4213 of this subpart, as 

appropriate.

(d) Not applicable

(e) Exhaust emissions from stationary CI ICE that are complying with the emission standards for new CI engines in 40 CFR 

part 1042 must not exceed the NTE standards for the same model year and maximum engine power as required in 40 CFR 

1042.101(c).

Not applicable

If you are an owner or operator, you must meet the monitoring requirements of this section. In addition, you must also meet 

the monitoring requirements specified in §60.4211. 

 

(a) If you are an owner or operator of an emergency stationary CI internal combustion engine that does not meet the 

standards applicable to non-emergency engines, you must install a non-resettable hour meter prior to startup of the engine.

 

(b) Not applicable

(a) All recordkeeping shall commence upon startup of the source and shall be kept for a period of 5 years and made 

available to the Department upon request.

(b) The company shall maintain a log of all preventative maintenance inspections of the source. The inspection logs, at a 

minimum, shall contain the dates of the inspections, the name of the person performing the inspection, any mechanical 

repairs and/or adjustments, any potential problems or defects that were encountered, and the steps taken to correct them.

(c) The company shall maintain a log of the following, at a minimum, from the operational inspections:

1. Completion of inspection - daily defined as at least once per calendar day, while the source is operating or as approved 

by the Department in the work practice inspection protocol.

(d) The permittee shall keep records of the fuel certification reports for each delivery of diesel fuel to verify compliance with 

the fuel restriction requirements.

The following conditions are related to the GHG Tailoring Rule (40 CFR 51, 52 and 98)

(e) The facility shall maintain sufficient records to adequately demonstrate compliance with the emission limitations 

associated with the GHG rule.

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

III.

IV.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

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 # 013

 # 014

 # 015

 # 016

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4214]

 [25 Pa. Code §127.12b]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4206]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4211]

What are my notification, reporting, and recordkeeping requirements if I am an owner or operator of a stationary CI 

internal combustion engine?

Plan approval terms and conditions.

How long must I meet the emission standards if I am an owner or operator of a stationary CI internal combustion 

engine?

What are my compliance requirements if I am an owner or operator of a stationary CI internal combustion engine?

(a) Not applicable

(b) If the stationary CI internal combustion engine is an emergency stationary internal combustion engine, the owner or 

operator is not required to submit an initial notification. Starting with the model years in table 5 to this subpart, if the 

emergency engine does not meet the standards applicable to non-emergency engines in the applicable model year, the 

owner or operator must keep records of the operation of the engine in emergency and non-emergency service that are 

recorded through the non-resettable hour meter. The owner must record the time of operation of the engine and the reason 

the engine was in operation during that time.

(c) Not applicable

(a) The permittee shall perform a daily operational inspection of the source until such time as the Department approves a 

work practice inspection protocol submitted by the permittee. After Departmental approval, the permittee shall perform 

periodic inspections of the significant source equipment and emission controls in accordance with the approved work 

practice inspection protocol.

(b) The permittee shall maintain and operate the source in accordance with the manufacturer's specifications, the 

manufacturer's preventative maintenance schedule, and good air pollution control practices. The facility shall maintain a 

copy of the manufacturer's preventative maintenance schedule on-site.

Owners and operators of stationary CI ICE must operate and maintain stationary CI ICE that achieve the emission 

standards as required in §§60.4204 and 60.4205 over the entire life of the engine.

(a) If you are an owner or operator and must comply with the emission standards specified in this subpart, you must do all 

of the following, except as permitted under paragraph (g) of this section:

(1) Operate and maintain the stationary CI internal combustion engine and control device according to the manufacturer's 

emission-related written instructions;

(2) Change only those emission-related settings that are permitted by the manufacturer; and

(3) Meet the requirements of 40 CFR parts 89, 94 and/or 1068, as they apply to you.

(b) Not applicable

(c) If you are an owner or operator of a 2007 model year and later stationary CI internal combustion engine and must comply

with the emission standards specified in § 60.4204(b) or § 60.4205(b), or if you are an owner or operator of a CI fire pump 

engine that is manufactured during or after the model year that applies to your fire pump engine power rating in table 3 to 

this subpart and must comply with the emission standards specified in § 60.4205(c), you must comply by purchasing an 

engine certified to the emission standards in § 60.4204(b), or § 60.4205(b) or (c), as applicable, for the same model year 

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

V.

VI.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
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 # 017 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

and maximum (or in the case of fire pumps, NFPA nameplate) engine power. The engine must be installed and configured 

according to the manufacturer's emission-related specifications, except as permitted in paragraph (g) of this section.

(d) Not applicable

(e) Not applicable

(f) Emergency stationary ICE may be operated for the purpose of maintenance checks and readiness testing, provided that 

the tests are recommended by Federal, State or local government, the manufacturer, the vendor, or the insurance company 

associated with the engine. Maintenance checks and readiness testing of such units is limited to 100 hours per year. There 

is no time limit on the use of emergency stationary ICE in emergency situations. The owner or operator may petition the 

Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not 

required if the owner or operator maintains records indicating that Federal, State, or local standards require maintenance 

and testing of emergency ICE beyond 100 hours per year. Emergency stationary ICE may operate up to 50 hours per year in 

non-emergency situations, but those 50 hours are counted towards the 100 hours per year provided for maintenance and 

testing. The 50 hours per year for non-emergency situations cannot be used for peak shaving or to generate income for a 

facility to supply power to an electric grid or otherwise supply non-emergency power as part of a financial arrangement with 

another entity. For owners and operators of emergency engines, any operation other than emergency operation, 

maintenance and testing, and operation in non-emergency situations for 50 hours per year, as permitted in this section, is 

prohibited.

(g) If you do not install, configure, operate, and maintain your engine and control device according to the manufacturer's 

emission-related written instructions, or you change emission-related settings in a way that is not permitted by the 

manufacturer, you must demonstrate compliance as follows:

(1) Not applicable

(2) Not applicable

(3) If you are an owner or operator of a stationary CI internal combustion engine greater than 500 HP, you must keep a 

maintenance plan and records of conducted maintenance and must, to the extent practicable, maintain and operate the 

engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, you must 

conduct an initial performance test to demonstrate compliance with the applicable emission standards within 1 year of 

startup, or within 1 year after an engine and control device is no longer installed, configured, operated, and maintained in 

accordance with the manufacturer's emission-related written instructions, or within 1 year after you change emission-related

settings in a way that is not permitted by the manufacturer. You must conduct subsequent performance testing every 8,760 

hours of engine operation or 3 years, whichever comes first, thereafter to demonstrate compliance with the applicable 

emission standards.

(a) The source is subject to 40 CFR 60 Subpart IIII Standards of Performance for Stationary Compression Ignition Internal 

Combustion Engines. [Compliance with this requirement will assure compliance with 40 CFR 63 Subpart ZZZZ]

(b) Any information required to be submitted as part of this plan approval should be submitted to the attention of Air Quality 

Program Manager, Air Quality Program, Southcentral Regional Office, 909 Elmerton Avenue, Harrisburg, PA 17110.

(c) In accordance with 40 CFR 60.4 copies of all requests, reports, applications submittals and other communications shall 

be forwarded to both EPA and the Department at the addresses listed below unless otherwise noted.

Air Quality Program Manager

Pa DEP

Air Quality Program

Southcentral Regional Office

VII. ADDITIONAL REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
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 # 018

 # 019

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4200]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4208]

Am I subject to this subpart?

What is the deadline for importing or installing stationary CI ICE produced in the previous model year?

909 Elmerton Avenue

Harrisburg, PA 17110.

Director

Air Toxics and Radiation

US EPA, Region III

1650 Arch Street

Philadelphia, PA 19103-2029

(d) Issuance of an Operating Permit is contingent upon satisfactory compliance with the plan approval conditions, upon the 

control device being installed, tested, and operated as stated within the application, and upon satisfactory demonstration 

that the emissions from the source will not be in violation of applicable Rules and Regulations of the Department.

(a) The provisions of this subpart are applicable to manufacturers, owners, and operators of stationary compression ignition

(CI) internal combustion engines (ICE) as specified in paragraphs (a)(1) through (4) of this section. For the purposes of this 

subpart, the date that construction commences is the date the engine is ordered by the owner or operator. 

 

(1) Not applicable 

 

(2) Owners and operators of stationary CI ICE that commence construction after July 11, 2005 where the stationary CI ICE 

are: 

 

 (i) Manufactured after April 1, 2006 and are not fire pump engines, or 

 

 (ii) Not applicable 

 

(3) Not applicable

(4) The provisions of § 60.4208 of this subpart are applicable to all owners and operators of stationary CI ICE that 

commence construction after July 11, 2005.

 

(b) Not applicable

 

(c) If you are an owner or operator of an area source subject to this subpart, you are exempt from the obligation to obtain a 

permit under 40 CFR part 70 or 40 CFR part 71, provided you are not required to obtain a permit under 40 CFR 70.3(a) or 40 

CFR 71.3(a) for a reason other than your status as an area source under this subpart. Notwithstanding the previous 

sentence, you must continue to comply with the provisions of this subpart applicable to area sources. 

 

(d) Not applicable

(e) Not applicable

(a) After December 31, 2008, owners and operators may not install stationary CI ICE (excluding fire pump engines) that do 

not meet the applicable requirements for 2007 model year engines.

(b) Not applicable

(c) Not applicable

(d) Not applicable

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

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 # 020

 # 021

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4218]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4219]

What parts of the General Provisions apply to me?

What definitions apply to this subpart?

(e) Not applicable

(f) Not applicable

(g) Not applicable

(h) In addition to the requirements specified in §§ 60.4201, 60.4202, 60.4204, and 60.4205, it is prohibited to import 

stationary CI ICE with a displacement of less than 30 liters per cylinder that do not meet the applicable requirements 

specified in paragraphs (a) through (g) of this section after the dates specified in paragraphs (a) through (g) of this section.

(i) The requirements of this section do not apply to owners or operators of stationary CI ICE that have been modified, 

reconstructed, and do not apply to engines that were removed from one existing location and reinstalled at a new location.

Table 8 to this subpart shows which parts of the General Provisions in §§60.1 through 60.19 apply to you.

As used in this subpart, all terms not defined herein shall have the meaning given them in the CAA and in subpart A of this 

part.

Certified emissions life means the period during which the engine is designed to properly function in terms of reliability and 

fuel consumption, without being remanufactured, specified as a number of hours of operation or calendar years, whichever 

comes first. The values for certified emissions life for stationary CI ICE with a displacement of less than 10 liters per cylinder

are given in 40 CFR 1039.101(g). The values for certified emissions life for stationary CI ICE with a displacement of greater 

than or equal to 10 liters per cylinder and less than 30 liters per cylinder are given in 40 CFR 94.9(a).

Combustion turbine means all equipment, including but not limited to the turbine, the fuel, air, lubrication and exhaust gas 

systems, control systems (except emissions control equipment), and any ancillary components and sub-components 

comprising any simple cycle combustion turbine, any regenerative/recuperative cycle combustion turbine, the combustion 

turbine portion of any cogeneration cycle combustion system, or the combustion turbine portion of any combined cycle 

steam/electric generating system.

Compression ignition means relating to a type of stationary internal combustion engine that is not a spark ignition engine.

Date of manufacture means one of the following things:

(1) For freshly manufactured engines and modified engines, date of manufacture means the date the engine is originally 

produced.

(2) For reconstructed engines, date of manufacture means the date the engine was originally produced, except as specified 

in paragraph (3) of this definition.

(3) Reconstructed engines are assigned a new date of manufacture if the fixed capital cost of the new and refurbished 

components exceeds 75 percent of the fixed capital cost of a comparable entirely new facility. An engine that is produced 

from a previously used engine block does not retain the date of manufacture of the engine in which the engine block was 

previously used if the engine is produced using all new components except for the engine block. In these cases, the date of 

manufacture is the date of reconstruction or the date the new engine is produced.

Diesel fuel means any liquid obtained from the distillation of petroleum with a boiling point of approximately 150 to 360 

degrees Celsius. One commonly used form is number 2 distillate oil.

Diesel particulate filter means an emission control technology that reduces PM emissions by trapping the particles in a flow 

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

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filter substrate and periodically removes the collected particles by either physical action or by oxidizing (burning off) the 

particles in a process called regeneration.

Emergency stationary internal combustion engine means any stationary internal combustion engine whose operation is 

limited to emergency situations and required testing and maintenance. Examples include stationary ICE used to produce 

power for critical networks or equipment (including power supplied to portions of a facility) when electric power from the 

local utility (or the normal power source, if the facility runs on its own power production) is interrupted, or stationary ICE used

to pump water in the case of fire or flood, etc. Stationary CI ICE used to supply power to an electric grid or that supply power 

as part of a financial arrangement with another entity are not considered to be emergency engines.

Engine manufacturer means the manufacturer of the engine. See the definition of “manufacturer” in this section.

Fire pump engine means an emergency stationary internal combustion engine certified to NFPA requirements that is used 

to provide power to pump water for fire suppression or protection.

Freshly manufactured engine means an engine that has not been placed into service. An engine becomes freshly 

manufactured when it is originally produced.

Installed means the engine is placed and secured at the location where it is intended to be operated.

Manufacturer has the meaning given in section 216(1) of the Act. In general, this term includes any person who 

manufactures a stationary engine for sale in the United States or otherwise introduces a new stationary engine into 

commerce in the United States. This includes importers who import stationary engines for sale or resale.

Maximum engine power means maximum engine power as defined in 40 CFR 1039.801.

Model year means the calendar year in which an engine is manufactured (see “date of manufacture”), except as follows:

(1) Model year means the annual new model production period of the engine manufacturer in which an engine is 

manufactured (see “date of manufacture”), if the annual new model production period is different than the calendar year and 

includes January 1 of the calendar year for which the model year is named. It may not begin before January 2 of the previous

calendar year and it must end by December 31 of the named calendar year.

(2) For an engine that is converted to a stationary engine after being placed into service as a nonroad or other non-stationary

engine, model year means the calendar year or new model production period in which the engine was manufactured (see 

“date of manufacture”).

Other internal combustion engine means any internal combustion engine, except combustion turbines, which is not a 

reciprocating internal combustion engine or rotary internal combustion engine.

Reciprocating internal combustion engine means any internal combustion engine which uses reciprocating motion to 

convert heat energy into mechanical work.

Rotary internal combustion engine means any internal combustion engine which uses rotary motion to convert heat energy 

into mechanical work.

Spark ignition means relating to a gasoline, natural gas, or liquefied petroleum gas fueled engine or any other type of 

engine with a spark plug (or other sparking device) and with operating characteristics significantly similar to the theoretical 

Otto combustion cycle. Spark ignition engines usually use a throttle to regulate intake air flow to control power during normal

operation. Dual-fuel engines in which a liquid fuel (typically diesel fuel) is used for CI and gaseous fuel (typically natural 

gas) is used as the primary fuel at an annual average ratio of less than 2 parts diesel fuel to 100 parts total fuel on an 

energy equivalent basis are spark ignition engines.

Stationary internal combustion engine means any internal combustion engine, except combustion turbines, that converts 

heat energy into mechanical work and is not mobile. Stationary ICE differ from mobile ICE in that a stationary internal 

combustion engine is not a nonroad engine as defined at 40 CFR 1068.30 (excluding paragraph (2)(ii) of that definition), 

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and is not used to propel a motor vehicle, aircraft, or a vehicle used solely for competition. Stationary ICE include 

reciprocating ICE, rotary ICE, and other ICE, except combustion turbines.

Subpart means 40 CFR part 60, subpart IIII.

SECTION D. Source Level Plan Approval Requirements
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Source ID: 102 Source Name: EMERGENCY FIREWATER PUMP (300 HP)

Source Capacity/Throughput: 

I. RESTRICTIONS.

 # 001

 # 002

 [25 Pa. Code §127.12b]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4205]

Plan approval terms and conditions.

What emission standards must I meet for emergency engines if I am an owner or operator of a stationary CI internal 

combustion engine?

(a) The emissions shall not exceed the following:

1. PM/PM10/PM2.5: 0.10 lb/hr or 0.005 tpy based on a 12-month rolling total [Compliance with this requirement will show 

compliance with 25 PA Code 123.13]

2. NOx: 1.70 lb/hr or 0.09 tpy based on a 12-month rolling total

3. CO: 1.70 lb/hr or 0.09 tpy based on a 12-month rolling total

4. VOC: 0.25 lb/hr or 0.013 tpy based on a 12-month rolling total

5. SOx: 0.0030 lb/hr or 0.00015 tpy based on a 12-month rolling total [Compliance with this requirement will show 

compliance with 25 PA Code 123.21]

6. H2SO4: 0.00075 lb/hr or 0.000038 tpy based on a 12-month rolling total

(b) The permittee may not allow the emission into the outdoor atmosphere of visible air contaminants in such a manner 

that the opacity of the emission is either of the following:

1. Equal to or greater than 15% for a period or periods aggregating more than three (3) minutes in any hour.

2. Equal to or greater than 50% at any time.

(a) Not applicable

(b) Not applicable

(c) Owners and operators of fire pump engines with a displacement of less than 30 liters per cylinder must comply with the 

emission standards in table 4 to this subpart, for all pollutants.

[From Table 4: 225<=KW<450 (300<=HP<600): Year 2009+ NMOC +NOx: 4.0 (3.0); PM: 0.2 (0.15) Emissions are in g/kW-hr

(g/hp-hr)]

Emission Restriction(s).

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

GHG

PM2.5

Conditions for this source occur in the following groups:

FML

FML03

PROC

102

STAC

S102

 16.000 Gal/HR ULTRA LOW SULFUR DISTILLAT

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 # 003

 # 004

 # 005

 # 006

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4217]

 [25 Pa. Code §127.12b]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4207]

 [25 Pa. Code §127.12b]

What emission standards must I meet if I am an owner or operator of a stationary internal combustion engine using 

special fuels?

Plan approval terms and conditions.

What fuel requirements must I meet if I am an owner or operator of a stationary CI internal combustion engine subject 

to this subpart?

Plan approval terms and conditions.

(d) Not applicable

(e) Owners and operators of emergency stationary CI ICE with a displacement of less than 30 liters per cylinder who 

conduct performance tests in-use must meet the NTE standards as indicated in § 60.4212.

(f) Not applicable

Not applicable

The emergency firewater pump shall fire only ultralow sulfur diesel fuel (sulfur content less than 15 parts per million by 

weight).

(a) Not applicable

 

(b) Beginning October 1, 2010, owners and operators of stationary CI ICE subject to this subpart with a displacement of 

less than 30 liters per cylinder that use diesel fuel must purchase diesel fuel that meets the requirements of 40 CFR 

80.510(b) for nonroad diesel fuel. [From 40 CFR 80.510(b): Sulfur content: 15 parts per million (ppm) maximum for NR or 

500 ppm maximum for LR; Cetane index or aromatic content, as follows: (i) A minimum cetane index of 40; or (ii) A 

maximum aromatic content of 35 volume percent]

(c) [Reserved]

(d) Not applicable

(e) Not applicable

(a) The annual operation during testing shall not exceed 100 hours per year.

(b) The duration of each test shall not exceed 30 minutes.

(c) The emergency generator and the emergency firewater pump shall not be tested simultaneously (within the same hour).

(d) The emergency generator and the emergency firewater pump shall not be tested during (within the same hour as) 

startup or shutdown of the combustion turbines.

Fuel Restriction(s).

Operation Hours Restriction(s).

 # 007 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4212]

What test methods and other procedures must I use if I am an owner or operator of a stationary CI internal combustion 

engine with a displacement of less than 30 liters per cylinder?

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

II. TESTING REQUIREMENTS.

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 # 008

 # 009

 # 010

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4213]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4209]

 [25 Pa. Code §127.12b]

 What test methods and other procedures must I use if I am an owner or operator of a stationary CI internal combustion

engine with a displacement of greater than or equal to 30 liters per cylinder?

What are the monitoring requirements if I am an owner or operator of a stationary CI internal combustion engine?

Plan approval terms and conditions.

Owners and operators of stationary CI ICE with a displacement of less than 30 liters per cylinder who conduct performance 

tests pursuant to this subpart must do so according to paragraphs (a) through (e) of this section.

(a) The performance test must be conducted according to the in-use testing procedures in 40 CFR part 1039, subpart F, for 

stationary CI ICE with a displacement of less than 10 liters per cylinder, and according to 40 CFR part 1042, subpart F, for 

stationary CI ICE with a displacement of greater than or equal to 10 liters per cylinder and less than 30 liters per cylinder.

(b) Exhaust emissions from stationary CI ICE that are complying with the emission standards for new CI engines in 40 CFR 

part 1039 must not exceed the not-to-exceed (NTE) standards for the same model year and maximum engine power as 

required in 40 CFR 1039.101(e) and 40 CFR 1039.102(g)(1), except as specified in 40 CFR 1039.104(d). This requirement 

starts when NTE requirements take effect for nonroad diesel engines under 40 CFR part 1039.

(c) Exhaust emissions from stationary CI ICE that are complying with the emission standards for new CI engines in 40 CFR 

89.112 or 40 CFR 94.8, as applicable, must not exceed the NTE numerical requirements, rounded to the same number of 

decimal places as the applicable standard in 40 CFR 89.112 or 40 CFR 94.8, as applicable, determined from the following 

equation in 40 CFR 60.4212(c). Alternatively, stationary CI ICE that are complying with the emission standards for new CI 

engines in 40 CFR 89.112 or 40 CFR 94.8 may follow the testing procedures specified in § 60.4213 of this subpart, as 

appropriate.

(d) Not applicable

(e) Exhaust emissions from stationary CI ICE that are complying with the emission standards for new CI engines in 40 CFR 

part 1042 must not exceed the NTE standards for the same model year and maximum engine power as required in 40 CFR 

1042.101(c).

Not applicable

If you are an owner or operator, you must meet the monitoring requirements of this section. In addition, you must also meet 

the monitoring requirements specified in § 60.4211.

(a) If you are an owner or operator of an emergency stationary CI internal combustion engine that does not meet the 

standards applicable to non-emergency engines, you must install a non-resettable hour meter prior to startup of the engine.

(b) Not applicable

(a) All recordkeeping shall commence upon startup of the source and shall be kept for a period of 5 years and made 

available to the Department upon request.

(b) The company shall maintain a log of all preventative maintenance inspections of the source. The inspection logs, at a 

minimum, shall contain the dates of the inspections, the name of the person performing the inspection, any mechanical 

repairs and/or adjustments, any potential problems or defects that were encountered, and the steps taken to correct them.

(c) The company shall maintain a log of the following, at a minimum, from the operational inspections:

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

III.

IV.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

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 # 011

 # 012

 # 013

 # 014

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4214]

 [25 Pa. Code §127.12b]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4206]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4211]

What are my notification, reporting, and recordkeeping requirements if I am an owner or operator of a stationary CI 

internal combustion engine?

Plan approval terms and conditions.

How long must I meet the emission standards if I am an owner or operator of a stationary CI internal combustion 

engine?

What are my compliance requirements if I am an owner or operator of a stationary CI internal combustion engine?

1. Completion of inspection - daily defined as at least once per calendar day, while the source is operating or as approved 

by the Department in the work practice inspection protocol.

(d) The permittee shall keep records of the fuel certification reports for each delivery of diesel fuel to verify compliance with 

the fuel restriction requirements.

The following conditions are related to the GHG Tailoring Rule (40 CFR 51, 52 and 98)

(e) The facility shall maintain sufficient records to adequately demonstrate compliance with the emission limitations 

associated with the GHG rule.

(a) Not applicable

(b) If the stationary CI internal combustion engine is an emergency stationary internal combustion engine, the owner or 

operator is not required to submit an initial notification. Starting with the model years in table 5 to this subpart, if the 

emergency engine does not meet the standards applicable to non-emergency engines in the applicable model year, the 

owner or operator must keep records of the operation of the engine in emergency and non-emergency service that are 

recorded through the non-resettable hour meter. The owner must record the time of operation of the engine and the reason 

the engine was in operation during that time.

(c) Not applicable

(a) The permittee shall perform a daily operational inspection of the source until such time as the Department approves a 

work practice inspection protocol submitted by the permittee. After Departmental approval, the permittee shall perform 

periodic inspections of the significant source equipment and emission controls in accordance with the approved work 

practice inspection protocol.

(b) The permittee shall maintain and operate the source in accordance with the manufacturer's specifications, the 

manufacturer's preventative maintenance schedule, and good air pollution control practices. The facility shall maintain a 

copy of the manufacturer's preventative maintenance schedule on-site.

Owners and operators of stationary CI ICE must operate and maintain stationary CI ICE that achieve the emission 

standards as required in §§ 60.4204 and 60.4205 over the entire life of the engine.

(a) If you are an owner or operator and must comply with the emission standards specified in this subpart, you must do all 

of the following, except as permitted under paragraph (g) of this section:

(1) Operate and maintain the stationary CI internal combustion engine and control device according to the manufacturer's 

emission-related written instructions;

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

V.

VI.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

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 # 015 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

(2) Change only those emission-related settings that are permitted by the manufacturer; and

(3) Meet the requirements of 40 CFR parts 89, 94 and/or 1068, as they apply to you.

(b) Not applicable

(c) If you are an owner or operator of a 2007 model year and later stationary CI internal combustion engine and must comply

with the emission standards specified in § 60.4204(b) or § 60.4205(b), or if you are an owner or operator of a CI fire pump 

engine that is manufactured during or after the model year that applies to your fire pump engine power rating in table 3 to 

this subpart and must comply with the emission standards specified in § 60.4205(c), you must comply by purchasing an 

engine certified to the emission standards in § 60.4204(b), or § 60.4205(b) or (c), as applicable, for the same model year 

and maximum (or in the case of fire pumps, NFPA nameplate) engine power. The engine must be installed and configured 

according to the manufacturer's emission-related specifications, except as permitted in paragraph (g) of this section.

(d) Not applicable

(e) Not applicable

(f) Emergency stationary ICE may be operated for the purpose of maintenance checks and readiness testing, provided that 

the tests are recommended by Federal, State or local government, the manufacturer, the vendor, or the insurance company 

associated with the engine. Maintenance checks and readiness testing of such units is limited to 100 hours per year. There 

is no time limit on the use of emergency stationary ICE in emergency situations. The owner or operator may petition the 

Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not 

required if the owner or operator maintains records indicating that Federal, State, or local standards require maintenance 

and testing of emergency ICE beyond 100 hours per year. Emergency stationary ICE may operate up to 50 hours per year in 

non-emergency situations, but those 50 hours are counted towards the 100 hours per year provided for maintenance and 

testing. The 50 hours per year for non-emergency situations cannot be used for peak shaving or to generate income for a 

facility to supply power to an electric grid or otherwise supply non-emergency power as part of a financial arrangement with 

another entity. For owners and operators of emergency engines, any operation other than emergency operation, 

maintenance and testing, and operation in non-emergency situations for 50 hours per year, as permitted in this section, is 

prohibited.

(g) If you do not install, configure, operate, and maintain your engine and control device according to the manufacturer's 

emission-related written instructions, or you change emission-related settings in a way that is not permitted by the 

manufacturer, you must demonstrate compliance as follows:

(1) Not applicable

(2) If you are an owner or operator of a stationary CI internal combustion engine greater than or equal to 100 HP and less 

than or equal to 500 HP, you must keep a maintenance plan and records of conducted maintenance and must, to the extent 

practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing 

emissions. In addition, you must conduct an initial performance test to demonstrate compliance with the applicable 

emission standards within 1 year of startup, or within 1 year after an engine and control device is no longer installed, 

configured, operated, and maintained in accordance with the manufacturer's emission-related written instructions, or within 

1 year after you change emission-related settings in a way that is not permitted by the manufacturer.

(3) Not applicable

(a) The source is subject to 40 CFR 60 Subpart IIII Standards of Performance for Stationary Compression Ignition Internal 

Combustion Engines. [Compliance with this requirement will assure compliance with 40 CFR 63 Subpart ZZZZ]

(b) Any information required to be submitted as part of this plan approval should be submitted to the attention of Air Quality 

VII. ADDITIONAL REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
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 # 016 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4200]

Am I subject to this subpart?

Program Manager, Air Quality Program, Southcentral Regional Office, 909 Elmerton Avenue, Harrisburg, PA 17110.

(c) In accordance with 40 CFR 60.4 copies of all requests, reports, applications submittals and other communications shall 

be forwarded to both EPA and the Department at the addresses listed below unless otherwise noted.

Air Quality Program Manager

Pa DEP

Air Quality Program

Southcentral Regional Office

909 Elmerton Avenue

Harrisburg, PA 17110.

Director

Air Toxics and Radiation

US EPA, Region III

1650 Arch Street

Philadelphia, PA 19103-2029

(d) Issuance of an Operating Permit is contingent upon satisfactory compliance with the plan approval conditions, upon the 

control device being installed, tested, and operated as stated within the application, and upon satisfactory demonstration 

that the emissions from the source will not be in violation of applicable Rules and Regulations of the Department.

(a) The provisions of this subpart are applicable to manufacturers, owners, and operators of stationary compression ignition

(CI) internal combustion engines (ICE) and other persons as specified in paragraphs (a)(1) through (4) of this section. For 

the purposes of this subpart, the date that construction commences is the date the engine is ordered by the owner or 

operator.

(1) Not applicable

(2) Owners and operators of stationary CI ICE that commence construction after July 11, 2005, where the stationary CI ICE 

are:

 (i) Manufactured after April 1, 2006, and are not fire pump engines, or

 (ii) Manufactured as a certified National Fire Protection Association (NFPA) fire pump engine after July 1, 2006.

(3) Not applicable

(4) The provisions of § 60.4208 of this subpart are applicable to all owners and operators of stationary CI ICE that 

commence construction after July 11, 2005.

(b) Not applicable

(c) If you are an owner or operator of an area source subject to this subpart, you are exempt from the obligation to obtain a 

permit under 40 CFR part 70 or 40 CFR part 71, provided you are not required to obtain a permit under 40 CFR 70.3(a) or 40 

CFR 71.3(a) for a reason other than your status as an area source under this subpart. Notwithstanding the previous 

sentence, you must continue to comply with the provisions of this subpart applicable to area sources.

(d) Not applicable

(e) Not applicable

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

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 # 017

 # 018

 # 019

 # 020

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4204]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4208]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4218]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4219]

What emission standards must I meet for non-emergency engines if I am an owner or operator of a stationary CI 

internal combustion engine?

What is the deadline for importing or installing stationary CI ICE produced in the previous model year?

What parts of the General Provisions apply to me?

What definitions apply to this subpart?

Not applicable

(a) After December 31, 2008, owners and operators may not install stationary CI ICE (excluding fire pump engines) that do 

not meet the applicable requirements for 2007 model year engines.

(b) Not applicable

(c) Not applicable

(d) Not applicable

(e) Not applicable

(f) Not applicable

(g) Not applicable

(h) In addition to the requirements specified in §§ 60.4201, 60.4202, 60.4204, and 60.4205, it is prohibited to import 

stationary CI ICE with a displacement of less than 30 liters per cylinder that do not meet the applicable requirements 

specified in paragraphs (a) through (g) of this section after the dates specified in paragraphs (a) through (g) of this section.

(i) The requirements of this section do not apply to owners or operators of stationary CI ICE that have been modified, 

reconstructed, and do not apply to engines that were removed from one existing location and reinstalled at a new location.

Table 8 to this subpart shows which parts of the General Provisions in §§60.1 through 60.19 apply to you.

As used in this subpart, all terms not defined herein shall have the meaning given them in the CAA and in subpart A of this 

part.

Certified emissions life means the period during which the engine is designed to properly function in terms of reliability and 

fuel consumption, without being remanufactured, specified as a number of hours of operation or calendar years, whichever 

comes first. The values for certified emissions life for stationary CI ICE with a displacement of less than 10 liters per cylinder

are given in 40 CFR 1039.101(g). The values for certified emissions life for stationary CI ICE with a displacement of greater 

than or equal to 10 liters per cylinder and less than 30 liters per cylinder are given in 40 CFR 94.9(a).

Combustion turbine means all equipment, including but not limited to the turbine, the fuel, air, lubrication and exhaust gas 

systems, control systems (except emissions control equipment), and any ancillary components and sub-components 

comprising any simple cycle combustion turbine, any regenerative/recuperative cycle combustion turbine, the combustion 

turbine portion of any cogeneration cycle combustion system, or the combustion turbine portion of any combined cycle 

steam/electric generating system.

Compression ignition means relating to a type of stationary internal combustion engine that is not a spark ignition engine.

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

SECTION D. Source Level Plan Approval Requirements
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Date of manufacture means one of the following things:

(1) For freshly manufactured engines and modified engines, date of manufacture means the date the engine is originally 

produced.

(2) For reconstructed engines, date of manufacture means the date the engine was originally produced, except as specified 

in paragraph (3) of this definition.

(3) Reconstructed engines are assigned a new date of manufacture if the fixed capital cost of the new and refurbished 

components exceeds 75 percent of the fixed capital cost of a comparable entirely new facility. An engine that is produced 

from a previously used engine block does not retain the date of manufacture of the engine in which the engine block was 

previously used if the engine is produced using all new components except for the engine block. In these cases, the date of 

manufacture is the date of reconstruction or the date the new engine is produced.

Diesel fuel means any liquid obtained from the distillation of petroleum with a boiling point of approximately 150 to 360 

degrees Celsius. One commonly used form is number 2 distillate oil.

Diesel particulate filter means an emission control technology that reduces PM emissions by trapping the particles in a flow 

filter substrate and periodically removes the collected particles by either physical action or by oxidizing (burning off) the 

particles in a process called regeneration.

Emergency stationary internal combustion engine means any stationary internal combustion engine whose operation is 

limited to emergency situations and required testing and maintenance. Examples include stationary ICE used to produce 

power for critical networks or equipment (including power supplied to portions of a facility) when electric power from the 

local utility (or the normal power source, if the facility runs on its own power production) is interrupted, or stationary ICE used

to pump water in the case of fire or flood, etc. Stationary CI ICE used to supply power to an electric grid or that supply power 

as part of a financial arrangement with another entity are not considered to be emergency engines.

Engine manufacturer means the manufacturer of the engine. See the definition of “manufacturer” in this section.

Fire pump engine means an emergency stationary internal combustion engine certified to NFPA requirements that is used 

to provide power to pump water for fire suppression or protection.

Freshly manufactured engine means an engine that has not been placed into service. An engine becomes freshly 

manufactured when it is originally produced.

Installed means the engine is placed and secured at the location where it is intended to be operated.

Manufacturer has the meaning given in section 216(1) of the Act. In general, this term includes any person who 

manufactures a stationary engine for sale in the United States or otherwise introduces a new stationary engine into 

commerce in the United States. This includes importers who import stationary engines for sale or resale.

Maximum engine power means maximum engine power as defined in 40 CFR 1039.801.

Model year means the calendar year in which an engine is manufactured (see “date of manufacture”), except as follows:

(1) Model year means the annual new model production period of the engine manufacturer in which an engine is 

manufactured (see “date of manufacture”), if the annual new model production period is different than the calendar year and 

includes January 1 of the calendar year for which the model year is named. It may not begin before January 2 of the previous

calendar year and it must end by December 31 of the named calendar year.

(2) For an engine that is converted to a stationary engine after being placed into service as a nonroad or other non-stationary

engine, model year means the calendar year or new model production period in which the engine was manufactured (see 

“date of manufacture”).

Other internal combustion engine means any internal combustion engine, except combustion turbines, which is not a 

SECTION D. Source Level Plan Approval Requirements
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reciprocating internal combustion engine or rotary internal combustion engine.

Reciprocating internal combustion engine means any internal combustion engine which uses reciprocating motion to 

convert heat energy into mechanical work.

Rotary internal combustion engine means any internal combustion engine which uses rotary motion to convert heat energy 

into mechanical work.

Spark ignition means relating to a gasoline, natural gas, or liquefied petroleum gas fueled engine or any other type of 

engine with a spark plug (or other sparking device) and with operating characteristics significantly similar to the theoretical 

Otto combustion cycle. Spark ignition engines usually use a throttle to regulate intake air flow to control power during normal

operation. Dual-fuel engines in which a liquid fuel (typically diesel fuel) is used for CI and gaseous fuel (typically natural 

gas) is used as the primary fuel at an annual average ratio of less than 2 parts diesel fuel to 100 parts total fuel on an 

energy equivalent basis are spark ignition engines.

Stationary internal combustion engine means any internal combustion engine, except combustion turbines, that converts 

heat energy into mechanical work and is not mobile. Stationary ICE differ from mobile ICE in that a stationary internal 

combustion engine is not a nonroad engine as defined at 40 CFR 1068.30 (excluding paragraph (2)(ii) of that definition), 

and is not used to propel a motor vehicle, aircraft, or a vehicle used solely for competition. Stationary ICE include 

reciprocating ICE, rotary ICE, and other ICE, except combustion turbines.

Subpart means 40 CFR part 60, subpart IIII.

SECTION D. Source Level Plan Approval Requirements
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Source ID: 103 Source Name: COOLING TOWER

Source Capacity/Throughput: 

I. RESTRICTIONS.

 # 001 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

(a) The PM emissions shall not exceed 2.03 lb/hr and 8.89 tpy based on a 12-month rolling basis.

(b) The PM10 emissions shall not exceed 1.31 lb/hr and 5.73 tpy based on a 12-month rolling basis.

(c) The PM2.5 emissions shall not exceed 0.49 lb/hr and 2.13 tpy based on a 12-month rolling basis.

(d) The total dissolved solids (TDS) of the cooling tower water shall not exceed 5,000 ppmw. [Compliance with the lb/hr 

limitations shall be demonstrated provided TDS concentrations do not exceed 5,000 ppmw.]

Emission Restriction(s).

 # 002

 # 003

 [25 Pa. Code §127.12b]

 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

Plan approval terms and conditions.

The permittee shall, at a minimum of once per quarter, sample and analyze the cooling tower water for total dissolved solids

(TDS) at a point which is representative of the water being evaporated to the atmosphere.

(a) All recordkeeping shall commence upon commencement of operation of the source and shall be kept for a period of 5 

years and made available to the Department upon request.

(b) The company shall maintain a log of all preventative maintenance inspections of the source. The inspection logs, at a 

minimum, shall contain the dates of the inspections, the name of the person performing the inspection, any mechanical 

repairs and/or adjustments, any potential problems or defects that were encountered, and the steps taken to correct them.

(c) The company shall maintain a log of the following, at a minimum, from the operational inspections:

1. Completion of inspection - daily defined as at least once per calendar day, while the source is operating or as approved 

by the Department in the work practice inspection protocol.

(d) The company shall maintain a daily log of the following:

1. Water circulation and makeup rates

Conditions for this source occur in the following groups: PM2.5

PROC

103

STAC

Z103

 9.730 M Gal/HR COOLING WATER

No additional testing requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements) and/or Section E (Source Group Restrictions).

II.

III.

IV.

TESTING REQUIREMENTS.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
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 # 004

 # 005

 [25 Pa. Code §127.12b]

 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

Plan approval terms and conditions.

(e) The company shall maintain records of the water sample TDS analysis.

(a) The permittee shall perform a daily operational inspection of the source until such time as the Department approves a 

work practice inspection protocol submitted by the permittee. After Departmental approval, the permittee shall perform 

periodic inspections of the significant source equipment and emission controls in accordance with the approved work 

practice inspection protocol.

(b) The permittee shall maintain and operate the source in accordance with the manufacturer's specifications, the 

manufacturer's preventative maintenance schedule, and good air pollution control practices. The facility shall maintain a 

copy of the manufacturer's preventative maintenance schedule on-site.

The permittee shall install drift eliminators with a vendor guarantee of 0.0005% or less drift.

No additional reporting requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements) and/or Section E (Source Group Restrictions).

V.

VI.

VII.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

ADDITIONAL REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
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Source ID: 110 Source Name: COLD CLEANING MACHINE (DEGREASER)

Source Capacity/Throughput: 

I. RESTRICTIONS.

 # 001 [25 Pa. Code §129.63]

Degreasing operations

Cold cleaning machines. Except for those subject to the Federal National emissions standards for hazardous air pollutants

(NESHAP) for halogenated solvent cleaners under 40 CFR Part 63 (relating to National emission standards for hazardous 

air pollutants for source categories), this subsection applies to cold cleaning machines that use 2 gallons or more of 

solvents containing greater than 5% VOC content by weight for the cleaning of metal parts.

a. Immersion cold cleaning machines shall have a freeboard ratio of 0.50 or greater.

b. Immersion cold cleaning machines and remote reservoir cold cleaning machines shall: 

 1. Have a permanent, conspicuous label summarizing the operating requirements in paragraph (c). In addition, the label 

shall include the following discretionary good operating practices: 

 (A) Cleaned parts should be drained at least 15 seconds or until dripping ceases, whichever is longer. Parts having 

cavities or blind holes shall be tipped or rotated while the part is draining. During the draining, tipping or rotating, the parts 

No additional requirements exist except as provided in other sections of this plan approval including Section B (Plan Approval

General Requirements).

PROC

110

STAC

Z110

No additional testing requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements).

No additional monitoring requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements).

No additional record keeping requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements).

No additional reporting requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements).

No additional work practice requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements).

II.

III.

IV.

V.

VI.

VII.

TESTING REQUIREMENTS.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

ADDITIONAL REQUIREMENTS.

SECTION D. Source Level Plan Approval Requirements
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should be positioned so that solvent drains directly back to the cold cleaning machine. 

 (B) When a pump-agitated solvent bath is used, the agitator should be operated to produce a rolling motion of the 

solvent with no observable splashing of the solvent against the tank walls or the parts being cleaned. 

 (C) Work area fans should be located and positioned so that they do not blow across the opening of the degreaser unit. 

 2. Be equipped with a cover that shall be closed at all times except during cleaning of parts or the addition or removal of 

solvent. For remote reservoir cold cleaning machines which drain directly into the solvent storage reservoir, a perforated 

drain with a diameter of not more than 6 inches shall constitute an acceptable cover. 

c. Cold cleaning machines shall be operated in accordance with the following procedures: 

 1. Waste solvent shall be collected and stored in closed containers. The closed containers may contain a device that 

allows pressure relief, but does not allow liquid solvent to drain from the container. 

 2. Flushing of parts using a flexible hose or other flushing device shall be performed only within the cold cleaning 

machine. The solvent spray shall be a solid fluid stream, not an atomized or shower spray. 

 3. Sponges, fabric, wood, leather, paper products and other absorbent materials may not be cleaned in the cold cleaning 

machine. 

 4. Air agitated solvent baths may not be used. 

 5. Spills during solvent transfer and use of the cold cleaning machine shall be cleaned up immediately. 

d. After December 22, 2002, a person may not use, sell or offer for sale for use in a cold cleaning machine any solvent with a

vapor pressure of 1.0 millimeter of mercury (mm Hg) or greater and containing greater than 5% VOC by weight, measured at

20°C (68°F) containing VOCs. 

e. On and after December 22, 2002, a person who sells or offers for sale any solvent containing VOCs for use in a cold 

cleaning machine shall provide, to the purchaser, the following written information: 

 1. The name and address of the solvent supplier. 

 2. The type of solvent including the product or vendor identification number. 

 3. The vapor pressure of the solvent measured in mm Hg at 20°C (68°F). 

f. A person who operates a cold cleaning machine shall maintain for at least 2 years and shall provide to the Department, 

on request, the information specified in paragraph (e). An invoice, bill of sale, certificate that corresponds to a number of 

sales, Material Safety Data Sheet (MSDS), or other appropriate documentation acceptable to the Department may be used to

comply with this section. 

g. Paragraph (d) does not apply: 

 1. To cold cleaning machines used in extreme cleaning service. 

 2. If the owner or operator of the cold cleaning machine demonstrates, and the Department approves in writing, that 

compliance with paragraph (d) will result in unsafe operating conditions. 

 3. To immersion cold cleaning machines with a freeboard ratio equal to or greater than 0.75.

SECTION D. Source Level Plan Approval Requirements
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I. RESTRICTIONS.

