06-05150A

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

### 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 PROGRAM06-05150A

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## PROPOSED 10/04/2013 10:42 AM 965778 DEP Auth ID: 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.06-05150A

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

### 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 #002 #003 #004 #005 #006 #007 #008 #009 #010 #011 #012 #013 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 Requirements06-05150A

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

### 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 Requirements06-05150A

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

### 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: DEGREASER06-05150A

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

### 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 FML0306-05150A

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## PROPOSED 10/04/2013 10:42 AM 965778 DEP Auth ID: #001

#002

#003

#004

#005 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]06-05150A

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## PROPOSED 10/04/2013 10:42 AM 965778 DEP Auth ID: #006

#007

#008 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]06-05150A

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## PROPOSED 10/04/2013 10:42 AM 965778 DEP Auth ID: #009

#010

#011

#012 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]06-05150A

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## PROPOSED 10/04/2013 10:42 AM 965778 DEP Auth ID: #013 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]06-05150A

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## PROPOSED 10/04/2013 10:42 AM 965778 DEP Auth ID: 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 Requirements06-05150A

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## PROPOSED 10/04/2013 10:42 AM 965778 DEP Auth ID: # 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 Requirements06-05150A

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## PROPOSED 10/04/2013 10:42 AM 965778 DEP Auth ID: (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 Requirements06-05150A

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## PROPOSED 10/04/2013 10:42 AM 965778 DEP Auth ID: # 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 Requirements06-05150A

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

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

030 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. 

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

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

031 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. 

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

032 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. 

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

033 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. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

103 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 PM2.5 Conditions for this source occur in the following groups: 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. 

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

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

110 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. 

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

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

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

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

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

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

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

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

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

### 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 pageof 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. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

### SECTION E. Source Group Plan Approval Restrictions.06-05150A

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## PROPOSED 10/04/2013 10:42 AM 965778 DEP Auth ID: 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. Naturalgas 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.06-05150A

Page 88 BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE



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

### SECTION F. Alternative Operation Requirements. No Alternative Operations exist for this Plan Approval facility.06-05150A

Page 89 BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE



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

### 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 PM1006-05150A

Page 90 BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE



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

### 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 TSP06-05150A

Page 91 BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE



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

### SECTION G. Emission Restriction Summary.

2,779,224.000 Tons/Yr based on 12-month rolling total Carbon Dioxide06-05150A

Page 92 BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE



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

### 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:06-05150A

Page 93 BERKS HOLLOW ENERGY ASSOC LLC/ONTELAUNEE



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

### 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 OfPennsylvania DepartmentofEnvironmentalProtection ReadingDistrict Office November7, 2013 · Subject:

To: AddendumMemo Berks HollowEnergyAssociates, LLC Ontelaunee Township, Berks County Title

### V PlanApprovalNo. 06-05150A WilliamWeavei· [W..I 

## 11)1)13 Regional Manager 

### Air QualityProgram Through:

From: KenHartzler 'KJ{



### Facility Air QualityPermitting 

### Air QualityProgram · ThomasHanlon, Chief 

### Air Quality Permitting Air QualityProgram

BerksHollowEnergyAssociates, LLC (Berks Hollow) submitted a plan approval applicationfor installationand startup ofa combined-cyclenatural gas fired electric generatingstationto be located

### in Ontelaunee Township, Berks County. 

### CommentPeriod Intentto issue theplan approvalwaspublished inthe PennsylvaniaBulletinonMarch 16, 2013. Thenewspapernotice waspublishedinthe Reading Eagle onMarch 18, 19, and20 of2013. On March7, 2013 copies oftheproposedplan approvalwere submittedto Mr. Bradley Cooley, SeniorEnvironmentalEngineer, Mr. William Borst, District Supervisor, andto Mr. Himanshu Vyas ofEPA. Dillingthe commentperiodthe following provided comments: 1) Berks HollowEnergyAssociates, L.L.C. 2)U.S. EPARegionIII 3) Clean