 # 001 [40 CFR Part 72 Regulations on Permits §40 CFR 72.30]

Requirements to apply.

(a) Duty to apply. The designated representative of any source with an affected unit shall submit a complete Acid Rain 

permit application by the applicable deadline in paragraphs (b) and (c) of this section, and the owners and operators of 

such source and any affected unit at the source shall not operate the source or unit without a permit that states its Acid Rain

program requirements. 

(b) Deadlines. 

(1) Not applicable

(2) Phase II.

 (i) Not applicable 

 (ii) For any source with a new unit under 72.6(a)(3)(i), the designated representative shall submit a complete Acid Rain 

permit application governing such unit to the permitting authority at least 24 months before the later of January 1, 2000 or 

the date on which the unit commences operation. 

 (iii) Not applicable 

Subpart C--Acid Rain Permit Application 

Group Name: CAIR

Group Description: CAIR - Acid Rain

Sources included in this group:

ID Name

031

032

COMBINED CYCLE UNIT #1

COMBINED CYCLE UNIT #2

No additional requirements exist except as provided in other sections of this plan approval including Section B (Plan Approval 

General Requirements).

II.

III.

IV.

V.

VI.

VII.

TESTING REQUIREMENTS.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

ADDITIONAL REQUIREMENTS.

No additional testing requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements).

No additional monitoring requirements exist except as provided in other sections of this plan approval including Section B (Plan

Approval General Requirements).

No additional record keeping requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements).

No additional reporting requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements).

No additional work practice requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements).

SECTION E. Source Group Plan Approval Restrictions.
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 # 002 [40 CFR Part 97 NOx Budget Trading Program and CAIR NOx and SO2 Trading Programs §40 CFR 97.106]

Standard requirements.

 (iv) Not applicable

 (v) Not applicable

 (vi) Not applicable

 (vii) Not applicable

 (viii) Not applicable

(3) Acid Rain Compliance Option Deadlines. The deadlines for applying for approval of any Acid Rain compliance options 

shall be the deadlines specified in the relevant section of subpart D of this part and in section 407 of the Act and regulations

implementing section 407 of the Act. 

(c) Duty to Reapply. The designated representative shall submit a complete Acid Rain permit application for each source 

with an affected unit at least 6 months prior to the expiration of an existing Acid Rain permit governing the unit during Phase 

II or such longer time as may be approved under part 70 of this chapter that ensures that the term of the existing permit will 

not expire before the effective date of the permit for which the application is submitted. 

(d) The original and three copies of all permit applications for Phase I and where the Administrator is the permitting 

authority, for Phase II, shall be submitted to the EPA Regional Office for the Region where the affected source is located. 

The original and three copies of all permit applications for Phase II, where the Administrator is not the permitting authority, 

shall be submitted to the State permitting authority for the State where the affected source is located.

(a) Permit requirements. (1) The CAIR designated representative of each CAIR NOX source required to have a title V 

operating permit and each CAIR NOX unit required to have a title V operating permit at the source shall:

(i) Submit to the permitting authority a complete CAIR permit application under § 97.122 in accordance with the deadlines 

specified in § 97.121; and

(ii) Submit in a timely manner any supplemental information that the permitting authority determines is necessary in order to

review a CAIR permit application and issue or deny a CAIR permit.

(2) The owners and operators of each CAIR NOX source required to have a title V operating permit and each CAIR NOX unit 

required to have a title V operating permit at the source shall have a CAIR permit issued by the permitting authority under 

subpart CC of this part for the source and operate the source and the unit in compliance with such CAIR permit.

(3) Except as provided in subpart II of this part, the owners and operators of a CAIR NOX source that is not otherwise 

required to have a title V operating permit and each CAIR NOX unit that is not otherwise required to have a title V operating 

permit are not required to submit a CAIR permit application, and to have a CAIR permit, under subpart CC of this part for 

such CAIR NOX source and such CAIR NOX unit.

(b) Monitoring, reporting, and recordkeeping requirements. (1) The owners and operators, and the CAIR designated 

representative, of each CAIR NOX source and each CAIR NOX unit at the source shall comply with the monitoring, reporting,

and recordkeeping requirements of subpart HH of this part.

(2) The emissions measurements recorded and reported in accordance with subpart HH of this part shall be used to 

determine compliance by each CAIR NOX source with the CAIR NOX emissions limitation under paragraph (c) of this 

section.

(c) Nitrogen oxides emission requirements. (1) As of the allowance transfer deadline for a control period, the owners and 

operators of each CAIR NOX source and each CAIR NOX unit at the source shall hold, in the source's compliance account, 

CAIR NOX allowances available for compliance deductions for the control period under § 97.154(a) in an amount not less 

than the tons of total nitrogen oxides emissions for the control period from all CAIR NOX units at the source, as determined 

Subpart AA - CAIR NOX Annual Trading Program General Provisions

SECTION E. Source Group Plan Approval Restrictions.
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in accordance with subpart HH of this part.

(2) A CAIR NOX unit shall be subject to the requirements under paragraph (c)(1) of this section for the control period starting

on the later of January 1, 2009 or the deadline for meeting the unit's monitor certification requirements under § 97.170(b)(1),

(2), or (5) and for each control period thereafter.

(3) A CAIR NOX allowance shall not be deducted, for compliance with the requirements under paragraph (c)(1) of this 

section, for a control period in a calendar year before the year for which the CAIR NOX allowance was allocated.

(4) CAIR NOX allowances shall be held in, deducted from, or transferred into or among CAIR NOX Allowance Tracking 

System accounts in accordance with subparts EE, FF, GG, and II of this part.

(5) A CAIR NOX allowance is a limited authorization to emit one ton of nitrogen oxides in accordance with the CAIR NOX 

Annual Trading Program. No provision of the CAIR NOX Annual Trading Program, the CAIR permit application, the CAIR 

permit, or an exemption under § 97.105 and no provision of law shall be construed to limit the authority of the United States 

to terminate or limit such authorization.

(6) A CAIR NOX allowance does not constitute a property right.

(7) Upon recordation by the Administrator under subpart EE, FF, GG, or II of this part, every allocation, transfer, or deduction 

of a CAIR NOX allowance to or from a CAIR NOX source's compliance account is incorporated automatically in any CAIR 

permit of the source.

(d) Excess emissions requirements. If a CAIR NOX source emits nitrogen oxides during any control period in excess of the 

CAIR NOX emissions limitation, then:

(1) The owners and operators of the source and each CAIR NOX unit at the source shall surrender the CAIR NOX 

allowances required for deduction under § 97.154(d)(1) and pay any fine, penalty, or assessment or comply with any other 

remedy imposed, for the same violations, under the Clean Air Act or applicable State law; and

(2) Each ton of such excess emissions and each day of such control period shall constitute a separate violation of this 

subpart, the Clean Air Act, and applicable State law.

(e) Recordkeeping and reporting requirements. (1) Unless otherwise provided, the owners and operators of the CAIR NOX 

source and each CAIR NOX unit at the source shall keep on site at the source each of the following documents for a period 

of 5 years from the date the document is created. This period may be extended for cause, at any time before the end of 5 

years, in writing by the permitting authority or the Administrator.

(i) The certificate of representation under § 97.113 for the CAIR designated representative for the source and each CAIR 

NOX unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation; 

provided that the certificate and documents shall be retained on site at the source beyond such 5-year period until such 

documents are superseded because of the submission of a new certificate of representation under § 97.113 changing the 

CAIR designated representative.

(ii) All emissions monitoring information, in accordance with subpart HH of this part, provided that to the extent that subpart 

HH of this part provides for a 3-year period for recordkeeping, the 3-year period shall apply.

(iii) Copies of all reports, compliance certifications, and other submissions and all records made or required under the 

CAIR NOX Annual Trading Program.

(iv) Copies of all documents used to complete a CAIR permit application and any other submission under the CAIR NOX 

Annual Trading Program or to demonstrate compliance with the requirements of the CAIR NOX Annual Trading Program.

(2) The CAIR designated representative of a CAIR NOX source and each CAIR NOX unit at the source shall submit the 

reports required under the CAIR NOX Annual Trading Program, including those under subpart HH of this part.

(f) Liability. (1) Each CAIR NOX source and each CAIR NOX unit shall meet the requirements of the CAIR NOX Annual 

SECTION E. Source Group Plan Approval Restrictions.
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 # 003 [40 CFR Part 97 NOx Budget Trading Program and CAIR NOx and SO2 Trading Programs §40 CFR 97.206]

Standard requirements.

Trading Program.

(2) Any provision of the CAIR NOX Annual Trading Program that applies to a CAIR NOX source or the CAIR designated 

representative of a CAIR NOX source shall also apply to the owners and operators of such source and of the CAIR NOX 

units at the source.

(3) Any provision of the CAIR NOX Annual Trading Program that applies to a CAIR NOX unit or the CAIR designated 

representative of a CAIR NOX unit shall also apply to the owners and operators of such unit.

(g) Effect on other authorities. No provision of the CAIR NOX Annual Trading Program, a CAIR permit application, a CAIR 

permit, or an exemption under § 97.105 shall be construed as exempting or excluding the owners and operators, and the 

CAIR designated representative, of a CAIR NOX source or CAIR NOX unit from compliance with any other provision of the 

applicable, approved State implementation plan, a federally enforceable permit, or the Clean Air Act.

(a) Permit requirements. (1) The CAIR designated representative of each CAIR SO2 source required to have a title V 

operating permit and each CAIR SO2 unit required to have a title V operating permit at the source shall:

(i) Submit to the permitting authority a complete CAIR permit application under § 97.222 in accordance with the deadlines 

specified in § 97.221; and

(ii) Submit in a timely manner any supplemental information that the permitting authority determines is necessary in order to

review a CAIR permit application and issue or deny a CAIR permit.

(2) The owners and operators of each CAIR SO2 source required to have a title V operating permit and each CAIR SO2 unit 

required to have a title V operating permit at the source shall have a CAIR permit issued by the permitting authority under 

subpart CCC of this part for the source and operate the source and the unit in compliance with such CAIR permit.

(3) Except as provided in subpart III of this part, the owners and operators of a CAIR SO2 source that is not otherwise 

required to have a title V operating permit and each CAIR SO2 unit that is not otherwise required to have a title V operating 

permit are not required to submit a CAIR permit application, and to have a CAIR permit, under subpart CCC of this part for 

such CAIR SO2 source and such CAIR SO2 unit.

(b) Monitoring, reporting, and recordkeeping requirements. (1) The owners and operators, and the CAIR designated 

representative, of each CAIR SO2 source and each CAIR SO2 unit at the source shall comply with the monitoring, reporting, 

and recordkeeping requirements of subpart HHH of this part.

(2) The emissions measurements recorded and reported in accordance with subpart HHH of this part shall be used to 

determine compliance by each CAIR SO2 source with the CAIR SO2 emissions limitation under paragraph (c) of this 

section.

(c) Sulfur dioxide emission requirements. (1) As of the allowance transfer deadline for a control period, the owners and 

operators of each CAIR SO2 source and each CAIR SO2 unit at the source shall hold, in the source's compliance account, a

tonnage equivalent in CAIR SO2 allowances available for compliance deductions for the control period, as determined in 

accordance with § 97.254(a) and (b), not less than the tons of total sulfur dioxide emissions for the control period from all 

CAIR SO2 units at the source, as determined in accordance with subpart HHH of this part.

(2) A CAIR SO2 unit shall be subject to the requirements under paragraph (c)(1) of this section for the control period starting

on the later of January 1, 2010 or the deadline for meeting the unit(s monitor certification requirements under § 

97.270(b)(1),(2), or (5) and for each control period thereafter.

(3) A CAIR SO2 allowance shall not be deducted, for compliance with the requirements under paragraph (c)(1) of this 

section, for a control period in a calendar year before the year for which the CAIR SO2 allowance was allocated.

(4) CAIR SO2 allowances shall be held in, deducted from, or transferred into or among CAIR SO2 Allowance Tracking 

Subpart AAA - CAIR SO2 Trading Program General Provisions

SECTION E. Source Group Plan Approval Restrictions.
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System accounts in accordance with subparts FFF, GGG, and III of this part.

(5) A CAIR SO2 allowance is a limited authorization to emit sulfur dioxide in accordance with the CAIR SO2 Trading 

Program. No provision of the CAIR SO2 Trading Program, the CAIR permit application, the CAIR permit, or an exemption 

under § 97.205 and no provision of law shall be construed to limit the authority of the United States to terminate or limit such

authorization.

(6) A CAIR SO2 allowance does not constitute a property right.

(7) Upon recordation by the Administrator under subpart FFF, GGG, or III of this part, every allocation, transfer, or deduction 

of a CAIR SO2 allowance to or from a CAIR SO2 source's compliance account is incorporated automatically in any CAIR 

permit of the source.

(d) Excess emissions requirements. If a CAIR SO2 source emits sulfur dioxide during any control period in excess of the 

CAIR SO2 emissions limitation, then:

(1) The owners and operators of the source and each CAIR SO2 unit at the source shall surrender the CAIR SO2 

allowances required for deduction under § 97.254(d)(1) and pay any fine, penalty, or assessment or comply with any other 

remedy imposed, for the same violations, under the Clean Air Act or applicable State law; and

(2) Each ton of such excess emissions and each day of such control period shall constitute a separate violation of this 

subpart, the Clean Air Act, and applicable State law.

(e) Recordkeeping and reporting requirements. (1) Unless otherwise provided, the owners and operators of the CAIR SO2 

source and each CAIR SO2 unit at the source shall keep on site at the source each of the following documents for a period 

of 5 years from the date the document is created. This period may be extended for cause, at any time before the end of 5 

years, in writing by the permitting authority or the Administrator.

(i) The certificate of representation under § 97.213 for the CAIR designated representative for the source and each CAIR 

SO2 unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation; 

provided that the certificate and documents shall be retained on site at the source beyond such 5-year period until such 

documents are superseded because of the submission of a new certificate of representation under § 97.213 changing the 

CAIR designated representative.

(ii) All emissions monitoring information, in accordance with subpart HHH of this part, provided that to the extent that 

subpart HHH of this part provides for a 3-year period for recordkeeping, the 3-year period shall apply.

(iii) Copies of all reports, compliance certifications, and other submissions and all records made or required under the 

CAIR SO2 Trading Program.

(iv) Copies of all documents used to complete a CAIR permit application and any other submission under the CAIR SO2 

Trading Program or to demonstrate compliance with the requirements of the CAIR SO2 Trading Program.

(2) The CAIR designated representative of a CAIR SO2 source and each CAIR SO2 unit at the source shall submit the 

reports required under the CAIR SO2 Trading Program, including those under subpart HHH of this part.

(f) Liability. (1) Each CAIR SO2 source and each CAIR SO2 unit shall meet the requirements of the CAIR SO2 Trading 

Program.

(2) Any provision of the CAIR SO2 Trading Program that applies to a CAIR SO2 source or the CAIR designated 

representative of a CAIR SO2 source shall also apply to the owners and operators of such source and of the CAIR SO2 

units at the source.

(3) Any provision of the CAIR SO2 Trading Program that applies to a CAIR SO2 unit or the CAIR designated representative of

a CAIR SO2 unit shall also apply to the owners and operators of such unit.

(g) Effect on other authorities. No provision of the CAIR SO2 Trading Program, a CAIR permit application, a CAIR permit, or 

SECTION E. Source Group Plan Approval Restrictions.
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 # 004 [40 CFR Part 97 NOx Budget Trading Program and CAIR NOx and SO2 Trading Programs §40 CFR 97.306]

Standard requirements.

an exemption under § 97.205 shall be construed as exempting or excluding the owners and operators, and the CAIR 

designated representative, of a CAIR SO2 source or CAIR SO2 unit from compliance with any other provision of the 

applicable, approved State implementation plan, a federally enforceable permit, or the Clean Air Act.

(a) Permit requirements. (1) The CAIR designated representative of each CAIR NOX Ozone Season source required to have

a title V operating permit and each CAIR NOX Ozone Season unit required to have a title V operating permit at the source 

shall:

(i) Submit to the permitting authority a complete CAIR permit application under § 97.322 in accordance with the deadlines 

specified in § 97.321; and

(ii) Submit in a timely manner any supplemental information that the permitting authority determines is necessary in order to

review a CAIR permit application and issue or deny a CAIR permit.

(2) The owners and operators of each CAIR NOX Ozone Season source required to have a title V operating permit and each 

CAIR NOX Ozone Season unit required to have a title V operating permit at the source shall have a CAIR permit issued by 

the permitting authority under subpart CCCC of this part for the source and operate the source and the unit in compliance 

with such CAIR permit.

(3) Except as provided in subpart IIII of this part, the owners and operators of a CAIR NOX Ozone Season source that is not 

otherwise required to have a title V operating permit and each CAIR NOX Ozone Season unit that is not otherwise required 

to have a title V operating permit are not required to submit a CAIR permit application, and to have a CAIR permit, under 

subpart CCCC of this part for such CAIR NOX Ozone Season source and such CAIR NOX Ozone Season unit.

(b) Monitoring, reporting, and recordkeeping requirements. (1) The owners and operators, and the CAIR designated 

representative, of each CAIR NOX Ozone Season source and each CAIR NOX Ozone Season unit at the source shall 

comply with the monitoring, reporting, and recordkeeping requirements of subpart HHHH of this part.

(2) The emissions measurements recorded and reported in accordance with subpart HHHH of this part shall be used to 

determine compliance by each CAIR NOX Ozone Season source with the CAIR NOX Ozone Season emissions limitation 

under paragraph (c) of this section.

(c) Nitrogen oxides ozone season emission requirements. (1) As of the allowance transfer deadline for a control period, the 

owners and operators of each CAIR NOX Ozone Season source and each CAIR NOX Ozone Season unit at the source shall

hold, in the source's compliance account, CAIR NOX Ozone Season allowances available for compliance deductions for the

control period under § 97.354(a) in an amount not less than the tons of total nitrogen oxides emissions for the control 

period from all CAIR NOX Ozone Season units at the source, as determined in accordance with subpart HHHH of this part.

(2) A CAIR NOX Ozone Season unit shall be subject to the requirements under paragraph (c)(1) of this section for the 

control period starting on the later of May 1, 2009 or the deadline for meeting the unit's monitor certification requirements 

under § 97.370(b)(1), (2), (3), or (7) and for each control period thereafter.

(3) A CAIR NOX Ozone Season allowance shall not be deducted, for compliance with the requirements under paragraph 

(c)(1) of this section, for a control period in a calendar year before the year for which the CAIR NOX Ozone Season 

allowance was allocated.

(4) CAIR NOX Ozone Season allowances shall be held in, deducted from, or transferred into or among CAIR NOX Ozone 

Season Allowance Tracking System accounts in accordance with subparts EEEE, FFFF, GGGG, and IIII of this part.

(5) A CAIR NOX Ozone Season allowance is a limited authorization to emit one ton of nitrogen oxides in accordance with the

CAIR NOX Ozone Season Trading Program. No provision of the CAIR NOX Ozone Season Trading Program, the CAIR 

permit application, the CAIR permit, or an exemption under § 97.305 and no provision of law shall be construed to limit the 

authority of the United States to terminate or limit such authorization.

Subpart AAAA - CAIR NOX Ozone Season Trading Program General Provisions

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(6) A CAIR NOX Ozone Season allowance does not constitute a property right.

(7) Upon recordation by the Administrator under subpart EEEE, FFFF, GGGG, or IIII of this part, every allocation, transfer, or 

deduction of a CAIR NOX Ozone Season allowance to or from a CAIR NOX Ozone Season source's compliance account is 

incorporated automatically in any CAIR permit of the source.

(d) Excess emissions requirements. If a CAIR NOX Ozone Season source emits nitrogen oxides during any control period 

in excess of the CAIR NOX Ozone Season emissions limitation, then:

(1) The owners and operators of the source and each CAIR NOX Ozone Season unit at the source shall surrender the CAIR 

NOX Ozone Season allowances required for deduction under § 97.354(d)(1) and pay any fine, penalty, or assessment or 

comply with any other remedy imposed, for the same violations, under the Clean Air Act or applicable State law; and

(2) Each ton of such excess emissions and each day of such control period shall constitute a separate violation of this 

subpart, the Clean Air Act, and applicable State law.

(e) Recordkeeping and reporting requirements. (1) Unless otherwise provided, the owners and operators of the CAIR NOX 

Ozone Season source and each CAIR NOX Ozone Season unit at the source shall keep on site at the source each of the 

following documents for a period of 5 years from the date the document is created. This period may be extended for cause, 

at any time before the end of 5 years, in writing by the permitting authority or the Administrator.

(i) The certificate of representation under § 97.313 for the CAIR designated representative for the source and each CAIR 

NOX Ozone Season unit at the source and all documents that demonstrate the truth of the statements in the certificate of 

representation; provided that the certificate and documents shall be retained on site at the source beyond such 5-year 

period until such documents are superseded because of the submission of a new certificate of representation under § 

97.313 changing the CAIR designated representative.

(ii) All emissions monitoring information, in accordance with subpart HHHH of this part, provided that to the extent that 

subpart HHHH of this part provides for a 3-year period for recordkeeping, the 3-year period shall apply.

(iii) Copies of all reports, compliance certifications, and other submissions and all records made or required under the 

CAIR NOX Ozone Season Trading Program.

(iv) Copies of all documents used to complete a CAIR permit application and any other submission under the CAIR NOX 

Ozone Season Trading Program or to demonstrate compliance with the requirements of the CAIR NOX Ozone Season 

Trading Program.

(2) The CAIR designated representative of a CAIR NOX Ozone Season source and each CAIR NOX Ozone Season unit at 

the source shall submit the reports required under the CAIR NOX Ozone Season Trading Program, including those under 

subpart HHHH of this part.

(f) Liability. (1) Each CAIR NOX Ozone Season source and each CAIR NOX Ozone Season unit shall meet the requirements 

of the CAIR NOX Ozone Season Trading Program.

(2) Any provision of the CAIR NOX Ozone Season Trading Program that applies to a CAIR NOX Ozone Season source or the 

CAIR designated representative of a CAIR NOX Ozone Season source shall also apply to the owners and operators of such 

source and of the CAIR NOX Ozone Season units at the source.

(3) Any provision of the CAIR NOX Ozone Season Trading Program that applies to a CAIR NOX Ozone Season unit or the 

CAIR designated representative of a CAIR NOX Ozone Season unit shall also apply to the owners and operators of such 

unit.

(g) Effect on other authorities. No provision of the CAIR NOX Ozone Season Trading Program, a CAIR permit application, a 

CAIR permit, or an exemption under § 97.305 shall be construed as exempting or excluding the owners and operators, and 

the CAIR designated representative, of a CAIR NOX Ozone Season source or CAIR NOX Ozone Season unit from 

compliance with any other provision of the applicable, approved State implementation plan, a federally enforceable permit, 

or the Clean Air Act.

SECTION E. Source Group Plan Approval Restrictions.
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I. RESTRICTIONS.

Emission Restriction(s).

 # 001 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

(a) The Permittee shall select and install any of the turbine options listed below (or newer versions of these turbines if the 

Department determines that such newer versions achieve equivalent or better emissions rates and exhaust parameters) as

part of the CCUs at the facility:

1. General Electric 7FA (GE 7FA)

2. Siemens SGT6-5000F (Siemens F)

 (b) No person may permit the emission from each CCU into the outdoor atmosphere of the following in a manner that 

exceeds the following (per unit):

1. GE 7FA

 (a) Nitrogen Oxides (NOx):

 (i) Normal operation with or without duct burner: 2.0 ppmvd @ 15% oxygen [This condition also assures compliance 

with 40 CFR 60 Subpart KKKK (60.4320)]

 (ii) Normal operation with duct burner: 25.69 #/hr

 (iii) Normal operation without duct burner: 19.76 #/hr

 (iv) Total normal operation: 83.5 tpy based on a 12-month rolling total

 (v) Total including startup and shutdown: 131.19 tpy based on a 12-month rolling total

 (b) Carbon Monoxide (CO):

 (i) Normal operation with or without duct burner: 2.0 ppmvd @ 15% oxygen

 (ii) Normal operation with duct burner: 15.64 #/hr

 (iii) Normal operation without duct burner: 12.03 #/hr

 (iv) Total normal operation: 50.84 tpy based on a 12-month rolling total

 (v) Total including startup and shutdown: 211.92 tpy based on a 12-month rolling total

 (c) Volatile Organic Compounds (VOC):

 (i) Normal operation with or without duct burner: 1.5 ppmvd @ 15% oxygen

 (ii) Normal operation with duct burner: 8.51 #/hr

 (iii) Normal operation without duct burner: 6.55 #/hr

 (iv) Total normal operation: 27.66 tpy based on a 12-month rolling total

 (v) Total including startup and shutdown: 93.85 tpy based on a 12-month rolling total

 (d) Sulfur Oxides (SOx):

 (i) Normal operation with duct burner: 5.77 #/hr

 (ii) Normal operation without duct burner: 4.31 #/hr

 (iii) Total normal operation: 18.29 tpy based on a 12-month rolling total

 (iv) Total including startup and shutdown: 19.11 tpy based on a 12-month rolling total

 (e) Sulfuric Acid (H2SO4):

 (i) Normal operation with duct burner: 0.87 #/hr

 (ii) Normal operation without duct burner: 0.65 #/hr

 (iii) Total normal operation: 2.74 tpy based on a 12-month rolling total

 (iv) Total including startup and shutdown: 2.88 tpy based on a 12-month rolling total

 (f) Particulate Matter (PM)/Particulate Matter 10 (PM10)/Particulate Matter 2.5 (PM2.5):

 (i) Normal operation with duct burner: 21.55 #/hr

 (ii) Normal operation without duct burner: 10.00 #/hr

 (iii) Total normal operation: 45.82 tpy based on a 12-month rolling total

Group Name: CCU

Group Description: Combined Cyle Units

Sources included in this group:

ID Name

031

032

COMBINED CYCLE UNIT #1

COMBINED CYCLE UNIT #2

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 (iv) Total including startup and shutdown: 48.56 tpy based on a 12-month rolling total

 (g) Ammonia Slip (NH3):

 (i) Total normal operation: 104.46 tpy based on a 12-month rolling total

2. Siemens F

 (a) Nitrogen Oxides (NOx):

 (i) Normal operation with or without duct burner: 2.0 ppmvd @ 15% oxygen [This condition also assures compliance 

with 40 CFR 60 Subpart KKKK (60.4320)]

 (ii) Normal operation with duct burner: 26.51 #/hr

 (iii) Normal operation without duct burner: 20.53 #/hr

 (iv) Total normal operation: 86.68 tpy based on a 12-month rolling total

 (v) Total including startup and shutdown: 131.60 tpy based on a 12-month rolling total

 (b) Carbon Monoxide (CO):

 (i) Normal operation with or without duct burner: 2.0 ppmvd @ 15% oxygen

 (ii) Normal operation with duct burner: 16.14 #/hr

 (iii) Normal operation without duct burner: 12.5 #/hr

 (iv) Total normal operation: 52.77 tpy based on a 12-month rolling total

 (v) Total including startup and shutdown: 177.56 tpy based on a 12-month rolling total

 (c) Volatile Organic Compounds (VOC):

 (i) Normal operation with or without duct burner: 1.5 ppmvd @ 15% oxygen

 (ii) Normal operation with duct burner: 8.78 #/hr

 (iii) Normal operation without duct burner: 6.80 #/hr

 (iv) Total normal operation: 28.72 tpy based on a 12-month rolling total

 (v) Total including startup and shutdown: 70.24 tpy based on a 12-month rolling total

 (d) Sulfur Oxides (SOx):

 (i) Normal operation with duct burner: 5.92 #/hr

 (ii) Normal operation without duct burner: 4.46 #/hr

 (iii) Total normal operation: 18.89 tpy based on a 12-month rolling total

 (iv) Total including startup and shutdown: 19.70 tpy based on a 12-month rolling total

 (e) Sulfuric Acid (H2SO4):

 (i) Normal operation with duct burner: 0.89 #/hr

 (ii) Normal operation without duct burner: 0.67 #/hr

 (iii) Total normal operation: 2.83 tpy based on a 12-month rolling total

 (iv) Total including startup and shutdown: 2.97 tpy based on a 12-month rolling total

 (f) Particulate Matter (PM)/Particulate Matter 10 (PM10)/Particulate Matter 2.5 (PM2.5):

 (i) Normal operation with duct burner: 21.5.5 #/hr

 (ii) Normal operation without duct burner: 10.00 #/hr

 (iii) Total normal operation: 45.82 tpy based on a 12-month rolling total

 (iv) Total including startup and shutdown: 48.56 tpy based on a 12-month rolling total

 (g) Ammonia Slip (NH3):

 (i) Total normal operation: 107.92 tpy based on a 12-month rolling total

(c) The emission limitations for NOx and CO are 1-hour block averages calculated once per hour and verified by CEMS. The

emission limitations for VOC, SOx, H2SO4, and PM/PM10/PM2.5 are 1-hour based on the average of three stack test runs.

(d) No person may permit the emission into the outdoor atmosphere of the following in a manner that exceeds the 

following:

1. Ammonia Slip (NH3 Slip) - 5 ppmv, on a dry basis corrected @ 15% oxygen, 1-hour block average verified by CEMS or as 

determined by USEPA Conditional Test Method (CTM-027), 'Procedure for Collection and Analysis of Ammonia in Stationary 

Sources' or other procedure approved by the Department.

2. A person may not permit the emission into the outdoor atmosphere of visible air contaminants in such a manner that the 

opacity of the emission is either of the following:

 (a) Equal to or greater than 10% for a period or periods aggregating more than 3 minutes in any 1 hour.

SECTION E. Source Group Plan Approval Restrictions.
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Fuel Restriction(s).

 # 002 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

 (b) Equal to or greater than 10% for a period or periods aggregating more than 6 minutes during startup and shutdown.

[This condition also assures compliance with 25 PA Code 123.41]

The source shall fire only natural gas that has a sulfur content not to exceed 0.68 gr / 100 scf natural gas. [This condition 

also assures compliance with 40 CFR 60 Subpart KKKK (60.4330) and 25 PA Code 123.22(c)]

 # 003 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

(a) Within 60 days after achieving the normal production rate at which the affected source will be operated, but not later than 

180 days after initial start-up of the source/control device, a stack test for PM (filterable & condensable), PM10 (filterable & 

condensable), PM2.5 (filterable & condensable), NOx, SOx, CO, VOC, ammonia slip, sulfuric acid, and HAPs 

(Formaldehyde) shall be performed in accordance with the provisions of Chapter 139 of the Rules and Regulations of the 

Department of Environmental Protection. The stack test shall be performed while the aforementioned source is operating at

greater than 90% of the rated capacity. Any testing performed at less than 90% of the rated capacity may subject the facility 

to a production limit of the production rate during the compliant testing. The stack test shall be conducted at the outlet of the 

control device.

1. [25 Pa. Code § 139.53(a)(3)] At least 60 calendar days prior to commencing an emissions testing program, a test 

protocol shall be submitted to the Department's Division of Source Testing and Monitoring and two copies to the 

appropriate Regional Office Department for review and approval. The test protocol shall meet all applicable requirements 

specified in the most current version of the Department's Source Testing Manual.

2. [25 Pa. Code § 139.53(a)(3)] At least 15 calendar days prior to commencing an emission testing program, notification as 

to the date and time of testing shall be given to the appropriate Regional Office. Notification shall also be sent to the 

Division of Source Testing and Monitoring. Notification shall not be made without prior receipt of a protocol acceptance letter

from the Department.

3. [25 Pa. Code § 139.53(a)(3)] Within 15 calendar days after completion of the on-site testing portion of an emission test 

program, if a complete test report has not yet been submitted, an electronic mail notification shall be sent to the 

Department's Division of Source Testing and Monitoring and the appropriate Regional Office indicating the completion date 

of the on-site testing.

4. [40 CFR Part 60.8(a), 40 CFR Part 61.13(f) and 40 CFR Part 63.7(g)] A complete test report shall be submitted to the 

Department no later than 60 calendar days after completion of the on-site testing portion of an emission test program. For 

those tests being conducted pursuant to 40 CFR Part 61, a complete test report shall be submitted within 31 days after 

completion of the test.

5. [25 Pa. Code Section 139.53(b)] A complete test report shall include a summary of the emission results on the first page 

of the report indicating if each pollutant measured is within permitted limits and a statement of compliance or noncompliance with all applicable permit conditions. The summary results will include, at a minimum, the following 

information:

 (a) A statement that the owner or operator has reviewed the report from the emissions testing body and agrees with the 

findings.

 (b) Permit number(s) and condition(s) which are the basis for the evaluation.

 (c) Summary of results with respect to each applicable permit condition.

II. TESTING REQUIREMENTS.

SECTION E. Source Group Plan Approval Restrictions.
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 # 004 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

 (d) Statement of compliance or non-compliance with each applicable permit condition.

6. [25 Pa. Code § 139.3] All submittals shall meet all applicable requirements specified in the most current version of the 

Department's Source Testing Manual.

7. All testing shall be performed in accordance with the provisions of Chapter 139 of the Rules and Regulations of the 

Department of Environmental Protection.

8. [25 Pa. Code Section 139.53(a)(1) and 139.53(a)(3)] All submittals, besides notifications, shall be accomplished through 

PSIMS*Online available through https://www.depgreenport.state.pa.us/ecomm/Login.jsp when it becomes available. If 

internet submittal cannot be accomplished, one copy of the submittal shall be sent to the Pennsylvania Department of 

Environmental Protection, Bureau of Air Quality, Division of Source Testing and Monitoring, 400 Market Street, 12th Floor 

Rachael Carson State Office Building, Harrisburg, PA 17105-8468 with deadlines verified through document postmarks. In 

a like manner, two copies of the submittal shall be sent to the appropriate Regional Office.

9. The permittee shall ensure all federal reporting requirements contained in the applicable subpart of 40 CFR are followed,

including timelines more stringent than those contained herein. In the event of an inconsistency or any conflicting 

requirements between state and the federal, the most stringent provision, term, condition, method or rule shall be used by 

default.

10. Actions Related to Noncompliance Demonstrated by a Stack Test:

 (a) If the results of a stack test, performed as required by this approval, exceed the level specified in any condition of this 

approval, the Permittee shall take appropriate corrective actions. Within 30 days of the Permittee receiving the stack test 

results, a written description of the corrective actions shall be submitted to the Department. The Permittee shall take 

appropriate action to minimize emissions from the affected facility while the corrective actions are being implemented. The 

Department shall notify the Permittee within 30 days, if the corrective actions taken are deficient. Within 30 days of receipt of 

the notice of deficiency, the Permittee shall submit a description of additional corrective actions to the Department. The 

Department reserves the authority to use enforcement activities to resolve noncompliant stack tests.

 (b) If the results of the required stack test exceed any limit defined in this plan approval, the test was not performed in 

accordance with the stack test protocol or the source and/or air cleaning device was not operated in accordance with the 

plan approval, then another stack test shall be performed to determine compliance. Within 120 days of the Permittee 

receiving the original stack test results, a retest shall be performed. The Department may extend the retesting deadline if 

the Permittee demonstrates, to the Department's satisfaction, that retesting within 120 days is not practicable. Failure of the 

second test to demonstrate compliance with the limits in the plan approval, not performing the test in accordance with the 

stack test protocol or not operating the source and/or air cleaning device in accordance with the plan approval may be 

grounds for immediate revocation of the plan approval to operate the affected source.

 (c) The facility shall perform subsequent stack test for PM (filterable & condensable), PM10 (filterable & condensable), 

PM2.5 (filterable & condensable), VOC, sulfuric acid, and HAPs (Formaldehyde) in accordance with the provisions in part (a)

every two years (22 to 26 months after the date of the previous test). The stack test shall be performed while the 

aforementioned source is operating at greater than 90% of the rated capacity. Any testing performed at less than 90% of the 

rated capacity may subject the facility to a production limit of the production rate during the compliant testing. The stack test 

shall be conducted at the outlet of the control device.

(a) All recordkeeping shall commence upon commencement of operation of the source and shall be kept for a period of 5 

years and made available to the Department upon request.

III.

IV.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

No additional monitoring requirements exist except as provided in other sections of this plan approval including Section B (Plan

Approval General Requirements).

SECTION E. Source Group Plan Approval Restrictions.
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 # 005

 # 006

 [25 Pa. Code §127.12b]

 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

Plan approval terms and conditions.

(b) The permittee shall submit the turbine option chosen to the Department, with emission values if newer models are 

chosen, for final approval prior to construction.

(c) The company shall maintain a log of all preventative maintenance inspections of the source and control device(s). The 

inspection logs, at a minimum, shall contain the dates of the inspections, the name of the person performing the 

inspection, any mechanical repairs and/or adjustments, any potential problems or defects that were encountered, and the 

steps taken to correct them.

(d) The company shall maintain a log of the following, at a minimum, from the operational inspections:

1. Visible emission of the stack - daily defined as at least once per calendar day, while the plant is operating or as approved

by the Department in the work practice inspection protocol.

(e) The company shall keep records (12-month rolling totals) of the following:

1. Fuel usage (natural gas)

(a) The permittee shall perform a daily operational inspection of the source until such time as the Department approves a 

work practice inspection protocol submitted by the permittee. After Departmental approval, the permittee shall perform 

periodic inspections of the significant source equipment and emission controls in accordance with the approved work 

practice inspection protocol.

(b) All gauges employed by the permittee to monitor the required control device operating parameters shall have a scale 

such that the expected normal reading shall be no less than twenty percent (20%) of full scale and be accurate within plus 

or minus two percent (+/- 2%) of full scale reading.

(c) The permittee shall operate the control device(s) at all times this source is in operation once operating parameters 

(temperature, flow, etc.) are sufficient for proper control device operation.

(d) The permittee shall maintain and operate this source and the control device(s) in accordance with the manufacturer's 

specifications, the manufacturer's preventative maintenance schedule, and good air pollution control practices. The facility 

shall maintain a copy of the manufacturer's preventative maintenance schedule on-site.

(e) The SCR system shall be designed so it will not inject ammonia into the system when the inlet temperature to the 

catalyst is less than the minimum catalyst temperature to be established as part of the O&M plan.

(f) Prior to commencement of operations, the permittee shall develop and submit to the Department for approval a Risk 

Management Plan (RMP) meeting the requirements of Clean Air Act Section 112(r) and 40 CFR 68 Subpart G, with respect 

to the storage of aqueous ammonia if the permittee intends to store aqueous ammonia with a concentration of 20% or 

greater such that the quantity of ammonia present at the facility at any time exceeds 20,000 pounds, and the permittee shall 

implement the Department approved RMP.

(a) The source is subject to the following:

1. 40 CFR 60 Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

V.

VI.

VII.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

ADDITIONAL REQUIREMENTS.

No additional reporting requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements).

SECTION E. Source Group Plan Approval Restrictions.
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2. Acid Rain Regulations (40 CFR 72-78) (Applicable)

3. CAIR (40 CFR 96) (Applicable - was replaced by CSAPR but CSAPR was stayed)

4. Cross State Air Pollution Rule (CSAPR) (40 CFR 97) (Not applicable - stayed 8-21-12)

5. Risk Management Program (40 CFR 68) (Applicable if greater than 20,000 lbs of aqueous ammonia at concentrations of

20% or greater is stored at facility)

(b) Any information required to be submitted as part of the above conditions should be submitted to the Air Quality Program 

Manager, Air Quality Program, Southcentral Regional Office, 909 Elmerton Avenue, Harrisburg, PA 17110.

(c) In accordance with 40 CFR 60.4 copies of all requests, reports, applications submittals and other communications shall

be forwarded to both EPA and the Department at the addresses listed below unless otherwise noted.

Air Quality Program Manager

Pa DEP

Air Quality Program

Southcentral Regional Office

909 Elmerton Avenue

Harrisburg, PA 17110

Director

Air Toxics and Radiation

US EPA, Region III

1650 Arch Street

Philadelphia, PA 19103-2029

(d) Issuance of an operating permit is contingent upon satisfactory compliance with conditions numbered above, upon the 

source being constructed and operating as stated on the application, and upon the satisfactory demonstration that the 

emissions from the source will not be in violation of applicable Rules & Regulations of the Department of Environmental 

Protection.

SECTION E. Source Group Plan Approval Restrictions.
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I. RESTRICTIONS.

 # 001

 # 002

 [25 Pa. Code §127.12b]

 [25 Pa. Code §123.51]

Plan approval terms and conditions.

Monitoring requirements

(a) Initial Application (Phase I): Proposal[s] containing information as listed in the Phase I section of the Department's 

Continuous Source Monitoring Manual for the CEMS[s] must be submitted at least 180 days prior to the planned initial 

source startup date.

(b) Performance Testing (Phase II): Testing as listed in the Phase II section of the Department's Continuous Source 

Monitoring Manual must be completed for the CEMS[s] no later than 180 days after initial source startup date and no later 

than 60 days after source achieves normal process capacity.

(c) Final Approval (Phase III): The final report of testing as listed in the Phase III section of the Department's Continuous 

Source Monitoring Manual must be submitted to the Bureau no later than 60 days after completion of testing.

(d) The owner or operator of the source shall not be issued an operating permit until the CEMS has received Phase III 

approval, in writing from the Department, when installation of a CEMS is made a condition of the plan approval. Until Phase 

III Department approval is obtained, operation shall be covered solely under condition of a plan approval.

(a) This section applies to combustion units with a rated heat input of 250 million Btus per hour or greater and with an 

annual average capacity factor of greater than 30%.

(b) Sources subject to this section shall install, operate and maintain continuous nitrogen oxides monitoring systems and 

other monitoring systems to convert data to required reporting units in compliance with Chapter 139, Subchapter C (relating

to requirements for continuous in-stack monitoring for statutory sources).

(c) Sources subject to this section shall submit results on a regular schedule and in a format acceptable to the Department 

and in compliance with Chapter 139, Subchapter C.

(d) Continuous nitrogen oxides monitoring systems installed under the requirements of this section shall meet the 

minimum data availability requirements in Chapter 139, Subchapter C.

(e) The Department may exempt a source from the requirements of subsection (b) if the Department determines that the 

installation of a continuous emission monitoring system would not provide accurate determination of emissions or that 

installation of a continuous emission monitoring system cannot be implemented by a source due to physical plant 

limitations or to extreme economic reasons. A source exempted from the requirements of subsection (b) shall satisfy 

alternative emission monitoring and reporting requirements proposed by the source and approved by the Department 

which provide oxides emission data that is representative of actual emissions of the source.

(f) Sources subject to this section shall comply by October 20, 1993, unless the source becomes subject to the 

requirements later than October 20, 1990. For sources which become subject to the requirements after October 20, 1990, 

the source has 36 months from the date the source becomes subject to this section. The Department may issue orders 

providing a reasonable extension of time for sources that have made good faith efforts to install, operate and maintain 

continuous monitoring devices, but that have been unable to complete the operations within the time period provided.

Group Name: CEM

Group Description: CEM

Sources included in this group:

ID Name

031

032

COMBINED CYCLE UNIT #1

COMBINED CYCLE UNIT #2

No additional requirements exist except as provided in other sections of this plan approval including Section B (Plan Approval 

General Requirements).

II.

III.

TESTING REQUIREMENTS.

MONITORING REQUIREMENTS.

SECTION E. Source Group Plan Approval Restrictions.
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 # 003 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

(a) The following continuous emission monitoring system[s] (CEMS[s]) must be installed, approved by the Department, 

operated and maintained in accordance with the requirements of 25 Pa. Code Chapter 139, Subchapter C (relating to 

requirements for source monitoring for stationary sources), and the 'Submittal and Approval', 'Record Keeping and 

Reporting', and 'Quality Assurance' requirements of Revision No. 8 of the Department's Continuous Source Monitoring 

Manual, 274-0300-001.

1. CEMS #1

 (a) Source Combination to be Monitored: Combined Cycle Unit #1 and #2 (separately)

 (b) Parameter to be Reported: CO

 (c) Units of Measurement to be Reported: ppmvd

 (d) Moisture Basis of Measurement to be Reported: dry

 (e) Correction basis of Measurements to be Reported: 15% O2

 (f) Data Substitution Required: No

 (g) Emission Standards

 (1) Emission Standard # 1:

 (a) Emission Standard Averaging Period Description: 1-hour average

 (b) Emission Standard Value: 2.0 ppmvd corrected to 15% O2

 (c) Emission Standard Direction: Violation if greater than emission standard value

 (d) Variable Emission Standard: No

2. CEMS #2

 (a) Source Combination to be Monitored: Combined Cycle Unit #1 and #2 (separately)

 (b) Parameter to be Reported: NOx

 (c) Units of Measurement to be Reported: ppmvd

 (d) Moisture Basis of Measurement to be Reported: dry

 (e) Correction basis of Measurements to be Reported: 15% O2

 (f) Data Substitution Required: No

 (g) Emission Standards

 (1) Emission Standard # 1

 (a) Emission Standard Averaging Period Description: 1-hour average

 (b) Emission Standard Value: 2.0 ppmvd corrected to 15% O2

 (c) Emission Standard Direction: Violation if greater than emission standard value

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 (d) Variable Emission Standard: No

3. CEMS #3 [This will consist of continuous measurement of CO2 in the exhaust of each CCU and calculation of combined 

mass emission rate from CCU #1 and CCU#2; continuous measurement of gross electrical output of the facility; and 

calculation of pounds of CO2 per gross MW-hour on a 12-month rolling average, calculated monthly]

 (a) Source Combination to be Monitored: Combined Cycle Unit #1 and #2 (separately)

 (b) Parameter to be Reported: CO2

 (c) Units of Measurement to be Reported: lbs per hr

 (d) Moisture Basis of Measurement to be Reported: NA

 (e) Correction basis of Measurements to be Reported: None

 (f) Data Substitution Required: Yes

 (g) Emission Standards

 (1) Emission Standard # 1

 (a) Emission Standard Averaging Period Description: 12-month sum, calculated monthly 

 (b) Emission Standard Value: Not applicable

 (c) Emission Standard Direction: Not applicable

 (d) Variable Emission Standard: No

4. CEMS #4 [This will consist of continuous measurement of CO2 in the exhaust of each CCU and calculation of combined 

mass emission rate from CCU #1 and CCU#2; continuous measurement of gross electrical output of the facility; and 

calculation of pounds of CO2 per gross MW-hour on a 12-month rolling average, calculated monthly]

 (a) Source Combination to be Monitored: Combined Cycle Unit #1 and #2 (separately)

 (b) Parameter to be Reported: Gross Electrical Outlet (GEO)

 (c) Units of Measurement to be Reported: MW-hr (gross)

 (d) Moisture Basis of Measurement to be Reported: NA

 (e) Correction basis of Measurements to be Reported: None

 (f) Data Substitution Required: Yes

 (g) Emission Standards

 (1) Emission Standard # 1

 (a) Emission Standard Averaging Period Description: 12-month sum, calculated monthly

 (b) Emission Standard Value: None

 (c) Emission Standard Direction: Not applicable

 (d) Variable Emission Standard: No

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 # 004 [25 Pa. Code §139.101]

General requirements.

5. CEMS #5

 (a) Source Combination to be Monitored: Combined Cycle Unit #1 and #2 (separately)

 (b) Parameter to be Reported: Ammonia

 (c) Units of Measurement to be Reported: ppmvd

 (d) Moisture Basis of Measurement to be Reported: dry

 (e) Correction basis of Measurements to be Reported: 15% O2

 (f) Data Substitution Required: No

 (g) Emission Standards

 (1) Emission Standard # 1

 (a) Emission Standard Averaging Period Description: 1-hour average

 (b) Emission Standard Value: 5.0

 (c) Emission Standard Direction: Violation if greater than emission standard value

 (d) Variable Emission Standard: No

(b) Compliance with any subsequently issued revisions to the Continuous Source Monitoring Manual will constitute 

compliance with the regulations.

(c) The facility shall monitor Gross Electrical Output (MW-hr) in order to comply with the CO2 emission standard.

This section applies to monitoring systems as defined in the manual referenced at 139.102(3) (relating to references), 

installations required or approved under Chapters 122, 124, 127 and 129 or in an order issued under section 4 of the act 

(35 P. S. 4004).

 (1) The submittal procedures specified in the publication entitled "Continuous Source Monitoring Manual," available from 

the Department shall be utilized to obtain Department approval. This publication includes:

 (i) Installation requirements.

 (ii) Performance specifications.

 (iii) Test procedures.

 (iv) Reporting requirements.

 (v) Quality assurance requirements.

 (vi) Administrative procedures for obtaining Department approval.

 (2) The monitoring system installation, certification and operation shall be conducted under the direct supervision of 

persons qualified by training and experience.

 (3) The monitoring systems may be designed to monitor source emissions or stack emissions if the representativeness 

of emissions can be verified. The method of conversion of monitoring results to source or stack emissions shall be 

approved by the Department.

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 (4) The location of monitoring devices shall be approved by the Department prior to installation. The selection of the 

monitoring location shall utilize applicable criteria in the manual referenced in 139.102(3). The Department has the authority

to determine which of the criteria are applicable. The representativeness of the measurements at the chosen monitoring 

location shall be verified.

 (5) The owner of a monitored source shall maintain records containing monitoring information and report data to the 

Department as specified in the manual referenced in 139.102(3). The records shall be maintained for 5 years and be 

available for inspection by Department personnel.

 (6) The owner of a monitored source shall provide permanent sampling facilities as specified in 139.1 (relating to 

sampling facilities) to permit verification testing by the Department. For extractive monitors, calibration gas inlets shall be 

available as near as possible to the monitor probe inlet to permit the Department to verify calibration of the monitoring 

system. Facilities shall be approved by the Department prior to construction.

 (7) Verification testing for monitoring systems shall be in accordance with Subchapter B (relating to monitoring duties of 

certain sources), and of the manual referenced in 139.102(3).

 (8) A quality assurance program shall be established and maintained by the owner of the monitored source. This 

program shall be in accordance with the criteria in the sources listed in 139.102.

 (9) The Department's approval will be based on the criteria specified in the manual referenced in 139.102(3). Failure to 

utilize the specified procedures or to conduct the quality assurance program could result in denying or rescinding the 

Department's approval.

 (10) The owner of a monitored source shall notify the Department when the monitoring system is inoperative for more 

than 1 hour during an air pollution episode as specified in Chapter 137 (relating to air pollution episodes). The notice shall 

be given within 2 hours of the malfunction.

 (11) Manual sampling conducted under Subchapter B may be required if the Department determines that the monitoring 

system data is not accurate or that the owner of the monitored source does not conduct the quality assurance program 

specified in the manual referenced in 139.102(3).

 (12) Required monitoring shall meet at least one of the following minimum data availability requirements unless other 

data availability requirements are stipulated elsewhere in this title, in a plan approval or permit condition under Chapter 127

(relating to construction, modification, reactivation and operation of sources), or in an order issued under section 4 of the 

act. For purposes of calculating data availability, "process down" time, as specified in the manual referenced in 139.102(3), 

shall be considered valid time.

 (i) In each calendar month, at least 90% of the time periods for which an emission standard or an operational parameter

applies shall be valid as set forth in the quality assurance section of the manual referenced in 139.102(3).

 (ii) In each calendar quarter, at least 95% of the hours during which the monitored source is operating shall be valid as 

set forth in the quality assurance section of the manual referenced in 139.102(3).

 (13) The monitor results shall be expressed in terms of the applicable standard or criteria required. The method used to 

convert monitor data shall be approved by the Department.

 (14) Monitoring systems shall comply with the applicable performance specifications section of the manual referenced in 

139.102(3). The Department has the authority to determine which of the performance specifications are applicable.

 (15) Verification of calibration standards shall be conducted in accordance with the applicable sampling methods in the 

Department's "Source Testing Manual" or as otherwise approved by the Department. The "Source Testing Manual" may be 

obtained from the Department.

 (16) The requirements of this section apply to monitoring to demonstrate compliance with emissions standards and 

process operational parameter criteria.

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 # 005

 # 006

 # 007

 [25 Pa. Code §127.12b]

 [25 Pa. Code §127.12b]

 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

Plan approval terms and conditions.

Plan approval terms and conditions.

[Additional authority for this permit condition is derived from 25 Pa. Code Sections 139.101(5) and 139.101(12), 139.103, 

139.108 or 139.111)]

(a) The permittee shall comply with the recordkeeping requirements established in 25 Pa. Code Chapter 139, Subchapter 

C (relating to requirements for source monitoring for stationary sources), (and) the 'Record Keeping and Reporting' 

requirements in the Department's Continuous Source Monitoring Manual, Revision No. 8, 274-0300-001.

(b) Records shall be retained for at least 5 years and shall be made available to the Department upon request.

(c) Compliance with any subsequently issued revision to the Continuous Source Monitoring Manual will constitute 

compliance with this permit condition.

[Additional authority for this permit condition is derived from 25 Pa. Code Sections 139.101(1)(iv), 139.101(10) and 

139.101(12), 139.103, 139.108 or 139.111)]

(a) The permittee shall submit quarterly reports of continuous emission monitoring to the Department in accordance with 

the requirements established in 25 Pa. Code Chapter 139, Subchapter C (relating to requirements for source monitoring for

stationary sources), (and) the "Record Keeping and Reporting" requirements as established in the Department's 

Continuous Source Monitoring Manual, Revision No. 8, 274-0300-001.

(b) The permittee shall report emissions for all periods of unit operation, including startup, shutdown and malfunction.

(c) Initial quarterly reports following system certification shall be submitted to the Department within 35 days following the 

date upon which the Department notifies the owner or operator, in writing, of the approval of the continuous source 

monitoring system for use in determining compliance with applicable emission standards.

(d) Subsequent quarterly reports shall be submitted to the Department within 30 days after the end of each calendar 

quarter.

(e) Failure to submit required reports of continuous emission monitoring within the time periods specified in this Condition, 

shall constitute violations of this Permit, unless approved in advance by the Department in writing.

(f) Compliance with any subsequently issued revision to the Continuous Source Monitoring Manual will constitute 

compliance with this permit condition.

[Additional authority for this permit condition is derived from 25 Pa. Code Sections 139.101(1)(iv), 139.101(2), 139.101(3), 

139.101(4), 139.101(6), 139.101(7), 139.101(8), 139.101(12), 139.101(14) and 139.101(15))]

(a) Continuous Emission Monitoring Systems and components must be operated and maintained in accordance with the 

requirements established in 25 Pa. Code Chapter 139, Subchapter C (relating to requirements for source monitoring for 

stationary sources) and the "Quality Assurance" requirements in the Department's Continuous Source Monitoring Manual, 

Revision No. 8, 274-0300-001.

(b) Compliance with any subsequently issued revision to the Continuous Source Monitoring Manual will constitute 

compliance with this permit condition.

(c) Data Availability Standards: Continuous emission monitoring shall meet the following minimum data availability 

requirements:

IV.

V.

VI.

RECORDKEEPING REQUIREMENTS.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

SECTION E. Source Group Plan Approval Restrictions.
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 # 008 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

 

1. In accordance with 25 Pa. Code Section 139.101(12), required monitoring shall, at a minimum, meet one of the following

data availability requirements unless otherwise stipulated in this permit, a plan approval, Title 25 or an order issued under 

Section 4 of the Air Pollution Control Act:

 (a) In each calendar month, at least 90% of the time periods for which an emission standard or an operational parameter

applies, shall be valid as set forth in the Quality Assurance section of Revision No. 8 of the Department's Continuous 

Source Monitoring Manual, 274-0300-001; or

 (b) In each calendar quarter, at least 95% of the hours shall be valid as set forth in the Quality Assurance section of 

Revision No. 8 of the Department's Continuous Source Monitoring Manual, 274-0300-001.

2. Compliance with any subsequently issued revisions to the Continuous Source Monitoring Manual will constitute 

compliance with the regulations.

3. Emission Standard(s) To Which Data Availability Standard applies: 

 (a) CO (ppmvd)

 (b) NOx (ppmvd)

 (c) CO2 (lbs per hr)

 (d) GEO (MW-hr gross)

 (e) Ammonia (ppmvd)

[25 Pa. Code §127.441(c) & Chapter 139; §§114(a)(3), 504(b) of the CAA] Sampling, Testing and Monitoring Procedures 

1. The permittee shall perform the emissions monitoring analysis procedures or test methods required under an 

applicable requirement including procedures and methods under Sections 114(a)(3) ( 42 U.S.C.A.§§ 7414 (a)(3)) or 504(b) 

( 42 U.S.C.A.§§ 7661c(b)) of the Clean Air Act.

2. Unless otherwise required by this permit, the permittee shall comply with applicable monitoring, quality assurance, 

recordkeeping and reporting requirements of the Air Pollution Control Act, 25 Pa. Code, Subpart C, Article III (relating to air 

resources), including Chapter 139 (relating to sampling and testing). The permittee shall also comply with applicable 

requirements related to monitoring, quality assurance, reporting and recordkeeping required by the Clean Air Act including 

§§ 114(a)(3) and 504(b) and regulations adopted thereunder, unless otherwise required by this permit.

VII. ADDITIONAL REQUIREMENTS.

SECTION E. Source Group Plan Approval Restrictions.
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I. RESTRICTIONS.

Emission Restriction(s).

 # 001 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

The following conditions are related to the GHG Tailoring Rule (40 CFR 51, 52 and 98)

No person may permit the emission into the outdoor atmosphere of the following in a manner that exceeds the following:

1. CO2 emission rate of 1,000 lb/MW-hr (gross) on a 12-operating month annual average basis for each CCU

2. CO2(e) emission rate of 1,380,899 tpy based on a 12-month rolling total for each CCU

3. CO2(e) emission rate of 2,779,224 tpy based on a 12-month rolling total for the entire facility

 # 002

 # 003

 [25 Pa. Code §127.12b]

 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

Plan approval terms and conditions.

The following conditions are related to the GHG Tailoring Rule (40 CFR 51, 52 and 98)

(a) The facility shall maintain sufficient records to adequately demonstrate compliance with the emission limitations 

associated with the GHG rule.

(b) The facility shall keep accurate and comprehensive records of:

1. The amount of SF6 dielectric fluid added to each circuit breaker unit each month.

2. The date and time that each alarm associated with the circuit breaker is activated, the corrective action taken to remedy 

the problem associated with each alarm, and the date corrective action remedied the problem.

Compliance with the emission limits must be demonstrated for each source based on the heat input of the source and 

emission factors and equations as described in Table A-13 of Appendix A of the Application.

Group Name: GHG

Group Description: Greenhouse Gas

Sources included in this group:

ID Name

030

031

032

033

101

102

FUEL PREHEATER

COMBINED CYCLE UNIT #1

COMBINED CYCLE UNIT #2

AUXILIARY BOILER

EMERGENCY GENERATOR (750 KW)

EMERGENCY FIREWATER PUMP (300 HP)

II.

III.

IV.

TESTING REQUIREMENTS.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

No additional testing requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements).

No additional monitoring requirements exist except as provided in other sections of this plan approval including Section B (Plan

Approval General Requirements).

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 # 004

 # 005

 [25 Pa. Code §127.12b]

 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

Plan approval terms and conditions.

The facility shall submit semi-annual reports no later than March 1 for the January 1 thru December 31 of the previous year 

period and by September 1 for the July 1 of the previous year thru June 30 of the concurrent year period. The report shall 

include:

1. The greenhouse gas and SF6 emissions including emission calculations from all air-contaminant sources, on a monthly

basis, in order to demonstrate compliance with the emission limitations for all sources at the facility.

2. The amount of SF6 dielectric fluid added to each circuit breaker unit each month.

3. The date and time that each alarm associated with the circuit breaker is activated, the corrective action taken to remedy 

the problem associated with each alarm, and the date corrective action remedied the problem.

The following conditions are related to the GHG Tailoring Rule (40 CFR 51, 52 and 98)

(a) The permittee shall incorporate instrumentation and control systems that will allow plant efficiency to be optimized to the 

maximum extent practicable. To maintain efficient operating characteristics, these systems shall be periodically 

maintained in accordance with the permittee's Preventative maintenance Program.

(b) Facility shall implement a sulfur hexafluoride (SF6) leak detection program to minimize SF6 leaks as follows. Circuit 

breakers are to be state-of-the-art sealed enclosed-pressure circuit breakers equipped with low-pressure alarms that are 

triggered when 10% of the SF6 by weight has escaped. When alarms are triggered, the facility will take corrective action as 

soon as practicable to fix the circuit breaker units to a like-new state to prevent the emission of SF6 to the maximum extent 

practicable.

(c) Facility shall develop a site Preventative Maintenance Program to maintain plant operating efficiency.

V.

VI.

VII.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

ADDITIONAL REQUIREMENTS.

No additional requirements exist except as provided in other sections of this plan approval including Section B (Plan Approval 

General Requirements).

SECTION E. Source Group Plan Approval Restrictions.
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I. RESTRICTIONS.

 # 001 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

As required in Section C, the permittee shall monthly calculate and record PM-2.5 emissions for the past month and the 

twelve-month rolling total of PM-2.5 emissions for the past twelve months. Facility emissions of PM-2.5 will be limited to 

less than 100 tpy in the following manner:

1. Emissions of PM-2.5 from each combustion turbine and HRSG unit with the duct burners off shall be limited to 10 lb/hr 

verified by annual stack testing of stacks S031 and S032. The stack test results shall be used for calculating PM-2.5 

emissions.

2. Emissions of PM-2.5 from each combustion turbine and HRSG unit with the duct burners on shall be limited to 21.55 

lb/hr verified by stack testing of stacks S031 and S032 once every five years. The stack test results shall be used for 

calculating PM-2.5 emissions.

NOTE: Prior to issuing a permit, Source Group CCU, Condition #003 of this plan approval requires stack testing of stacks 

Group Name: PM2.5

Group Description: PM2.5

Sources included in this group:

ID Name

030

031

032

033

101

102

103

FUEL PREHEATER

COMBINED CYCLE UNIT #1

COMBINED CYCLE UNIT #2

AUXILIARY BOILER

EMERGENCY GENERATOR (750 KW)

EMERGENCY FIREWATER PUMP (300 HP)

COOLING TOWER

No additional requirements exist except as provided in other sections of this plan approval including Section B (Plan Approval 

General Requirements).

II.

III.

IV.

V.

VI.

VII.

TESTING REQUIREMENTS.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

ADDITIONAL REQUIREMENTS.

No additional testing requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements).

No additional monitoring requirements exist except as provided in other sections of this plan approval including Section B (Plan

Approval General Requirements).

No additional record keeping requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements).

No additional reporting requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements).

No additional work practice requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements).

SECTION E. Source Group Plan Approval Restrictions.
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S031 and S032 with duct burners both off and on.

3. Each set of stack tests shall be conducted annually for PM-2.5 emissions eleven (11) to fourteen (14) calender months 

after the previous stack tests. Stack tests shall be conducted using EPA Test Methods 5 and 202 assuming PM-2.5 

emissions are equal to the PM/PM-10 emission rate. Stack tests may instead be conducted using another EPA approved 

PM-2.5 test method when approved in writing by the Department.

4. For Source 030 (Fuel Preheater), the permittee may use the vendor guaranteed PM-2.5 emission factor of 0.007 

lb/mmBtu to calculate PM-2.5 emissions. If the permittee conducts a stack test on Source 030, the permittee may instead 

use the results of the stack test provided the stack test was conducted in the past fourteen calender months.

5. For Source 033 (Auxiliary Boiler), the permittee may use the vendor guaranteed PM-2.5 emission factor of 0.005 lb/mmBtu

to calculate PM-2.5 emissions. If the permittee conducts a stack test on Source 033, the permittee may instead use the 

results of the stack test provided the stack test was conducted in the past fourteen calender months.

6. For Source 103 (Cooling Tower), the permittee may multiply the PM-2.5 emission factor of 0.49 lb/hr by actual operating 

hours to determine PM-2.5 emissions. The emission factor is based on typical particle size distributions for cooling towers.

 If the permittee conducts a stack test on Source 103, the permittee may instead use the results of a stack test provided the 

stack test was conducted in the past fourteen calender months.

7. For Source 101 (Emergency Generator), the permittee may use the vendor guaranteed PM-2.5 emission factor of 0.20 

g/kw-hr to calculate PM-2.5 emissions. If the permittee conducts a stack test on Source 101, the permittee may instead use

the results of the stack test provided the stack test was conducted in the past fourteen calender months.

8. For Source 102 (Firewater Pump), the permittee may use the vendor guaranteed PM-2.5 emission factor of 0.15 g/bhp-hr 

to calculate PM-2.5 emissions. If the permittee conducts a stack test on Source 102, the permittee may instead use the 

results of the stack test provided the stack test was conducted in the past fourteen calender months.

SECTION E. Source Group Plan Approval Restrictions.
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I. RESTRICTIONS.

Emission Restriction(s).

Operation Hours Restriction(s).

 # 001

 # 002

 [25 Pa. Code §127.12b]

 [25 Pa. Code §127.12b]

Plan approval terms and conditions.

Plan approval terms and conditions.

(a) The startup and shutdown emissions from each CCU shall be limited to the following (per unit):

1. GE 7FA

 (a) NOx: S/U: 173.18 lb/hr (1-hour block average) and 43.30 tpy & S/D: 173.18 lb/hr (1-hour block average) and 4.39 tpy

 (b) CO: S/U: 150.35 tpy & S/D: 10.73 tpy

 (c) VOC: S/U: 61.97 tpy & S/D: 4.23 tpy

 (d) SOx: S/U: 0.71 tpy & S/D: 0.12 tpy

 (e) H2SO4: S/U: 0.12 tpy & S/D: 0.02 tpy

 (f) PM/PM10/PM2.5: S/U: 2.40 tpy & S/D: 0.34 tpy

2. Siemens F

 (a) NOx: S/U: 162.13 lb/hr (1-hour block average) and 40.53 tpy & S/D: 162.13 lb/hr (1-hour block average) and 4.39 tpy

 (b) CO: S/U: 114.06 tpy & S/D: 10.73 tpy

 (c) VOC: S/U: 37.30 tpy & S/D: 4.23 tpy

 (d) SOx: S/U: 0.71 tpy & S/D: 0.12 tpy

 (e) H2SO4: S/U: 0.12 tpy & S/D: 0.02 tpy

 (f) PM/PM10/PM2.5: S/U: 2.40 tpy & S/D: 0.34 tpy

(a) Startup is defined as the period beginning with ignition in the combustion turbine and lasting until either:

1. The combustion process, air pollution control equipment, and associated control systems have attained normal 

operating conditions for two consecutive 15-minute averaging periods, or

2. Five hours after ignition, whichever occurs first.

(b) Startup shall be limited to 500 total hours in any consecutive 12-month period.

(c ) For the GE 7F5A combustion turbine shutdown is defined as the period beginning with the lowering of unit load below 

50% with the intent of ceasing operation of the unit and concluding with the cessation of combustion in the turbine, limited to

a maximum of one hour in duration.

(d) For the Siemens F combustion turbine shutdown is defined as the period beginning with the lowering of unit load below 

60% with the intent of ceasing operation of the unit and concluding with the cessation of combustion in the turbine, limited to

a maximum of one hour in duration.

(e) Shutdown shall be limited to 60 total hours in any consecutive 12-month period.

(f) Malfunction is defined as any sudden, infrequent, and not reasonably preventable failure of air pollution control 

equipment, process equipment, or a process to operate in a normal or usual manner that may result in an increase in the 

Group Name: STARTUP & SHUTDOWN

Group Description: Startup & Shutdown

Sources included in this group:

ID Name

031

032

COMBINED CYCLE UNIT #1

COMBINED CYCLE UNIT #2

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emissions of air contaminants.

II.

III.

IV.

V.

VI.

VII.

TESTING REQUIREMENTS.

MONITORING REQUIREMENTS.

RECORDKEEPING REQUIREMENTS.

REPORTING REQUIREMENTS.

WORK PRACTICE REQUIREMENTS.

ADDITIONAL REQUIREMENTS.

No additional testing requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements).

No additional monitoring requirements exist except as provided in other sections of this plan approval including Section B (Plan

Approval General Requirements).

No additional record keeping requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements).

No additional reporting requirements exist except as provided in other sections of this plan approval including Section B (Plan 

Approval General Requirements).

No additional work practice requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements).

No additional requirements exist except as provided in other sections of this plan approval including Section B (Plan Approval 

General Requirements).

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I. RESTRICTIONS.

Emission Restriction(s).

 # 001

 # 002

 # 003

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4320]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4325]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4330]

What emission limits must I meet for nitrogen oxides (NOX)?

What emission limits must I meet for NOX if my turbine burns both natural gas and distillate oil (or some other 

combination of fuels)?

What emission limits must I meet for sulfur dioxide (SO2)?

[Compliance with the NOx limit of 2.0 ppmvd @ 15% oxygen for the CCU under 127.12b will show compliance with this 

requirement]

(a) You must meet the emission limits for NOX specified in Table 1 to this subpart. [From Table 1: For new turbine firing 

natural gas and > 850 mmbtu/hr: 15 ppm at 15% O2 or 54 ng/J of useful output (0.43 lb/MWh) and For heat recovery units 

operating independent of the combustion turbine: 54 ppm @ 15% O2 or 110 ng/J of useful output (0.86 lb/MWh)]

(b) If you have two or more turbines that are connected to a single generator, each turbine must meet the emission limits for

NOX .

Not applicable

[Compliance with the sulfur limit in the fuel of 0.68 gr / 100 scf natural gas under 127.12b will show compliance with this 

requirement]

(a) If your turbine is located in a continental area, you must comply with either paragraph (a)(1), (a)(2), or (a)(3) of this 

section. If your turbine is located in Alaska, you do not have to comply with the requirements in paragraph (a) of this section 

until January 1, 2008.

(1) You must not cause to be discharged into the atmosphere from the subject stationary combustion turbine any gases 

which contain SO2 in excess of 110 nanograms per Joule (ng/J) (0.90 pounds per megawatt-hour (lb/MWh)) gross output;

(2) You must not burn in the subject stationary combustion turbine any fuel which contains total potential sulfur emissions in

excess of 26 ng SO2 /J (0.060 lb SO2 /MMBtu) heat input. If your turbine simultaneously fires multiple fuels, each fuel must 

meet this requirement; or

(3) Not applicable

(b) Not applicable

 # 004 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4400]

How do I conduct the initial and subsequent performance tests, regarding NOX ?

(a) You must conduct an initial performance test, as required in § 60.8. Subsequent NOX performance tests shall be 

conducted on an annual basis (no more than 14 calendar months following the previous performance test).

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Group Name: SUBPART KKKK

Group Description: Subpart KKKK

Sources included in this group:

ID Name

031

032

COMBINED CYCLE UNIT #1

COMBINED CYCLE UNIT #2

II. TESTING REQUIREMENTS.

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(1) There are two general methodologies that you may use to conduct the performance tests. For each test run:

(i) Not applicable

(ii) Measure the NOX and diluent gas concentrations, using either EPA Methods 7E and 3A, or EPA Method 20 in appendix A 

of this part. Concurrently measure the heat input to the unit, using a fuel flowmeter (or flowmeters), and measure the 

electrical and thermal output of the unit. Use EPA Method 19 in appendix A of this part to calculate the NOX emission rate in 

lb/MMBtu. Then, use Equations 1 and, if necessary, 2 and 3 in § 60.4350(f) to calculate the NOX emission rate in lb/MWh.

(2) Sampling traverse points for NOX and (if applicable) diluent gas are to be selected following EPA Method 20 or EPA 

Method 1 (non-particulate procedures), and sampled for equal time intervals. The sampling must be performed with a 

traversing single-hole probe, or, if feasible, with a stationary multi-hole probe that samples each of the points sequentially. 

Alternatively, a multi-hole probe designed and documented to sample equal volumes from each hole may be used to 

sample simultaneously at the required points.

(3) Notwithstanding paragraph (a)(2) of this section, you may test at fewer points than are specified in EPA Method 1 or EPA 

Method 20 in appendix A of this part if the following conditions are met:

(i) You may perform a stratification test for NOX and diluent pursuant to

(A) [Reserved], or

(B) The procedures specified in section 6.5.6.1(a) through (e) of appendix A of part 75 of this chapter.

(ii) Once the stratification sampling is completed, you may use the following alternative sample point selection criteria for 

the performance test:

(A) If each of the individual traverse point NOX concentrations is within ±10 percent of the mean concentration for all traverse

points, or the individual traverse point diluent concentrations differs by no more than ±5ppm or ±0.5 percent CO2 (or O2 ) 

from the mean for all traverse points, then you may use three points (located either 16.7, 50.0 and 83.3 percent of the way 

across the stack or duct, or, for circular stacks or ducts greater than 2.4 meters (7.8 feet) in diameter, at 0.4, 1.2, and 2.0 

meters from the wall). The three points must be located along the measurement line that exhibited the highest average 

NOX concentration during the stratification test; or

(B) Not applicable

(C) For turbines with a NOX standard less than or equal to 15 ppm @ 15% O2, you may sample at a single point, located at 

least 1 meter from the stack wall or at the stack centroid if each of the individual traverse point NOX concentrations is within 

±2.5 percent of the mean concentration for all traverse points, or the individual traverse point diluent concentrations differs 

by no more than ±1ppm or ±0.15 percent CO2 (or O2) from the mean for all traverse points.

(b) The performance test must be done at any load condition within plus or minus 25 percent of 100 percent of peak load. 

You may perform testing at the highest achievable load point, if at least 75 percent of peak load cannot be achieved in 

practice. You must conduct three separate test runs for each performance test. The minimum time per run is 20 minutes.

(1) Not applicable

(2) For a combined cycle and CHP turbine systems with supplemental heat (duct burner), you must measure the total NOx 

emissions after the duct burner rather than directly after the turbine. The duct burner must be in operation during the 

performance test.

(3) Not applicable

(4) Compliance with the applicable emission limit in § 60.4320 must be demonstrated at each tested load level. 

Compliance is achieved if the three-run arithmetic average NOx emission rate at each tested level meets the applicable 

emission limit in § 60.4320.

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 # 005

 # 006

 # 007

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4405]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4410]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4415]

How do I perform the initial performance test if I have chosen to install a NOX-diluent CEMS?

How do I establish a valid parameter range if I have chosen to continuously monitor parameters?

How do I conduct the initial and subsequent performance tests for sulfur?

(5) If you elect to install a CEMS, the performance evaluation of the CEMS may either be conducted separately or (as 

described in § 60.4405) as part of the initial performance test of the affected unit.

(6) The ambient temperature must be greater than 0°F during the performance test.

If you elect to install and certify a NOX - diluent CEMS under § 60.4345, then the initial performance test required under § 

60.8 may be performed in the following alternative manner:

(a) Perform a minimum of nine RATA reference method runs, with a minimum time per run of 21 minutes, at a single load 

level, within plus or minus 25 percent of 100 percent of peak load. The ambient temperature must be greater than 0°F 

during the RATA runs.

(b) For each RATA run, concurrently measure the heat input to the unit using a fuel flow meter (or flow meters) and measure

the electrical and thermal output from the unit.

(c) Use the test data both to demonstrate compliance with the applicable NOX emission limit under § 60.4320 and to 

provide the required reference method data for the RATA of the CEMS described under § 60.4335.

(d) Compliance with the applicable emission limit in § 60.4320 is achieved if the arithmetic average of all of the NOX 

emission rates for the RATA runs, expressed in units of ppm or lb/MWh, does not exceed the emission limit.

Not applicable

(a) You must conduct an initial performance test, as required in § 60.8. Subsequent SO2 performance tests shall be 

conducted on an annual basis (no more than 14 calendar months following the previous performance test). There are three

methodologies that you may use to conduct the performance tests.

(1) If you choose to periodically determine the sulfur content of the fuel combusted in the turbine, a representative fuel 

sample would be collected following ASTM D5287 (incorporated by reference, see § 60.17) for natural gas or ASTM D4177 

(incorporated by reference, see § 60.17) for oil. Alternatively, for oil, you may follow the procedures for manual pipeline 

sampling in section 14 of ASTM D4057 (incorporated by reference, see § 60.17). The fuel analyses of this section may be 

performed either by you, a service contractor retained by you, the fuel vendor, or any other qualified agency. Analyze the 

samples for the total sulfur content of the fuel using:

(i) Not applicable

(ii) For gaseous fuels, ASTM D1072, or alternatively D3246, D4084, D4468, D4810, D6228, D6667, or Gas Processors 

Association Standard 2377 (all of which are incorporated by reference, see § 60.17).

(2) Measure the SO2 concentration (in parts per million (ppm)), using EPA Methods 6, 6C, 8, or 20 in appendix A of this part. 

In addition, the American Society of Mechanical Engineers (ASME) standard, ASME PTC 19-10-1981-Part 10, “Flue and 

Exhaust Gas Analyses,” manual methods for sulfur dioxide (incorporated by reference, see § 60.17) can be used instead of 

EPA Methods 6 or 20. For units complying with the output based standard, concurrently measure the stack gas flow rate, 

using EPA Methods 1 and 2 in appendix A of this part, and measure and record the electrical and thermal output from the 

unit. Then use the following equation from 40 CFR 60.4415(a)(2) to calculate the SO2 emission rate.

(3) Measure the SO2 and diluent gas concentrations, using either EPA Methods 6, 6C, or 8 and 3A, or 20 in appendix A of 

this part. In addition, you may use the manual methods for sulfur dioxide ASME PTC 19-10-1981-Part 10 (incorporated by 

reference, see 60.17). Concurrently measure the heat input to the unit, using a fuel flowmeter (or flowmeters), and 

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

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 # 008

 # 009

 # 010

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4335]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4340]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4345]

How do I demonstrate compliance for NOX if I use water or steam injection?

How do I demonstrate continuous compliance for NOX if I do not use water or steam injection?

What are the requirements for the continuous emission monitoring system equipment, if I choose to use this option?

measure the electrical and thermal output of the unit. Use EPA Method 19 in appendix A of this part to calculate the SO2 

emission rate in lb/MMBtu. Then, use Equations 1 and, if necessary, 2 and 3 in 60.4350(f) to calculate the SO2 emission 

rate in lb/MWh.

(b) [Reserved]

Not applicable

(a) If you are not using water or steam injection to control NOX emissions, you must perform annual performance tests in 

accordance with § 60.4400 to demonstrate continuous compliance. If the NOX emission result from the performance test is 

less than or equal to 75 percent of the NOX emission limit for the turbine, you may reduce the frequency of subsequent 

performance tests to once every 2 years (no more than 26 calendar months following the previous performance test). If the 

results of any subsequent performance test exceed 75 percent of the NOX emission limit for the turbine, you must resume 

annual performance tests.

(b) As an alternative, you may install, calibrate, maintain and operate one of the following continuous monitoring systems:

(1) Continuous emission monitoring as described in §§ 60.4335(b) and 60.4345, or

(2) Not applicable

If the option to use a NOX CEMS is chosen:

(a) Each NOX diluent CEMS must be installed and certified according to Performance Specification 2 (PS 2) in appendix B to

this part, except the 7-day calibration drift is based on unit operating days, not calendar days. With state approval, Procedure

1 in appendix F to this part is not required. Alternatively, a NOX diluent CEMS that is installed and certified according to 

appendix A of part 75 of this chapter is acceptable for use under this subpart. The relative accuracy test audit (RATA) of the 

CEMS shall be performed on a lb/MMBtu basis.

(b) As specified in § 60.13(e)(2), during each full unit operating hour, both the NOX monitor and the diluent monitor must 

complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each 15-minute quadrant of the

hour, to validate the hour. For partial unit operating hours, at least one valid data point must be obtained with each monitor 

for each quadrant of the hour in which the unit operates. For unit operating hours in which required quality assurance and 

maintenance activities are performed on the CEMS, a minimum of two valid data points (one in each of two quadrants) are 

required for each monitor to validate the NOX emission rate for the hour.

(c) Each fuel flowmeter shall be installed, calibrated, maintained, and operated according to the manufacturer's 

instructions. Alternatively, with state approval, fuel flowmeters that meet the installation, certification, and quality assurance 

requirements of appendix D to part 75 of this chapter are acceptable for use under this subpart.

(d) Each watt meter, steam flow meter, and each pressure or temperature measurement device shall be installed, 

calibrated, maintained, and operated according to manufacturer's instructions.

(e) The owner or operator shall develop and keep on-site a quality assurance (QA) plan for all of the continuous monitoring 

equipment described in paragraphs (a), (c), and (d) of this section. For the CEMS and fuel flow meters, the owner or 

operator may, with state approval, satisfy the requirements of this paragraph by implementing the QA program and plan 

described in section 1 of appendix B to part 75 of this chapter.

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

III. MONITORING REQUIREMENTS.

SECTION E. Source Group Plan Approval Restrictions.
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 # 011

 # 012

 # 013

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4350]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4355]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4360]

How do I use data from the continuous emission monitoring equipment to identify excess emissions?

How do I establish and document a proper parameter monitoring plan?

How do I determine the total sulfur content of the turbine's combustion fuel?

For purposes of identifying excess emissions:

(a) All CEMS data must be reduced to hourly averages as specified in § 60.13(h).

(b) For each unit operating hour in which a valid hourly average, as described in § 60.4345(b), is obtained for both NOX and 

diluent monitors, the data acquisition and handling system must calculate and record the hourly NOX emission rate in units

of ppm or lb/MMBtu, using the appropriate equation from method 19 in appendix A of this part. For any hour in which the 

hourly average O2 concentration exceeds 19.0 percent O2 (or the hourly average CO2 concentration is less than 1.0 percent

CO2 ), a diluent cap value of 19.0 percent O2 or 1.0 percent CO2 (as applicable) may be used in the emission calculations.

(c) Correction of measured NOX concentrations to 15 percent O2 is not allowed.

(d) If you have installed and certified a NOX diluent CEMS to meet the requirements of part 75 of this chapter, states can 

approve that only quality assured data from the CEMS shall be used to identify excess emissions under this subpart. 

Periods where the missing data substitution procedures in subpart D of part 75 are applied are to be reported as monitor 

downtime in the excess emissions and monitoring performance report required under § 60.7(c).

(e) All required fuel flow rate, steam flow rate, temperature, pressure, and megawatt data must be reduced to hourly 

averages.

(f) Calculate the hourly average NOX emission rates, in units of the emission standards under § 60.4320, using either ppm 

for units complying with the concentration limit or the following equation for units complying with the output based standard:

(1) Not applicable

(2) For combined-cycle and combined heat and power complying with the output-based standard, use Equation 1 of this 

subpart, except that the gross energy output is calculated as the sum of the total electrical and mechanical energy 

generated by the combustion turbine, the additional electrical or mechanical energy (if any) generated by the steam turbine 

following the heat recovery steam generator, and 100 percent of the total useful thermal energy output that is not used to 

generate additional electricity or mechanical output, expressed in equivalent MW, as in the following equations in 40 CFR 

60.4350(f)(2).

(3) Not applicable

(g) Not applicable

(h) For combined cycle and combined heat and power units with heat recovery, use the calculated hourly average emission 

rates from paragraph (f) of this section to assess excess emissions on a 30 unit operating day rolling average basis, as 

described in § 60.4380(b)(1).

Not applicable

You must monitor the total sulfur content of the fuel being fired in the turbine, except as provided in § 60.4365. The sulfur 

content of the fuel must be determined using total sulfur methods described in § 60.4415. Alternatively, if the total sulfur 

content of the gaseous fuel during the most recent performance test was less than half the applicable limit, ASTM D4084, 

D4810, D5504, or D6228, or Gas Processors Association Standard 2377 (all of which are incorporated by reference, see § 

60.17), which measure the major sulfur compounds, may be used.

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

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 # 014

 # 015

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4365]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4370]

How can I be exempted from monitoring the total sulfur content of the fuel?

How often must I determine the sulfur content of the fuel?

You may elect not to monitor the total sulfur content of the fuel combusted in the turbine, if the fuel is demonstrated not to 

exceed potential sulfur emissions of 26 ng SO2 /J (0.060 lb SO2 /MMBtu) heat input for units located in continental areas 

and 180 ng SO2 /J (0.42 lb SO2 /MMBtu) heat input for units located in noncontinental areas or a continental area that the 

Administrator determines does not have access to natural gas and that the removal of sulfur compounds would cause 

more environmental harm than benefit. You must use one of the following sources of information to make the required 

demonstration:

(a) The fuel quality characteristics in a current, valid purchase contract, tariff sheet or transportation contract for the fuel, 

specifying that the maximum total sulfur content for oil use in continental areas is 0.05 weight percent (500 ppmw) or less 

and 0.4 weight percent (4,000 ppmw) or less for noncontinental areas, the total sulfur content for natural gas use in 

continental areas is 20 grains of sulfur or less per 100 standard cubic feet and 140 grains of sulfur or less per 100 

standard cubic feet for noncontinental areas, has potential sulfur emissions of less than less than 26 ng SO2 /J (0.060 lb 

SO2 /MMBtu) heat input for continental areas and has potential sulfur emissions of less than less than 180 ng SO2 /J (0.42 

lb SO2 /MMBtu) heat input for noncontinental areas; or

(b) Representative fuel sampling data which show that the sulfur content of the fuel does not exceed 26 ng SO2 /J (0.060 lb 

SO2 /MMBtu) heat input for continental areas or 180 ng SO2 /J (0.42 lb SO2 /MMBtu) heat input for noncontinental areas. At a

minimum, the amount of fuel sampling data specified in section 2.3.1.4 or 2.3.2.4 of appendix D to part 75 of this chapter is 

required.

The frequency of determining the sulfur content of the fuel must be as follows:

(a) Not applicable

(b) Gaseous fuel. If you elect not to demonstrate sulfur content using options in § 60.4365, and the fuel is supplied without 

intermediate bulk storage, the sulfur content value of the gaseous fuel must be determined and recorded once per unit 

operating day.

(c) Custom schedules. Notwithstanding the requirements of paragraph (b) of this section, operators or fuel vendors may 

develop custom schedules for determination of the total sulfur content of gaseous fuels, based on the design and operation

of the affected facility and the characteristics of the fuel supply. Except as provided in paragraphs (c)(1) and (c)(2) of this 

section, custom schedules shall be substantiated with data and shall be approved by the Administrator before they can be 

used to comply with the standard in § 60.4330.

(1) The two custom sulfur monitoring schedules set forth in paragraphs (c)(1)(i) through (iv) and in paragraph (c)(2) of this 

section are acceptable, without prior Administrative approval:

(i) The owner or operator shall obtain daily total sulfur content measurements for 30 consecutive unit operating days, using 

the applicable methods specified in this subpart. Based on the results of the 30 daily samples, the required frequency for 

subsequent monitoring of the fuel's total sulfur content shall be as specified in paragraph (c)(1)(ii), (iii), or (iv) of this section,

as applicable.

(ii) If none of the 30 daily measurements of the fuel's total sulfur content exceeds half the applicable standard, subsequent 

sulfur content monitoring may be performed at 12-month intervals. If any of the samples taken at 12-month intervals has a 

total sulfur content greater than half but less than the applicable limit, follow the procedures in paragraph (c)(1)(iii) of this 

section. If any measurement exceeds the applicable limit, follow the procedures in paragraph (c)(1)(iv) of this section.

(iii) If at least one of the 30 daily measurements of the fuel's total sulfur content is greater than half but less than the 

applicable limit, but none exceeds the applicable limit, then:

(A) Collect and analyze a sample every 30 days for 3 months. If any sulfur content measurement exceeds the applicable 

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

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 # 016

 # 017

 # 018

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4375]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4390]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4395]

What reports must I submit?

What are my reporting requirements if I operate an emergency combustion turbine or a research and development 

turbine?

When must I submit my reports?

limit, follow the procedures in paragraph (c)(1)(iv) of this section. Otherwise, follow the procedures in paragraph (c)(1)(iii)(B)

of this section.

(B) Begin monitoring at 6-month intervals for 12 months. If any sulfur content measurement exceeds the applicable limit, 

follow the procedures in paragraph (c)(1)(iv) of this section. Otherwise, follow the procedures in paragraph (c)(1)(iii)(C) of 

this section.