### AirCouncil 4)DynegyGeneration, a DivisionofDynegyInc. 5) Representative Jerry Knowles 6) Approximately 125 email commenters, eachprovidingthe same general comments. Attachedto this memo is a comment/response document whichaddresses all ofthe comments received, withthe exceptionofthe EPAcomments which asked for expandedinformationinthe technicalreviewmemo onthe BACT/LAERanalysis, SOz monitoring andPM2.5 monitoring. Theexpandedtechnical reviewmemo items are as follows:

### Berks HollowEnergy, PA06-05150A 2 November7, 2013


### BACTILAERAnalysis TheProjectis subjectto theNSRprogram (PSD andNNSR). Pursuantto thePSD regulations, theProjectis a major stationary source andmustutilizeBACTfor eachregulatedNSRpollutant thatitwouldhave thepotentialto**em~t** 

### ina significant amount. The Projectis subjecttoNNSR, as Berks CountyispattoftheNotiheast OzoneTransport Regionand also designatedas nonattaiurnent for PM2.5. TheProjectis a major source ofNOxandVOC,butwillbe a minor sourceforPM2.5. A LAERanalysis is required for ozoneprecursors (VOC andNOx). Forallpollutants emitted at significant levels, a BACTdetemtinationmustbeperf01medusing a "top-down" approach. Thisbeginswiththe most stringent control altemative·(top), which must beutilizedunless itis demonstrated thattechnical considerations, orenergy, envirournental, or econontic impactsjustifyinfeasibility. Theprocess continues until an alternative cannotbe elintinatedbased onthe criteriaabove. TheDepartmentperformed a reviewofthe RBLC database and a subsequentreview ofplanapprovals issuedinthe stateto detetmine whatcontrol technologies have beenrequiredto beinstalledinthepastfor this type ofsource. The· Depatimentreviewedthe BACT /LAER/BA T analysis providedbythefacility and detetmined thatallrelevant controltechnologies were includedintheiranalysis. Thefacility's analysis then removed cetiaintechnologies thatwere detemtined to betechnically infeasible andthenranked theremaining control technologiesinorder ofmosteffective. TheDepatimentreviewedthe informationprovided and agrees withthefacility's detemtination as to whichcontrol technologies were technically infeasible. Afterreviewingthe rankingto ensurethe most· effectivewas atthetop, the facilitythenproposedto usethe most effective controlthusno further analysiswasrequired. Section 5 ofthe applicationcontains their complete analysis includingthe various controltechnologies for eachpollutantanalyzed,justifications as to whatis technically feasible andwhatistechnically infeasible, andthe ranking oftheremaining technicallyfeasible controltechnologiesbased oneffectiveness. Becausecostfactors werenot evaluated, tltis analysis canalso beusedfor LAER. A summaty oftheBACT/LAERanalysis is listedbelow. Forthe combinedcycleunits (CCUs), the use ofachievedinpractice emissionrates when detetminingLAERfor NOxandVOCs was considered. ForNOx,DEP reviewed continuous emissionmonitoring (CEM) datafrom existing combinedcyclefacilities to detetmine acltievable NOxrates whenestablishingLAER forBerksHollow. VOCrates depend largely onfuel characteristics and combustiontechnology, whichdifferfrom siteto site, so achieved inpracticerates were determinednottoberepresentative insetting LAER. 

### BACT/LAER/BAT for Turbines (CCV): CCUBACTfOr CarbonMonoxide: Thefollowingtable includes a list ofpotential controltechnologies. Control Technology Combustion or PostControl Good Combustion Practices (GCP) Combustion

### Berks HollowEnergy, PA 06-05150A 3 November 7, 2013

Oxidation Catalyst Post Control SCONOX Post Control 

### Based onthe lack ofavailabili1y ofSCONOXtechnology onprojects ofthis size, this teclmology has beendeternlinedto be infeasible. Theremainingtwo technicallyfeasible control technologies (GCP and oxidation catalyst) are compatible andthe facili1y has decidedto use both as the control forthis source. TheBACT detennination is use ofGCP and oxidationcatalystwithanemissionlimitation of2.0 ppmvd CO correctedto 15% 