(C) Begin monitoring at 12-month intervals. If any sulfur content measurement exceeds the applicable limit, follow the 

procedures in paragraph (c)(1)(iv) of this section. Otherwise, continue to monitor at this frequency.

(iv) If a sulfur content measurement exceeds the applicable limit, immediately begin daily monitoring according to 

paragraph (c)(1)(i) of this section. Daily monitoring shall continue until 30 consecutive daily samples, each having a sulfur 

content no greater than the applicable limit, are obtained. At that point, the applicable procedures of paragraph (c)(1)(ii) or 

(iii) of this section shall be followed.

(2) The owner or operator may use the data collected from the 720-hour sulfur sampling demonstration described in 

section 2.3.6 of appendix D to part 75 of this chapter to determine a custom sulfur sampling schedule, as follows:

(i) If the maximum fuel sulfur content obtained from the 720 hourly samples does not exceed 20 grains/100 scf, no 

additional monitoring of the sulfur content of the gas is required, for the purposes of this subpart.

(ii) If the maximum fuel sulfur content obtained from any of the 720 hourly samples exceeds 20 grains/100 scf, but none of 

the sulfur content values (when converted to weight percent sulfur) exceeds half the applicable limit, then the minimum 

required sampling frequency shall be one sample at 12 month intervals.

(iii) If any sample result exceeds half the applicable limit, but none exceeds the applicable limit, follow the provisions of 

paragraph (c)(1)(iii) of this section.

(iv) If the sulfur content of any of the 720 hourly samples exceeds the applicable limit, follow the provisions of paragraph 

(c)(1)(iv) of this section.

(a) For each affected unit required to continuously monitor parameters or emissions, or to periodically determine the fuel 

sulfur content under this subpart, you must submit reports of excess emissions and monitor downtime, in accordance with 

§ 60.7(c). Excess emissions must be reported for all periods of unit operation, including start-up, shutdown, and 

malfunction.

(b) For each affected unit that performs annual performance tests in accordance with § 60.4340(a), you must submit a 

written report of the results of each performance test before the close of business on the 60th day following the completion 

of the performance test.

Not applicable

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

IV.

V.

RECORDKEEPING REQUIREMENTS.

REPORTING REQUIREMENTS.

No additional record keeping requirements exist except as provided in other sections of this plan approval including Section B 

(Plan Approval General Requirements).

SECTION E. Source Group Plan Approval Restrictions.
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 # 019

 # 020

 # 021

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4333]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4380]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4385]

What are my general requirements for complying with this subpart?

How are excess emissions and monitor downtime defined for NOX ?

How are excess emissions and monitoring downtime defined for SO2?

All reports required under § 60.7(c) must be postmarked by the 30th day following the end of each 6-month period.

(a) You must operate and maintain your stationary combustion turbine, air pollution control equipment, and monitoring 

equipment in a manner consistent with good air pollution control practices for minimizing emissions at all times including 

during startup, shutdown, and malfunction.

(b) When an affected unit with heat recovery utilizes a common steam header with one or more combustion turbines, the 

owner or operator shall either:

(1) Determine compliance with the applicable NOX emissions limits by measuring the emissions combined with the 

emissions from the other unit(s) utilizing the common heat recovery unit; or

(2) Develop, demonstrate, and provide information satisfactory to the Administrator on methods for apportioning the 

combined gross energy output from the heat recovery unit for each of the affected combustion turbines. The Administrator 

may approve such demonstrated substitute methods for apportioning the combined gross energy output measured at the 

steam turbine whenever the demonstration ensures accurate estimation of emissions related under this part.

For the purpose of reports required under § 60.7(c), periods of excess emissions and monitor downtime that must be 

reported are defined as follows:

(a) Not applicable

(b) For turbines using continuous emission monitoring, as described in §§ 60.4335(b) and 60.4345:

(1) An excess emissions is any unit operating period in which the 4-hour or 30-day rolling average NOX emission rate 

exceeds the applicable emission limit in § 60.4320. For the purposes of this subpart, a “4-hour rolling average NOX 

emission rate” is the arithmetic average of the average NOX emission rate in ppm or ng/J (lb/MWh) measured by the 

continuous emission monitoring equipment for a given hour and the three unit operating hour average NOX emission rates 

immediately preceding that unit operating hour. Calculate the rolling average if a valid NOX emission rate is obtained for at 

least 3 of the 4 hours. For the purposes of this subpart, a “30-day rolling average NOX emission rate” is the arithmetic 

average of all hourly NOX emission data in ppm or ng/J (lb/MWh) measured by the continuous emission monitoring 

equipment for a given day and the twenty-nine unit operating days immediately preceding that unit operating day. A new 30-

day average is calculated each unit operating day as the average of all hourly NOX emissions rates for the preceding 30 unit

operating days if a valid NOX emission rate is obtained for at least 75 percent of all operating hours.

(2) A period of monitor downtime is any unit operating hour in which the data for any of the following parameters are either 

missing or invalid: NOX concentration, CO2 or O2 concentration, fuel flow rate, steam flow rate, steam temperature, steam 

pressure, or megawatts. The steam flow rate, steam temperature, and steam pressure are only required if you will use this 

information for compliance purposes.

(3) For operating periods during which multiple emissions standards apply, the applicable standard is the average of the 

applicable standards during each hour. For hours with multiple emissions standards, the applicable limit for that hour is 

determined based on the condition that corresponded to the highest emissions standard.

(c) Not applicable

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

VI. WORK PRACTICE REQUIREMENTS.

SECTION E. Source Group Plan Approval Restrictions.
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 # 022

 # 023

 # 024

 # 025

 # 026

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4300]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4305]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4310]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4315]

 [40 CFR Part 60 Standards of Performance for New Stationary Sources §40 CFR 60.4420]

What is the purpose of this subpart?

Does this subpart apply to my stationary combustion turbine?

What types of operations are exempt from these standards of performance?

What pollutants are regulated by this subpart?

What definitions apply to this subpart?

If you choose the option to monitor the sulfur content of the fuel, excess emissions and monitoring downtime are defined as

follows:

(a) For samples of gaseous fuel and for oil samples obtained using daily sampling, flow proportional sampling, or 

sampling from the unit's storage tank, an excess emission occurs each unit operating hour included in the period 

beginning on the date and hour of any sample for which the sulfur content of the fuel being fired in the combustion turbine 

exceeds the applicable limit and ending on the date and hour that a subsequent sample is taken that demonstrates 

compliance with the sulfur limit.

(b) Not applicable

(c) A period of monitor downtime begins when a required sample is not taken by its due date. A period of monitor downtime 

also begins on the date and hour of a required sample, if invalid results are obtained. The period of monitor downtime ends

on the date and hour of the next valid sample.

This subpart establishes emission standards and compliance schedules for the control of emissions from stationary 

combustion turbines that commenced construction, modification or reconstruction after February 18, 2005.

(a) If you are the owner or operator of a stationary combustion turbine with a heat input at peak load equal to or greater than 

10.7 gigajoules (10 MMBtu) per hour, based on the higher heating value of the fuel, which commenced construction, 

modification, or reconstruction after February 18, 2005, your turbine is subject to this subpart. Only heat input to the 

combustion turbine should be included when determining whether or not this subpart is applicable to your turbine. Any 

additional heat input to associated heat recovery steam generators (HRSG) or duct burners should not be included when 

determining your peak heat input. However, this subpart does apply to emissions from any associated HRSG and duct 

burners.

(b) Stationary combustion turbines regulated under this subpart are exempt from the requirements of subpart GG of this 

part. Heat recovery steam generators and duct burners regulated under this subpart are exempted from the requirements of

subparts Da, Db, and Dc of this part.

Not applicable

The pollutants regulated by this subpart are nitrogen oxide (NOX) and sulfur dioxide (SO2).

As used in this subpart, all terms not defined herein will have the meaning given them in the Clean Air Act and in subpart A 

(General Provisions) of this part.

Biogas means gas produced by the anaerobic digestion or fermentation of organic matter including manure, sewage 

sludge, municipal solid waste, biodegradable waste, or any other biodegradable feedstock, under anaerobic conditions. 

Biogas is comprised primarily of methane and CO2.

Combined cycle combustion turbine means any stationary combustion turbine which recovers heat from the combustion 

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

VII. ADDITIONAL REQUIREMENTS.

SECTION E. Source Group Plan Approval Restrictions.
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turbine exhaust gases to generate steam that is only used to create additional power output in a steam turbine.

Combined heat and power combustion turbine means any stationary combustion turbine which recovers heat from the 

exhaust gases to heat water or another medium, generate steam for useful purposes other than additional electric 

generation, or directly uses the heat in the exhaust gases for a useful purpose.

Combustion turbine model means a group of combustion turbines having the same nominal air flow, combustor inlet 

pressure, combustor inlet temperature, firing temperature, turbine inlet temperature and turbine inlet pressure.

Combustion turbine test cell/stand means any apparatus used for testing uninstalled stationary or uninstalled mobile 

(motive) combustion turbines.

Diffusion flame stationary combustion turbine means any stationary combustion turbine where fuel and air are injected at 

the combustor and are mixed only by diffusion prior to ignition.

Duct burner means a device that combusts fuel and that is placed in the exhaust duct from another source, such as a 

stationary combustion turbine, internal combustion engine, kiln, etc., to allow the firing of additional fuel to heat the exhaust 

gases before the exhaust gases enter a heat recovery steam generating unit.

Efficiency means the combustion turbine manufacturer's rated heat rate at peak load in terms of heat input per unit of power

output—based on the higher heating value of the fuel.

Emergency combustion turbine means any stationary combustion turbine which operates in an emergency situation. 

Examples include stationary combustion turbines used to produce power for critical networks or equipment, including 

power supplied to portions of a facility, when electric power from the local utility is interrupted, or stationary combustion 

turbines used to pump water in the case of fire or flood, etc. Emergency stationary combustion turbines do not include 

stationary combustion turbines used as peaking units at electric utilities or stationary combustion turbines at industrial 

facilities that typically operate at low capacity factors. Emergency combustion turbines may be operated for the purpose of 

maintenance checks and readiness testing, provided that the tests are required by the manufacturer, the vendor, or the 

insurance company associated with the turbine. Required testing of such units should be minimized, but there is no time 

limit on the use of emergency combustion turbines.

Excess emissions means a specified averaging period over which either (1) the NOX emissions are higher than the 

applicable emission limit in § 60.4320; (2) the total sulfur content of the fuel being combusted in the affected facility exceeds

the limit specified in § 60.4330; or (3) the recorded value of a particular monitored parameter is outside the acceptable 

range specified in the parameter monitoring plan for the affected unit.

Gross useful output means the gross useful work performed by the stationary combustion turbine system. For units using 

the mechanical energy directly or generating only electricity, the gross useful work performed is the gross electrical or 

mechanical output from the turbine/generator set. For combined heat and power units, the gross useful work performed is 

the gross electrical or mechanical output plus the useful thermal output (i.e., thermal energy delivered to a process).

Heat recovery steam generating unit means a unit where the hot exhaust gases from the combustion turbine are routed in 

order to extract heat from the gases and generate steam, for use in a steam turbine or other device that utilizes steam. Heat 

recovery steam generating units can be used with or without duct burners.

Integrated gasification combined cycle electric utility steam generating unit means a coal-fired electric utility steam 

generating unit that burns a synthetic gas derived from coal in a combined-cycle gas turbine. No solid coal is directly burned

in the unit during operation.

ISO conditions means 288 Kelvin, 60 percent relative humidity and 101.3 kilopascals pressure.

Lean premix stationary combustion turbine means any stationary combustion turbine where the air and fuel are thoroughly 

mixed to form a lean mixture before delivery to the combustor. Mixing may occur before or in the combustion chamber. A 

lean premixed turbine may operate in diffusion flame mode during operating conditions such as startup and shutdown, 

extreme ambient temperature, or low or transient load.

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Natural gas means a naturally occurring fluid mixture of hydrocarbons (e.g., methane, ethane, or propane) produced in 

geological formations beneath the Earth's surface that maintains a gaseous state at standard atmospheric temperature 

and pressure under ordinary conditions. Additionally, natural gas must either be composed of at least 70 percent methane 

by volume or have a gross calorific value between 950 and 1,100 British thermal units (Btu) per standard cubic foot. Natural 

gas does not include the following gaseous fuels: landfill gas, digester gas, refinery gas, sour gas, blast furnace gas, coalderived gas, producer gas, coke oven gas, or any gaseous fuel produced in a process which might result in highly variable 

sulfur content or heating value.

Noncontinental area means the State of Hawaii, the Virgin Islands, Guam, American Samoa, the Commonwealth of Puerto 

Rico, the Northern Mariana Islands, or offshore platforms.

Peak load means 100 percent of the manufacturer's design capacity of the combustion turbine at ISO conditions.

Regenerative cycle combustion turbine means any stationary combustion turbine which recovers heat from the combustion 

turbine exhaust gases to preheat the inlet combustion air to the combustion turbine.

Simple cycle combustion turbine means any stationary combustion turbine which does not recover heat from the 

combustion turbine exhaust gases to preheat the inlet combustion air to the combustion turbine, or which does not recover 

heat from the combustion turbine exhaust gases for purposes other than enhancing the performance of the combustion 

turbine itself.

Stationary combustion turbine means all equipment, including but not limited to the turbine, the fuel, air, lubrication and 

exhaust gas systems, control systems (except emissions control equipment), heat recovery system, and any ancillary 

components and sub-components comprising any simple cycle stationary combustion turbine, any 

regenerative/recuperative cycle stationary combustion turbine, any combined cycle combustion turbine, and any combined 

heat and power combustion turbine based system. Stationary means that the combustion turbine is not self propelled or 

intended to be propelled while performing its function. It may, however, be mounted on a vehicle for portability.

Unit operating day means a 24-hour period between 12 midnight and the following midnight during which any fuel is 

combusted at any time in the unit. It is not necessary for fuel to be combusted continuously for the entire 24-hour period.

Unit operating hour means a clock hour during which any fuel is combusted in the affected unit. If the unit combusts fuel for 

the entire clock hour, it is considered to be a full unit operating hour. If the unit combusts fuel for only part of the clock hour, it

is considered to be a partial unit operating hour.

Useful thermal output means the thermal energy made available for use in any industrial or commercial process, or used in

any heating or cooling application, i.e., total thermal energy made available for processes and applications other than 

electrical or mechanical generation. Thermal output for this subpart means the energy in recovered thermal output 

measured against the energy in the thermal output at 15 degrees Celsius and 101.325 kilopascals of pressure.

SECTION E. Source Group Plan Approval Restrictions.
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SECTION F. Alternative Operation Requirements.

No Alternative Operations exist for this Plan Approval facility.
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SECTION G. Emission Restriction Summary.

Source Id Source Description

030

031

032

033

FUEL PREHEATER

COMBINED CYCLE UNIT #1

COMBINED CYCLE UNIT #2

AUXILIARY BOILER

Emission Limit

Emission Limit

Emission Limit

Emission Limit

Pollutant

Pollutant

Pollutant

Pollutant

 0.050

 4,996.300

 0.035

 0.007

 0.002

 0.001

 0.005

 5.000

 107.920

 211.920

 1,000.000

 1,380,899.000

 131.600

 48.560

 48.560

 19.700

 2.970

 48.560

 93.850

 5.000

 107.920

 211.920

 1,000.000

 1,380,899.000

 131.600

 48.560

 48.560

 19.700

 2.970

 48.560

 93.850

 3.310

 12,346.000

 1.010

 0.460

Lbs/MMBTU

Tons/Yr

Lbs/MMBTU

Lbs/MMBTU

Lbs/MMBTU

Lbs/MMBTU

Lbs/MMBTU

PPMV

Tons/Yr

Tons/Yr

Lbs

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

PPMV

Tons/Yr

Tons/Yr

Lbs

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

0.0021 lb/mmBtu

0.00048 lb/mmbtu

dry basis corrected to 15% O2

based on 12-month rolling total

based on 12-month rolling total

1000 lb/MW-hr (gross)

carbon dioxide equivalent

based on 12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

dry basis corrected to 15% O2

based on 12-month rolling total

based on 12-month rolling total

1000 lb/MW-hr (gross)

carbon dioxide equivalent

based on 12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

12-month rolling total

carbon dioxide equilvant

12-month rolling total

based on 12-month rolling total

CO

Carbon Dioxide

NOX

PM10

SO2

Sulfuric Acid

VOC

Ammonia

Ammonia

CO

Carbon Dioxide

Carbon Dioxide

NOX

PM10

PM2.5

SOX

Sulfuric Acid

TSP

VOC

Ammonia

Ammonia

CO

Carbon Dioxide

Carbon Dioxide

NOX

PM10

PM2.5

SOX

Sulfuric Acid

TSP

VOC

CO

Carbon Dioxide

NOX

PM10
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SECTION G. Emission Restriction Summary.

Site Emission Restriction Summary

Emission Limit Pollutant

 11.300

 4.800

 39.370

 99.990

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

based on 12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

Hazardous Air Pollutants

Formaldehyde

SO2

PM2.5

Source Id Source Description

101

102

103

EMERGENCY GENERATOR (750 KW)

EMERGENCY FIREWATER PUMP (300 HP)

COOLING TOWER

Emission Limit

Emission Limit

Emission Limit

Pollutant

Pollutant

Pollutant

 0.460

 0.190

 0.040

 0.460

 0.140

 0.290

 65.000

 0.530

 0.017

 0.017

 0.001

 0.000

 0.017

 0.030

 0.090

 19.000

 0.090

 0.005

 0.005

 0.000

 0.000

 0.005

 0.013

 2.130

 5.730

 8.890

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

Tons/Yr

based on 12-month rolling total

12-month rolling total

12-month rolling total

12-month rolling total

12-month rolling total

12-month rolling total

carbon dioxide equivalent

12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

0.00055 ton/yr

0.00013 ton/yr

12-month rolling total

12-month rolling total

12-month rolling total

carbon dioxide equivalent

12-month rolling total

based on 12-month rolling total

based on 12-month rolling total

0.00015 ton/yr

0.000038 ton/yr

12-month rolling total

12-month rolling total

PM-2.5

12-month rolling total

12-month rolling total

PM2.5

SOX

Sulfuric Acid

TSP

VOC

CO

Carbon Dioxide

NOX

PM10

PM2.5

SOX

Sulfuric Acid

TSP

VOC

CO

Carbon Dioxide

NOX

PM10

PM2.5

SOX

Sulfuric Acid

TSP

VOC

PM-CON

PM10

TSP
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SECTION G. Emission Restriction Summary.

 2,779,224.000 Tons/Yr based on 12-month rolling total Carbon Dioxide
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SECTION H. Miscellaneous.

a) The Capacity/Hour numbers listed in Sections A and D of this permit for individual sources are for informational purposes only 

and are not to be considered enforceable limits. Enforceable emission limits are listed in the Restriction section for each source. 

b) Source ID: Department assigned ID number for the source

 Source Name: Department assigned name for the source

 Capacity: The maximum capacity for the source (not a limit)

 Fuel/Material: The fuel/material assigned to SCC for the source

Schematics:

 FML: Fuel material location

 Comb: Combustion source

 Proc: Process

 CD: Control device

 EP: Emission point

Pollutant:

 Ammonia: Ammonia

 CO: Carbon Monoxide

 CO2: Carbon Dioxide

 HAP: Hazardous Air Pollutants

 NOx: Nitrogen Oxide

 PM10: PM < 10 microns

 PM2.5: PM < 2.5 microns

 SOx: Sulfur Oxide

 Sulfuric Acid: Sulfuric Acid

 TSP: Total Suspended Particulate

 VOC: Volatile Organic Compound

c) For the purpose of this plan approval, the combustion turbines incorporated into the Combined Cycle Units will be one of the two 

proposed make and models:

1. General Electric 7FA (2.99 mmscf/hr natural gas)

2. Siemens SGTS-5000F (2.99mmscf/hr natural gas)

d) For the purpose of this plan approval, Source 031 (Combined Cycle Unit) consists of the following:

1. A combustion turbine generator (CTG) and a heat recovery steam generator (HRSG) that will provide steam to drive a single 

steam turbine generator (STG). The combined cycle unit (CCU) is a CTG and a HRSG. Each HRSG will be equipped with a natural

gas-fired duct burner (770 mmbtu/hr) which may be utilized at times of peak power demand to supplement power output by raising 

the heat content of the exhaust gas and thereby increasing the amount of steam generated.

e) For the purpose of this plan approval, Source 032 (Combined Cycle Unit) consists of the following:

1. A combustion turbine generator (CTG) and a heat recovery steam generator (HRSG) that will provide steam to drive a single 

steam turbine generator (STG). The combined cycle unit (CCU) is a CTG and a HRSG. Each HRSG will be equipped with a natural

gas-fired duct burner (770 mmbtu/hr) which may be utilized at times of peak power demand to supplement power output by raising 

the heat content of the exhaust gas and thereby increasing the amount of steam generated.

f) For the purpose of this plan approval, Source 033 (Auxiliary Boiler) consists of the following:

1. Forty (40) mmbtu/hr natural gas fired boiler. Make and model will be determined at a later date. (expected operating hours = 

4,600 hr/yr)

g) For the purpose of this plan approval, Source 101 (Emergency Generator) consists of the following:

1. The generator is rated at 1,135 bhp (750 kW) and fired with ULSD. Make and model will be determined at a later date. (expected

operating hours = 100 hr/yr)

h) For the purpose of this plan approval, Source 102 (Emergency Firewater Pump) consists of the following:
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SECTION H. Miscellaneous.

1. The fire pump is rated at 300 hp and fired with ULSD. Make and model will be determined at a later date. (expected operating 

hours = 100 hr/yr)

i) For the purpose of this plan approval, Source 103 (Cooling Water Tower) consists of the following:

1. A multi-cell mechanical draft cooling tower with a water circulation rate of 162,206 gpm; with a TDS concentration of 5,000 ppmv; 

and with an associated drift of 0.0005%.

j) For the purpose of this plan approval, Source 030 (Fuel Preheater) consists of the following:

1. 8.5 mmbtu/hr natural gas fired fuel gas heater. Make and model will be determined at a later date.

k) For the purpose of this plan approval, Source 110 (Cold Cleaning Machine (Degreaser))) consists of the following:

1. One (1) cold cleaning machine degreaser.

l) The following equipment and activities are not subject to any other specific restrictions, work practices, testing, monitoring, 

record keeping or reporting requirements:

 

1. Aqueous ammonia storage tank(s) and handling equipment

m) For LAER purposes, the following ULSD storage tanks are required to have conservation vent valves, and are subject to the 

following limits:

1. One (1) 2,000 gallon diesel storage tank (VOC emissions not to exceed 0.0007 tpy)

2. One (1) 500 gallon diesel storage tank (VOC emissions not to exceed 0.0002 tpy)
****** End of Report ******
Commonwealth Of Pennsylvania 

Department of Environmental Protection 

Reading District Office 

November 7, 2013 · 

Subject: 

To: 

Addendum Memo 

Berks Hollow Energy Associates, LLC 

Ontelaunee Township, Berks County 

Title V Plan Approval No. 06-05150A 

William Weavei· [W..I 11)1)1 3 

Regional Manager 

Air Quality Program 

Through: 

From: Ken Hartzler 'KJ{ 

Facility 

Air Quality Permitting 

Air Quality Program · 

Thomas Hanlon, Chief 

Air Quality Permitting 

Air Quality Program 

Berks Hollow Energy Associates, LLC (Berks Hollow) submitted a plan approval application for 

installation and startup of a combined-cycle natural gas fired electric generating station to be 

located in Ontelaunee Township, Berks County. 

Comment Period 

Intent to issue the plan approval was published in the Pennsylvania Bulletin on March 16, 2013. 

The newspaper notice was published in the Reading Eagle on March 18, 19, and 20 of 2013. On 

March 7, 2013 copies of the proposed plan approval were submitted to Mr. Bradley Cooley, 

Senior Environmental Engineer, Mr. William Borst, District Supervisor, and to Mr. Himanshu 

Vyas of EPA. 

Dilling the comment period the following provided comments: 

1) Berks Hollow Energy Associates, L.L.C. 

2) U.S. EPA Region III 

3) Clean Air Council 

4) Dynegy Generation, a Division of Dynegy Inc. 

5) Representative Jerry Knowles 

6) Approximately 125 email commenters, each providing the same general comments. 

Attached to this memo is a comment/response document which addresses all of the comments 

received, with the exception of the EPA comments which asked for expanded information in the 

technical review memo on the BACT/LAER analysis, SOz monitoring and PM2.5 monitoring. 

The expanded technical review memo items are as follows: 
Berks Hollow Energy, PA 06-05150A 2 November 7, 2013 

BACTILAER Analysis 

The Project is subject to the NSR program (PSD and NNSR). Pursuant to the PSD regulations, 

the Project is a major stationary source and must utilize BACT for each regulated NSR pollutant 

that it would have the potential to em~t in a significant amount. The Project is subject to NNSR, 

as Berks County is patt of the N otiheast Ozone Transport Region and also designated as 

nonattaiurnent for PM2.5. The Project is a major source ofNOx and VOC, but will be a minor 

source for PM2.5. A LAER analysis is required for ozone precursors (VOC and NOx). 

For all pollutants emitted at significant levels, a BACT detemtination must be perf01med using a 

"top-down" approach. This begins with the most stringent control altemative· (top), which must 

be utilized unless it is demonstrated that technical considerations, or energy, envirournental, or 

econontic impacts justify infeasibility. The process continues until an alternative cannot be 

elintinated based on the criteria above. The Department performed a review of the RBLC 

database and a subsequent review of plan approvals issued in the state to detetmine what control 

technologies have been required to be installed in the past for this type of source. The· 

Depatiment reviewed the BACT /LAER/BA T analysis provided by the facility and detetmined 

that all relevant control technologies were included in their analysis. The facility's analysis then 

removed cetiain technologies that were detemtined to be technically infeasible and then ranked 

the remaining control technologies in order of most effective. The Depatiment reviewed the 

information provided and agrees with the facility's detemtination as to which control 

technologies were technically infeasible. After reviewing the ranking to ensure the most· 

effective was at the top, the facility then proposed to use the most effective control thus no 

further analysis was required. Section 5 of the application contains their complete analysis 

including the various control technologies for each pollutant analyzed, justifications as to what is 

technically feasible and what is technically infeasible, and the ranking of the remaining 

technically feasible control technologies based on effectiveness. Because cost factors were not 

evaluated, tltis analysis can also be used for LAER. A summaty of the BACT/LAER analysis is 

listed below. 

For the combined cycle units (CCUs), the use of achieved in practice emission rates when 

detetmining LAER for NOx and VOCs was considered. For NOx, DEP reviewed continuous 

emission monitoring (CEM) data from existing combined cycle facilities to detetmine acltievable 

NOx rates when establishing LAER for Berks Hollow. 

VOC rates depend largely on fuel characteristics and combustion technology, which differ from 

site to site, so achieved in practice rates were determined not to be representative in setting 

LAER. 

BACT/LAER/BAT for Turbines (CCV): 

CCU BACT fOr Carbon Monoxide: 

The following table includes a list of potential control technologies. 

Control Technology Combustion or Post Control 

Good Combustion Practices (GCP) Combustion 
Berks Hollow Energy, PA 06-05150A 3 November 7, 2013 

Oxidation Catalyst Post Control 

SCONOX Post Control 

Based on the lack of availabili1y of SCONOX technology on projects of this size, this teclmology 

has been deternlined to be infeasible. The remaining two technically feasible control 

technologies (GCP and oxidation catalyst) are compatible and the facili1y has decided to use both 

as the control for this source. 

The BACT detennination is use of GCP and oxidation catalyst with an emission limitation of2.0 

ppmvd CO corrected to 15% 02 based on a 1-hour averaging period. These limits apply 

regardless of the operational status of the duct burners (firing or not firing). For periods of 

startup and shutdown, enlissions will be controlled by combustion controls and in accordance 

with the startup and shutdown defnlitions and enlission will be limited to those listed for startup 

and shutdown periods. 

CCU BACT and LAER tor VOC: 

The following table includes a list of potential control technologies. 

Control Technology Combustion or Post Control 

Good Combustion Practices (GCP) Combustion 

Oxidation Catalyst Post Control 

SCONOX Post Control 

Based on the lack of availabili1y of SCONOX technology on projects of this size, tllis technology 

has been deternlined to be infeasible. The remaining two technically. feasible control 

technologies (GCP and oxidation catalyst) are compatible and the facili1y has decided to use both 

as the control for this source. 

The BACT and LAER deternlination for VOC is use of GCP and oxidation catalyst with an 

enlission limitation of 1.5 ppmvd VOC conected to 15% 02. This linllt applies regardless of the 

operational status of the duct burners (firing or not firing). For periods of startup and shutdown, 

enlissions will be controlled by combustion controls and in accordance with the startup and 

shutdown definitions and enlission will be limited to those listed for startup and· shutdown 

periods. 

CCU BACT and LAER {Or NO,~ 

The following table includes a list of potential control technologies. 

Control Technology Combustion or Post Control 

Wet Injection Combustion 

DLN Combustor (dry low NOx) Combustion 

XONON Combustion 

Selective Catalytic Reduction (SCR) Post Control 

SCONOX Post Control 

Selective Non-Catalyst Reduction (SNCR) Post Control 
Berks Hollow Energy, PA 06-05150A 4 November 7, 2013 

SNCR has been dete1mined to be technically infeasible because of the required operating 

temperature of the SNCR is much higher than the operating temperature of the exhaust gas 

downstream of the HRSG which is approxinlately 150F to 290F. SCONOX has also been 

dete1mined to be technically infeasible because it has not been applied to a facility of this size, 

therefore it is not available. XONON has been determined to be technically infeasible because 

application on a large combined-cycle unit has not been demonstrated. Finally Wet Injection, 

while technically feasible is not being considered because the DLN Combustor would provide 

equivalent or higher level of control. The remaining two technically feasible control 

technologies (DLN Combustors and SCR) are compatible and the facility has decided to use both 

as the control for this source. 

The BACT and LAER dete1mination is DLN Combustors and SCR with an emission limitation 

of2.0 ppmvd NOx corrected to 15% 0 2 based on a 1-hour averaging period. This linlit was 

dete1mined to be LAER from the i-eview of CEM data at existing combined cycle facilities. 

These linlits apply regardless of the operational status of the duct bmners (firing or not firing). 

For periods of startup and shutdown, emissions will be controlled by combustion controls and in 

accordance with the stattup and shutdown definitions and emission will be limited to those listed 

for startup and shutdown periods. 

CCU BACT [or PMIPMJO: 

The following table includes a list of potential control technologies. 

Control Technology Combustion or Post Control 

Good Combustion Practices (GCP) Combustion 

Pipeline Quality Natural Gas Combustion 

Fabric Filter (baghouse) Post Control 

Electrostatic Precipitator (ESP) Post Control 

Wet Electrostatic Precipitator (WESP) Post Control 

Wet Scrubber Post Control 

The post combustion control technologies have been dete1mined to be technically infeasible. 

This is because of the high operating temperatures, high airflow volUllles, fine particulate 

distribution, and inherently low uncontrolled emission rates. Also, a review of the RBLC 

showed no combined cycle units equipped with add-on controls for PMIPMlO. 

The remaining two technically feasible control technologies (GCP and Pipeline Quality Natural 

Gas) are compatible and the facility has decided to use both as the control for this source. 

The BACT determination is GCP and Pipeline Quality Natural Gas with an emission linlitation 

of the following: · 

Normal Operation- Duct Bmners off 

GE 7FA: 10.0 #lhr 

Siemens F: 10.0 #Jill: 
Berks Hollow Energy, PA 06-05150A 

Normal Operation- Duct Burners on 

GE 7FA: 21.55 #!hr 

Siemens F: 21.55 #/hr 

5 November 7, 2013 

The duct burner on limit is different than the limit for LS Power's Hickory Run facility because 

the duct burners at the Berks Hollow facility are larger than those at Hickory Run (770 vs 500 

mmBtu!hr). For periods of startup and shutdown, emissions will be controlled by combustion 

controls and in accordance with the stmiup and shutdown defmitions and emission will be 

limited to those listed for startup and shutdown periods. 

CCU BAT for SOx and Sulfuric Acid Mist: 

The following table includes a list of potential control technologies. 

Control Technology Combustion or Post Control 

Fuel Treatment Combustion 

Pipeline Quality Natural Gas Combustion 

Flue Gas Desulfurization {FGD) Post Control 

Wet Scrubber Post Control 

Spray Dryer Absorber {Dry Scrubber) ·Post Control 

Fuel treatment has been determined to be technically infeasible because of the very low sulfur 

content of the pipeline natmal gas. FGD has been determined to be technically infeasible 

because its efficiency decreases with lower inlet SOx concentrations. Also, FGD has not been 

used on projects of this size, therefore it would not be considered available. The only remaining 

control technology is the pipeline quality natural gas. 

The BAT determination for both SOx and HzS04 is use of pipeline quality natural gas with an 

emission limitation of 0.68 grains sulfur per 100 scf natural gas based on fuel monitoring. This 

value is different than the limit set for LS Power's Hickory Run faCility because the natural gas 

supplier is different for the two facilities. 

CCU BACT (or GHG: 

The following table includes a list of potential control technologies. 

Control Technology 

Carbon Capture & Storage {CCS) 

Energy Efficiency utilization 

CCS has not been demonstrated on a facility of this size, therefore it has been determined that it 

is infeasible. Energy efficiency utilization will include: combine cycle technology (significantly 

higher levels of electric generation efficiency than traditional fossil fuel generating facilities); 

equipment maintenance; instrumentation & control systems; HRSG design consideration; and 

high efficiency auxiliary equipment. Energy efficiency is the only technical feasible option 

remaining. 
Berks Hollow Energy, PA 06-05150A 6 November 7, 2013 

The BACT determination is use of energy efficiency with an emission limitation of 1,000 lb 

C02/MW-hr (gross) on a 365-day rolling average which is based on proposed NSPS. Please see 

the attached comment and response document for a detailed discussion of the selection of this 

limit. 

BACT/LAERIBAT for Altxiliary Boiler: 

The auxiliary boiler will be used to shorten the cold and warm start duration of the combustion 

turbines. The auxiliary boiler will be used to provide high pressure steam when the combined 

cycle generating unit is offline in order accommodate more rapid startup following extended 

shutdown periods: The auxiliary boiler will primarily run during the period prior to initiation of 

startup of the combustion turbines and during startup. The boiler may be operated during periods 

when the CCUs are not in steady-state operation. The applicant searched EPA's RBLC 

database and consulted vendor literature. 

BACT/BAT for GHG is proposed as the use of good combustion practices and the use of 

pipeline quality natural gas. Natural gas has the lowest C02 emission rate of all fossil fuels. The 

applicant also proposes to limit operation of the boiler to 4,600 hours per year. This will be 

implicit in the atmual emission limits imposed on tllis source in the plan approval. The applicant 

states that the very low baseline emissions, coupled with the implicit operating hour limitation, 

and the results of the RBLC search, would indicate the technical infeasibility of any add-on 

controls for GHG. DEP concurs with this assessment. 

LAER/BACT/BAT (as applicable) for other pollutants from the auxiliary boiler, were proposed 

as follows. These proposals are identical to the limits proposed for identical equipment at the 

Hickory Run facility, and are acceptable to DEP: 

NOx: ultra lowNOx blll"ilers and emission limit ofO.Olllb/mmBtu or 1.01 tpy. 

S02 and H2S04: use of pipeline quality natural gas, and emission limits of0.0021lb/mmBtu or 

0.19 tpy, and 0.00048lb/mmBtu or 0.04 tpy respectively. 

CO and VOC: good combustion practices and emission limits of 0.036 lb/mmBtu or 3.31 tpy, 

and 0.0015lb/mmBtu or 0.14 tpy respectively. 

PM/PMlO: good combustion practices, use of pipeline quality natural gas, and an emission limit 

of 0.005 lb/mmBtu or 0.46 tpy. 

BACT/LAERIBAT for Emergency Generator and Fire Water Pump: 

BACT/BAT for GHG is proposed as the use of good combustion practices and the limiting of 

operating hours to 100 hours per year for non-emergency situations per NSPS Subpart IIII. 

LAER/BACT/BAT (as applicable) for other pollutants from the generator and fire water pump, 

were proposed as follows. The limits for the emergency generator are equivalent to the NSPS 

Subpart IIII and MACT Subpart ZZZZ standards for the affected sources. The limits for the fn·e 
Berks Hollow Energy, PA 06-05150A 7 November 7, 2013 

pump were revised based on information found in the RBLC for a similar sized fire pump 

recently pennitted for Arcadis, Inc.'s Oregon Clean Energy Center: 

NOx: good combustion practices and emission limits of I 0.6lb/hr or 0.53 tpy, and 1.70 lb/hr or 

0.09 tpy, respectively for the emergency generator and fn·e water pump. Berks Hollow assumed 

that 100% of the vendor's Subpart IIII certification ofNOx + NMOC were NOx emissions, and 

used AP-42 estimates for VOC emissions. These assumptions were acceptable to the 

Department based on the small tpy ofNOx and VOC from the sources. The company shall 

comply with all applicable provisions ofNSPS Subpmi IIII. 

S02 and H2S04: use ofULSD, and emission limits of0.011lb!hr or 0.00055 tpy, and 0.0030 

lb!ln· or 0.00015 tpy respectively for S02, and 0.0025 lb!hr or 0.00013 tpy and 0.00075lb!hr or 

0.000038 tpy respectively for H2S04. 

CO: good combustion practices and emission limit of 5. 79 lb!hr or 0.29 tpy and 1.70 lb!hr or 

0.09 tpy respectively. 

VOC: good combustion practices and emission limits of 0.63 lb!ln· or 0.03 tpy and 0.25 lb!hr or 

0.013 tpy, respectively for the emergency generator and fire water pump. Berks Hollow 

assumed that 100% of the vendor's Subpart IIII cetiification ofNOx + NMOC emissions were 

NOx emissions, and used AP-42 estimates for VOC emissions. These assumptions were 

acceptable to the Department based on the small tpy ofNOx and VOC from the sources. The · 

company shall comply with all applicable provisions ofNSPS Subpart IIII. 

PMIPM1 0: good combustion practices, proper maintenance and emission limits of 0. 33 lb!hr or 

0.017 tpy, and 0.10 lb/hr or 0.005 tpy, respectively for the emergency generator and fue water 

pump. 

BACT/LAERIBAT for Cooling Tower: 

The application notes that the use of high efficiency drift eliminating media to de-entrain 

droplets from the air flow exiting the cooling tower is a commercially proven technique to 

reduce PMIPM1 0 emissions. The applicant proposes to use high efficiency drift eliminators, 

with drift rate limit of0.0005 percent. This is consistent with the most stringent detenninations 

for mechanical draft cooling towers found in EPA's RBLC database. 

The total dissolved solids (TDS) content of the cooling water was conservatively estimated at 

5, 000 ppm. PM1 0 and PM2.5 fi'actions of the total PM were calculated based on a paper by 

Reisman and Frisbie, "Calculating Realistic PM10 Emissions from Cooling Tower", and 

detennined to be 64.4% and 24.0% of Total PM respectively. PM emission rates (lb!hr) were 

dete1mined by multiplying the water circulation rate (81,167,886lb!hr) x Drift x TDS/1,000,000. 

BACT/LAERIBAT for Fuel Heater: 

BACT/BAT for GHG from the fuel heater is proposed as the use of good combustion practices 

and the use of pipeline quality natural gas. Natural gas has the lowest C02 emission rate of all 

fossil fuels. The applicant states that the very low baseline emissions, coupled with the results of 
Berks Hollow Energy, PA 06-05150A 8 November 7, 2013 

the RBLC search, would indicate the technical infeasibility of any add-on controls for GHG. 

DEP concurs with this assessment. 

LAER!BACT/BAT (as applicable) for other pollutants from the fuel heater, were proposed as 

follows. These proposals are acceptable to DEP: 

NOx: good combustion practices and emission limit of 0.03 5 lb/mrnBtu. The emission limit is 

based on vendor data. 

S02 and H2S04: use of pipeline quality natural gas, and emission limits of0.002llb/mmBtu 

and 0.00048 lb/mmBtu respectively, based on 0.68 gr/1 00 dscf maximum sulfur in natural gas 

verified by purchase contract. 

CO and VOC: good combustion practices and emission limits of 0.05 lb/mmBtu and 0.005 

lb/mmBtu respectively, based on vendor data and AP-42 emission factors. 

PM/PM! 0: good combustion practices, use of pipeline quality natural gas, and an emission limit 

of 0.007 lb/mmBtu, based on AP-42 emission factors. 

BACT!LAER/BAT for Fuel Storage Tanks: 

The only applicable pollutant for the fuel storage tanks is VOC. Based on the low emissions and 

high cost of controls for these sources, the applicant proposes the following as LAER: 

conservation vent valves and emission limits of0.0007 tons/yr and 0.0002 tons/yr respectively 

for the 2K-gallon ULSD tank and 500-gallon ULSD tanks. These limits have been placed in 

Section H of the draft plan approval. 

Verification of S02 limits: 

Berks Hollow has taken volnntary emission limits for S02 to remain under 40 tpy. The limits on 

individual units are: 

CCUl 

CCU2 

Fuel Preheater 

Auxiliary Boiler 

Emergency Generator 

FirePnmp 

Total 

GE 7FA Option (tpy) 

19.11 

19.11 

0.19 

0.19 

0.00055 

0.00016 

38.60 

Siemens F Option (tpy) 

19.70 

19.70 

0.19 

0.19 

0.00055 

0.00016 

39.78 

Compliance with the S02i'SOx limits established in the Plan Approval will be demonstrated 

through monitoring of the fuel sulfur content and the amonnt of fuel burned. The emission limits 

are based on a fuel sulfur content of0.68 gr/100 dscffor natural gas and 15 ppm for fuel oil. The 

fuel sulfur content of the natural gas will be determined based on a custom fuel monitoring plan 
Berks Hollow Energy, PA 06-05150A 9 November 7, 2013 

as described in Section E, Group Name KKKK, Condition #015 of the Plan Approval. Fuel 

sulfur content data for natural gas and fuel oil will be provided by all fuel suppliers periodically. 

As required by the Plan Approval, daily records of fuel consumption will be maintained to 

ensure that 12-month rolling total emission limits for S02/SOx are not exceeded. Fuel 

consumption records for the CCUs, fuel heater, and auxiliary boiler will be recorded on a nearly 

continuous basis using a calibrated meter and data acquisition system. 

Verification of PM2.5 limits: 

Berks Hollow has taken voluntary emission limits for PM2.5 to remain under 100 tpy. 

The Plan Approval includes PM2.5 limits on a 12-month rolling total for each emissions source, 

which total to less than 100 tpy for all emission sources combined. Section VII of Group Name 

PM2.5 in Section E of the Plan Approval sets fmihreshictions on facility-wide PM2.5 emissions 

and requirements for demonstrating compliance with the PM2.5 limit for each emissions source. 

Section C of the Plan Approval includes requirements of25 Pa. Code Ch. 135 regarding 

submission of an annual emission statement, which would include calculations ofPM2.5 

emissions from each source and facility-wide. 

For purposes of compliance demonstration, PM2.5 emissions from the combustion turbines will 

be determined from stack testing during normal operations and worst -case emission factors based 

on OEM data for startup and shutdown periods. Maximum potential annual emissions ofPM2.5 

from startup and shutdown operations are approximately 2% of the facility-wide PM2.5 

emissions. Since PM2.5 emissions are a result of fuel combustion and no post-combustion 

controls are necessary, PM2.5 emissions are expected to be consistent and proportional to the 

amount of fuel bumed. 

Compliance with the PM2.5 limits for the remaining sources will be demonstrated in part by 

vendor guarantees and records of fuel consumption of the auxiliary boiler, fuel heater and 

emergency engines; and emission factors and monitoring ofTDS for the cooling tower. 