### 02based ona 1-houraveragingperiod. These limits apply regardless ofthe operational status ofthe ductburners (firing ornotfiring). Forperiods of startup and shutdown, enlissionswill becontrolledby combustion controls andinaccordance withthe startup and shutdowndefnlitions and enlissionwill belimitedto those listed for startup and shutdownperiods. CCUBACTandLAER tor VOC: Thefollowing table includes a list ofpotential control technologies.
Control Technology Combustion or Post Control Good Combustion Practices (GCP) Combustion Oxidation Catalyst Post Control SCONOX Post Control 

### Basedonthe lack ofavailabili1y ofSCONOXtechnology onprojects ofthis size, tllis technology has been deternlinedto beinfeasible. Theremainingtwotechnically.feasible control technologies (GCP and oxidationcatalyst) are compatible and the facili1y has decidedto use both as the control for this source. TheBACTand LAERdeternlinationfor VOCis use ofGCP and oxidationcatalystwith an enlissionlimitation of1.5 ppmvdVOC conectedto 15% 

### 02. This linllt applies regardless ofthe operationalstatus oftheductburners (firing ornotfiring). Forperiods ofstartup and shutdown, enlissions willbe controlledbycombustion controls andinaccordance withthe startup and shutdown definitions and enlissionwill belimitedto those listed for startup and· shutdown periods. CCUBACTandLAER {Or**NO,~** 

### The following table includes a listofpotential control technologies.
ControlTechnology 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

### BerksHollowEnergy, PA06-05150A 

## 4 November7, 2013

SNCRhas been dete1minedtobe technically infeasiblebecause oftherequired operating temperature ofthe SNCRismuchhigherthan the operating temperature ofthe exhaust gas downstream ofthe HRSGwhichis approxinlately 150Fto 290F. SCONOXhas also been dete1mined to betechnicallyinfeasiblebecause ithas notbeenapplied to a facility ofthis size, therefore it isnot available. XONONhasbeendeterminedto betechnically infeasiblebecause application ona large combined-cycleunithas notbeendemonstrated. FinallyWetInjection, while technicallyfeasible is notbeing considered becausetheDLN Combustorwouldprovide equivalentorhigher level ofcontrol. Theremainingtwo technicallyfeasible control technologies (DLN Combustors and SCR) are compatible and the facility has decidedto use both asthe control forthis source. The BACT and LAERdete1minationis DLN Combustors and SCRwithanemissionlimitation of2.0ppmvdNOxcorrectedto 15% 

## 0 2 

### based ona 1-hour averagingperiod. This linlitwas dete1minedto beLAERfrom thei-eviewofCEMdataatexistingcombined cycle facilities. Theselinlits applyregardless ofthe operational status ofthe ductbmners (firing ornotfiring). Forperiods ofstartup and shutdown, emissions will be controlledbycombustioncontrols and in accordance withthe stattup and shutdown definitions and emissionwill be limited to those listed for startup and shutdownperiods.


## CCUBACT[or

## PMIPMJO: Thefollowing tableincludes a list ofpotential controltechnologies.
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 

### Thepostcombustioncontroltechnologies havebeendete1mined to betechnicallyinfeasible. This isbecause ofthe highoperatingtemperatures, highairflowvolUllles, fine particulate distribution, and inherentlylowuncontrolled emissionrates. Also, areviewofthe RBLC showedno combined cycle units equippedwith add-oncontrols for PMIPMlO. Theremainingtwo technically feasible control technologies (GCP andPipeline QualityNatural Gas) are compatible and the facility has decidedto useboth as the control for this source. TheBACTdetermination is GCP andPipeline QualityNatural Gas with anemissionlinlitation ofthefollowing: · Normal Operation- DuctBmners off GE7FA: 10.0

## #lhr SiemensF: 10.0 

### #Jill:

### BerksHollowEnergy, PA 06-05150A

Normal Operation- DuctBurners on GE7FA: 21.55 

## #!hr SiemensF: 21.55 #/hr 5 November7, 2013

Theduct burner onlimitis differentthanthelimitfor LS Power'sHickoryRunfacility because the ductburners attheBerksHollowfacility are larger thanthose atHickory Run(770 vs 500 mmBtu!hr). Forperiods ofstartup and shutdown, emissions willbecontrolledbycombustion controls andinaccordance withthe stmiup and shutdown defmitions and emissionwill be limitedtothose listedfor startup and shutdownperiods. 

### CCUBATfor SOx andSulfuricAcidMist: Thefollowing table includesa list ofpotential controltechnologies. 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 DryerAbsorber {Dry Scrubber) ·Post Control 

### Fueltreatmenthasbeendetermined to betechnically infeasiblebecause ofthe verylowsulfur contentofthepipelinenatmalgas. FGD hasbeendeterminedto betechnically infeasible becauseitsefficiency decreases withlowerinlet SOx concentrations. Also, FGDhasnotbeen usedonprojects ofthis size, therefore itwouldnotbe considered available. The only remaining control technologyis thepipeline qualitynatural gas. TheBATdeterminationfor bothSOx and HzS04 is use ofpipeline qualitynatural gas with an emissionlimitationof0.68 grains sulfurper 100 scfnatural gas based onfuel monitoring. This valueis differentthanthelimitsetfor LS Power'sHickory RunfaCility becausethenatural gas supplierisdifferentfor thetwo facilities. 

### CCUBACT(or GHG: The following table includes a listofpotentialcontroltechnologies. Control Technology Carbon Capture 

### & Storage {CCS) Energy Efficiency utilization 

### CCS has notbeen demonstrated ona facility ofthis size, therefore ithas beendeterminedthatit is infeasible. Energyefficiencyutilizationwillinclude: combine cycletechnology (significantly higherlevels ofelectric generationefficiencythantraditional fossil fuel generatingfacilities); equipmentmaintenance; instrumentation 

## & control systems; HRSGdesign consideration; and highefficiency auxiliary equipment. Energy efficiencyisthe onlytechnical feasible option remaining.

### Berks HollowEnergy, PA06-05150A 6 November7, 2013

TheBACTdeterminationisuse ofenergy efficiencywith anemissionlimitation of 1,000 lb C02 /MW-hr (gross) ona 365-dayrolling average whichis based onproposedNSPS. Please see the attached comment andresponse documentfor a detailed discussion ofthe selectionofthis limit. 

### BACT/LAERIBAT forAltxiliaryBoiler: Theauxiliaryboilerwill beusedto shortenthe cold andwarm start durationofthe combustion turbines. The auxiliaryboilerwill be usedtoprovidehighpressure steamwhenthe combined cycle generatingunitis offline inorder accommodatemorerapid startup following extended shutdownperiods: Theauxiliary boiler will primarilyrun duringtheperiodpriorto initiation of startup ofthe combustionturbines and during startup. Theboilermaybe operated duringperiods whenthe CCUs arenotin steady-stateoperation. The applicant searched EPA'sRBLC database andconsultedvendorliterature. BACT/BATfor GHGis proposed as the use ofgood combustionpractices andtheuse of pipeline qualitynatural gas. Natural gas has the lowestC02emissionrate ofall fossil fuels. The applicant also proposesto limit operationoftheboilerto 4,600hoursperyear. This willbe implicitinthe atmual emissionlimits imposed ontllis sourceintheplan approval. The applicant states thatthe verylowbaseline emissions, coupledwiththeimplicit operatinghourlimitation, andtheresults ofthe RBLC search, wouldindicate the technical infeasibility ofany add-on controls for GHG. DEP concurswiththis assessment. LAER/BACT/BAT (as applicable) for otherpollutantsfromthe auxiliaryboiler, wereproposed as follows. Theseproposals are identicalto thelimitsproposedfor identical equipment atthe Hickory Runfacility, and are acceptableto DEP: NOx: ultralowNOxblll"ilers and emissionlimit ofO.Olllb/mmBtuor 1.01 tpy. S02 andH2S04: use ofpipelinequality natural gas, andemissionlimits of0.0021lb/mmBtuor 0.19 tpy, and 0.00048lb/mmBtuor 0.04 tpyrespectively. CO andVOC: good combustionpractices and emissionlimits of0.036 lb/mmBtu or3.31 tpy, and 0.0015lb/mmBtuor 0.14 tpyrespectively. PM/PMlO: good combustionpractices, use ofpipelinequalitynatural gas, and anemissionlimit of0.005 lb/mmBtu or 0.46tpy. 