GHG Analysis 

The original draft Plan Approval included an annual limit on C02e emissions for each emissions 

source except for the Fuel Heater. The Plan Approval now includes a limit of2, 779,224 tons per 

year. The annual C02e limits account for emissions of all GHG emissions including C02, 

methane (CH4), nitrous oxide (N20) and sulfur hexafluoride (SF6). For all fuel burning sources, 

the emissions estimates provided in Table A-13 of Appendix A of the Application are based on 

heat input and EPA -approved emission factors and global warming potentials listed in 40 CFR 

98. Equation G-4 from Appendix G of 40 CFR 75 was used to calculate C02 emissions for the 

CCUs, auxiliary boiler and fuel heater. The C02e limits established in the Plan Approval ensure 

compliance with all individual GHG emissions since heat input is used as a basis for calculation 

of emissions for individual GHGs. 

The GHG BACT limit for the CCUs is 1,000 lbs C02 per MWh on a 12-operating month annual 

average basis. The compliance demonstration with this standard includes emissions from all 

operating modes including stariup and shutdown. 
Berks Hollow Energy, PA 06-05150A 10 November 7, 2013 

. A facility ·wide C02e limit of2,779,224 tons per year has been included in Section E, Group 

GHG. 

Changes made to the original draft plan approval include the following: 

1.) add 121.7 reference in Condition C.017 

2.) add reference to ERC provisions of 127.208 in Condition C.018 

3.) add C02e facility limit in Section E Group GHG Condition #001 

4.) add vendor guarantee requirement for cooling tower drift eliminators in Section D, Source 

103, Condition #005 

5.) increase ammonia tpy limits from 77.45 and 80.47 tpyfrom the GE 7FA and Siemens F units, 

respectively, to 104.46 tpy for the GE 7FA and 107.92 tpy for the Siemens Fin Section E Group 

CCU Condition #00 1 

6.) change the CO, NOx and ammonia short te1m emission limits from 3-hour rolling averages to 

1-hour block averages in Section E, Group CCU, Condition#001 

7 .) impose short-term NOx stmtup limits in Section E, Group Startup & Shutdown, Condition 

#001 

8.) add differentiation of shutdown definition between GE and Siemens turbine options in 

Section E, Group Stmtup & Shutdown, Condition #002 

9.) reduce stack testing frequency for "duct burners on" option in Section E, Group PM2.5, 

Condition #001 

1 0.) add summary table of emissions standards in Section Gas requested by EPA 

Conclusions and Recommendations 

I recommend Title V Plan approval No. 06-05150A be redistributed back to EPA for their 

concunence with the revisions that have been made. 

CC: Pennits 

Reading District 

SC Region 06-05150A, B5 
Berks Hollow Energy Associates, L.L.C. 

April 5, 2013 

Mr. Ken Hmtzler 

Air Quality Permitting 

Depmiment of Environmental Protection (DEP) 

Reading District Offi<;e 

I 005 Crossroads Boulevard 

Reading, P A 19605 

Re: Comments to Draft Plan Approval No. 06~05150A 

Berks Hollow Energy Associates, LLC (BHEA) 

Dear Mr. Hatizler: 

ATTACHMfNT A 

c/o LS Power Development, LLC 

400 Chesterfield Center. Suite 110 

St. Louis, Missoun 63017 

(636) 532-2200 · Fax (636) 532-2250 

BHEA has received the letter dated March II, 2013 which transmitted the draft Plan 

Approval No. 06-05150A. BHEA would like to offer the enclosed comments to cetiain 

conditions in the Plan Approval. 

Please feel free to contact me (636-534-3268) if you have any questions. 

Sincerely, 

Bradley J. Cooley 

Senior Environmental Engineer 

Enclosures 

CC: Thomas Hanlon, P .E., PADEP 

Fred Osman, Osman Environmental 
ENCLOSURE 

BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) COMMENTS 

TO DRAFT PLAN APPROVAL No. 06-05150A 

On March 11, 2012, the Pennsylvania Department of Environmental Protection (DEP) issued to BHEA the 

draft Plan Approval No. 06-05150A requesting comments within 30 days. BHEA respectfully submits its 

comments, which are presented below. 

Section C, Site Level Plan Approval Requirements 

Condition #006 

' BHEA Comment: The condition limits emissions of HAPs to less than 4.8 tpy for a single HAP 

(formaldehyde) and 11.3 tpy of total HAP. Because the Berks Hollow Energy Station (BHES) project 

(the Project) is an area source of HAPs (ie, less than 10 tpy of a single HAP and 25 tpy of total HAP) 

the proposed limit Is unnecessarily restrictive. BHEA requests that/he limits be changed Ia 10 lpy of 

a single HAP and 25tpy of total HAP to be consistent with the d~finilion of an area source. 

Section E, Source Group Plan Appmval Restrictions, Group Name: CCU 

Condition #001 

BHEA Comment: The condition, in part, limits emissions of ammonia (NH3) to 5 ppmvd@ 15% 0 2, 

and less than 77.45 and 80.47 tpy ji'Oln the GE 7FA and Siemens F units, respectively. DEP based 

the annual limit on the maximum hourly emission rates for the fired (ie, duel burners on) and 1111fired 

(ie, duel burners off) cases, which are presell/ed in Table A-13 and A-14 of Appendfr: A of the 

Application, and the hours of operation for each case presented in Table A-2. 

The hours of operation in Table A-2 were used specifically for calculating worst case emissions for 

pollutants which are products of combustion including emissions during startup and shutdown. 

Because NH3 is not emitted during startup and shutdown operations, the approach for calculating 

worst case annual emissions is different than that presented in Table A-2. Specifically, since the 

hoursfor startup (maximum of 500 hours) and shutdown (maximum of 60 hours) are upper bounds, 

the combined cycle units will run for more than the 8200 hours (7365 hours normal operation, 835 

hours with duct burners fired) presented in Table A-2, the absolute worst case annual emissions 

should be calculated by assuming the highest hourly emission for the maximum possible annual 

operating hours (8760 hours). Based on this approach the annual emission limit for NH3 should be 

calculated as follows: 

Annual PTE (tpy) = Worst Case Emission rate (lblhr) x Maximum Annual Operating Hours (hr) 

x 1 ton/2000 lbs 

ForGE 7FA (see Table A-13, Case 1 for worst case NH3 emission rate) 

Annual PTE (tpy) = 23.851b/hr x 8760 hr x 1 ton/2000 lbs 

= 104.46 tons per year (tpy) 

For Siemens F (see Table A-14, Case 10 for worst case NH3 emission rate) 

Annual PTE (tpy) = 24.641blhr x 8760 hr x 1 ton/2000 lbs 

= 107.92 tpy 

Berks Hollow Energy Associates, LLC 1 4/5/2013 
ENCLOSURE 

BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) COMMENTS 

TO DRAFT PLAN APPROVAL No. 06-0SlSOA 

BHEA requests that DEP delete the condition limiting NHJ annual emissions since a 5 ppm limit is 

included as part of Condition #001. If DEP insists on including an annual limit, BHEA requests that 

the NHJ limits be set as 104.46 tpy for the GE 7FA and 107.92 tpy for the Siemens F. 

Section E, Source Group Plan Approval Restrictions, Group Name: PM2.5 

Condition #001 

BHEA Comment: The condition requires annual stack testing for PM2.5 (EPA Methods 202 and 5) 

both with duct bumers off and on. Duct bumers will be operated typically during periods of peak 

power demand only, making it difficult to predict when duct bumers will be operated. Operating duct 

bumers expressly for the purpose of stack testing may result in significant costs to BHEA, 

particularly during periods of low power prices. Because of this uncertainty, BHEA requests that the 

condition be changed to require stack testing no more than once per five (5) year period. 

Section E, Source Group Plan Approval Restrictions, Group Name: STARTUP & SHUTDOWN 

Condition #002 

BHEA Comment: The condition defines shutdown as "the period beginning with lowering of unit load 

below 60% with the intent of ceasing operation ... " The GE 7FA combustion turbines are capable of 

fuming down to 50% load during normal operation. As such, BHEA requests the condition be changed to 

read "the period beginning with lowering of unit load below 50% with the intent of ceasing operation ... " 

Berks Hollow Energy Associates, LLC 2 4/5/2013 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION Ill 

Mr. Thomas Hanlon 

Chief, Air Quality Permitting 

Air Quality Program 

1650 Arch Street 

Philadelphia, Pennsylvania 19103·2029 

Pennsylvania Department of Environmental Protection 

Reading District Office 

1005 Crossroads Boulevard 

Reading, PA 19605 

APR 0 9 2013 

RE: Proposed Plan Approval for Berks Hollow Energy Associates, LLC 

Ontelaunee Township, Berks County 

Plan Approval No. 06-05150A 

Dear Mr. Hanlon: 

Thank you for the opporttmity tci review the Pennsylvania Depattment of Environmental 

Protection's proposed plan approval for Berks Hollow Energy Associates, LLC, a combined-cycle 

natural gas fired electric generating station, in Berks County, Pennsylvania. Based on our evaluation of 

the proposed plan approval and Technical Review Memo, we have identified several comments that are 

included ih the attachment. We provide these conunents to help ensure that the project meets all federal 

requirements, that the permit provides all necessary information so that it is readily accessible to the 

public, and that the record provides adequate support for the permit decision. We look fotward to 

working with you in addressing all the issues raised. 

If you have questions, please do not hesitate to contact me at 215-814-2173 or Mr. Himanshu 

Vyas of my staff at 215-814-2112. 

ec: Ken Hartzler, P ADEP 

Enclosure 

Sil.,rcly y~, ,., 

~fu&(j j(/,?.,y~"'~ j}P-z_. 

Kathleen Cox 

Associate Director, 

Office of Permits and Air Taxies (3AP10) 

0 Printed on100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free. 

Customer Service Hotll11e: 1-800-438-2474 
Comments on Plan Approval 

1. Emission Offsets: The proposed facility is subject to the Nonattainment New Source Review 

(NNSR) requirements because the facility is located in an ozone transport region and has the 

potential to emit greater than 100 tons ofNOx and 50 tons ofVOCs in any consecutive 12 

month period. Therefore, a purchase of Emission Reduction Credits (ERCs) to offset the 

NOx and VOC emissions increases is required. According to Pa. Code 127.208, an owner or 

operator of a facility shall acquire ERCs for use as offsets from an ERC generating facility 

located within the same nonattainment area. As NOx is considered a precursor to PM2.5, the 

NOx ERCs must be obtained from within the PM2.5 nonattainment area that includes Berks 

County, Pennsylvania. 

2. BACTILAER analyses: EPA does not believe that the Technical Review Memo (TRM) and 

proposed plan approval sufficiently describe the Best Available Control Technology 

(BACT)!Lowest Achievable Emissions Rate (LAER) analyses that were performed. In a 

BACT analysis, the reviewing authority should evaluate the energy, environmental, 

economic and other costs associated with each alternative technology, and the benefit of 

reduced emissions that the technology would bring. The reviewing authority then specifics 

emissions limitations for the source that reflects the maximum degree of reduction achievable 

for each pollutant regulated under the Clean Air Act. The plan approval conditions must 

reflect all operational limitations in order to show compliance with these emissions 

limitations. The TRM should provide the top-down BACT/LAER options and an analysis for 

why the chosen emission controls meet the BACT/LAER standard. 

3. NOx controls: The record indicates that the use of dry low-NOx (DLN) combustors and 

Selective Catalytic Reduction (SCR) would fulfill LAER for NOx and BACT for N02. The 

analysis also indicates that the use of oxidation catalysts would constitute LAER for VOC 

emissions and BACT for CO emissions. However, the plan approval does not appear to 

require the operation of these controls at all times when the combustion turbines and duct 

burners are operating. Since these control devices are necessary to meet the required 

emission limits, the plan approval should require the operation of the controls at all times. 

4. Greenhouse Gas (GHG) pollutants: EPA has the following concerns: 

a. The TRM and proposed plan approval do not sufficiently address all GHG pollutants. 

GHG emission limits should account for not only COz, but for all of the GHGs that 

are emitted (methane, nitrous oxide, SF6). Please also clarify how compliance will be 

demonstrated for each of the GHGs. The plan approval, as cunently written, does not 

include sufficient requirements or means of calculation to ensure compliance with the 

COze limits. 

b. It is unclear whether the C02 emission limit applies for the turbhies during times of 

stattup and shutdown. Please confirm that the limit applies during all periods of 

operation or indicate an altemate limit for stmt up and shutdown. 

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c. The proposed plan approval references the Tailoring Rule ( 40 CFR Patts 51 and 52) 

for calculating GHG emissions. This is incorrect. The reference should be to the 40 

CFR Part 98 tables on global warming potential. 

5. The BACTILAER analysis for the Cooling Tower: The BACT!LAER analysis for 

particulate matter emissions from the Cooling Tower indicates that the emission rates were 

determined using both the drift rate limit and the total dissolved solids. Therefore, the plan 

approval should contain requirements to control and monitor the drift rate and the total 

dissolved solids content of the cooling water. These requirements are necessary to ensure 

compliance with the emissions limits. 

6. The BACT/LAER analysis for the Auxiliarv Boiler: The BACT!LAER for Auxiliary Boiler 

relies on 4,600 hours/year of operation limit and the use of only pipeline quality natural gas 

as a fuel. However, only the "expected operating hours" is listed in the plan approval, and 

that too in the Miscellaneous section and not in the Source Level Requirements section. 

These operational requirements should be reflected properly in the plan approval conditions 

to ensure compliance with the emissions limits. Additionally, there is a discrepancy in the 

description of the expected operating hours of the Auxiliary Boiler in the TRM. The TRM 

notes on that "Once the gas turbines are at steady-state the auxiliary boiler will be taken off 

line." Since the TRM and the plan approval define stmt-up and shut-down operations for the 

CCU and limit those to 500 hours and 60 hours per year each, it would make sense that the 

Auxiliary Boiler would only operate for 560 hours per year. Please explain the additional 

expected homs of operation for the Auxiliary Boiler. 

7. S02 emission limit and monitoring: EPA has the following concerns: 

a. The TRM notes that Berks Hollow is taking voluntary emission limit for S02 of less 

than 40 tpy. However, the TRM does not provide exactly what the permit limit is, 

and how it will be monitored to ensure the facility does not exceed this federally 

enforceable limit. For clarity, please provide this information in the TRM. 

b. The plan approval provides annual SOx emission limits on a rolling 12-month basis 

for the two turbine options that, when including normal operations and startup and 

shutdown times, add up to 39.44 tpy. This limit is just below the SER threshold for 

S02. If S02 is not precisely measured during all operating times, including stmtup 

and shutdown, this limit is highly suspect. 

c. The plan approval application uses variable grains of sulfur in the term "pipeline 

quality natural gas" that vary fi·om as high as 20 grains S per I 00 scfto 0.68 grains S 

per l 00 scf. Please specifY the quality of natural gas to be used at Berks Hollow and 

the emissions of S02 expected from burning that quality of natural gas. 

8. PM2.5 emission limit and monitoring: EPA has the following concerns: 

a: The TRM notes that Berks Hollow is taking voluntaty emission limit for PM2.5 of 

less than 100 typ. However, the TRM does not provide exactly what this limit is, and 

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how it will be monitoring to ensure the facility does not exceed this federally 

enforceable limit. For clarity, please provide this inf01mation in the TRM. 

b. The plan approval provides annual PM2.5 emission limits on a rolling 12-month basis 

for the two turbine options as well as other units, when including normal operations 

and startup and shutdown times, add up to more than 99.25 tpy. This limit is just 

below the major source threshold for PM2.5. IfPM2.5 is not precisely measured 

during all operating times, including startup and shutdown, this limit is highly 

suspect. 

9. Missing Section from the proposed plan approval: The proposed plan approval is missing 

Section G for listing "Emission Restriction Summary" for all pollutants from all emission 

units. Please provide this section in the plan approval for ease of compliance assurance. A 

similar facility recently permitted by PADEP, Hickory Run Energy, LLC, has a plan 

approval drafted by Northwest Regional Office that contains such a section. The proposed 

plan approval is also missing Section F, titled "Altemative Operating Scenario(s)" in the 

table of contents. · 

10. Missing SIP requirement: Pennsylvania's State Implementation Plan (SIP) at 40 CPR 

52.2020 includes the general standard against air pollution codified at 25 Pa. Code §121.7. 

This general standard states that "No person may permit air pollution as that term is defined 

in the act." Pa. Code 127.502(a) require.s that applicable requirements for stationary air 

contamination sources shall be included in the operating permit. The definition of 

"applicable requirements" atPa. Code §121.1 includes any standard provided for in the 

Commonwealth's SIP. In Pennsylvania's merged permitting program, applicable 

requirements of a plan approval are administratively brought into the title V permit; however, 

since this is a new facility, it has no current title V permit. We note that the plan approval 

should include the general standard in order to facilitate that requirement being included in 

the title V permit, when issued to Berks Hollow, will have the general standard in it . 

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Comments on Modeling Report 

Section 2.1.1 Combined Cycle Units: 

A7TACHf.l ft!T C 

~PA ff\oOC~ING 

(e>N/IfN 1 S 

NOx controls on the combined cycle combustion turbine generators imposed under PM-2.5 

and/or ozone should be operated year round to ensure compliance with the N02 NAAQS. 

Section 2.3 Applicable Pollutants: 

PADEP should consider Berks Hollow's potential impact on cunent PM-2.5 concentrations in 

Berks County. While its PM-2.5 contributions may be minimal, Berks Hollow may impact the 

county's attainment status under the 1997 NAAQS and EPA's revised PM-2.5 NAAQS. 

Section 3.6 Receptor Data Description: 

Model peaks in the base load tuns for the GE and Siemens combustion turbines occurred outside 

the fine Cartesian model receptor grid that extended approximately 1 km from the Berks Hollow 

facility. It appears that the model receptor grid was revised in the N02 NAAQS and Increment 

Runs to examine the area near the highest modeled concentration. It would be helpful if P ADEP 

could address how the model receptor grids capture the maximum modeled concentrations in 

accordance with section 7.2.2 (a) of Appendix W. 

Section 4.1 Significant Impact Analysis: 

Do the load scenarios described in this section include duct firing (described in Section3.5)? 

For example, can the combustion turbines be fired at 100% with m· without duct firing and would 

the stack parameters and emission rates change between these two potential operating modes? . 

Stack parameters for the GE and Siemens combustion turbines are quite similar. Did PADEP 

confirm the similarity in emissions profiles for Berks Hollow's GE and Siemens combustion 

. turbines for all pollutants? 

Section 4.1.3 NO, Significance: 

How long do start up/shut down cycles typically last and how long does it take for the NOx 

control equipment to become fully functional? 

Berks Hollow could have used PVMRM or a Tier 2 ambient ratio in its significance analysis to 

reduce the radius of influence used to identify off-site sources for its cumulative analysis. The 

off-site inventory could also have been reduced (in number) co!)sidering the closeness of the 

background monitoring site to Berks Hollow. Many of the smaller sources are probably 

adequately accounted for in the N02 background concentration. See section 8.2.3 of Appendix 

W for additional guidance on this topic. 

Section 4.3.1 1-hr NO• NAAQS: 

The repott discussed the modeled 1-hr N02 NAAQs violations noted in the Berks Hollow 

modeling analysis. EPA Region 3 would like P A DEP to address these violations in more detail. 

The modeling analysis adequately demonstrates that Berks Hollow is not causing or significantly 

contributing to any modeled violations. 

EPA Region 3 conducted some additional analysis using Berks Hollow's NAAQS and Increment 

N02 runs. It appears that two sources are contributing to the modeled N02 violations. These 

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sources are the Titus Station Generating Station in Cumtu Township and Lehigh Cement on 

Evansville Road. 

Titus Station: This facility is slated to close in the next couple of years. This should 

eliminate any modeled violations attributable to this source once closure is confirmed and 

finalized. 

Lehigh Cement: The modeled emission rate used by Berks Hollow was roughly 

2,622.85 tpy (75.4 g/s). Actual NOx emission rates from 2009-11 taken from PA DEP's 

eFACTS system ranged from 1,146 tpy in 2010 to 1,610 tpy in 2009. NOx emissions 

prior to 2009 exceeded 2,000 tpy. Running Lehigh Cement using 2009 actual (annual) 

emissions reduces modeled concentrations from 224 J.tglm3

, which exceeds the standard 

of 188 J.tg/m3

, to 172 J.tg/m3 (without background). Reducing Lehigh Cement's allowable 

emission rate to reflect actual emissions over the last thr~e (3) years may eliminate the 

modeled violations. PA DEP should investigate this possibility. 

Section 6.1 Air Quality Related Values (AQRVS): 

Berks Hollow should include the Q/d values for each of the Class I areas in a table or appendix. 

Section 6.2 PSD Increment: 

PADEP should provide more explanation why Berks Hollow was exempted from the Class I 

increment analysis. 

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Berks Hollow Energy Associates, L.L.C. 

May 28,2013 

Mr. Tom Hanlon 

Chief, Air Quality Permitting 

Air Quality Program 

Department of Environmental Protection (DEP) 

Reading District Office 

1005 Crossroads Boulevard 

Reading, PA 19605 

Re: Response to EPA Comments 

Berks Hollow Energy Associates, LLC (BHEA) 

Draft Plan Approval No. 06-0SlSOA 

Dear Mr. Hanlon: 

c/o LS Power Development, LLC 

400 Chesterfield Center, Suite 110 

St. Louis, Missouri 63017 

(636) 532-2200 ·Fax (636) 532-2250 

BHEA has reviewed the letter from EPA dated April 9, 2013 regarding comments to the 

draft Plan Approval No. 06-5150A. BHEA respectfully offers the enclosed responses for 

consideration by DEP. 

Please feel free to contact me (636-534-3268) if you have any questions. 

Sincerely, 

Bradley J. Cooley 

Senior Environmental Engineer 

Enclosures 
ENCLOSURE 

RESPONSES TO EPA COMMENT LEDER DATED April 9, 2013 REGARDING 

BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06·05150A 

In a letter dated April9, 2013, EPA submitted to DEP comments to the draft Plan Approval No. 06-0SlSOA issued 

for the proposed Berks Hollow project. BHEA has reviewed the comments and is providing responses to select 

comments for consideration by DEP in development its formal Response-To-Comments. 

The original text of the select EPA comments is presented below in bold font with the BHEA response provided 

immediately below. 

SHES Response to EPA Comments: 

3. NOx controls: The record indicates that the use of dry low-NOx (DLN) combustors 

and Selective Catalytic Reduction (SCR) would fulfill LAER for NOx and BACT for 

N02. The analysis also indicates that the use of oxidation catalysts. would constitute 

LAER for VOC emissions and BACT for CO emissions. Howevet·, the plan approval 

does not appear to require the operation of these controls at all times when the 

combustion turbines and duct burners are operating. Since these control devices are 

necessary to meet the required emission limits, the plan approval should require the 

operation of the controls at all times. 

BHEA Response: BHEA will operate the SCR and oxidation catalyst units ("post-combustion control devices") at 

all times during normal operation including periods when the duct burners are fired. Post-combustion control 

devices cannot be operated during periods of startup or shutdown since temperatures of the exhaust gases will be 

below the necessary range for proper operation of the control devices. The Plan Approval includes Condition 

#005(c) under Section E, Group Name CCU, which requires operation of the air pollution control devices at all 

times during normal operation and reads as follows: 

"The permittee shall operate the control device(s) at all times this source is in operation once operating 

parameters (temperature, flow, etc.) are sufficient for proper control device operation." 

BHEA believes this condition satisfactorily addresses EPA's comment and does not believe an additional condition 

is necessary. 

4. Greenhouse Gas (GHG) nollutants: EPA has the following concems: 

a. The TRM and proposed plan approval do not sufficiently address all GHG 

pollutants. GHG emission limits should account for not only C02, but for all of the 

GHGs that are emitted (methane, nitrous oxide, SF6). Please also clarify how 

compliance will be !jemonstrated for each of the GHGs. The plan approval, as 

currently written, does not include sufficient requirements or means of calculation to 

ensure compliance with the C02e limits. 

BHEA Response: The Plan Approval includes an annual limit on C02e emissions for each emissions source except 

for the Fuel Heater. BHEA proposes that the Plan Approval include a limit of 4,996.3 tons C02e on a 12-month 

rolling basis for the Fuel Heater (Source JD 030). The armual C02e limits account for emissions of all GHG 

emissions including C02, methane (CH4), nitrous oxide (N20) and sulfur hexafluoride (SF6). For all fuel burning 

sources, the emissions estimates provided in Table A-13 of Appendix A of the Application are based on heat input 

and EPA-approved emission factors and global warming potentials listed in 40 CFR 98. Equation G-4 from 

Appendix G of 40 CFR 75 was used to calculate C02 emissions for the CCUs, auxiliary boiler and fuel heater. 

Page 1 of 5 
ENCLOSURE 

RESPONSES TO EPA COMMENT LEDER DATED April9, 2013 REGARDING 

BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA 

The C02e limits established in the Plan Approval ensure compliance with all individual GHG emissions since heat 

input is used as a basis for calculation of emissions for individual GHGs. BHEA suggests that DEP include in 

Section E under Group Name GHG of the Plan Approval a condition for each source specifying that compliance 

must be demonstrated based on the heat input of the source and emission factors and equations as described in the 

Table A-13 of Appendix A of the Application. 

b. It is unclear whether the C02 emission limit applies for the turbines during 

times of startup and shutdown. Please confirm that the limit applies during all 

periods of operation or indicate an alternate limit for start np and shutdown. 

BHEA ResQonse: The GHG BACT limit for the CCUs is 1,000 lbs C02 per MWh on a 12-operating month annual 

average basis. The compliance demonstration with this standard includes emissions from all operating modes 

including startup and shutdown. 

5. The BACT/LAER analysis for the Cooling Tower: The BACT!LAER analysis for 

particulate matter emissions from the Cooling Tower indicates that the emission rates 

were determined using both the drift rate limit and the total dissolved solids. Therefore, 

the plan approval should contain requirements to control and monitor the drift rate and 

the total dissolved solids content of the cooling water. These requirements are necessary to 

ensure compliance with the emissions limits. 

BHEA Response: The Plan Approval requires monitoring of the total dissolved solids content of the cooling tower 

water. Although the Plan Approval does not specify conditions related to the drift rate or use of drift eliminators, 

Source 103 (Cooling Water Tqwer) is defined in Section H of the Plan Approval as follows: 

"A multi-cell mechanical draft cooling tower with a water circulation rate of 162,206 gpm; with a TDS 

concentration of 5,000 ppmv; and with an associated drift of0.0005%." 

Since drift rate cannot be monitored, BHEA proposes that DEP add a condition to the Plan Approval requiring 

installation of drift eliminators with a vendor guarantee of 0.0005% or less drift. 

6. The BACT/LAER analvsis for the Auxiliarv Boiler: The BACT/LAER for Auxiliary Boiler 

relies on 4,600 hours/year of operation limit and the use of only pipeline quality natural gas 

as a fuel. However, only the "expected operating hours" is listed in the plan approval, and 

that too in the Miscellaneous section and not in the Source Level Requirements section. 

These operational requirements should be reflected properly in the plan approval conditions 

to ensure compliance with the emissions limits. Additionally, there is a discrepancy in the 

description of the expected operating hours of the Auxiliary Boiler in the TRM. The TRM 

notes on that "Once the gas turbines are at steady-state the auxiliary boiler will be tal<en off 

line." Since the TRM and the plan approval define start-up and shut-down operations for 

the CCU and limit those to 500 hours and 60 hours per year each, it would make sense that 

the Auxiliary Boiler would only operate for 560 hours per year. Please explain the 

additional expected hours of operation for the Auxiliary Boiler. 

BHEA Response: BHEA believes EPA may have misunderstood the description in the TRM. The TRM neither 

Page 2 of 5 
ENCLOSURE 

RESPONSES TO EPA COMMENT LETTER DATED April9, 2013 REGARDING 

BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA 

states nor implies that operation of the auxiliruy boiler will be limited to startup and shutdown periods only. The 

auxiliary boiler will be used to provide high pressure steam when the combined cycle generating unit is offline in 

order accommodate more rapid startup following extended shutdown periods. Hence, the auxiliruy boiler will 

primarily run during the period prior to initiation of strutup of the combustion turbines and during startup, and thus 

the number of hours of operation will necessarily be greater than that of startup operations (or 500 hours). A 

separate annual limit for hours of operation is not necessary since 12-month rolling total limits have been established 

for each pollutant. lfDEP determines that a condition limiting hours of operation of the auxiliary boiler is 

necessary, BHEA is willing to accept an operating limit of 4,600 hours. 

7. S02 emission limit and monitoring: EPA has the following concerns: 

a. The TRM notes that Berks Hollow is taking voluntary emission limit for S02 of less 

than 40 tpy. However, the TRM does not provide exactly what the permit limit is, 

and how it will be monitored to ensure the facility does not exceed this federally 

enforceable limit. For clarity, please provide this information in the TRM. 

BHEA Response: S02 limits are established in the Plan Approval for each emissions source, and the sum of those 

limitations is less than 40 tpy for all sources combined. If further clarification is needed, a Source Group could be 

added in Section E of the Plan Approval to reflect the facility-wide S02 limit of 40 tpy and the method for 

demonstrating compliance with S02 emission limits for each emissions source which would be based on the fuel 

sulfur content and the runount of fuel burned. 

b. The plan approval provides annual SOx emission limits on a rolling 12-month basis 

for the two turbine options that, when including normal operations and startup and 

shutdown times, add up to 39.44 tpy. This limit is just below the SER threshold for 

S02. If S02 is not precisely measured during all operating times, including 

startup and shutdown, this limit is highly suspect. 

BHEA Response: Compliance with the S02/SOx limits established in the Plan Approval will be demonstrated 

through monitoring of the fuel sulfur content and the runount of fuel burned. The emission limits are based on a fuel 

sulfur content of0.68 gr/1 00 dscffor natural gas and 15 ppm for fuel oil. The fuel sulfur content of the natural gas 

will be determined based on a custom fuel monitoring plan as described in Section E, Group Nrune KKKK, 

Condition# 015 of the Plan Approval. Fuel sulfur content data for natural gas and fuel oil will be provided by all 

fuel suppliers periodically. As required by the Plan Approval, daily records of fuel consumption will be maintained 

to ensure that 12-month rolling total emission limits for S02/S0x are not exceeded. In fact, fuel consumption 

records for the CCUs, fuel.heater, and auxiliary boiler will be recorded on a nearly continuous basis using a 

calibrated meter and data acquisition system. Based on this approach, BlffiA does not believe any additional 

monitoring requirements are necessary to ensure compliance with the S02/S0x emission limitations. 

c. The plan approval application uses variable grains of sulfur in the term "pipeline 

quality natural gas" that vary from as high as 20 grains S per 100 scfto 0.68 grains 

S per 100 scf. Please specify the quality of natural gas to be used at Berks Hollow 

and the emissions of S02 expected from burning that quality of natural gas. 

Page 3 ofS 
ENCLOSURE 

RESPONSES TO EPA COMMENT LEITER DATED April9, 2013 REGARDING 

BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA} PLAN APPROVAL NO. 06-0SlSOA 

BHEA Response: The fuel sulfur content of the natural gas supplied will not exceed 0.68 gr/100 dscf. The 

reference to 20 gr/1 00 dscf in Section 3 of the Application reflects the value which exempts stationary gas turbines 

from the NSPS S02 standard (see 40 CFR §60.4330(f)). The expected project S02 emissions from combustion of 

the natural gas are presented in Appendix A of the Application for each emissions source. Those values are 

calculated based on an expected fuel sulfur content.of:S0.68 gr/100 dscf. Thos calculated S02 emission values are 

reflected in the S02 emission limits established in the Plan Approval. 

8. PM2.5 emission limit and monitoring: EPA has the following concerns: 

The TRM notes that Berks Hollow is taking voluntary emission limit for PM2.5 of less 

than 100 typ. However, the TRM does not provide exactly what this limit is, and how 

it will he monitoring to ensure the facility does not exceed this federally enforceable 

limit. For clarity, please provide this information in the TRM. 

BHEA Response: The Plan Approval includes PM2.5 limits on a 12-month rolling total for each emissions source, 

which total to Jess than 100 tpy for all emission sources combined. Section VII of Group Name PM2.5 in Section E 

of the Plan Approval sets forth restrictions on facility-wide PM2.5 emissions and requirements for demonstrating 

compliance with the PM2.5 limit for each emissions source. Section C of the Plan Approval includes requirements 

of 25 Pa. Code Ch. 135 regarding submission of an annual emission statement, which would include calculations of 

PM2.5 emissions from each source and facility-wide. Compliance with the PM2.5 limits will be demonstrated in 

patt by stack testing for the CCUs during normal operation; worst-case emission factors based on original equipment 

manufacturer (OEM) data for startup and shutdown periods for the CCUs; vendor guarantees and records of fuel 

consumption of the auxiliary boiler, fuel heater and emergency engines; and emission factors and monitoring of 

TDS for the cooling tower. Based on the compliance demonstration and reporting requirements set forth in the Plan 

Approval, BHEA does not believe any additional monitoring or reporting requirements are necessary to ensure 

compliance with the PM2.5 emission limitations. 

b. The plan approval provides annual PM2.5 emission limits on a rolling 12-month 

basis for the two turbine options as well as other units, when including normal 

operations and startup and shutdown times, add up to more than 99.25 tpy. This 

limit is just below the major source threshold for PM2.5. If PM2.5 is not precisely 

measured during all operating times, including startup and shutdown, this limit is 

highly suspect. 

BHEA Response: For purposes of compliance demonstration, PM2.5 emissions from the combustion turbines will 

be determined from stack testing during normal operations and worst-case emission factors based on OEM data for 

startup and shutdown periods, which is also the basis for the emission estimates presented in Table A-2 of Appendix 

A of the Application. Maximum potential annual emissions ofPM2.5 from startup and shutdown operations is 

approximately 2% of the fucility-wide PM2.5 emissions, and actual annual emissions will typically be much less 

than permitted since stattup and shutdown operations will typically occur less than the limit of 500 annual hours. 

Since PM2.5 emissions are a result of fuel combustion and no post-combustion controls are necessary, PM2.5 

emissions are expected to be consistent and proportional to the amount of fuel burned. For this reason and the fact 

that fuel flow to the turbines will be monitored continuously, direct continuous monitoring of PM2.5 is not 

necessary or practicable. 

Page 4 of 5 
ENCLOSURE 

RESPONSES TO EPA COMMENT LETTER DATED April9, 2013 REGARDING 

BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA 

Because the PM2.5 limit for each emissions source represents the worst case emission rate, compliance with the 

PM2.5 limits for each emissions source will ensure that facility-wide emissions will be below the major source 

threshold for PM2.5 of 100 tpy. As a result, BHEA does not believe any additional conditions are necessary to 

ensure that facility-wide PM2.5 emissions are below the major source threshold. 

Page 5 of 5 
April IS, 2013 

Via Electronic and First Class Mail 

Mr. Thomas Hanlon 

Facilities Permitting Chief 

P A DEP Air Quality Program 

909 Elmerton Avenue 

Harrisburg, P A 17110 

Re: Berks Hollow Energy Associates, LLC, Berks Hollow Energy Station 

Plan Approval No. 06-0SlSOA 

Mr. Hanlon, 

Clean Air Council ("Council") hereby submits the following comments in response to the 

Pennsylvania Department of Environmental Protection's ("PA DEP") notification that it intends 

to issue Plan Approval 06-05150A to Berks Hollow Energy Associates, LLC ("Berks Hollow"), 

for installation and stattup of a combined-cycle natural gas fired electric generation station, 

Berks Hollow Energy Station ("Station") to produce up to 855 MW of electricity at 5662 

Leesport Avenue in Ontelaunee Township, Berks County. 

Clean Air Council is a non-profit environmental organization headquartered at 135 South 19th 

Street, Suite 300, Philadelphia, Pennsylvania 19103. For more than 40 years, the Council has 

fought to improve the air quality across Pennsylvania. The Council has members across the 

Commonwealth. The Council's mission is to protect everyone's right to breathe clean air. 

Background/Introduction: 

On Aprill8, 2012, Berks Hollow submitted an application for the construction of a natural gasfired combined cycle electric generation facility that is designed to generate up to 855 MW of 

electricity. The Station will generate electricity using 2 combustion turbine generators and 2 heat 

recovery steam generators that will provide steam to drive a single steam turbine generator. Each 

I 
heat recovery steam generator will be equipped with a duct burner which may be utilized at time 

of peak power demands to supplement power output. The source is subject to Prevention of 

Significant Deterioration ("PSD") and New Source Review ("NSR") requirements. The proposed 

project will also include a natural gas-fired fuel gas heater, a natural gas-fired auxiliary boiler; a 

diesel engine-driven emergency generator;~ diesel engine-driven firewater pump; a multi-cell 

evaporative cooling tower; and associated emission control systems, a cold cleaning degreaser, 

tanks, and other balance of plant equipment. This will be a Title V facility. 

On March 16,2013, PA DEP provided notice of its intent to issue Plan Approval 06-05150A. 

Comments: 

I. PA DEP may not issue the Plan Approval until it has determined that the sources comply 

with applicable regulations, which it cannot do without knowing the make and model of 

the sources. 

Pennsylvania's plan approval regulations require an application to show "that the source will 

comply with applicable air requirements of [25 Pa. Code, Att. III] and requirements promulgated 

by the Administrator of the [U.S. Environmental Protection Agency ("EPA")] .... " A source is 

any "place, facility or equipment, stationary or mobile, at, from or by reason of which there is 

emitted into the outdoor atmosphere any air contaminant."2 

Berks Hollow has not provided a make or model to PA DEP for the combustion turbines, at the 

very least. Without access to the application it is unclear whether there are other sources where 

the make and model have also not been provided. The turbines, at the very least, meet the 

definition of a "source" and must comply with the "applicable requirements." 

Although Berks Hollow has indicated that the Station will contain these sources, the precise 

pieces of equipment have yet to be specified. The application thus omitted information crucial to 

showing that the sources would comply with applicable air requirements, meaning PA DEP may 

not approve it.3 PA DEP should find the application incomplete and refrain from acting on it 

until Berks Hollow submits the make and model of pollution sources to be installed. 

2. It is illegal, arbitrary, and capricious for PA DEP to declare an undetermined source to be 

BACT. 

Applicants for a plan approval must show that "the emissions from a new source will be the 

minimum attainable through the use of the best available technology." 4 Best available control 

technology ("BACT") is an emissions limitation based on the maximum degree of reduction for 

each regulated NSR pollutant which would be emitted from any proposed major facility which 

PA DEP, on a case-by-case basis, taking into account energy, environmental and economic 

1 25 Pa. Code.§ 127.12(a)(4). 

2 /d. § 121.1. 3 25 Pa. Code at 127.12(b) ("The Department will not approve an application which fails to meet the requirements of 

subsection (a)."). 4 25 Pa. Code§ 127.12(a)(5). 

2 
impacts and other costs, determines is achievable for the facility through application of 

production processes or available methods, systems and techniques, including fuel cleaning or 

treatment or innovative fuel combustion techniques for control of the pollutant.5 

Although PA DEP noted that "[t]he facility is proposing two different supply options and will 

pick one option prior to construction," it nevetiheless recommended that they be considered 

BACT. BACT is a "systemic analysis."6 Thus, it naturally involves comparisons among 

technologies. In conducting a BACT analysis, "one cannot look at particular emissions 

parameters in a vacuum."7 Nevertheless, the whole of the PA DEPs BACT analysis is done in a 

vacuum. 

PA DEP may not find the plan approval to be complete without a BACT determination, which it 

cannot complete when it lacks the make and model of the sources.

8 Implicit in the requirement 

that an applicant demonstrate its source is BACT is that PA DEP must make a determination that 

the source is actually BACT. In this case, PA DEP determines that good combustion practices, 

oxidation catalysts, dry low nitrogen oxides ("NOx") burners and selective catalytic reduction are 

BACT despite not knowing the make or model of the sources. PA DEP goes so far as to provide 

separate emissions limits for each turbine that Berks Hollow may choose. A BACT 

determination is an emissions limit, not a series of options. 

Berks Hollow has failed to specifically identify the turbines they intend to install and operate and 

PA DEP may not approve those sources as BACT until they are specifically identified and that 

information is made available for public comment. EPA has made clear that if an owner/operator 

makes changes that "lead to changes in emissions, impacts on air quality, or control 

technologies ... such changes require [the permitting agency] to conduct comprehensive analysis 

of the changes, and the public should have an oppmiunity to provide comment on any such 

changes. "

9 

3. PA DEP must perform a full and independent BACT analysis for each source and each 

pollutant. 

This Plan Approval's main flaw is the cursory review and blind acceptance of Berks Hollow's 

proposed BACT. In a matter of four pages PA DEP accepts BACT limits for six source types 

and tens of pollutants. This is entirely insufficient and does not constitute a proper BACT 

analysis. PA DEP's reliance on the Hickory Run review does not excuse it from performing a 

sufficient BACT analysis. 

5 25 Pa. Code§ 121.1. 6 Residents Opposed to Black Bridge Incinerator (ROBBI) v. PA DEP, 1993 WL 190536, at *27 (EHB May 18, 

1993). 

7 Id 

8 See 25 Pa. Code § 127.12(b) (Department will not approve an application that fails to show, inter alia, that the 

source will be BAT). 9 See Letter from Becky Weber, Director, Air and Waste Management Division, U.S. EPA Reg. VII, to John 

Mitchell, Director, KS Dept. of Health and Envt. (Abengoa Bioenergy) (Apr. I, 2011). 

3 
BACT is a "case-by-case" analysis that takes "into account energy, environmental and economic 

impacts and other costs." 10 PA DEP must perform this case-by-case analysis in the Review 

Memo and may not rely on Hickory Run or defer to Berks Hollow. 

4. The Station should be required to use natural gas with a sulfur content of 0.25 gr/1 00 scf. 

PA DEP has determined that BACT for sulfur oxide ("SOx'') and ("H2S04") is use of pipeline 

quality natural gas with an emissions limitation of 0.68 gr/1 00 scf. 

However, in a recent Plan Approval application for a similar natural gas-fired power plant, ( 41-

00084A) Moxie Patriot, LLC, indicated that the sulfur content of the gas they will use is 0.25 

gr/1 00 scf according to the specifications provided by the fuel supplier. It is unclear why this 

Station will have a sulfur content limit nearly three times the available fuel supply. The Council 

requests that PA DEP lower the sulfur content or provide an explanation. 

Further, it does not appear that the proposed Plan Approval includes monitoring for the sulfuric 

acid mist. The Plan Approval should include a method of demonstrating compliance with the 

fuel sulfur limit. 

5. The Proposed Plan Approval must be revised to require that PMu_is limited and 

monitored separately from PM10 • 

Particulate Matter ("PM") is treated as two separate pollutants under the Clean Air Act: PM10 and 

PM2.s· EPA has stated that because PM2.s now has a separate and distinct NAAQS, PM to can no 

longer be treated as a surrogate for PM25. 72 Fed. Reg. at 20,659. Therefore, consistent with the 

EPA's treatment of emissions information for these pollutants, the final plan approval for the 

Station must include separate and distinct limitations and standards for PM10 and PM2.s 

emissions. 

6. "Good combustion practices" must be defined and enforceable. 

PA DEP selects "good combustion practices" as BACT and lowest achievable emissions rate for 

various pollutants on various sources at the Station. "Good combustion practices," however, are 

not defined. PA DEP should include a description of the various practices that will be required 

for each pollutant on each source and must incorporate them into the Plan Approval. 

7. The greenhouse gas limit must include methane and nitrous oxide and be based on COie. 

Under the definition of "Subject to regulation" in the greenhouse gase ("GHG") tailoring rule at 

40 CFR 52.2l(b)(49)(i), and under the definition of"Regulated NSR pollutant" at 40 CFR 

52.2l(b)(60)(iv), both of which are incorporated by reference into State rules, the pollutant that 

is subject to regulation, and therefore a regulated NSR pollutant, is defined as GHG, not carbon 

dioxide ("C02"). Therefore, the BACT emission limit should be expressed in terms of total GHG 

emissions, as COrequivalent ("C02e"), and the Plan Approval should indicate how compliance 

will be demonstrated for the two non-C02 GHGs to be emitted. 

10 See e.g. Groce, eta/., v. PA DEP, 2006 WL 3485200 , at * 8 (EHB Nov. 22, 2006). 

4 
To account for methane and nitrous oxide emissions and determine compliance with the 

emission limits for total GHGs, EPA recommends use of emission factors from Table C-2 of 40 

CFR patt 98 and global warming potentials from Table A-1 of 40 CFR part 98, along with the 

actual measured heat input for the combustion turbines. The Plan Approval should also state that 

the results of future stack tests can be used to determine a source-specific emission factor to 

calculate GHG emissions from the Station. 

8. The Plan Approval must include a BACT limit for GHGs and may not rely solely on the 

NSPS. 

While NSPS TTTT is an applicable requirement, it is not a substitute for a GHG BACT analysis. 

Further, as discussed above, TTTT sets a standard of I 000 lbs C02/MWh. A GHG BACT 

determination requires an enforceable limit on all GHGs. 

The largest source ofGHGs at the Station will be C02 from the combined cycle units. Generally, 

permit writers compare thermal efficiencies of various units to determine what BACT is and then 

regulate GHGs by setting a lbs C02e/MWh standard along with a net heat rate figure. The 

Review Memo should be able to show that the most efficient combined cycle unit is chosen for 

the Station, or it should justify why a unit with a lower efficiency was selected. PA DEP must 

then go on to ensure that BACT is set for each source and for all GHGs including methane and 

nitrous oxide. 

The measures selected for BACT here are vague and unenforceable. PA DEP indicates that: 

The remaining GHG control option is the efficient use of energy. The turbines and duct 

burners will be designed for emissions of greenhouse gases that are less than 1000 

pounds of C02 per megawatt-hour of electricity produced, in conformance with EPA's 

proposed NSPS mle for Electric Utility Generating Units (proposed 3/27/12). This would 

constitute BACT and BAT for GHGs. 

To adequately support a BACT determination, PA DEP must, at minimum, clarify whether all 

available control options were considered, whether the option selected is the best-performing 

option that is known to be available and technically feasible, whether energy, environmental and 

economic impacts affected the selection of the control option, and if the best-performing option 

was not selected provide an explanation and suppmting basis for that selection. 

PA DEP may not merely set a C02 standard on the combined cycle units and "good combustion 

practices" on other sources. Each source that emits GHGs must have an enforceable limit and the 

Station as a whole must have enforceable limits. A 1000 lbs C02/MWh on the combined cycle 

units limit does not represent BACT. 11 

11 See e.g. Sumpter Power Plant with a GHG BACT limit of954 lb C02e/M\Vh and Palmdale Hybrid Power Project 

with a GHG BACT limit of774 C02e/MWh. 

5 
9. Specific engineering practices should be incorporated into the final permit. 

Condition #004 in the proposed permit indicates that "[t]he permittee shall maintain and operate 

the sources associated in accordance with good engineering practices as described in the plan 

approval application submitted to the Department." 

This condition is vague and unenforceable. PA DEP references 25 Pa. Code§ 127.12(a)(l 0) in 

the Condition, however this section merely provides that an application must "[s]how that the 

source and the air cleaning devices are capable of being and will be operated and maintained in 

accordance with good air pollution control practices." 

Ifthere are engineering practices necessary to keep the air cleaning devices properly operated 

and maintained those should be specifically included in the Plan Approval. 

The Council encourages PA DEP to perform an independent evaluation of the Plan Approval 

application and to respond to all comments from the public to ensure that any final action is 

consistent with applicable federal and state requirements. Further, the Council urges PA DEP to 

ensure that the bases for decisions are transparent and that the record provides adequate support 

for the Plan Approval decisions. 

Thank you for the opportunity to comment. Please keep us apprised of any future actions related 

to Plan Approval 37-337 A. 

Sincerely, 

Joseph Otis Minott, Esq. 

Executive Director 

6 
Berks Hollow Energy Associates, L.L.C. 

May30, 2013 

Mr. Tom Hanlon 

Chief, Air Quality Permitting 

Air Quality Program 

Department of Environmental Protection (DEP) 

Reading District Office 

1005 Crossroads Boulevard 

Reading, P A 19605 

Re: Response to Comments from the Clean Air Council 

Berks Hollow Energy Associates, LLC (BHEA) 

Draft Plan Approval No. 06-0SlSOA 

Dear Mr. Hanlon: 

c/o LS Power Development, LLC 

400 Chesterfield Center, Suite 110 

St. Louis, Missouri 63017 

{636) 532-2200 - Fax (636) 532-2250 

BHEA has reviewed the letter from the Clean Air Council dated April 15,2013 regarding 

comments to the draft Plan Approval No. 06-5150A. BHEA respectfully offers the enclosed 

responses for consideration by DEP. 

Please feel free to contact me (636-534-3268) if you have any questions. 

Sincerely, 

Bradley J. Cooley 

Senior Environmental Engineer 

Enclosures 
ENCLOSURE 

RESPONSES TO COMMENT LEITER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA 

Following are Berks Hollow Energy Associates' ("BHEAs" or "the Applicant's") responses to comments 

dated AprillS, 2013, from Clean Air Council (or "Commenter"). The text of the Commenter's letter is 

provided below (with footnotes removed), with responses to each comment interspersed within the 

text in bold font. 

===================================================================================== 

1. PA DEP may not issue the Plan Approval until it has determined that the sources 

comply with applicable regulations. which it cannot do without knowing the make and 

model of the sources. 

Pe1msylvania's plan approval regulations require an application to show "that the source will 

comply with applicable air requirements of [25 Pa. Code, Art. III] and requirements promulgated 

by the Administrator of the [U.S. Environmental Protection Agency ("EPA")] .... "A source is 

any "place, facility or equipment, stationary or mobile, at, from or by reason of which there is 

emitted into the outdoor atmosphere any air contaminant." 

Berks Hollow has not provided a make or model to PA DEP for the combustion turbines, at the 

very least. Without access to the application it is unclear whether there are other sources where 

the make and model have not been provided. The turbines, at the very least, meet the definition 

of a "source" and must comply with the "applicable requirements." 

Although Berks Hollow has indicated that the Station will contain these sources, the precise 

pieces of equipment have yet to be specified. The application thus omitted information crucial to 

showing that the sources would comply with applicable air requirements, meaning PA DEP may 

not approve it. PA DEP should find the application incomplete and refi·ain from acting on it until 

Berks Hollow submits the make and model of pollution sources to be installed. 

Response 1: Permit applications are required by 25 Pa. Code §127.12{a)(4) to "[s]how 

that the source will comply with applicable requirements of this article and 

requirements promulgated by the Administrator of the EPA under the Clean Air Act 

{42 U.S.C.A. §§7401-7706)." The comment seems to suggest that this provision means 

that an application must contain a listing of specific equipment and control device 

make and model numbers in order to demonstrate compliance with applicable air 

regulations. Section 127.12 does not contain such a mandate. Rather, §127.12(a)(2) 

specifies that an application must "[c]ontain information that is requested by the 

Department and is necessary to perform a thorough evaluation of the air 

contamination aspects of the source." The air quality plan approval application 

("Application") submitted by the Applicant contained all information requested by 

DEP and necessary to perform a thorough evaluation of the air contamination aspects 

of the source. That information included, in many cases, specific manufacturers and 

models, and in other cases descriptions of the specific types of control equipment 

(such as SCR controls for NOX) and the specific operating performance criteria of such 

units. This information is sufficient to determine the operating characteristics, 

Page 1 of 14 
ENCLOSURE 

RESPONSES TO COMMENT LETTER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN AP-PROVAL NO. 06-0SlSOA 

emission characteristics, and expected control performance of each of the emission 

units proposed for inclusion in the Project. 

Although final design and equipment selection for the Project has not yet been 

completed, the equipment proposed for installation has been clearly defined, and the 

Application provides information that is sufficient to satisfy the requirement in 25 Pa. 

Code §127.12(a)(4) to show that the source will comply with applicable requirements 

of the PA Co~e and requirements promulgated by EPA under the Clean Air Act. 1 

The Applicant requested the flexibility to select from the following combustion 

turbine generator ("CTG") options, which were evaluated in detail in the Application: 

• General Electric 7FA; or 

• Siemens SGT6-5000F 

As BHEA explained in the cover letter to the Application, "[t]his flexibility is being 

proposed so that there will be a diversity of equipment supply options. This diversity 

will help ensure that equipment will be available when construction is ready to begin 

and will provide a competitive supply market. The application was prepared using the 

highest emissions from either turbine for each pollutant. Either of the two turbines 

selected will comply with the limits proposed in the application. For purposes of 

completeness, information for both turbines is included in Appendix A, Tables A-14 

and A-15, of the application. In either case the turbines will be equipped with 

selective catalytic reduction SCR for control of Nitrogen Oxides (NOx) and catalytic 

oxidation for control of Carbon Monoxide (CO)." The analyses submitted with the 

Application including emissions calculations and air dispersion modeling encompassed 

the range of operational parameters associated with each CTG option to ensure that 

each option would be thoroughly evaluated. 

As such, the parameters specific to each CTG option were analyzed in detail in BHEA's 

Application and in the Department's review of the Application. Applicable data for 

each CTG option was listed in the plan approval application forms in Section 4; specific 

emissions and performance data was provided for each CTG option (Application 

Appendix A); CTG-specific information was accounted for in the Best Available Control 

Technology (BACT) analysis; and each CTG option was evaluated separately in the air 

dispersion modeling analysis (Application Appendix B). Thus, to the extent pertinent, 

equipment-specific parameters have been taken into account in the Applicant's 

demonstrations of compliance with the applicable regulations. Going forward, the 

requirements of the Plan Approval establish the performance requirements based on 

1 Refer to Section 3 of BHEA's Application for detailed discussions of such applicable requirements. 

Page 2 of 14 
ENCLOSURE 

RESPONSES TO COMMENT LETIER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA 

applicable air quality regulatory standards, and those performance requirements 

serve as design and operating criteria that will govern final equipment selection and 

installation. The source testing and monitoring requirements of the Plan Approval 

ensure that all applicable requirements will be met. 

In summary, the level of detail in the Application was sufficient to make the required 

demonstration that the project emissions sources will comply with applicable federal 

and state air regulations. No changes to the Plan Approval are warranted based on 

this comment. 

2. It is illegal, arbitrary. and capricious for PA DEP to declare an undetermined source to 

be BACT. 

Applicants for a plan approval must show that "the emissions from a new source will be the 

minimum attainable through the use of the best available technology."Best available control 

technology ("BACT") is an emissions limitation based on the maximum degree of reduction for 

each regulated NSR pollutant which would be emitted from any proposed major facility which 

P A DEP, on a case-by-case basis, taking into account energy, environmental and economic 

impacts and other costs, determines is achievable for the facility through application of 

production processes ol' available methods, systems and techniques, including fuel cleaning or 

treatment or innovative fuel combustion techniques for control of the pollutant. 

Although PA DEP noted that "[t]he facility is proposing two different supply options and will 

pick one prior to construction," it nevertheless recommended that they be considered BACT. 

BACT is a "systemic analysis."Thus, it naturally involves comparisons among technologies. In 

conducting a BACT analysis, "one cannot look at patticular emissions parameters in a vacuum." 

Nevertheless, the whole ofPA DEPs BACT analysis is done in a vacuum. 

PA DEP may not find the Plan Approval to be complete without a BACT determination, which it 

cannot complete when it lacks the make and model of the sources. Implicit in the requirement 

that an applicant demonstrate its source is BACT is that PA DEP must make a determination that 

the source is actually BACT. In this case, P A DEP determines that good combustion practices, 

oxidation catalysts, dry low nitrogen oxides ("NOx'') burners and selective catalytic reduction are 

BACT despite not knowing the make or model of the sources. PA DEP goes so far as to provide 

· separate emissions limits for each turbine that Berks Hollow may choose. A BACT 

determination is an emissions limit, not a series of options. 

Berks Hollow has failed to specifically identify the turbines they intend to install and operate and 

PA DEP may not approve those sources as BACT until they are specifically identified and that 

information is made available for public comment. EPA has made clear that if an owner/operator 

makes changes that "lead to changes in emissions, impacts on air quality, or control 

technologies ... such changes require[the permitting agency] to conduct comprehensive analysis 

Page 3 of 14 
ENCLOSURE 

RESPONSES TO COMMENT LEDER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC {BHEA) PLAN APPROVAL NO. 06-0SlSOA 

of the changes, and the public should have an opportunity to provide comment on any such 

changes." 

Response 2: ·BHEA's Application and the Plan Approval include BACT/LAER limits that 

were established in accordance with the applicable PSD BACT /LAER requirements for 

each pollutant specific to each CTG option. The Application provided information 

sufficient for DEP to consider the expected emission characteristics of each emitting 

source and the effect of pollution control equipment. Each air emission source and 

control technology was detailed in the Application, allowing a consideration and 

analysis of the available control options in the required "top-down" methodology. The 

BACT analysis was not conducted "in a vacuum" as the comment alleges. 

The comment is incorrect in asserting that DEP lacks the make and model of the CTGs 

and therefore cannot make a BACT determination. Although Pennsylvania's 

regulations do not require the make and model of every piece of equipment, in this 

case, the specific make and model information for the CTG units was provided in the 

Application and the Plan Approval (see Response 1 above for the specific list of CTG 

options). In turn, after application of the top-down analysis of control methods, 

BACT /LAER limits were listed for each option,· and the public was afforded an 

opportunity to review and provide comments on the proposed limits. 

There is no EPA regulation, guidance, case law, or precedent that would prohibit DEP 

from listing BACT /LAER limits applicable to more than one equipment option in a PSD 

permit, and the comment does not mention any specific issues with the limits that 

were established for the various CTG options. Other recent PSD permit precedents 

that authorize multiple CTG equipment options or do not specify the exact model of 

CTG authorized are commonplace and include, but are certainly not limited to, the 

following examples: 

• West Deptford Energy Associates {New Jersey) 

• CPV Warren {Virginia) 

• Patillo Branch Power Company {Texas) 

• King Power Station (Texas) 

• La Paloma Energy Center (Texas) 

• Wolf Hollow 1, LP- Plant 2 {Texas) 

• Panda Sherman Power, LLC (Texas) 

• Lamar Power Partners II, LLC {Texas) 

• Cobisa-Greenville, LLP (Texas) 

• BP Cherry Point Cogeneration {Washington) 

• Moxie Energy- Liberty {Pennsylvania) 

• Moxie Energy- Patriot {Pennsylvania) 

Page 4 of 14 
ENCLOSURE 

RESPONSES TO COMMENT LEDER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA 

• Tenaska Arkansas Partners, LP (Arkansas} 

• Union Generating Station (Arkansas} 

• South Eastern Energy Corp. (Alabama} 

• Tenaska Alabama II Generating Station (Alabama} 

• Granite Power Partners (Florida} 

• Haywood Energy Center (Tennessee} 

• Port Westward (Oregon} 

• Klamath Generation, LLC (Oregon} 

It should be noted that EPA has reviewed the Plan Approval for BHEA and expressed 

no concerns over the multiple CTG equipment options that are authorized. 

A LAER analysis was specifically required for NOx and VOC emissions for the CCUs. 

LAER is the most stringent emission limitations achieved in practice for such class or 

category of source, and does not consider economic or other impacts. As such, BHEA 

selected the lowest emission limitation achieved in practice for the class of equipment 

being considered for the project, namely "F"-class turbine technology. Because the 

LAER analysis is more stringent, a separate BACT analysis for NOx and VOC was not 

required, although the information necessary for a BACT analysis was provided in 

Section 5 of the Application. A BACT analysis for greenhouse gasses and other 

applicable pollutants was provided in the Application that included both CCU options. 

3. PA DEP must perform a full and independent BACT analysis for each source and each 

pollutant. 

This Plan Approval's main flaw is the cursory review and blind acceptance of Berks Hollow's 

proposed BACT. In a matter offour pages PA DEP accepts BACT limits for six source types 

and tens of pollutants. This is entirely insufficient and does not constitute a proper BACT 

analysis. PA DEP's reliance on the Hickory Run review does not excuse it from performing a 

sufficient BACT analysis. 

BACT is a "case-by-case" analysis that takes "into account energy, environmental and economic 

impacts and other costs." PA DEP must perfotm this case-by-case analysis in the Review Memo 

and may not rely on Hickory Run or defer to Berks Hollow. 

Response 3: Section 5 of BHEA's Application includes a detailed BACT/LAER analysis, 

which DEP reviewed in detail. To memorialize that review, BHEA recommends that 

DEP include this information in the Technical Review Memo. 

4. The Station shonld be required to use natural gas with a sulfur content of0.25 gr/100 

scf. 

Page 5 of 14 
ENCLOSURE 

RESPONSES TO COMMENT LEITER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA 

PA DEP has determined that BACT for sulfur oxide ("SOx") and ("H2S04") is use of pipeline 

quality natural gas with an emissions limitation of0.75 gr/100 scf. 

However, in a recent Plan Approval application for a similar natural gas-fired power plant ( 41-

00084A) Moxie Patriot, LLC indicated that the sulfur content of the gas they will use is 0.25 

. gr/1 00 scf according to the specifications provided by the fuel supplier. It is unclear why this 

plant will have a sulfur content limit three times the available fuel supply. The Council requests 

that P A DEP lower the sulfur content or provide an explanation. 

Further, it does not appear that the proposed Plan Approval includes monitoring for the sulfuric 

acid mist. The Plan Approval should include a method of demonstrating compliance with the 

fuel sulfur limit. 

Response 4: The Project is not a major source of 502 emissions and thus does not 

require a BACT analysis for S02 emissions. The limit of 0.68 gr/100 dscf was based on 

fuel sulfur content obtained from the expected natural gas supplier Texas Eastern 

Transmission Company {TETCO). 

Regarding the Commenter's contention that the Plan Approval does not include 

monitoring for sulfuric acid mist, this is incorrect since the Plan Approval conditions 

found in Section E, Group Name CCU, Subsection II, #003{a) and {b) require stack 

testing initially and again every two years. 

Finally, regarding demonstration of compliance with the fuel sulfur limit, the Plan 

Approval already includes compliance demonstration provisions in accordance with 

NSPS KKKK in Section E, Group Name SUBPART KKKK, Conditions #007, #013, #014, 

and #015. 

5. The Proposed Permit must be revised to require that PM2.5 is limited and monitored 

separately from PMlO. 

Particulate Matter ("PM") is treated as two separate pollutants under the Clean Air Act: PMIO 

and PM2.5. EPA has stated that because PM2.5 now has a separate and distinctNAAQS, PMIO 

can no longer be treated as a surrogate for PM2.5. 72 Fed. Reg. at 20,659. Therefore, consistent 

with the EPA's treatment of emissions information for these pollutants, the final plan approval 

for the Station must include separate and distinct limitations and standards for PM! 0 and PM2.5 

emissions. 

Response s:·· Neither the Applicant nor DEP has used PM10 as a surrogate for PM2.5. 

The Plan Approval clearly provides emission limitations and monitoring for both PM10 

and PM2.5. While maximum expected PM2.5 and PM10 emission rates for the 

Page 6 of14 
ENCLOSURE 

RESPONSES TO COMMENT LETTER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA 

combined cycle units are numerically equivalent, PM2.5 and PMlO were addressed 

separately as appropriate in the Application and the Plan Approval. Note that the Plan 

Approval includes in Section E, Group Name PM2.5, Condition #001 compliance 

verification stack tests for PM2.5 using EPA Methods 5 and 202 (filterable and 

condensable), assuming PM2.5 is equal to PM/PMlO, or another EPA approved PM2.5 test method such as Method 201A. 

6. "Good combustion practices" must be defined and enforceable. 

PA DEP selected "good combustion practices" as BACT and lowest achievable emissions rate 

for various pollutants on various sources at the Station. "Good combustion practices," however, 

are not defmed. PA DEP should include a description of the various practices that will be 

required for each pollutant on each source and must incorporate them into the Plan Approval. 

Response 6: Good combustion practices generally means operation of the combustion 

unit in a manner that minimizes emissions per the manufacturer's design and 

specifications. The Plan Approval sets forth Work Practice Requirements for the 

various emissions sources which include a requirement to maintain and ope.rate the 

source in accordance with the manufacturer's specifications, and perform a daily 

operational inspection until the Department approves a work practice inspection 

protocol submitted by the permittee. BHEA will comply with these requirements and 

submit a work practice inspection protocol based on manufacturer's 

recommendations and specifications to ensure proper operation of the source and 

minimization of emissions through good combustion practices. Compliance with the 

emissions limits and work practice requirements in the Plan Approval will provide 

documentation of the implementation of good combustion practices. Based on the 

foregoing, the Plan Approval provides sufficient assurance of the implementation of 

good combustion practices, and no revisions to the Plan Approval are warranted. 

7. The greenhouse gas limit must include methane and nitrous oxide and be based on 

C02 e. 

Under the definition of"Subject to regulation" in the greenhouse gas ("GHG") tailoring rule at 

40 CFR 52.21(b )( 49)(i), and under the definition of "Regulated NSR pollutant" at 40 CFR 

52.21(b)(60)(iv), both of which are incorporate by reference into State rules, the pollutant that is 

subject to regulation, and therefore a regulated NSR pollutant, is defmed as GHG, not carbon · 

dioxide ("C02''). Therefore, the BACT emission limit should be expressed in terms of total GHG 

emissions, as C02-equivalent ("C02e"), and the Plan Approval record should indicate how 

compliance will be demonstrated for the two non-C02 GHGs to be emitted. 

To account for the methane and nitrous oxide emissions in detetmining compliance with the 

emission limits for total GHGs, EPA recommends use of emission factors from Table C-2 of 40 

Page 7 of 14 
ENCLOSURE 

RESPONSES TO COMMENT LEITER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06·051SOA 

CFR part 98 and global warming potentials from Table A-1 of 40 CFR part 98, along with the 

aetna! measured heat input to the combustion turbines. The Plan Approval should also state that 

the results of future stack tests can be used to determine a source-specific emission factor to 

calculate GHG emissions from the Station. 

Response 7: The comment appears to misperceive the limitations set forth in the Plan 

Approval. The Plan Approval contains limitations on both C02 and C02 equivalents 

. (C02(e)). Specifically, Condition E.l# 001(2) un.der Source Group GHG states the 

following: 

"No person may permit the emission into the outdoor atmosphere of the 

following in a manner that exceeds the following: 

[ ... ] 

2. C02( e) emission rate of 1,380,899 tpy based on a 12-month rolling total for 

each CCU." 

The C02(e) limitations take into account emissions of C02, methane, and nitrous 

oxide. Compliance with the C02(e) emission limitation will be monitored via a 

combination of CEMS monitoring for C02 plus emission factors and calculations for 

methane and nitrous oxide derived from 40 CFR 98. 

We note that in recently evaluating C02, methane, and nitrous oxide emissions from 

electric generating units, EPA explained as part of the preamble to the New Source 

Performance Standards for greenhouse gas emissions from new electric generating 

units that: "[t]he estimated emissions for N20 and CH4 from fossil fuel-fired EGUs (9.0 

and 0. 7 Tg of C02 equivalent, respectively) is about 0.4 percent of total C02 

equivalent emissions from fossil fuel-fired electric power generating units."2 Further, 

EPA has recently concluded that sufficient data is not available to establish separate 

limits for nitrous oxide or methane in terms of lb/MWh, stating that "[w]e are not 

proposing separate N20 or CH4 emission limits or an equivalent C02 emission limit in 

today's action because of a lack of available data for these affected sources."3 Given 

the relatively small contribution of nitrous oxides and methane from such units, the 

C02( e) limitation set forth in the Plan Approval plus the compliance checks provided 

are adequate to assure control of GHG emissions. 

The Commenter also suggests that the plan approval should state that results of 

future stack tests could be used to determine source-specific emission factors to 

calculate GHG emissions from the ·project. However, GHG emission rates from a 

natural gas fired power plant will vary depending upon operating condition,' including 

2 77 FR 22404, April13, 2012. 3 . 

77 FR 22404, April13, 2012. 

Page 8 of 14 
ENCLOSURE 

RESPONSES TO COMMENT LEITER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC {BHEA) PLAN APPROVAL NO. 06-0SlSOA 

ambient temperature, loading, and other factors. Emissions from a stack test can, as a 

practical matter, only provide a "snap-shot" of emissions at a given operating 

condition. Since the project is designed to operate at varying loads (matcHing 

electrical grid requirements) and differing modes (with and without duct burners, 

etc.), it is not practical to use a stack test to set a· single GHG emissions factor, as 

suggested by the comment. Instead, it is more realistic, and adequately protective, to 

set the type of annual C02(e) emissions limitation capping GHG emisstons from all 

sources and all operating modes, and to directly and continuously monitor the most 

significant element of those emissions (i.e., C02}, while tracking nitrous oxide and 

methane emissions via the emission factor methodology in 40 CFR Part 98. 

8. The Plan Approval must include a BACT limit for GHGs and may not rely solely on 

the NSPS. 

While NSPS TTTT is an applicable requirement, it is not a substitute for a GHG BACT analysis. 

Fmther, as discussed above, TTTT sets a standard of i 000 lb C021MWh. A GHG BACT 

determination requires an enforceable limit on all GHGs. 

The largest source of GHGs at the Station will be C02 from the combined cycle units. Generally, · 

permit writers compare thermal efficiencies of various units to determine what BACT is and then 

regulate GHGs by setting a lbs C02eiMWh standard along with a net heat rate figure. The 

Review Memo should be able to show that the most efficient combined cycle unit is chosen for 

the Station, or it should justify why a unit with a lower efficiency was selected. PA DEP must 

then go on to ensure that BACT is set for each source and for all GHGs including methane and 

nitrous oxide. 

The measures selected for BACT here are vague and unenforceable. PA DEP indicates that: 

The remaining GHG control option is the efficient use of energy. The turbines and duct 

burners will be designed for emissions of greenhouse gases that are less than 1000 

pounds of C02 per megawatt -hour of electricity produced, in conf01mance with EPA's 

proposed NSPS rule for Electric Generating Units (proposed 3/27/12). This would 

constitute BACT and BAT for GHGs. 

To adequately support a BACT determination, PA DEP must, at minimum, clarify whether all 

available control options were considered, whether the option selected is the best-performing 

option that is known to be available and technically feasible, whether energy, environmental and 

economic impacts affected the selection of the control option, and if the best-performing option 

was not selected provide an explanation and supporting basis for that selection. 

PA DEP may not merely set a C02 standard on the combined cycle units and "good combustion 

practices" on other sources. Each source that emits GHGs must have an enforceable limit and the 

Page 9 of14 
ENCLOSURE 

RESPONSES TO COMMENT LETTER FROM CLEAN AIR COUNCIL DATED April15, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-05150A 

Station as a whole must have enforceable limits. A 1000 lbs C02/MWh on the combined cycle 

units limit does not represent BACT. 

Response 8: The comment appears to misperceive the process which was followed for 

setting GHG BACT limits for the BHEA Project. In that process, the applicant and DEP 

considered {1) available information concerning C02 and other GHG emissions from 

natural gas-fired combined cycle power plants, including emission information 

amassed as part of EPA's extensive analysis leading up to proposal of the New Source 

Performance Standards in Subpart nn, {2) information concerning GHG emissions for 

other projects contained in the EPA's RACT, BACT, LAER Clearinghouse {RBLC) 

database; and {3) a case-by-case evaluation of other control technologies. Each of 

these sources of information and analyses are discussed below. 

EPA's GHG permitting guidance states the following with respect to consideration of 

NSPS information in determining GHG BACT limits: 

"The CAA specifies that BACT cannot be less stringent than any applicable 

standard of performance under the New Source Performance Standards 

(NSPS) .... To the extent EPA completes an NSPS for a relevant source category, 

BACT determinations that follow will need to consider the levels of the GHG 

standards and the supporting rationale for the NSPS.... Thus, the guidance in 

this document. should be viewed taking into consideration the potential 

development of an NSPS for a particular source category."4 

Based on this guidance, consideration of NSPS limits and supporting rationale is 

properly part of DEP's consideration in setting GHG BACT limits. 

In this case, the applicant conducted a GHG BACT analysis for the proposed combined 

cycle unit options which can be found in Section 5.3.5 of the Application. An emissions 

limit of 1,000 lb C02/MWh was selected as BACT, which Is consistent with EPA's 

determination as part of the proposed NSPS Subpart nn. Specifically, in its notice of 

the proposed rule dated March 27, 2012, EPA cites the basis for the proposed 

emissions limit as follows: 

"To establish an appropriate, natural gas-based standard, we reviewed the 

emissions rate of natural gas-fired (non-CHP) combined cycle facilities used in 

the power sector that commenced operation between 2006 and 2010 and that 

report complete generation data to EPA. Based on this analysis, nearly 95% of 

these facilities meet the proposed standards on an annual basis. These units 

4 PSD and Title V Permitting Guidance far Greenhouse Gases, EPA EPA-457/B-11-001, March 2011. 

Page 10 of 14 
ENCLOSURE 

RESPONSES TO COMMENT LEITER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA 

represent a wide range of geographic locations (with differing el,evations and 

ambient temperatures), operational characteristics, and sizes.'' 5 

In terms of describing best available control, EPA states the following as part of its 

NSPS rulemaking: 

"[A] NGCC [natural gas combined-cycle] facility is the best system of emission 

reduction for new base load and intermediate load EGUs." 6 • 

Thus, in its recent NSPS evaluation, EPA both endorsed natural gas combined cycle 

technology as the best system for emission reduction (basically, BACT), and also 

defined the performance obtained by such units in terms of controlled GHG emissions 

resulting from use of such technology. 

At the time that SHEA's application was prepared, the EPA's RBLC database was 

queried for determinations of "Carbon Dioxide" for Combined Cycle Fuel Combustion 

Units greater than 25 MW (i.e., Process Type 15.210) but no results were found. In its 

comments, the Commenter referenced BACT determinations made for the Sumpter 

Power Plant (954 lb C02e/MWh) and the Palmdale Hybrid Power Project (774 lb 

C02e/MWh)7

• The Palmdale project is not considered relevant since the project is 

dissimilar from the BHEA Project. The Palmdale project is a hybrid plant consisting of a 

CCU, with a concentrated solar power (CSP) unit which supplies additional steam to 

the steam turbine for supplemental power generation. The Sumpter project is also 

substantially different, representing a conversion of an older, small simple cycle 

turbine to combined cycle with no SCR and the addition of an unfired (i.e., no duct 

burners) heat recovery steam generator (HRSG). Sumpter is not comparable to the 

BHEA Project due to the small size and age of the turbines, the absence of duct firing, 

and the absence of SCR controls (which tend to place an additional efficiency 

constraint on such a facility). 

Since the submission of the Application, EPA has added to the RBLC database GHG 

BACT information for certain new projects. Of the projects listed in the RBLC database 

for C02, only the Moxie Liberty project is somewhat similar to the BHEA Project since 

it is a gas-fired, combined cycle unit. The Palmdale and Sumpter projects are listed in 

the RBLC database but are not comparable to the Project for the reasons explained 

above. The other projects listed are cogeneration or simple cycle units which are not 

comparable to the Project. The GHG emissions limit found in Moxie Liberty's Plan 

5 77 FR 22414, April13, 2012. 6 77 FR 22414, April13, 2012. 7 Note: a review of the permit for this facility showed that the GHG emission limit was actually in units of lb 

C02/MWh (not C02e). 

Page 11 of 14 
ENCLOSURE 

RESPONSES TO COMMENT LETIER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA 

Approval No. 08-00045A is in terms of tons of C02e in any 12 consecutive month 

period. The proposed configuration of the CCUs for Moxie Liberty is a lx1 (i.e., one 

combustion turbine coupled to one steam turbine) which differs from the BHEA 

Project's 2x1 configuration (i.e., two combustion turbines coupled to one steam 

turbine), and the proposed turbine technologies are "G" and "H" class turbines 

whereas BHEA is proposing "F" class turbines; thus, this project is not directly 

comparable to BHEA's Project. 

Finally, the application recognized that BACT involves a case-by-case determination of 

potentially available control technologies for the source. As presented in the 

Application, the GHG BACT analysis performed for the. Project combined cycle units 

considered carbon capture and sequestration (CCS) and energy efficiency, which are 

recommended for consideration in EPA's PSD and Title V Permitting Guidance for 

Greenhouse Gases dated March 2011. Since CCS was not selected, energy efficiency 

was the only available option. As noted by EPA, combined cycle technology is the 

most efficient fossil fuel-based electric generating technology and the "best system of 

emission reduction for new baseload and intermediate load EGUs" although 

efficiencies and emission rates among different turbine technologies and 

configurations will vary to some degree, and will also vary depending on loading and 

operating conditions. 

Recognizing these conditions, the Plan Approval sets limitations on GHG in several 

ways: a direct control of C02 emissions per MWh {thereby controlling the vast 

majority of all GHG emissions from the facility) and an additional annual C02{e) 

limitation (encompassing all GHG emissions) reflected in Section E, Group Name GHG, 

Condition #001. 

The proposed limit of 1,000 lb C02/MWh on a rolling 365-day averaging period is 

appropriate for the Project's CCUs for the following reasons: 

1) The limit is based on very recent information on emission performance of natural 

gas fired power plants which was amassed in the development of NSPS Subpart 

TTTI, based on a wide range of new units which commenced operation between 

2006 and 2010. 

2) The limit incorporates all operating modes including startup, shutdown, normal 

operation (including ramping and steady-state), part load operations and duct 

burner operation; and accounts for future degradation. 

3) The information from the NSPS development studies represent the best 

information available, ~iven the lack of more recent GHG emissions data for 

combined cycle units that are comparable to the proposed Project. 

Page 12 of 14 
ENCLOSURE 

RESPONSES TO COMMENT LETIER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA 

Because the number of shutdown and startup events, the load following profile, the 

ambient conditions, and the hours of operation of the duct burners will vary from 

year-to-year, the GHG emissions intensity will vary as well. The proposed Project has 

also been defined specifically as a nominal 685-MW (855-MW peak) plant with an 

intermediate to base-load operating profile, which may differ from other gas-fired 

. combined cycle projects that may be larger and operate base-load primarily. For 

these reasons, the proposed limit based on NSPS Subpart TTTT is appropriate in the 

absence of necessary GHG data and demonstrated, long-term performance of similar 

combined cycle units. The proposed limit also applies at all times rather than only 

during normal operation, so provides a higher level of compliance assurance. 

As demonstrated above, the BACT limits for the Project properly considered NSPS 

supporting information, along with the top-down analysis presented in the 

Application in accordance with EPA guidance. No changes to the Plan Approval are 

warranted based on the comment. 

Further, although methane and nitrous oxides represent a negligible contribution of 

GHGs from combined cycle plants (estimated to be less than 0.4% of emissions from 

such facilities), DEP included total annual C02.e limits specific to each CTG option 

which account for N2.0 and methane emissions. 

Finally, the comment mentions source-specific and facility-wide GHG limits. It is noted 

that the Plan Approval contains enforceable GHG limits set for each source and for the 

facility as a whole. 

9. Specific engineering practices should be incorporated into the final permit. 

Condition #004 in the proposed permit indicates that "[t]he permittee shall maintain and operate 

the sources associated in accordance with good engineering practices as described in the plan 

approval application submitted to the Department." 

This condition is vague and unenforceable. PA DEP references 25 Pa. Code§ 127.12(a)(l0) in 

the Condition, however this section merely provides that an application must "[ s ]how that the 

source and the air cleaning devices are capable of being and will be operated and maintained in 

accordance with good air pollution control practices." 

If there are engineering practices necessary to keep the air cleaning devices properly operated 

and maintained those shoulcl be specifically included in the Plan Approval. 

Response 9: Condition #004 in Section B of the Plan Approval is a standard permit 

condition, and DEP's practice is that this condition is written into each Plan Approval 

Page 13 of 14 
ENCLOSURE 

RESPONSES TO COMMENT LETTER FROM CLEAN AIR COUNCIL DATED April15, 2013 

REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-05150A 

using the language "[t]he permittee shall maintain and operate the sources and 

associated air cleaning devices in accordance with good engineering practice as 

described in the plan approval application submitted to the Department." DEP 

believes that this language is sufficient for implementation of 25 PA Code § 

127 .12(a){10). The specific requirements ensuring proper operation and maintenance 

of the control devices are included for each emissions source in the Plan Approval. 

===================================================================================== 

Page 14 of 14 
Dynllgy Oenerallon, A Division of Oynegy Inc. 

Ontelaunee Ene1gy Cenlet 

SUS Pottwlllc Pike 

Reading, PA 1960S·97l9 

Phone 610.916.66oo 

Fax 61o.g16.66o1 

www.dynegy.com 

ArrAcHMf:-NI E 

..L .;,...Jfll' 

'1 

DYNEGY 

Mr. William R. Weaver 

Air Quality Program Manager 

Pennsylvania Department of Environmental Protection 

Southcentral Region 

909 Elmerton Avenue 

Harrisburg, Pennsylvania 17110 

Dear Mr. Weaver: 

IR{~~~o~~[Q) 

APR 1 G 2013 

OEP SOUTHCENTHAL REGION 

AIR QUALlTY PROGRAM 

Ontelaunee Power Operating Company hereby submits the attached comments regarding the proposed 

Air Plan Approval for the Berks Hollow Energy facility (06·05150A) that was noticed for public comment 

In the March 16, 2013 edition of the Pennsylvania Bulletin. 

The proposed Berks Hollow facility Is located Immediately adjacent to our facility, In Ontelaunee 

Township, Berks County. We are concerned that the proposed Air Plan Approval Is not protective of the 

recently-promulgated 1-hr national Ambient Air Quality Standard for NO,. 

Please feel free to contact me at 610·916-6531, or Larry Waite of Dynegy's environmental compliance 

group at 618·206-5928. 

Sincerely, 

~cu.~ D,\Q_.g . .., 

Martin Daley ) 

Vice President, GasCo 

Dynegy, Inc. 
Comments of Ontelaunee Power Operating Company Regardln 

Draft Air Plan Approval for Berks Hollow Energy {06-0SlSOA) 

[g{ [E «:; {Ell~[EIQ) 

APR 1 6 2013 

DEP SOUTHCENTRAL REGION 

AIR QUAUlY PROGRAM 

Ontelaunee Power Operating Company, LLC (OPOC) owns and operates Ontelaunee Energy Center 

· (OEC), which is located Immediately adjacent and to the south of the proposed Berks Hollow Energy 

facility. Our goal In providing these comments on the proposed Air Plan Approval is to ensure that 

PADEP has verified and documented in the permit record that the proposed Berks Hollow facility will not 

cause or contribute to exceedances of applicable ambient air quality standards at or near our facility. 

Ontelaunee Energy Center Is concerned that the proposed short-term NOx emission limits for the 

Combined Cycle Units (CCUs) detailed in Section E, Source Group ccu, condition #001 of the draft Plan 

Approval are Insufficient to assure compliance with the 1-hr National Ambient Air Quality Standard 

(NAAQS) for NO,. We believe the draft Plan Approval contains two specific deficiencies In NOx emission 

limits that must be corrected. 

• Per condition 11001{c) of the draft Plan Approval, the short-term emission limits for NOx (ppm 

and lb/hr) are expressed as 3-hour rolling averages. 

• No short-term NOx emission limits apply during ccu startups. 

In normal operation and firing duct burners, the Siemens CTs could emit Sib NOx one hour, 69lb NOx 

the following hour, and 5 lb NOx the following hour, and still satisfy the 26.511b NOx /hr emission limit 

when calculated on a 3-hr rolling average. We believe this scenario could easily occur If the facility's 

ammonia supply system experienced a malfunction and ammonia flow to the Selective Catalytic 

Reduction (SCR) units was interrupted. The air dispersion modeling analysis must clearly demonstrate 

that the 1·hr N02 NAAQS will not be exceeded at any point at or beyond the Berks Hollow Energy facility 

fencellne when the two CCUs are each emitting NOx at the rate of 69 lb/hr, and other facility 

combustion sources (such as the fuel gas heater and auxiliary boiler) are In operation. If dispersion 

modeling of such a scenario does predict an exceedance, PADEP must Impose 1-hr average NOx mass 

emission limits at levels that modeling demonstrates no exceedances will occur. (Note that PADEP has 

imposed short-term NOx emission limits on the Ontelaunee CCUs of both a 1-hour averaging time and a 

3-hour averaging time. We believe that PADEP should impose short-term NOx emission limits on the 

Berks Hollow CCUs that are equally protective). 

We are also concerned that the 1-hr N02 NAAQS maybe exceeded during CCU startups, when no shortterm mass emission limits or concentration limits for NOx apply. NOx emission rates from combined 

cycle CTs tend to be highest during. startups, when suboptimum combustion conditions exist in the gas 

turbine's combustors, and when SCR temperatures are still too low to effectively control NOx emissions 

In the CT exhaust. It is also during this time when stack gas temperatures and flow are lowest, leading 

to poor atmospheric dispersion conditions. The Berks Hollow CCUs might conceivably emit 70 lb NOx 

during the first hour of a cold startup, and still be in compliance with all NOX emission limitations In the 

draft Air Plan Approval. The air dispersion modeling analysis must clearly demonstrate that the 1-hr NO, 

NAAQS will not be exceeded at any point at or beyond the Berks Hollow Energy facility fencellne when 

the two CCUs are each emitting NOx at the rate of 70 lb/hr, and other facility combustion sources (such 
as the fuel gas heater and auxiliary boiler) are in operation. If dispersion modeling of such a startup 

scenario does predict an exceedance, PADEP must impose a 1-hr average NDx mass emission limit 

applicable during CCU startups at levels that modeling demonstrates no exceedances will occur. 

In summary, in order to assure compliance with the 1-hr N02 NAAQS at all times, we urge PADEP to 

include limits on NOx concentration and/or mass emission rate during normal operation that are based 

on a 1-hour averaging time, and also include a 1-hour average mass emission rate limit for NOx that 

applies during CCU startups. The specific NOx emission rates for these addltlonal1-hour average limits 

should be based on the results of air dispersion modeling that includes operation of other facility 

combustion sources as appropriate, and Is performed using representative background concentrations. 
JERRY KNOWLES • MEMBER 

124TH U!GI$lATIV€ DISTRICT 

HARRISBURG OFFICE: 

ROOM 155 8 EAST WING 

PO BOX202124 

1-tA.R.RISBURG PA 17120·2124 

PHONE: (717) 787-9029 

FAXc (717) 260-6573 

DISTRICT OFFICES: 

237 WEST BROAD STREET 

TAMAQUA PA 18252-1818 

PHONE: {570) 668·1240 

FAX: (570} 952-3374 

~.ouz.e .of ~.epr.ez.ettfati&.ez Commonwealth of Pennsylvania 

Harrisburg 

Tom Santanna, Director 

Office of Legislative Affairs 

Department of Environmental Protection 

400 Market St, P 0 Box 2063 

Harrisburg, PA 17105-2063 

Dear Mr. Santanna: 

April16, 2013 

A 1Tii ol //IIi "-I T rCOMMITTEES: 

COMMERCE 

GAMING OVERSIGHT 

LOCAL GOVERNMENT 

STATE GOVERNMENT 

E·MAIL: jlrnow!es@pahousugop.eom 

I have received several complaints from constituents in Berks County who are upset with 

the application for an Air Quality Permit submitted by Berks Hollow Power Plant to construct a 

natural gas power plant in Ontelaunee Township. 

My constituents would like the Department to hold a public hearing on their application 

before any permits are issued to discuss the plant function and voice their concerns on this project. 

Because of the serious nature of their concerns, I wanted to bring it to your immediate 

attention. I am writing today to ask that the appropriate officials carefully review this request to 

schedule a public hearing. 

As always, thank you for your attention to this matter. I look forward to your response. 

JPK:Ir 

I 

I 

I 

! 
Attachment G 

Comments received from various commenters via email 

Regarding Berks Hollow Energy Associates, LLC 

Draft Plan Approval No. 06-05150A 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

sjandat3@yahoo.com 

Monday, April15, 2013 12:56 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

purpleabe@hotmail.com 

Tuesday, April16, 2013 12:01 AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone .. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards {NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

bjpease@hotmail.com 

Monday, Apri115, 201311:59 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who Jive in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas Is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

'( 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

s.streng@verizon.net 

Monday, Apri115, 2013 7:24PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

lf 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

Rabold92@aol.com 

Monday, April15, 2013 5:59PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

pslshopper@yahoo.com 

Monday, April 15, 2013 5:25 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane. 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

norberry@fast.net 

Monday, April15, 2013 5:00 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

My reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

7 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

annikapri@earthlink.net 

Monday, April15, 2013 4:49 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint ·of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to. ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

inkless800@aol.com 

Monday, Apri115, 2013 4:48PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to Issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

martin@sustainlv.org 

Monday, April15, 2013 4:47PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

The PA DEP needs to "protect Pennsylvania's air, land and water from pollution and to provide for the health and safety 

of its citizens through a cleaner environment" as per its mission. Clearly, the DEP's actions pertaining to fracking of shale 

formations and the processing and distribution of the resulting natural gas, have been anything but protective of PA's 

environment and citizens. The prospective issuance by the PA DEP of a permit for the Berks Hollow natural gas-fired 

power plant is another step in the wrong direction. That the DEP would permit the environmental and health impacts 

that will result from the proposed power plant in Ontelaunee Township, Berks County, is unconscionable, 

Further, natural gas, which is mostly methane, has a significant impact on climate change. Methane is 105 times more 

potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate 

change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty year timeframe. 

The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that a warmer 

climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

The PA DEP should be including greenhouse gas analyses in their review of power plants and be ensuring that methane 

as well as carbon dioxide emissions are not permitted but should be promoting use of solar, wind, geothermal, microhydro and other sustainable production facilities. 

On a purely technical point, PA DEP should not be issuing a permit until Berks Hollow Energy Associates provides a make 

and model for all of the equipment listed in the permit application and PADEP has performed their technology analysis 

based on specific makes and models to ensure the best technology is required. 

Can the PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs}?. 

This power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. Natural gas itself as well as production 

pollutant add to the global climate crisis. I ask that you deny approval of this facilility. 

Sincerely, 

1 

I •> 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

JYA46@aol.com 

Monday, April15, 2013 4:34PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

,, 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

veracole@comcast.net 

Monday, April15, 2013 4:27PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

brasch@ptd.net 

Monday, April15, 2013 4:25PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I write to request that the Pa DEP hold a public meeting and hearing for the Berks Hollow Power Plant air permit. This 

would allow more local residents to learn about the project, ask questions, and directly communicate with 

representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the public does not always know 

when a project like this power plant is proposed and would greatly benefit from a public hearing and meeting. 

My concern is that the people have not been sufficiently informed about this, and no major meetings have been 

established to give people who are most directly affected adequate time to prepare and research the effects. Certainly, 

if Pa. government is to be as transparent as your governor claims it is, then more opportunity to research and learmn 

can not be a bad thing. 

Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Sincerely, 

1 

I ? 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

katherineminch@gmail.com 

Monday, April15, 2013 4:20PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards {NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

I'( 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

mkeenan1969@comcast. net 

Monday, April15, 2013 4:20 PM 

Hanlon, ihomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

I ' 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

gallag.her@live.com 

Monday, April 15, 2013 4:09 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards {NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

soupyx@gmail.com 

Monday, April15, 2013 4:08 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions·globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

/1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

terzhc@yahoo.com 

Monday, April15, 2013 3:41 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

IS 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

nam5161@aol.com 

Monday, April15, 2013 3:32 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards {NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

I ? 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

laddkidder@gmail.com 

Monday, Apri115, 2013 3:28PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

pawsitive@hometownu.com 

Monday, Apri115, 2013 3:09PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

:'I 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

mberman 116@hotmail.com 

Monday, April 15, 2013 2:59 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

)/ 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

foosballgirl80@gmail.com 

Monday, April15, 2013 2:07PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards {NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

bravenewrays@live.ca 

Monday, April15, 2013 2:03PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

7 'I 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

eric@protectingourwaters.com 

Monday, April15, 2013 1:59PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

?- s 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

kchp58@gmail.com 

Monday, April15, 2013 1:55PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is· mostly methane, has a significant impact on climate change. Methane 

is 105. times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not in.clude a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

wldrose71@yahoo.com 

Monday, April 15, 2013 1 :54 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards {NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

forestgirl57 @gmail.com 

Monday, April 15, 2013 1 :50 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

kelly. finanOB@alumnLjuniata.edu 

Monday, April 15, 2013 1:43 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

skinandscents@hotmail.com 

Monday, April15, 2013 1:36PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

'' _,-, {) 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

aludra@aol.com 

Monday, Apri115, 2013 1:30PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

This power plant will have a dramatic negative impact on the air in its vicinity and in our region. I am extremely worried 

that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns 

about the environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, 

Berks County, PA. I ask that you post-pone your approval of this permit until after some of the following questions are 

answered and until PA DEP has hosted a public hearing and meeting on this facility. This power plant will create 

significant public health and environmental impacts. Air pollutants from this facility are detrimental to the health of 

residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

lizrdgpa@yhoo.com 

Monday, Apri115, 2013 1:26PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards {NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

Blackwolfcries@yahoo.com 

Monday, April15, 2013 1:23PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy ofthis information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

kmayberry@lccc.edu 

Monday, April15, 20131:17 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who Jive in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to Jearn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

5 '( 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

equilibria.llc@gmail.com 

Monday, April 15, 2013 12:57 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking th·e time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

tony@ecovillage.ithaca.ny.us 

Monday, April15, 2013 12:36 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

debbiezlambert@gmail.com 

Monday, April15, 2013 12:34 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

slbritland@gmail.com 

Monday, Apri115, 201312:25 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to Jearn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize / 

compliance with the National Ambient Air Quality Standards {NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

bossybootsbert@gmail.com 

Monday, April15, 2013 12:20 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

:3 'I 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

dougshire@hotmail.com 

Monday, April15, 201311:51 AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

suebern123@aol.com 

Monday, April15, 2013 11:28 AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

'1/ 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

elanshapiro343@gmail.com 

Monday, April15, 2013 11:03 AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy ofthis information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards {NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

dennisjameswilson@gmail.com 

Monday, Apri115, 2013 10:14 AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

jyccmpbll@aol.com 

Monday, April 15, 2013 9:37AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am a resident of Berks County for the past 23 years. During that time, I have seen Berks County change markedly from 

a lovely, bucolic place to live, with many beautiful farms and countryside, small towns and a medium-sized city, to a 

place increasingly dominated by suburban sprawl, toxic waste, and industrialization. In the past few years, despite 

excellent health practices in all respects, I have experienced almost non-stop sinus infections that interfere with my 

ability to work, function, and enjoy life. When I am out of the Lehigh Valley for any lenght of time, they disappear, upon 

returning, I can feel my sinuses close up as soon as we enter the valley. I understand from talking to health care 

providers that asthma and other respiratory diseases are rife in Berks County. I can only despair at how much worse this 

could get if the proposed gas plant is built! 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

1 
\fl{·( 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

2 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

p.m.rose@verizon.net 

Monday, April15, 2013 9:17AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy·Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

'h 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

jol206@lehigh.edu 

Monday, April15, 2013 8:57AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

jenhanf@yahoo.com 

Monday, April15, 2013 8:36AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some ofthe 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

antz1919@ptd.net 

Monday, April15, 2013 8:32AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

To whom it may concern, 

aveli919@live.kutztown.edu 

Friday, April12, 2013 5:22 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely concerned to hear that there is a new natural gas power plant slated for Berks County. As a resident of 

Kutztown, I already worry about the potential adverse health effects associated with East Penn Manufacturing's various 

lead and sulfur-emitting industrial operations, the pollution caused by the Atlas Chemical facility in Mertztown, all 

manner of carcinogens pumped into the air and water from numerous local quarries, railroads, smelters, steel mills and 

foundries--the list goes on and on. In addition to all of these major polluters, the people of Berks already contend with 

the noxious particulate pollution generated at the existing natural gas power plant near the intersection of 222 and 183. 

The EPA has repeatedly warned that Berks' air quality ranks among the worst in the Northeast. But that's. not all. Many 

of us know, or know of, a family which lost a love one due to exposure to toxins lurking underneath Muhlenberg High 

School. Even rural areas aren't immune: mushroom soil and animal manure, and occasionally, diluted human feces, are 

spread on thousands of acres of agricultural fields. If all of this weren't enough, tales abound of hastily-dug, 1950s-era 

battery disposal pits which pockmark the fields of northern Berks and leach a witches' brew of acids and oxides into the 

water table. How much more poison must our neighbors, friends, parents and children ingest before cancers and birth 

defects begin to devastate our communities? When is enough enough? 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

kgeorge@dekabatteries.com 

Monday, April15, 2013 7:55AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

harmswy@yahoo.com 

Sunday, April14, 2013 11:22 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

janesan@comcast.net 

Sunday, April 14, 2013 11 :06 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

naturopath@ecovillage. ithaca. ny. us 

Sunday, April14, 2013 10:41 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

lcferrill@yahoo.com 

Sunday, April14, 201310:41 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

robinfkoch@aol.com 

Sunday, April14, 2013 9:43PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

HELP! I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power 

plant. I have major concerns about the environmental and health impacts that will result from the proposed power plant 

in Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a PUBLIC hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating CLIMATE CHANGE. Natural gas, which is mostly methane, has a significant impact on climate change. 

Compared to coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great 

in a twenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists 

estimate that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. LET"S DO IT RIGHT with an all inclusive review. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

organicallymark@yahoo.com 

Sunday, April14, 2013 9:34PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards {NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

bobnatalini@yahoo.com 

Sunday, April14, 2013 9:24PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried tliat PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

STASHBONKASSOC@COMCAST.NET 

Sunday, April14, 2013 9:22PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs}. 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

peterjonsnyder@yahoo.com 

Sunday, April14, 2013 9:05PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval ofthis permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

)'/ 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

Underwoodrm@yahoo.com 

Sunday, April14, 2013 8:37PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

nutmegaloha@yahoo.com 

Sunday, April14, 2013 8:28PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

jkc1961 @hotmail.com 

Sunday, April14, 2013 6:21 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

(,? 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate.will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

MTRApple@aol.com 

Sunday, April14, 2013 5:51 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

(,} 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

pkarch@enter.net 

Sunday, April14, 2013 5:08PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

NO I NO I NO I ... to another natural gas power plant ... another insult to the environment. The answers to fuel shortages 

capable of meeting consumer demands is obvious: reduce demand by sensible conservation, and an educational system 

that teaches and encourages conservation, backed by non-polluting renewable energy resources. It is certainly not to 

provide more and cheaper fuel to encourage greater and more thoughtless consumption. The only people benefitting 

from that philosophy is the power companies and the politicians they are in bed with I 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Peter Karch, Ph.D. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

skostouf@enter.net 

Sunday, April14, 2013 3:53PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has·hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

pdavid48@gmail.com 

Sunday, April14, 2013 3:46PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

L) ' I ,-, 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

kathiember@gmail.com 

Sunday, April14, 2013 2:15PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am sorry to be sending you a form letter. Like a lot of people, I am very busy, but I am also very concerned about this 

issue. 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

(, / 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

lindakenepaske@aol.com 

Sunday, April14, 20131:30 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

c, ,\' 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

kjsnyder@hometownu.com 

Sunday, April14, 2013 1:17PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

jml122571@gmail.com 

Sunday, April14, 20131:14 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great In a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

dshaffer2200@hotmail.com 

Sunday, April14, 2013 9:52AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

·;I 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely; 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

judbissimm@yahoo.com 

Sunday, April14, 2013 9:43AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

pier2022@hotmail.com 

Sunday, April14, 2013 8:56AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval ofthis station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

dhawkrd@comcast.net 

Sunday, April14, 2013 8:11AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year time frame. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

7 '( 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PA DEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

Janiskauffman@gmaiol.com 

Sunday, April14, 2013 7:43AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to Jearn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate cha'nge. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

anjelsea@aol.com 

Sunday, April14, 2013 7:38AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

)C 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

kojak1415@comcast.net 

Saturday, April13, 2013 10:04 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

., ] 

Just what we don't need--air pollution, particularly methane. As leading environmental scientists are telling us, natural 

gas is not a solution to our energy crisis. I am extremely worried that PA DEP is preparing to issue a permit for the Berks 

Hollow natural gas-fired power plant. I have major concerns about the environmental and health impacts that will result 

from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of 

this permit until after some of the following questions are answered and until PA DEP has hosted a public hearing and 

meeting on this facility. This power plant will create significant public health and environmental impacts. Air pollutants 

from this facility are detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards {NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

ehsilverman@yahoo.com 

Saturday, April 13, 2013 9:44 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

Positivelytowles@yahoo.com 

Saturday, April 13, 2013 6:12 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who Jive in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to Jearn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

anniehasz@gmail.com 

Saturday, Apri113, 2013 4:54PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who Jive in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to Jearn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

lamessino@yahoo.com 

Saturday, April 13, 2013 4:01 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 

'?I 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

sonnema17@yahoo.com 

Saturday, April13, 2013 3:51 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

'iP 

I live in Berks county and am concerned about the fact that the PA DEP is preparing to issue a permit for the Berks 

Hollow natural gas-fired power plant. We have bad enough air quality in this area without adding yet another source of 

pollution. It is important that you take into consideration the environmental and health impacts that will result from the 

proposed power plant in Ontelaunee Township, Berks County, PA. I ask that you postpone your approval of this permit 

until after some of the following questions are answered and until PA DEP has hosted a public hearing and meeting on 

this facility. This power plant will create significant public health and environmental impacts. Air pollutants from this 

facility are detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

ercoli93@me.com 

Saturday, April 13, 2013 3:47 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change, Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

Rabold92@aol.com 

Saturday, Apri113, 2013 2:23 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

canuary@verizon.net 

Saturday, April13, 20131:58 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next' two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs}. 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

videoinnovation@epix.net 

Saturday, April 13, 2013 1:42 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

ceres@hometownu.com 

Saturday, April13, 2013 1:05PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am writing to request that PA DEP hold a public meeting and hearing for the Berks Hollow Power Plant air permit. How 

is it possible that one isn't scheduled before approving a permit for a project as large as this one? A hearing is necessary 

to allow more local residents to learn about the project, ask questions, and directly communicate with representatives 

from Berks Hollow Energy Associates and PA DEP staff. The majority of the public does not always know when a project 

like this power plant is proposed and would greatly benefit from a public hearing and meeting. Again, I strongly 

recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

oscodaartist20 13@yahoo.com 

Saturday, Apri113, 2013 12:58 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am writing on behalf of the nearly 700 concerned citizens supporting a ban on fracking in the Great Lakes region. Our 

members are very concered that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power 

plant. Our concerns are specific to the environmental and health impacts that will result from the proposed power plant 

in Ontelaunee Township, Berks County, PA. We request that you post-pone your approval of this permit until after there 

has been serious research and inquiry into the impacts on human and environmental health that this plant will create. 

The PA DEP should also host a public hearing on this intended action, accepting comments and questions from the 

people of the area, regarding the opening of this facility. People living in this region have the right to be informed of 

significant public health and environmental impacts that will effect them and their families. Air pollutants from this 

facility present hazards to the health of residents who live in this region and downwind. 

Beyond the potential health and environmental impacts, we are concerned about the impact of natural gas pollution 

which has been shown to accelerate climate change. Natural gas, which is mostly methane, has a significant impact on 

climate change. Methane is 105 times more potent as a greenhouse gas than carbon dioxide. When compared to coal, 

the impact of shale gas on climate change is thought to be at least 20% to 50% over a twenty year time period. The gas 

industry is the largest human-made source of methane emissions globally. Scientists estimate that a warmer climate will 

increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, our members are very concerned that the PA DEP did not include a greenhouse gas analysis in their 

review of this power plant. We are requesting that the PA DEP take the time to study this area of potential hazard and to 

provide this information to the public, allowing them to participate in the decision making process being fully informed 

and their good faith in the PA DEP restored. 

Additionally, the PA DEP must not issue a permit until Berks Hollow Energy Associates has provided a make and model 

for all of the equipment listed in the permit application. The PA DEP must perform a technology analysis based on 

specific makes and models to ensure the safety and feasibility of the technology to be employed in this facility. 

We request that the PA DEP ensure that the approval of this station will not deteriorate regional air quality and 

jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). While our concerns apply specifically 

to this proposed site in Pennsylvania, we are acutely aware of the danger presented by the shale gas industry across the 

entire region that has been charged with the care and well being of the Great Lakes. We currently have over 700 active 

members from all of the Great Lakes states, as well as members from other areas of the U.S. and the International 

community. The Great Lakes make up 1/5 of the world's supply of fresh water, and therefore are considered an asset 

belonging to all citizens of the world. Water and air quality standards throughout the region should recognize this 

important truth, and those charged with trust in enforcing those standards should approach their responsibility with all 

due diligence and concern. Our concerns apply to the lakes and all tributaries that nourish them. The air that surrounds 

them, and the millions of human lives impacted by their presence on earth. 

Thank you for taking the time to read and consider our comments. Please keep us informed as to any new decisions 

made regarding public hearings, as well as updates on this permit. 

1 
Sincerely, 

2 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

janewbeck@yahoo.com 

Saturday, Apri113, 201312:22 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon. dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

audreyjsimpson@gmail.com 

Saturday, April13, 201312:17 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

brendan@hometownu.com 

Saturday, Apri113, 2013 11:40 AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

barczman@gmail.com 

Saturday, April 13, 2013 11:19 AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

kellamo@verizon.net 

Saturday, April13, 2013 11:09 AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this Information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

hpmt3@aol.com 

Saturday, April 13, 2013 10:45 AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Weaver, William 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

pksacks@live.com 

Saturday, Apri113, 2013 10:42 AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

How many tragedies will it take before we ban fracking? Right now money is calling the shots. Let democracy take its 

originally-intended course, allow the people to decide. 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have 

major concerns about the environmental and health impacts that will result from the proposed power plant in Ontelaunee 

Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the following questions 

are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power plant will create significant 

public health and environmental impacts. Air pollutants from this facility are detrimental to the health of residents who live in 

this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks Hollow 

Power Plant air permit. This would allow m'?re local residents to learn about the project, ask questions, and directly 

communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the public does not 

always know when a project like this power plant is proposed and would greatly benefit from a public hearing and meeting. 

Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on accelerating 

climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane is 105 times more 

potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change 

footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty year timeframe. The gas 

industry is the largest human-made source of methane emissions globally. Scientists estimate that a warmer climate will 

increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of this 

power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane in 

addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the equipment 

listed in the permit application. PADEP must perform their technology analysis based on specific makes and models to ensure 

the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Weaver, William 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

measbs76@yahoo.com 

Saturday, April13, 2013 10:14 AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have 

major concerns about the environmental and health impacts that will result from the proposed power plant in Ontelaunee 

Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the following questions 

are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power plant will create significant 

public health and environmental impacts. Air pollutants from this facility are detrimental to the health of residents who live in 

this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks Hollow 

Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and directly 

communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the public does not 

always know when a project like this power plant is proposed and would greatly benefit from a public hearing and meeting. 

Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on accelerating 

climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane is 105 times more 

potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change 

footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty year timeframe. The gas 

industry is the largest human-made source of methane emissions globally. Scientists estimate that a warmer climate will 

increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of this 

power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane in 

addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the equipment 

listed in the permit application. PADEP must perform their technology analysis based on specific makes and models to ensure 

the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

pkmmiddleton@gmail.com 

Saturday, April13, 2013 10:03 AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval ofthis permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

'I; 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

karenomara@aol.com 

Saturday, Apri113, 2013 9:54AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

wid rose 71 @yahoo.com 

Saturday, April 13, 2013 9:33AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

minchyrocks@inbox.com 

Saturday, April13, 2013 8:00AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

WBowlhead@aol.com 

Saturday, April13, 2013 5:52AM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I o I 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

aaron@campusactivism.org 

Friday, April12, 2013 11:43 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

george@funantiques. net 

Friday, April12, 2013 11:34 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

email4_mystuff@yahoo.com 

Friday, April12, 2013 11:04 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

Scott@WeldonPiace.com 

Friday, April12, 2013 10:03 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

r 0 .~ 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

Michaeltheartist2@yahoo.com 

Friday, April12, 2013 9:23PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

1 o b 

Natural gas is a fossil fuel that is toxic to drill, frack and transfer. Methane migration and leakage is a primary 

greenhouse gas and cause of global warming. I am extremely worried that PA DEP is preparing to issue a permit for the 

Berks Hollow natural gas-fired power plant. I have major concerns about the environmental and health impacts that will 

result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone 

your approval of this permit until after some of the following questions are answered and until PA DEP has hosted a 

public hearing and meeting on this facility. This power plant will create significant public health and environmental 

impacts. Air pollutants from this facility are detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

garriganbyerly@gmail.com 

Friday, April12, 2013 9:15PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who Jive in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to Jearn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards {NAAQs) . 

. Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

katstoica@yahoo.com 

Friday, April12, 2013 9:14PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change, Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs}. 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

moonirams@yahoo.com 

Friday, April12, 2013 9:10PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

JanaTK720@gmail.com 

Friday, April12, 2013 8:53PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

morningsky!p@yahoo.com 

Friday, April12, 2013 8:51 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

/I ! 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

emilywurth@hotmail.com 

Friday, April12, 2013 8:46PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

II; 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis Includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

keller.james.m@gmail.com 

Friday, April12, 2013 8:31 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval ofthis station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

dawnharris.22@gmail.com 

Friday, April12, 2013 8:05PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

II V 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

mgsatmsc@gmail.com 

Friday, April12, 2013 7:17PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

Lucentempyrean@aol.com 

Friday, April12, 2013 7:15PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

!I!, 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

cdonohoe@earthlink.net 

Friday, April12, 2013 7:14PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

We do not need a natural gas plant in Ontelaunee Township. We do not need a natural gas plant at alii What we need 

are investments in renewable energies, not fossil fuel energies that contribute to air pollution, climate change, and 

environmental devastation. I am extremely concerned to learn that a permit may be issued for such a power plant. Our 

air quality is already poor. The VOCs emitted from a natural gas-fired plant will only make it worse. 

I insist that a public hearing be held before any permit is issued and before any steps are taken to further this project! 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

valliesong@yahoo.com 

Friday, April12, 2013 5:50PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

1}8 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

karen.feridun@gastruth.org 

Friday, April12, 2013 4:01 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

/17 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval ofthis permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Permitting Chief Thomas 

matthewblkwalker@gmail.com 

Friday, April12, 2013 3:39PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Westmoreland County, PA. I ask that you post-pone your approval of this permit until after some 

of the following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This 

power plant will create significant public health and environmental impacts. Air pollutants from this facility are 

detrimental to the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

melissa@mtwatershed.com 

Monday, April15, 2013 4:32 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

Regions across Pennsylvania experience periods of air inversion where moisture and air pollutants become trapped 

below a layer of cold air as the weather changes throughout the day and seasons. This air inversion puts southwest 

Pennsylvanians at risk of ground level ozone exposure in addition to the many toxins emitted by the plant. 

r z 1 

This plant will be supplied via regional shale gas wells developed using hydraulic fracturing that entails heavy truck 

traffic, methane migration, flaring, chemical evaporation, and diesel equipment emissions. Thousands of more shale gas 

wells will be needed to supply the plant. Cryogenic processing plants, dehydrator stations, compressor stations, 

metering stations, and pipeline construction are required to process and transport the gas. Once the plant is online, 

additional compressor station engines will be needed to replace the pressure lost in gas transmission lines. 

Asthma patients exposed to the plant's emissions could be triggered into fits, more asthma patients may be diagnosed, 

and children with developing lungs and seniors with respiratory disorders are disproportionately at risk. It is foolishness 

to allow this type of facility to emit carbon monoxide, formaldehyde, volatile organic compounds, nitrogen oxides, 

hazardous air pollutants, particulate matter, sulfur oxides, sulfuric acid mist, and greenhouse gases. 

This is public endangerment and neglect at best, especially considering that cumulative air emissions are not considered 

for each new permit even though each new facility contributes to the cumulative 'toxic load' in our air. All of the 

required gas infrastructure and cumulative air quality impacts should be considered part of the permit application and 

review process. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

neeron631 @yahoo.com 

Tuesday, April16, 2013 2:58PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant-is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critiGal decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

Bonisham@yahoo.com 

Tuesday, April 16, 2013 5:58 PM 

Hanlon, Thomas 

Comment regarding Title V Plan Approval No. 06-05150A 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

My main reason in writing to the Department is to request that PA DEP hold a public meeting and hearing for the Berks 

Hollow Power Plant air permit. This would allow more local residents to learn about the project, ask questions, and 

directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority of the 

public does not always know when a project like this power plant is proposed and would greatly benefit from a public 

hearing and meeting. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy of this information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Wilkes, Dawne 

From: 

Sent: 

To: 

Subject: 

Mr. Hanlon 

maxinemac@yahoo.com 

Sunday, Apri114, 2013 10:29 AM 

Hanlon, Thomas 

Title V Plan Approval No. 06-05150A: Residents Should Have A Say!!! 

I z 'I 

Pennsylvania state government has got to start standing up for the rights of PA citizens to live in a healthy environment, 

with clean air and water, and stop the destruction of our lands by international corporations who have no concern for 

the quality of our lives. 

I am extremely worried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I 

have major concerns about the environmental and health impacts that will result from the proposed power plant in 

Ontelaunee Township, Berks County, PA. I ask that you post-pone your approval of this permit until after some of the 

following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power 

plant will create significant public health and environmental impacts. Air pollutants from this facility are detrimental to 

the health of residents who live in this region and downwind. 

I ask that PA DEP hold a public meeting and hearing for the Berks Hollow Power Plant air permit. This would allow more 

local residents to learn about the project, ask questions, and directly communicate with representatives from Berks 

Hollow Energy Associates and PA DEP staff. The majority of the public does not always know when a project like this 

power plant is proposed and would greatly benefit from a public hearing and meeting. Again, I strongly recommend that 

you hold a meeting and hearing on this power plant. 

Beyond the potential health impacts, I am also concerned about the life-cycle impacts of natural gas pollution on 

accelerating climate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane 

is 105 times more potent a greenhouse gas than carbon dioxide over the next two most critical decades. Compared to 

coal, the climate change footprint of shale gas is at least 20% greater and possibly more than twice as great in a twenty 

year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate 

that a warmer climate will increase the frequency of days with unhealthy levels of ground-level ozone. 

For these reasons, I am very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of 

this power plant. I request that PA DEP provide a copy ofthis information and ensure that this analysis includes methane 

in addition to carbon dioxide. 

Also, PA DEP cannot issue a permit until Berks Hollow Energy Associates provides a make and model for all of the 

equipment listed in the permit application. PADEP must perform their technology analysis based on specific makes and 

models to ensure the best technology is required. 

I also request that PA DEP ensure that the approval of this station will not deteriorate regional air quality and jeopardize 

compliance with the National Ambient Air Quality Standards (NAAQs). 

Thank you for taking the time to read and consider my comment, and please respond back with any decisions on public 

hearings or updates on this permit. 

Sincerely, 

1 
Attachment H- Comment and Response Document 

Regarding Draft Plan Approval No. 06..05150A 

for Berks Hollow Energy Associates, LLC 

Facility Proposed for Ontelaunee Township, Berks County 

#: · Comment:· Res onse 

Commonts rocolvod from Berks Hollow via Iotter dated 415/13 

1 C 006: The condition limits emissions of HAPs to less than 4.8 tpyfor a single HAP (formaldehyde) and 11.3tpy of DEP has not made the requested Change. Recent plan approvals issed to Moxie Energy LLC and Hickory 

total HAP. Because the Berks Hollow Energy Station (BHES) project (the Project) is an area source of HAPs (ie, less Run Energy LLC have included a site specific limit on the total HAPs which can be emited from the fac!JJty. 

than 10 tpy of a single HAP and 25 tpy of total HAP) tho proposed limit Is unnecessarily restrictive. SHEA requests In addition, the Hickory Run Energy LLC plan approval contains a limit on the individual HAP formalohydo. 

that tho limits be changed to 10 tpy of a single HAP and 25 tpy of total HAP to be consistent with the definition of an 

aro:<:~ source. 

2 E SG CCU 001: The condition, In part, limits emissions of ammonia (NH3) to 5 ppmvd@ 15% 02, and less than The condition has been changed. The NH31imits are 104.46 tpy for the GE 7FA and 107.92 tpyforthe 

77.45 and 80.47 tpyfrom the GE 7FAand Siemens F units, respectively, DEP based the annualllmiton the Siemens F. 

maximum hourly emission rates for the fired (ie, duct burners on) and unfired (ie, duct burners off) cases, which are 

presented in Table A-13 and A-14 of Appendix A of the Application, and the hours of operation for each case 

presented in Table A-2, 

The hours of operation in Table A-2 were used specifically for calculating worst case emissions for pollutants which 

are products of combustion Including emissions during startup ond shutdown. Because NH3 Is not emitted during 

startup and shutdown operations, the approach for calculating worst case annual emissions is different than that 

presented in Table A-2. Specifically, since tho hours for startup (maximum of 500 hours) and shutdown (maximum of 

SO hours) are upper bounds, the combinad cycle units will run for more than the 8200 hours (7365 hours normal 

operation, 835 hours with duct burners fired) presented in Table A-2, the absolute worst case annual emissions 

should be calculated by assuming tho highest hourly emission for the maximum possible annual operating hours 

(8760 hours). Based on this approach the annual emission limit for NH3 should be calculated as follows:.[see 

comment letter for calculation]. BHEA requests that DEP delete the condition llmltlng NH3 onnual emissions since a 

5 ~~~~~tb: ~~l~ded as part of Conditio~:~~~~~~~~ ,Insists on Including an annual limit, SHEA requests that the 

NHII!';stas F:>~ "'F 

3 E SG PM2.5 001: The condition requires annual stack testing for PM2.5 (EPA Methods 202 and 5) both with duct The condition has been changed to require annual stack testing for PM2.5 with the duct bumers off and 

burners off and on. Duct burners will be operated typically during periods of peak power demand only, making it testing once every five years while the duct burners are operational. 

difficult to predict when duct burners will be operated. Operating duct burners expressly for the purpose of stack 

testing may result in significant costs to BHEA, particularly during periods of low power prices. Because of this 

uncertainty, BHEA requests that the condition be changed to require stack testing no more than once per five (5) 

oar PEtriod 

4 ESC STARTUP & SHUTDOWN 002: The condition defines shutdown as 'the period beginning with lowering of unit The condition has been changed to read: (c) For the GE 7F5A combustion turbin& shutdown is defin&d as 

. 

load below 60% with the Intent of ceasing operation ... ' Tho GE ?FA combustion turbines are capable of turning down the pl!ln'od beginning with the lowering of unit losd below 50"A with the Intent of ceasing o~ratlon of the unit 

to 50% toad during normal operation. As such, BHEA requests the condition be changed to read 'the period and concluding with the:t cessation of combustion in the turbine, limited to a maximum of one hour in 

beginning with lowering of unit load below 50% with the intent of ceasing operation duration. (d) For the Siemens F combustion turbinfl shutdown is defined as the period beginning with the 

lowering of unit load below 60% with the Intent of cessing o~ratlon of th& unit end concluding with the 

cessation of combustion in the turbin&, limited to a maximum of one hour In duration. 

Comments rocoivod from EPA Ro lon Ill vi~ lottcrdl!tod 4/9113 

5 1. Emission Offsets: Tho proposed facJIIty is subject to the Nonattainment New Source Review (NNSR) The ERC provisions in the plan approval will be modified to reflect the restriction expressed in this 

requirements because the facility is located In an ozone transport region and has the potential to emit greater than comment. 

100 tons of NO xand 50 tons ofVOCs in any consecutive 12 month period. Therefore, a purchase of Emission 

Reduction Credits (ERCs) to offset tho NOx and VOC emissions Increases is required. According to Pa. Code 

127.208, an owner or operator of a facility shall acquire ERCs for use as offsets from an ERC generating facJllty 

located within the same nonatt8inment area As NOx is considered a precursor to PM2,5, the NOx ERCs must be 

obtained from within the PM2.5 nonattainmont ::..ro:!l th:<:~t Include$ S~rk~ {;qu~tv. Penn~ lvania 

6 2. BACT/LAER anal}'3cs: EPA does not believe that the Technical Reviaw Memo (TRM) and proposed plan The addendum memo (attached to this C&R document) Includes an expanded discussion of the 

approvol sufficiently describe the Best Available Control Technology (BACT)ILowest Achievable Emissions Rate BACT/LAER reviaw, as requested by this comment 

(LAER) analyses that were performed. In a BACT analysis, the reviewing authority should evalu8te the energy, 

environmental, economic and other costs associatad with each alternative technology, and the benefit of raduced 

emissions that the technology would bring, The revlawlng authority then specifies emissions limitations for the source 

that reflects the maximum degree of reduction achievable for each pollutant regulated under the Clean Air Act. The 

plan approvol conditions must reflect all operatlonollimitations in order to show compliance with these emissions 

limitations. The~~~~~~~~~~~~~!~~. top..down BACTILAER options and an analysis for why the chosen emission 

controlo:: meet the A Tl an r . 

7 3_ NOx controls: The record Indicates that the use of dry 10w-NOx (OLN) combustors and Selective Catalytic The plan approval requires the use of control equipment during periods of startup, shutdown, and 

Reduction (SCR) would fulfill LAER for NOx and BACT for N02. Tho analysis also Indicates that the use of oxidation malfunctions as part of 40 CFR 60.4333 (Subpart KKKK). Additionally, The Plan Approval includes 

catolysts would constitute LAER for VOC emissions and BACT for CO emissions. However, the plan approval does Condition #OOS(c) under Section E, Group Name CCU, whiCh requires operation of the air pollution control 

not appear to require the operation of these controls at all times when the combustion turbines and duct burners are devices at all times during normal operotlon and reads as follows: "The permittee shall operate the control 

operating. Since these control devices are necessary to meet the required emission limits, the plan approval should devlce(s) at all times this source is in operation once operating parameters (temperature, now, etc.) ara 

req1,1ire tho Qwration of the controls at all times sufficient for proper control device operation." 

8 4, Greenhouse Gas {GHG) pollutants: EPA has the following concerns: a, The TRM and proposed plan approval The plan approval will be revised to include a facility wide GHG (C02e) limit. Compliance with the facility 

do not sufficiently address all GHG pollutants. GHG emission limits should account for not only C02, but for all of the wide limit will be shown by using emission factors in Tables C-1 and C-2 of Part 98 and the global warming 

GHGs that are omitted (methane, nitrous oxide, SF6). Please also clarify how compliance will be demonstrated for potentials In Table A·1 of part 98 along with the heat Input for the sources. SF6 emissions will be 

eaCh of the GHGs. The plan approval, as currently written, does not include sufficient requirements or means of accounted for whenever the facility has to add SF6 dielectric fluid to each circuit breaker unit 

colculation to ensure com liance with the CQ~e limits. _ --·-·--·-·-

Page1of11 

'Chan e· to· Permit?: 

No 

v., 

v., 

v., 

Yos 

No 

No 

v., 
Attachment H - Comment and Response Document 

Regarding Draft Plan Approval No. 06-05150A 

for Berks Hollow Energy Associates, LLC 

Facility Proposed for Ontelaunee Township, Berks County 

gas as a fuel. However, only the "0xpected 

Miscellaneous section and not in the Source Level 

should be reflected properly in the plan approval conditions 

limits, Additionally, there is a discrepancy In the description of the expected 

Auxiliary Boiler in the TRM. The TRM notes on that "Once the gas turbinas are at steady-state 

be taken off line." Sin00 the TRM and the plan approval define start-up and shut-down 

and limit those to 500 hours and 60 hours per year each, it would make sense that the 

only operate for 560 hours per year. Please explain the additional expecte? hours of operation 

operations and startup and shutdown times, add up to more than 

l

tpy. This limit is just below the ma]or source threshold for PM2.5. If PM2.5 is not precisely measured during all 

operating times, Including startup and shutdown, thls limit is highly suspect. 

bollerwllt be used to provide steam when the CCU are offline to 

combined cycle startup following extended shutdowns. Since 12-month rolling 

established for each pollutant, we do not believe a condition limiting the hours of 

the Plen Approve/ will be 

of fuel burned. The emission limits are based on e fuel sulfur content of 0. 68 gr/1 00 

15 ppm for fuel oil, ThE! fuEl! sulfur content of the natural ges will be determ/nOO 

fuel monitoring plan as described In Section E, Group Name KKKK, Condition# 015 of 

. . Fuel sulfur content data for natural gas and fuel oil will be provided by ell fuftl suppliers 

I periodically. As re;quired by the Plem Approval, daily records of fuel consumption will be meintelnOO to 

ensure that 12-month rolling tote! emission limits for S021SOx ere not exceeded. In fact, fuel consumption 

the CCUs, fuel heater, Md auxiliary bolter will be recorded on a nearly continuous be sis using B 

end date Bcquisition system. Based on this approach, BHEA does not believe any 

ing re;quirements ere n~SS8ry to ensure compliance with the S02/SOx emission 

Jepartment concurs with this responsa. 

during normBI operations end 

on OEM dato for stBrtup Bnd shutdown periods, which Is also the basis 

ld In Tobie A-2 of Appendix A of the Appi!CEJtion. MBximum potentiBI 

of PM2.S from startup and shutdown opl!lrtltions is approximBtely 2% of the facility-wide 

PM2.S emissions, Bnd ectuB/Bnnual emissions will typiC811y be much !ftss thBn permitted since startup and 

shutdown opemtlons will typ/ClJIIy occur less than the limit of 500 en nuB/ hours. Since PM2,5 emissions are 

a result of fuel combustion and no post-combustion controls Bra necessery, PM2.S emissions ere expected 

to be consistent Bnd proportionBI to the amount offual burned. For this reBson Bnd the fact that fuel flow to 

the turbines will be monitored continuously, direct continuous monitoring of PM2.5 is not necesSf.lry or 

- -··-- L •- &Jceusa tha PM2S limit for each emissions source represents the worst C8Sa amiss/on rate, 

with the PM2.5Jimits for each emissions souf'C(J will ensure that fecJI/ty-wide emissions will be 

threshold for PM2.5 of 100 tpy. As a result, BHEA does not believe Bny BddltlonBI 

y to ensure thBt fBc/1/ty-wide PM2.5 emissions Bre below the major SOUI'C(J 

The Department concurs with this response. 

Page 2 of 11 
Attachment H ~Comment and Response Document 

Regarding Draft Plan Approval No. 06-05150A 

for Berks Hollow Energy Associates, LLC 

Facility Proposed for Ontelaunee Township, Berks County 

#: : Comment· R&s onse •;;; 

18 9. Missing Soctlon from tho proposod plan approv.ml: Tho propoood pion approval Is missing Section G for listing Tho roquostod soction hos boen o.dded to the plan approval. 

"Emission Restriction Summary" for all pollutants from all emission units. Please provide this section in the plan 

approval for ease of compliance assurance. A similar facility recently permitted by PADEP, Hickory Run Energy, LLC, 

has a plan approval drnftod by Northwest Regional Office that conbins such a section. The proposed plan approval 

is also missing Section F, titled "Alternative Operating Scenario(s)" in the table of contents. 

19 10. Missing SIP roqulromont: Pennsylvania's State Implementation Plan (SIP) at 40 CFR 52.2020 Includes the The requested requirement has boon added to the plan approval. 

general standard against oir pollution cod~ed at 25 Pa, Code § 121.7. This general standard states that ''No person 

may permit air pollution as thst term is defined in the act." Pa. Code 127.502(s) requires that opplicable requirements 

for stationary air contamination sources shall be included in the operating permit The definition of "applicable 

requirements" at Pa. Code § 121.1 includes any standard provided for In the Commonweslth's SIP, In Pennsylvania's 

merged permitting program, applicable requirements of a plan approval are administratively brought into the title V 

permit; however, since this is a new facility, it has no current title V permit. We note that the plan approval should 

I ~~~~:a the general ~~:nt~ard In orde;t!~~~~itate that requirement being Included in the title V permit, When issued to er !l Hollow will h:;~v hf} Q¢r'lt;~ml an a In It 

EPA Comments on Modolln Ro ort from 4/9113 fottor: 

20 Section 2.1.1 Combined Cyclo Unlts: NOx controls on the combined cycle combustion turbine generators imposed See the responses to Comments 21, 22 and 27. Also, In a submission to DEP dated 8119/13, Berks Hollow 

under PM-2.5 nnd/or ozone should be operated year round to ensure compliance with the N02 NAAQS. states WOx cantrofs (I.e., Se11ective Cetalytic Reduction) will bel opersted yesr round and during all periods 

of normal operations, but will not be opersted during periods of stertup end shutdown as the temperature of 

the exhaust gss will be below thst requlrod for opemtlon of the SCR system." Furthermore, Condition 

005(c) in the CCU group of the plan npproval states "The permittee shs/1 operste the cantrol device(s) Bt all 

times this source is In operotion once oporotJng parameters (t~mpersture, flow, etc.) are suffident for proper 

control devfce opemflbn. " 

21 Soctlon 2.3 Appllcablo Pollutants: PADEP should consider Berks Hollow's potential impact on curront P¥-2.5 From a permitting perspective, the proposed Berks Hollow facility will be located in the Reading, PA PM-2.5 

concentrations in Berks County. While its PM-2.5 contributions may be minimal, Berks Hollow may impact the nonattainment area and therefore subject to the Nonattainment New Source RoviGW requirements for PMcounty's mtainmont status under the 1997 NAAQS and EPA's revised PM-2.5 NAAQS. 2.5. The projected PM-2.5 omissions from tho proposed Berks Hollow facility are less than the major 

source threshold of 100 tons per year (tpy). According to planning staff In the Division of Alr Resource 

Manag<:~ment, the DEP can consider the potential impact of the proposed Berks Hollow facility on continued 

attainment with tho 1997 PM-2.5 NAAQS In tho process of finalizing tho mninton<mce plan for tho RMding, 

PA PM-2.5 area. The EPA allows states to use an emissions test for maintenance. Maintenance is 

demonstrated when the total actual projected emissions of the area in the maintenance year (2025) and 

interim year (2017) do not exceed tho lovellp..tho attainment year (2007), In regard to the revised PM-2.5 

NAAQS, the DEP is in tho process of preparing recommendations to the EPA for area designations and can 

consider tho proposed Berks Hollow facility in making those recommendations, 

22 Section 3.6 Receptor Data Description: Model peaks in the base load runs for the GE ond Siemens combustion Initially, the Berks Hollow 1-hour N02 NAAQS analysis considered all receptors at which Berks Hollow was 

turbines occurrod outside tho fin<:~ Cartesian model receptor grid that extended approximately 1 km from the Berks prodictod to have a significant concentration (based on the 1-hour N02 significance analysis), along with 

Hollow facility. It appears that the modo! receptor grid was revised in tho N02 NAAQS and Increment Runs to additional receptors placed 100 meters apart around distant Isolated significant receptors. The Berks 

oxamino tho area near the highest modeled concentration. It would be helpful if PADEP could address how the model Hollow 1-hour N02 NAAQS analysis was then refined in a subsequent model run that Included additional 

receptor grids capture the maximum modeled concentrations In accordance with section 7.2.2 (a) of Appendix W. receptors placed 100 meters aport around the location of the controiilng 1-hour N02 NAAQS concentration, 

Section 4. 1. The location of the controlling 1-hour N02 NAAQS concentration is approximately 8 kilometers (km) from 

the proposed Berks Hollow facility. The DEP believes that a receptor spacing of 100 meters is sufficient to 

capture tho maximum 1-hour N02 modeled concentration at this distance from the proposed facility 

The Berks Hollow annual N02 NAAQS and increment analyses also considered all receptors at which 

Berks Hollow wa.s predicted to have a significant concentration (based on the annual N02 significance 

analysis). These significant receptors are located within a few hundred meters of the proposed Berks 

Hollow facility, In an area where the receptor spacing In the significance analysis wa.s 50 meters. The DEP 

believes that a receptor spacing of 50 meters is sufficient to capture the maximum annual N02 modeled 

concentration at this distance from the proposed facility. 

23 Significant Impact Analysis: Do the load scenarios described in this section include duct firing {described In The lo.:Jd scenarios described in section 4.1 of tho Berks Hollow Modeling Report (January 30, 2013) 

Section 3.5)? For example, can the combustion turbines bo fired at 100% with or without duct firing and would the account for firing of the duct burners. Tobie A-2, Table A-14, and Table A-15 in Appendix B of the Berks 

stack parameters and emission rates change botv.roon those two potential oporoting modes? Hollow Modeling Report provide the emission rates and associated stock parameters for various opernting 

loads, with and without firing of the duct burners, for both the GE and Siemens combustion turbines. As 

indicated by these tables, the emission rates and associated stack parameters differ, for example, when 

comparing tho combustion turbines at 100 percent load with and wlthout firing of the duct bumers. 

24 Stack parameters for the GE and Siemens combustion turbines are quite similar. Old PADEP confirm the similarity In DEP did confirm the similarity in emissions profiles for Berks Hollow's GE and Siemens combustion 

emissions profiles for Berks Hollow's GE and Siemens combustion turbines for all pollutants? turbines. Because of the similar size and heat input of the two types of turbines, the stack parameters aro 

similar. Tables A-14 and S-15 of the application present the emissions for each ooeratina scenario. 

Page3of11 

Chan e to·Permit? 

y, 

Yes 

No 

No 

No 

No 

No 

No 
• 

Attachment H ~Comment and Response Document 

Regarding Draft Plan Approval No. 06-05150A 

for Berks Hollow Energy Associates, LLC 

Facility Proposed for Ontelaunee Township, Berks County 

Comment R&S onsc-: :1·: 

25 Section 4.1.3 N02 Slgnlflc~nco: How long do startup/shut down cycles typically last and how long does it take for According to BHEA's 8/19/13 letter "startup/shutdown cycle durations will vary bes~d on smbil!lnt 

the NOx control equipment to become fully functional? conditions, temperoture of the equipment end other rectors. It is anticipated that typical stertups will/est less 

than 2 hours, but startup durotions mey be longer for cold starts end short~rfor hoVwsrm starts. For this 

reason, en ennuellimlt of 500 hours Is appropriate to account for varietions in startup frequency end 

duretion. Shutdowns w/llusuDIIy /sst less than 30 minutes, but msy be shorter at times. H The DEP accepts 

this response. According to a 9/13/13 email from SHEA "The NOx control equipment (SCR) depends on 

two peremrJf(Jrs to be fully functional: 1) exhaust ges temperature end 2) ammonia injection. Ammonie 

Injection will be initiated by th~ distributed control system (DCS) when the exhaust tempereturo roeches the 

minimum required operating tempereture for the SCR, et which po/nt NOx will b~ converted to nitrogen end 

wster by the action of the emmonia and catalyst. Since the SCR is a static component of the HRSG, there is 

no "startup" procedure for it. As a practical metter emmonis injection will commence after the sterlup period 

at 50% /oed for the GE 7FA end at 60% for the Siemens F." The DEP accepts this response. 

26 Berks Hollow could have used PVMRM or a Tier 2 ambient ratio in its significance analysis to reduce the radius of In regard to the use of the Tier 3 Plume Volume Molar Ratio Method (PVMRM) or a Tier 2 ambient ratio, 

influence used to identify off-site sources for its cumulative analysis. The off-site Inventory could also have been Berks Hollow chose to perform a more conservative analysis to determine its 1-hour N02 area of significant 

reduood (in number) considering the closeness of the background monitoring site to Berks Hollow. Many of the impact by using the Tier 1 approach described in subsection 5.2.4 of the EPA's "Guideline on Air Quality 

smaller sources are probably adequately accounted for in the N02 background conoontration. See section 8.2.3 of Models' (Guideline), codified as 40 CFR Part 51, Appendix W. This decision and the decision to include 

Appendix W for additional guidance on this topic. many of the smaller NOX emission sources in the model likely yielded a more conservative estimate of the 

INn; '"; "" '"''' 'NAAM, · 27 Soctlon 4,3,1 1-hr N02 NAAQS: The report discussed the modeled 1-hr N02 NAAQs violations noted in the Berks According to the EPA's policy, the issuance of the Berks Hollow plan approval is not dependant on the DEP 

Hollow modeling analysis. EPA Region 3 would like PADEP to address these violations in more detail. The modeling addressing modeled NAAQS violations. The EPA Region II! agrees with the DEP that the Berks Hollow air 

analysis adequately demonstrates that Berks Hollow is not causing or significantly contributing to any modeled qualtty analysis adequately demonstrates that Berks Hollow's proposed NOX emissions will not cause or 

violations. EPA Region 3 conducted some additional analysis using Berks Hollow's NAAQS and Increment N02 runs. significantly contribute to air pollution In violation of the 1-hour N02 NAAQS. That said, the DEP intends to 

It appears that two sources are contributing to the modeled N02 violations. These sources are the Titus Generating address the modeled violations in accordanoo with the EPA's July 5, 1988 memorandum from Gerald A 

Station in Cumru Township and Lehigh Cement on Evansville Road. Emison, 'Air Quality Analysis for Prevention of Significant Deterioration (PSD)." 

28 Titus Station: This facility is slated to close in the next couple of years. This should eliminate any modeled 

violations attributable to this source once closure Is confirmed and finallzed. 

29 Lohlgh C<Jmont: The modeled emission rata used by Berks Hollow was roughly 2,622.85 tpy (75.4 g/s). Actual NOx 

emission rates from 2009-11 taken from PADEP's eFACTS system ranged from 1,146 tpy in 2010 to 1,610 tpy In 

2009. NOx emissions prior to 2009 exceeded 2,000 tpy. Running Lehigh Cement using 2009 actual (annual) 

emissions reduoos modeled concentrations from 224 ug/m3, which exceeds the standard of 188 ugfm3, to 172 ug/m3 

(without background). Reducing Lehigh Cement's allowable emission rme to reflect actual emissions over the last 

three (3) years mav eliminate the modeled violations, PADEP should investi~ate this osslbilit . 

30 Section 6.1 Air Quality Related Values (AQRVS): Berks Hollow should include the Q/d values for each of the Class According to section 3.2 (Initial Screening Criteria) of the 'Federal Land Managers' Air Quality Related 

! areas in a table or appendix. Values Work Group (FLAG) Phase I Report- Revised 201 0,' the Federal Land Managers (FLM) consider a 

source to be located greffier than 50 km from a Class I area to have nagliglble Impacts with respect to Class 

1 air quality related values (AQRV) if its total 502, NOX, PM-10, and sulfuric acid mist (H2S04) annual 

emissions (Q, in tpy, based on 24-hour maximum allowable emissions) divided by the distance (D, in km) 

from the Class I area is 10 or less. Berks Hollow's annual emissions (Q) is equal to 656.56 tpy based on 

the following: 46.51 tpy of S02 plus 486.24 tpy of NOX plus 116.79 tpy of PM-10 plus 7.02 tpy of H2S04. 

The Berks Hollow Q/D value for each nearby Class I area is provided in the following table: 

Class I Area Barks Hollow Distance Q/D 

to Class I Area (km) 

Brigantine Wilderness -151 656.46/151 .. 4.3 

Shenandoah National Park -251 656.461251 .. 2.6 

Dolly Sods Wilderness -331 656.461331 ""2.0 

Otter Creak Wilderness -354 656.46/354"' 1.9 

James River Face Wilderness - 437 656.46/437 "' 1,5 

31 Section 6.2 PSD lncromont: PADEP should provide more explanation why Berks Hollow was exempted from the The DEP determined that It was not necessary for Berks Hollow to perform a Class I increment analysis for 

Closs I increment analysis. N02 and PM~10 by executing AERMOD with Barks Hollow's proposed emissions of NOX and PM-10 (GE 

and Siemens combustion turbines), Class I area receptors provided by the FLMs, and 2006-2010 

meteorological data from Reading Regional Airport (KRDG). Due to its steady-state assumptions, 

AERMOD should provide overly conservative estimates of Berks Hollow's N02 and PM-1 0 Impact In Class I 

areas, all of which are located well beyond AERMOD's ovaluated near-field range of 50 km. The DEP 

compared Berks Hollow's estimated N02 and PM-1 0 Impacts to the EPA's proposed Class l area significant 

impact levels (SIL) (see 61 FR 38250, July23, 1996) for N02 and PM-10. All impacts were well below the 

EPA's ro osed Class! area SILs. 

Comments rocolvod from tho Cfoan Air Council v/o fottordotod 411.5113 

Page4of11 

Chan <!l'to Permit?· 

No 

No 

No 

No 

No 
• 

Attachment H ~Comment and Response Document 

Regarding Draft Plan Approval No. 06~05150A 

for Berks Hollow Energy Associates, LLC 

Facility Proposed for Ontelaunee Township, Berks County 

Comment·· R~$ Ot"l!le ' 32 1. PA OEP may not issue the Plan Approval until It has determined that tho sources comply with applicable SHEA's Plan Approval Application contained all that was necessary to perform a thorough technical 

regulations, which it cannot do without knowing the make and model of tho sources ... Berks Hollow has not provided evaluation of tho air contaminant aspects of the sources associated with the project as speclfled in the 

a make or model to PA DEP for the combustion turbines, at the very least. Without access to the application It Is Department's draft Technical Review Memo. Information regarding make and model of the air contaminant 

unclear whether thoro are other sources whore the make and model have also not boon provided. The turbines, at souroos as woll as manufacturer con bo provided, but Is not nt'lcessarlly nooded by tht'l Departmt'lnt to 

the very least, meet the definition of a 'source' and must comply with the 'appllcable requirements." Although Berks perform a through technical evaluation of the air contaminant aspects of the sources associated with the 

Hollow has Indicated that the Station will contain those sources, the precise pieces of oqulpmont have yet to be project. The information in SHEA's Application included, in many cases, specific manufacturers and 

specffied. The application thus omitted information crucial to showing that the sources would comply with applicable models, and in other cases descriptions of the specific types of control equipment (such as SCR controls for 

air roquiromonts, meaning PA DEP may not approve it. PA DEP should find the application incomplete and refrain NOx) and the specific operating performance criteria of such units. This infoi"IT\l'ltion is sufflciant to 

from acting on it until Berks Hollow submits the make and model of pollution sources to be Installed. datermine tho operating characteristics, emission characteristics, and expected control performance of each 

of the emission units proposed for the Facility. The Department requires BHEA to incorporate the 

engineering designs for tha air contaminant aspects of a source that are specified in the Plan Approval. 

BHEA has proposed two combustion turbine generator ('CTG') options for this project. They are listed in 

the Application as to manufacturer and model as follows. 

• General Electric 7FA 

• Siemens SGTS-SOOOF 

These CTG options have emission profiles provided by the manufacturer for the model chosen. Using 

those emission profiles for each CTG option and general design criteria for the control equipment, BHEA 

proposed emission limitations and control technologies that would satisfy BACT, LAER and BAT. The 

Department has evaluated proposed emissions from each of the two models. Each CTG option was 

evaluated separately in the air dispersion modeling analysis. The Plan Approval contains emission limits 

specific to the make and model. Tha Facility will be required to use control equipment that meets the 

design criteria they used in determining the emission limits. In summary, the level of detail In the 

Application was sufficient to make the required demonstration that the sources In the project will comply 

with aoolicable foo'eral and state air reo;ulatlons 

33 2. It is illegal, arbitrary, and capricious for PA DEP to declare an undetermined source to be BACT. Applicants for a See the Response to Comment 32, above. In addition, the Department responds as follows: 

plan approval must show that 'the emissions from a new source will be the minimum attainable through the use Of the SHEA's Application and the Plan Approval include BACT limits that were established In accordance with the 

best available technology.' applicable PSD BACT requirements for each pollutant specific to each CTG unit. The application provided 

information sufficient for the Department to consider the expected emission characteristics of each emitting 

source and the systemic effects of emissions control parameters. Each air emission source was detailed, 

allowing a consideration and analysis of the available control options in the required "top-down" 

methodology. 

Tho comment is incorrect In asserting that the Department lacks the make and model of the CTGs and 

therefore cannot make 3 BACT determination. Although the Department's regulations do not require the 

make and model of every piece of equipment, in this case, the specific make and model Information for tha 

CTG units was provided in the Application. In turn, after application of the top-down analysis of control 

methods, BACT limits were listed for each option, and the public was afforded an opportunity to review and 

provide comments on the proposed BACT limits. There is no EPA regulation, guidance, case law, or 

precedent that would prohibit DEP from listing BACT limits applicable to more than one equipment option In 

a PSD permit, and the comment does not mention any specific Issues with the BACT limits that were 

established for the various CTG options. Recent PSD permit precedents that have authorized multiple CTG 

equipment options or do not specify the exact model of CTG. In summary, the level of detail in the 

Application was sufficient to make tha required demonstration that the control technologies and associated 

34 Best available control technology ('BACT") Is an emissions limitation based on the maximum degree of reduction for See the Response to Comments 32 and 33 

each regulatoo' NSR pollutant which would be emitted from any proposed major facility which PA DEP, on a case-bycase basis, taking into account energy, environmental and economic impacts and other costs, determines is 

achievable for the facility through application of production processes or available methods, systems and techniques, 

including fuel cleaning or treatment or innovative fuel combustion techniques for control of the pollutant 

35 Although PA DEP noted that "[t]he facility is proposing two different supply options and will pick one option prior to See the Response to Comments 32 and 33 

construction," it nevertheless recommended that they be considered BACT. BACT Is a 'systemic analysis.' Thus, it 

naturally involves comparisons among technologies. In conducting a BACT analysis, 'one cannot look at particular 

emissions parameters in a vacuum." Nevertheless, the whole of the PA DEPs BACT analysis is done in a vacuum. 

PA DEP may not find tho plan approval to be complete without a BACT determination, which it cannot complete when 

it lacks the make and model of the sources. 

36 Implicit in the requirement that an applicant demonstrate its source is BACT Is that PA DEP must makes See the Response to Comments 32 and 33 

determination that the source is actually BACT. In this caSG, PA DEP determines that good combustion practices, 

oxidation catalysts, dry low nitrogen oxides ("NOx") burners and selective catalytic reduction are BACT despite not 

knowing the make or model of the sources. PA DEP goes so far as to provide separate emissions limits for each 

turbine that Berks Hollow may choose. 

37 A BACT determination is an omissions limit not a series of o lions. See the Res nSG to Comments 32 and 33 

38 Berks Hollow has failed to specifically idenUfy the turbines they intend to install and operate and PA DEP may not See the Response to Comments 32 and 33 

opprove those sources as BACT until they are specifically identified and that information is made available for public 

comment. 

Page5of11 

Ch:!ln a·to Parmit1 

No 

No 

No 

No 

No 

No 

No 
Attachment H- Comment and Response Document 

Regarding Draft Plan Approval No. 06-05150A 

for Berks Hollow Energy Associates, LLC 

Facility Proposed for Ontelaunee Township, Berks County 

., Comment Ras nse: •; I ,,, 

39 EPA hos mode clear that if an owner/oparotor makes changes that "lead to changes In emissions, Impacts on air Soothe Response to Comments 32 and 33 

quality, or control technologies ... such changes require [the permitting agency] to conduct comprehensive analysis of . . ,;k . "'lr.h • 

40 3. PA DEP must perform a full and independent BACT analysis for each source and each pollutant. This Plan The addendum to the TRM provides 3dditional detail into the analysis that was performed for 

Approval's main flaw Is the cursory review and blind accaptance of Berks Hollow's proposed BACT. In a matter of LAERIBACT/BAT 3nalysls for the project No substantive changes to the original LAERIBACT/BAT 

four pages PA DEP accepts BACT limits for six source types and tens of pollutants. This is entirely insufficient and determlmrtions were made. 

does not constitute a proper BACT analysis. 

41 PA DEP's reliance on tho Hickory Run review does not excuse it from performing a sufficient BACT analysis. BACT Is See the response to Comment 40. 

a 'caso.by..case' analysis that takes 'into account energy, environmental and economic impacts and other costs.' PA 

DEP must poliorm this caso-by-case analysis in the Review Memo and may not rely on Hickory Run or defer to Berks 

Hollow. 

42 4. The Station should be required to use natural gas with a sulfur content of 0.25 gr/100 scl. PA OEP has determined The facility is not a major source of S02 emissions and thus does not require a BACT analysis for S02 

that BACT for sulfur oxide ('SOx") 3nd ('H2S04") is use of pipeline quality natural gas with an emissions limitation of emissions. The limit of 0,68 gr/100 dscf was based on fuel sulfur content obtained from the expected natural 

0.68 gr/1 00 set. However, In a recent Plan Approval application for a similar natural gas-fired power plant, (41- gas supplier Texas Eastem Transmission Company (TETCO). Different natural gas pipeline companies 

00084A) Moxie Patriot, LLC, Indicated that the sulfur content of the gas they will use is 0.25 gr/100 sd according to obtain natural gas from different sources. Consequently, the natural gas sulfur content associated with a 

the specifications provided by the fuel supplier. It is unclear why this Station will have a sulfur content limit nearly given pipeline company is not 3n Indicator of the sulfur content of natural gas provided by another pipeline 

throo times the available fuel supply. The Council requests that PA DEP lower the sulfur content or provide an company. Therefore, the commentator's comparison offuel sulfur limits Is not appropriate since the Moxie 

explanation. Patriot facility (located In Clinton Township, Lycoming .county) will be supplied natural gas by Transco (a 

Williams compan 

43 Further, it does not appear that the proposed Plan Approval includes monitoring for the sulfuric acid mist. The Plan Plan Approval Section E Group CCU Condition #003 requires stack testing for sulfuric acid mist. 

Approval should include a method of demonstratlno com liance with the fuel sulfur limit. 

44 5. The Proposed Plan Approval must be revised to require that PM2.5 Is limited and monitored separately from PM10 is not used as a surrogate for PM2.5 in the Plan Approval Application. SHEA has detemined that all 

PM1 0. Particulate Matter ("PM') is treated as two separate pollutants under the Clean Air Act: PM10 and PM2.5. EPA particulate matter emissions from the the pfO))?Sed facility would be PM2.5. The Plan Approval includes 

has stated that because PM2.5 now has a separate and distinct NAAQS, PM1 0 can no longer be treated as a emission limits and monitoring for PM, PM10, and PM2.5. 

surrogate for PM2.5. 72 Fed. Reg. at 20,659. Therefore, consistent with the EPA's treatment of emissions information 

for these pollutants, the final plan approval for the Station must include separate and distinct limitations and 

standards for PM1 0 and PM2.5 emissions. 

45 6. "Good combustion practices" must be defined and enforce3ble. PA DEP selects "good combustion practices' as Good combustion practices are defined by the manufacturer for each CTG set and are specified in the Plan 

BACT ond lowest achievable emissions rote for various pollutants on various sources ut the Station. 'Good Approval as oporating and maintaining the source and control device in accordance with manufacturer's 

combustion practices." however, are not defined. PA DEP should Include a description of the various practices that specifications. The Plan Approval requires that SHEA shall muintain a copy of the manufacturer's 

will be required for each pollutant on each source and must incorporate them into the Plan Approval. preventative maintenance schedule on-site (Section E Group CCU Condition #005(d)). Additionally, the 

Plan Approval requires verification of proper operation and maintenance of the emission units in 

accordance with the daily operational inspections required by the Plan Approval (Section E Group CCU 

Condition #OOS(a). The Plan Approval raquires the record keeping of preventativa maintenance and 

operational inspections for each emission unit in accordance with the Plan Approval (Section E Group CCU 

Condition #004 (c) and( d). Additionally, demonstmting compliance with the emission limits In the Plan 

Approval will provide further documentation of the implementation of good combustion practices. 

Therefore, the Plan Approval properly identifies what is considered good combustion practices and 

rovides mechanisms to determine com liance. 

46 7. The greenhouse gas limit must Include mathane and nitrous oxide and be based on C02e. Under the definition of The Plan Approval already contains CCU limitations on both C02 and C02 equivalents (C02e). Section E 

''Subjoct to regulation" in the greenhouse gas ("GHG") tailoring rule at 40 CFR 52.21(b)(49)(i), and under the Group GHG states a C02e limit of 1,380,899 tpy based on a 12-month rolling total for each CCU. 

definition of 'Regulated NSR pollutanr at 40 CFR 52.21 (b)(60)(iv), both of which are Incorporated by reference into Compliance with the C02(o) emission limitation will be monitored via a combination of CEMS monitoring for 

State rules, the pollutant that is subject to regulation, and therefore a regulated NSR pollutant, is defined as GHG, C02 plus emission factors and calculations for methane and nitrous oxide derived from 40 CFR 98. 

not carbon dioxide ("C02"), Therefore, the BACT omission limit should be exprel'lsed In terms of total GHG 

emissions, as C02-oquivalent ("C02o"), and the Plan Approval should Indicate how compliance will be demonstrated 

for the two non-C02 GHGs to be emitted 

47 To account for methane and nitrous oxide emissions and determine compliance with the emission limits for total In a response dated May 30, 2013 SHEA stated : "We note that in recently evaluating C02, methene, and 

GHGs, EPA recommends use of emission factors from Table C-2 of 40 CFR part 98 and global warming potentials nitrous oxide emissions from (1/fJCtn'c gene~ratlng units, EPA e>Xplained as part of the preambi<J to the New 

from Table A-1 of 40 CFR part 98, along with the actual measured heat Input for the combustion turbines. Source Performance Standards forgre<Jnhouse gas emissions from new electric generstlng units that: "[tjh(fl 

estimated emissions for N20 end CH4 from fossil fuel-fired EGUs (9.0 end 0. 7 Tg of C02 equivalent, 

respectively) is about 0.4 f)(flrcent of total C02 equivalent emissions from fossil fU(fll~fired electric power 

generstlng units." Further, EPA hss recently concluded thst sufficient dsts is not ava/lsbfe to estsblish 

sepsrste limits for nitrous oxide or methane In terms of lb!MWh, ststing thst "[w]e sre not proposing 

sepsrste N20 or CH4 emission limits or sn equivalent C02 emission limit in todsy's action because of s 

lack of svallable data for these efffJCted sources." Given the relatively smell contribution of nitrous oxides 

snd methsne from such units, the C02(e) limitation set forth In the Pfsn Approval plus the compliance 

cMcks provided are adequste to sssure control of GHG emissions." The Department concurs with this 

Page6of11 

Chan a to'Permlt? ' No • 

No 

No 

No 

No 

No 

No 

No 

No 
Attachment H ~Comment and Response Document 

Regarding Draft Plan Approval No. 06~05150A 

for Berks Hollow Energy Associates, LLC 

Facility Proposed for Ontelaunee Township, Berks County 

calculate GHG omissions from thl'l Station. 

substituto for a GHG BACT analysis. 

limit on all GHGs. The largest source of GHGs at the Station will be C02 from the combined cycle units. 

·:writers compare thermal efficiencies of various units to determine what BACT is and then regulate 

a lbs C02e/MWh standard along with a net heat rate figure. The Review Memo should bo ablo to 

st efficient combined cycle unit Is chosen for the Station, or it should justify why a unit with a lower 

!efficiency was selected. PA DEP must then go on to ensure that BACT Is sot for each source and for all GHGs 

methane and nitrous oxide. 

SHEA Facility. In that procoss, SHEA and DEP considered (1) available Information 

Dioxide and other GHG emissions from natural gas-fired combined cycle power plants, 

information amassed as part of EPA's analysis leading up to proposal of the New 

a Standards In Subpart rrrT, (2) Information concerning GHG emissions for other 

in the EPA's RACT, BACT, LAER Clearinghouse (RBLC) database; and (3) a case-bycase evaluation of other control technologies. As presented In the Application, the GHG BACT analysis 

performed for the Project combined cycle units considered carbon capture and sequestration (CCS) and 

energy efficiency, which are recommended for consideration In EPA's PSD and Title V Permitting Guidance 

for Greenhouse Gases dated March 2011. Since CCS was not selected, energy efficiency was the only 

available option. As noted by EPA, combined cycle technology is the most efficient fossil fuel-based 

electric generating technology and the 'best system of emission reduction for new basaload and 

Intermediate load EGUs" althoUgh efficiencies and emission rates among different turbine technologies and 

configurations will vary to some degree, and will also vary depending on loading and operating conditions. 

Recognizing those conditions, the Plan Approval sets limitations on GHG In several ways: a direct control 

-C02 emissions per MWh (thereby controlling the vast majority of all GHG emissions from the facility) and 

additional annual C02( e) limitation (encompassing all GHG emissions) which has been Included In Plan 

concurs, 

lb C02/MWh on a rolling 

because: 1) The limit Is based on very 

fired power plants which was amassed in the 

range of new units whiCh commenced operation 

operating modes Including startup, shutdown, normal 

duct bumer operation. 3) The Information from the 

information available, given the lack of more recent GHG 

that are comparable to the proposed Project. EPA's GHG 

V Permitting Guidance for Greenhouse Gases, EPA EPA-457/B-11-001 

th respect to consideration of NSPS information in determining GHG 

BACT limits: "The CAA specifies that BACT cannot be less stringent then eny epplicable standard of 

performance under the New Source Performance Standards (NSPS) .... To the extent EPA completes en I 

NSPS for a relewmt source category, BACT determinetions that foflow wffl need to consider the leW')/S of the 

GHG standards and the supporting rotlona/e for the NSPS.... Thus, the guidance In this document should 

be viewed taking Into consideration the potential development of en NSPS fore pert/euler source catcgory." 

• In terms of describing best available control, EPA states the following as part of 

NGCC [natural gas combined-cycle} facility Is the best system of emission 

'!and intermediate toed EGUs." Thus, in its recent NSPS evaluation, EPA both 

_ combined cycle technology as the best system for emission reduction (basically, 

I BACT), and also defined the performance obtained by such units in terms of controlled GHG emissions 

resulting from use of such technology. 

Page7of11 
• Comment· 

cAttachment H -Comment and Response Document 

Regarding Draft Plan Approval No. 06..05150A 

for Berks Hollow Energy Associates, LLC 

Facility Proposed for Ontelaunee Township, Berks County 

RO$ Ol'l!ld: 

M. the time that BHEA's Applicatlon was prepared, the EPA's RBLC database was queried for 

determinations of "Carbon Dioxide' for Combined Cycle Fuel Combustion Units greater than 25 MW (I.e., 

Process Type 15.210) but no results were found. The Commentator referenced BACT determinations made 

for the Sumpter Power Plant (9541b C02o/MWh) and the Palmdale Hybrid Power Project (7741b 

C02o!MWh) . The Sumpter project Is substantially different from tho proposed SHEA facility, representing 

a conversion of an older, small simple cycle turbine with no SCR to combined cycle with the addition of an 

unfired (I.e., no duct bumers) heat rocovory stoam generotor (HRSG). Sumpter is not comparable to the 

SHEA Project due to the small size and age of the turbines, tho a~sonce of duct firing,_and the absonco of 

SCR controls (which tend to place an additional efficiency constraint on such a facility). Similarly, the 

Palmdale project is not considered rolevant since It Is a hybrid plant consisting of a CCV, with a 

concontrated solar power (CSP) unit which supplies additional steam to the steam turbine for supplomontal 

power generation. Since the submission of the Application, EPA has added to the RBLC database GHG 

BACT information for certain new projects. Of the projects listed in the RBLC database for C02, only the 

Moxie Uberty project is somewhat similar to the SHEA Project since it Is a gas-fired, combined cycle unit 

with similar proposed turbine technologies. The other projects listed are cogeneration or simple cycle units 

which are not comparable to the Project. The GHG emissions limit found in Moxie Uberty's Plan Approval 

No. 08-00045A Is In terms of tons of C02 a in any 12 consecutive month porlod. The proposed 

configuration of the CCUs for Moxie Liberty is a 1x1 (i.e., ono combustion turbino coupled to one steam 

turbine) which differs from the SHEA Project's 2x1 configuration (i.e., two combustion turbines coupled to 

one steam turbine); thus, this project Is not directly comparable to SHEA's Project. Bocause the number of 

shutdown and startup events, the load following profile, the ambient conditions, and tho hours of operation 

of the duct burners will vary from year-to-yoar, the GHG emissions intensity will vary as well. For this 

reason, tho proposod limit b;:~sod on NSPS Subpart rrrr is appropriate In the absence of nece~ssary GHG 

data and demonstrated, long-term perfolll'\ance of similar combined cycle units. 

As demonstratod above, the BACT limits for the Project properly considered NSPS supporting Information, 

along with the top-down analysis presented in the Application in accordance with EPA guidance. No 

changes to the Plan Approval aro warranted based on the common!. Further, although methane and 

· CMn etoPermlt?· 

nitrous oxides represent a negllgiblo contribution of GHGs from combined cycle plants (ostirrwted to be less 

than 0.4% of emissions from such facilities), total annual C02( e) limits specific to each CTG option which 

account for methane and nitrous oxide emissions are included. Also, It is noted that the Plan Approval 

contains onforceable GHG limits set for each source and for the facility as a whole. 

51 The measures selected for BACT here are vague and unonforceable. PA DEP Indicates that The remaining GHG See the response to comments 49 and 50. No 

control option is the efficient use of energy. The turbines and duct bumers writ be designed for emissions of 

greenhouse gases that ere less than 1000 pounds of C02 par megawatt-hour of electricity produced, in conformanoo 

with EPA's proposed NSPS rule for Electn'c Utility Generating Units (proposed 3127/12). This would constitute BACT 

and BAT for GHGs. 

52 To adequately support a BACT determination, PA DEP must, ot minimum, clarify whether all avoilable control options Soe the response to comments 49 and 50. No wore considered, whether the option selocted is the best-porformlng option thot Is known to be available and 

technically feasible, whether energy, environmental and oconomic impacts affected the selection of the control 

option, and if the best-performing option was not selected provide an explanation and supporting basis for that 

selection. 

53 PA DEP may not merely set a C02 standard on tho combined cycle units and "good combustion practices" on other Soe the response to comments 49 and 50. No 

sources. Each sour~~~h~ ~~~~o~7~;,~~st have an enforceable llm1\~~ !~Station as a ~~~C~ust have 

' llm;t, A j ~ole "";,' I' . "' oct ceo<,eot I 

54 9. Specific engineering practices should be incorporated Into the final permit. Condition #004 In the proposed permit The Plan Approval contains Conditions for monitoring, recordkeeplng, reporting and work practice No 

indicates that '[t]he permittee shall maintain and oporate the sources associated in accordance with good roquiroments to help ensure that the sources and control devices are maintained and operated in 

engineoring practices as described in the plan approval application submitted to the Department.' This condition is accordance with good enginoering and air pollution control proctlces. 

vague and unenforceable. PA DEP references 25 Pa. Code§ 127.12(a)(1 0) in the Condition,, however this section 

moroly provides that an application must "[s]how that tho source and tho air cleaning dovices aro capable of be!lng 

and will be operated and maintainod in accordance with good air pollution control practices." If thore are enginooring 

practices necessary to keep tho air cleaning devices properly oporatod and maintained those should be specifically 

included in the Plan Approval. 

55 Tho Council encourages PA DEP to perform an independent evaluation of tho Plan Approval application and to DEP has carefully reviewed the SHEA application and has responded to tho public comments. No 

respond to all comments from tho public to ensum that ony final action Is consistent with applicable federal and state 

recuirements. 

56 Further, the Council urges PA DEP to on sura that the bases for decisions are transparent and that the record DEP believos that the rocord in this case is cloar, and supports DEP's rocommendation for conditions to No 

lProvides adeouate suoOort for the Plan Aotlroval decisions. · include In this plan approval. 

omm n roc Jv '' m n faun Pw' mtfn om an via lottor datod 4116113 

57 Ontelaunee Power Oporatlng Company, LLC (OPOC) owns and operates Ontelaunoe Energy Centor (OEC), which is PADEP has verified and documented In tho permit record that the proposed Berks Hollow facility will not Ye• 

located lmmodiately adjacent and to tho south of tho proposed Barks Hollow Ene~rgy facility. Our goal In providing cause or contribute to exceedances of applicablo ambiont air quality standards. Conditon #001 (c) in 

these comments on the proposed Air Plan Approval is to onsure that PADEP has vertfied and documented in the Soction E Group CCV has been changed to clarify that short term NOx limits aro based on 1~hour block 

pormlt record that tho proposed Berks Hollow facility will not causa or contribute to oxceedances of applicable averagos. 

ambient air cualitv standards at or noar our facilitv. 

Page8of11 
# 

Attachment H ~Comment and Response Document 

Regarding Draft Plan Approval No. 06~05150A 

for Berks Hollow Energy Associates, LLC 

Facility Proposed for Ontelaunee Township, Berks County 

comme!'1r · Res n!le: ' 

58 Ontolounae Energy Center is concem<Xl thot the proposed short-term NOx emission limits for the Combined Cycle See the response to Comment Sf, 

Units (CCUs) detailed in Section E, Source Group CCU, condition #001 of the draft Plan Approval are Insufficient to 

assuro complionce with the 1-hr Nationol Ambient Air Quality Standord (NAAQS) for N02. We believe th,e draft Plan 

Approval contains two specific deficiencies in NOx emission limits that must be corrected. 

59 Per condition #001 (c) of the draft Plan Approval, the short-term emission limits for NOx (ppm and lbfhr) aro Condition #001 (c) In Section E Group CCU has been changed to state ttwt emission limitaitons for NOx am 

exoressed as 3-hour rollino averaoes. 1-hour block averaoes. 

60 No short-term NOx emission limits apply during CCU startups. Conditions 001 (a)(1 )(a) and 001 (a)(2)(a) of Section E Group Startup and Shutdown have been modified to 

limit NOx emisisons to 173,18 lbfhr and 162.13 lb/hr respectively during start up and shut down operations. 

These rates were used In the modeling analysis and included as an attachment to a 6/21/13 email from 

Andrew Fleck to Thomas Hanlon. The omait and attachemnt are included as an attachment to this 

document 

61 In normal operation and firing duct bumers, the Siemens CTs could emit Sib NOx one hour, 691b NOxthefollowing Soothe response to Comment 59. 

hour, and 5 lb NOx tho following hour, and still satisfy tho 26.5 lb NOx fhr emission limit when calculated on a 3-hr 

rolling average. We believe this scenario could easily occur ifthe~a~ili~~ 

1

ammonia supply system experienced a 

malfunction and ammonia flow to the Soloctlvo CataiVtic Reduction SCR units wos interrUoted. 

62 The air dispersion modeling analysis must clearly demonstrate !hot the 1-hr N02, NAAQS will not be exceoded at See the response to Comment 57. 

any point at or beyond the Berks Hollow Energy facility fence line when the two CCUs are each emitting NOx at the 

rate of 69 lb/hr, and other facility combustion sources (such as tho fuel gas heater and auxiliary boiler) are In 

operation. If dispersion modeling of such a scenario does predict an exooedance, PADEP must impose 1·hr average 

NOx mass emission limits at levels that modelino demonstrates no exce<Xlances will occur. 

63 (Note that PADEP has imposed short-term NOx emission limits on the Ontelaunoo CCUs of both a 1-hour averaging See the response to Comment 59. 

time and a 3-hour ovoraging time. We believe that PADEP should Impose short-term NOx emission limits on the 

Berks Hollow CCUs that are eouall r oroteetivel. 

64 We are also concerned that the 1-hr N02 NAAQS may be exceeded during CCU startups, when no short term mass See the response to Comment 60. 

emission limits or concentration limits for NOx apply. 

65 NOx emission rates from combined cycle CTs tend to be highest during startups, when suboptimum combustion See the response to Comments 57 and 60. 

conditions exist in the gas turbine's combustors, and when SCR temperatures are still too low to effectively control 

NOx emissions In the CT exhaust. It Is also during this time when stack gas temperatures and flow are lowest, 

leadino to ooor atmosoherlc dlsoersion conditions. 

66 The Berks Hollow CCUs might conceivably emit 70 lb NOx during the first hour of a cold startup, and still be in See the response to Comment 57: 

complinnce with all NOx emission limitations in the draft Air Plan Approval, Tho air dispersion modeling analysis must 

clearly demonstrate that the 1·hr N02 NAAQS will not be exceeded at any point at or beyond the Berks Hollow 

Energy facility fence line when the two CCUs are each emitting NOx at tho rate of 70 lbfhr, and other facility 

combustion source~ /such as the fuel cas heater and auxiliarv boiler) are in oooration. 

67 If dispersion modeling of such a startup scenario does predict an exceedance, PADEP must impose a 1·hr average See the response to Comments 57 and 60. 

NOx mass emission limit appllcoble during CCU startups at levels that modeling demonstrates no exce&dances will 

-occur. 

68 In summary, in order to assure compliance with the 1-hr N02 NAAQS at all times, we urge PADEP to include limits See the response to Comments 57 and 60. 

on NOx conoontratlon and/or mass emission rate during normal operation that are based on a 1·hour averaging time, 

and also include a 1-hour average mass emission rate limit for NOx that applias during CCU startups. The specific 

NOx emission rates for theso additional1-hour average limits should be based on the results of air dispersion 

modeling that includes operation of other facility combustion souroos as appropriate, and is performed using 

reoresontatlvo backaround concentrations. 

Commonts rtlcolvod from PA Stato Ro • Jo Knowlos vlu lottor dutod 4116113 

69 I have received several complaints from constituents in Berks County who are upset with the application for an Air DEP has followed the public comment provisions of the law in this case and has made a roasoned decision 

Quality Permit submitted by Berks Hollow Power Plant to construct a natural gas power plant in Ontelaunee to not conduct a formal public hearing. In March 2013, DEP published notice of a 30-<lay public comment 

Township. My constituents would !Ike the Department to hold a public hearing on their application before any permits period for this application, In reviewing requests for a public hearing in this case, DEP considered whether 

are issued to discuss the plant function and voice their conooms on this projoct. Because of the serious nature of there was significant, Identifiable local public interest. DEP was informed that only four people had 

their concerns, I wanted to bring it to your immediate attention. I am writing today to ask that the appropriate officials contacted Rep. Knowles with requests for a public hearing. DEP also took the extra step of contacting 

carefully review this request to schedule a public hearing. Ontelaunee Township officials and was advised that no one had expressed any issues or concerns at the 

Board of Su orvisors' montl')ly meetin~s or with the zonin~ and olanninq commission. 

During the public comment period, DEP also received 124 e-mail comments, many of them using an 

identical form letter, objecting to the proposed facility and requesting a public hearing. Nearly all of thasa 

comment e·mails had no name or contact information other than thee-moil address. Significant, identifiable 

local public Interest could not be substontlated duo to tho lack of contact Information In the a--malls. Based 

on tho ovallable information, DEP responded to Representative Knowles In mid-May and to the e-mail 

commonters In mid·June, indicatin!=l that a public hearing would not be held. 

Page9of11 

Cha eto.Pe~mlt?'; ··I 

y, 

Yes 

Yes 

I 

Yes ! 

Yes 

Yes 

Yes 

Yes 

Ye• 

Yes 

Yes 

I 

No 

I 
Attachment H- Comment and Response Document 

Regarding Draft Plan Approval No. 06-05150A 

for Berks Hollow Energy Associates, LLC 

Facility Proposed for Ontelaunee Township, Berks County 

local residents to learn about the project, ask questions, 

Berks Hollow Energy Associates and PA DEP stoff. The majority 

a project like this power plant Is proposed and would greatly benefit from a 

. Again, I strongly recommend that you hold a meeting and hearing on this power plant. 

""''" "'" "'10~"'""' 11 "" "'"'• '""' u "'"'u '""' !-'"''"'" '"" "'"'1 ..,., with devol oping lungs and seniors with respiratory disorders are disproportionately at risk. 

this type of facility to omit carbon monoxide, formaldehyde, volatile organic compounds, 

hozardous air pollutants, particulate matter, sulfur oxides, sulfuric acid mist. and greenhouse gases. 

comments. The CAC Is a nonIt was alleged that the commenters had provided the 

necessary 1aenmymg 1nrormat1on sucn as name, address and telephone number to the CAC, and had re 

on the CAC website to forward their comments onto DEP. Nevertheless, the comments actually received by 

DEP did not include the necessary identifying information. CAC has not contacted DEP's Southcentral 

Regional Offico to confirm or deny whether the allegations about its website are true. In any case, the 

public comment period had ended well before these all(.lgations came to light. DEP has determined that it is 

not appropriate to revisit the public hearing decision. Nevertheless, DEP has reviewed and considered the 

various issues raised In the emailed comments. These are addressed in Comments 70·100 of this Comment! 

Page10of11 
Attachment H- Comment and Response Document 

Regarding Draft Plan Approval No. 06-05150A 

for Berks Hollow Energy Associates, LLC 

Facility Proposed for Ontelaunee Township, Berks County 

I Manufacturing's various lead and sulfur-emitting industrial operations, the pollution csused by the Atlas Chemical 

focillty In Mertztown, ell manner of carcinogens pumped into the olr ond water from numerous local quarrlos, 

smelters, stool mills and foundries-the list goes on and on. In addition to all of these major polluters, the 

Berks already contend with the noxious particulate pollution generated at the existing natural gas power 

the intersection of 222 and 183. Tho EPA has repeatedly warned that Berks' air quality ranks among the 

"'responses 

Page11 of11 
Hanlon, Thomas 

From: Hanlon, Thomas 

Sent: 

To: 

Tuesday, October22, 201310:12 AM 

Hanlon, Thomas 

Subject: FW: Berks Hollow 

Attachments: Berks Hollow N02 Model Emissions.xls 

From: Fleck, Andrew 

Sent: Friday, June 21, 2013 9:26AM 

To: Hanlon, Thomas 

Cc: Ramamurthy, Krishnan; Roble, Daniel 

Subject: RE: Berks Hollow 

Tom, 

I believe you may have received an email and/or voice message from Krish in regard to your questions on 

Berks Hollow emission limits. I add that the additional lb/hr emission limits on the Berks Hollow 

combustion turbines should be no greater than the emission rates modeled in the N02 air quality analysis 

to support the Berks Hollow plan approval application. Berks Hollow's modeled N02 emission rates for 

each turbine manufacturer (GE and Siemens) are attached. For normal operation, the maximum model 

emission rates are highlighted. For startup/shutdown, it is the emission rate that the model emission rate 

is based on and the number of hours per year that should be of interest to you, and these are highlighted 

as well. 

Andrew 

Andrew Fleck I Environmental Group Manager 

Department of Environmental Protection I Bureau of Air Quality 

Rachel Carson State Office Building 

400 Market Street I Harrisburg, PA 17101 

Phone: 717.783.9243 I Fax: 717.772.2303 

www.dep.state.pa.us 

1 
GE 

Scenario CT N02 Model Emission Rate 

g/s lb/hr 

· Normal100% Load 1 3.2369 25.6899 

2 3.2369 25.6899 

Normal 80% Load 1 2.4897 19.7597 

2 2.4897 19.7597 

Normal 50% Load 1 1.6039 12.7294 

2 1.6039 12.7294 

Startup/Shutdown 1 1.2448 9.8794 * 

2 1.2448 9.8794 * 

* Startup/shutdown model em1ss1on rate based on 173.18 lb/hr t1mes 500 hr/8760 

Siemens 

Scenario CT N02 Model Emission Rate 

g/s lb/hr 

Normal100% Load 1 3.3402. 26.5097 

2 3.3402 26.5097 

Normal 82% Load 1 2.5867 20.5295 

2• 2.5867 20.5295 

Normal 50% Load 1 1.7614 13.9795 

2 1.7614 13.9795 

Startup/Shutdown 1 1.1655 9.2501 * 

2 . 1.1655 9.2501 * . *Startup/shutdown model em1ss1on rate based on 162.13 lb/hr times 500 hr/8760