### BACT/LAERIBAT forEmergency GeneratorandFire WaterPump: BACT/BATfor GHGis proposed as theuse ofgoodcombustionpractices andthelimiting of operatinghoursto 100hoursperyearfor non-emergency situationsperNSPS SubpartIIII. LAER/BACT/BAT (as applicable) for otherpollutants fromthegenerator and fire waterpump, were proposed as follows. The limits for the emergency generatorare equivalentto theNSPS SubpartIIII andMACT SubpartZZZZ standards forthe affected sources. Thelimits for the fn·e

### Berks HollowEnergy, PA 06-05150A 7 November7, 2013

pump wererevisedbased oninformationfound intheRBLC for a similarsizedfire pump recentlypennittedforArcadis, Inc.'s Oregon CleanEnergy Center: NOx: good combustionpractices and emissionlimits ofI0.6lb/hror 0.53 tpy, and 1.70 lb/hr or 0.09 tpy, respectively for the emergency generator and fn·e waterpump. Berks Hollowassumed that 100% ofthe vendor's SubpartIIIIcertificationofNOx

### +NMOCwereNOxemissions, and usedAP-42 estimates for VOCemissions. These assumptions were acceptable to the Departmentbased onthe smalltpy ofNOxand VOCfromthe sources. The company shall complywithall applicableprovisions ofNSPS SubpmiIIII. S02 and H2S04: use ofULSD, and emissionlimits of0.011lb!hror 0.00055 tpy, and 0.0030 lb!ln· or 0.00015 tpyrespectivelyfor S02, and 0.0025 lb!hr or 0.00013 tpy and 0.00075lb!hror 0.000038 tpyrespectively for H2S04. CO: goodcombustionpractices andemission limitof5.79 lb!hr or0.29 tpy and 1.70 lb!hr or 0.09 tpy respectively. VOC: goodcombustionpractices and emissionlimits of0.63 lb!ln· or 0.03 tpy and 0.25 lb!hr or 0.013 tpy, respectivelyfor the emergency generatorand fire waterpump. Berks Hollow assumed that 100% ofthevendor's SubpartIIII cetiificationofNOx

## +NMOCemissions were NOxemissions, andusedAP-42 estimates for VOCemissions. These assumptions were acceptable to theDepartmentbased onthe smalltpy ofNOxandVOCfrom the sources. The · company shall complywith all applicable provisions ofNSPS SubpartIIII. PMIPM10: good combustionpractices, propermaintenance andemissionlimits of0.33 lb!hr or 0.017 tpy, and 0.10 lb/hr or 0.005 tpy, respectively for the emergency generatorand fuewater pump. 

### BACT/LAERIBAT for Cooling Tower: The applicationnotes thatthe use ofhigh efficiency drift eliminating mediato de-entrain droplets from the air flow exitingthe coolingtoweris a commerciallyproventechnique to reducePMIPM10 emissions. The applicantproposesto usehighefficiency drifteliminators, withdriftrate limit of0.0005 percent. This is consistentwiththemost stringent detenninations for mechanical draft coolingtowers found inEPA'sRBLC database. The total dissolved solids (TDS) content ofthe coolingwater was conservatively estimatedat 5,000 ppm. PM10 andPM2.5 fi'actions ofthetotal PMwere calculatedbased ona paperby Reisman and Frisbie, "CalculatingRealisticPM10 Emissionsfrom CoolingTower", and detenninedto be 64.4% and 24.0% ofTotal PMrespectively. PMemissionrates (lb!hr) were dete1minedbymultiplyingthe water circulationrate (81,167,886lb!hr) x Driftx TDS/1,000,000. 

### BACT/LAERIBAT for FuelHeater: BACT/BATfor GHGfrom the fuel heater isproposed as theuse ofgood combustionpractices andtheuse ofpipeline qualitynatural gas. Natural gas has the lowest C02 emissionrate ofall fossil fuels. The applicant states thattheverylowbaseline emissions, coupled withthe results of

### Berks HollowEnergy, PA06-05150A 8 November7, 2013
the RBLC search, would indicatethetechnical infeasibility ofany add-oncontrols for GHG. DEP concurs withthis assessment. LAER!BACT/BAT (as applicable) forotherpollutants from thefuel heater, wereproposed as follows. Theseproposals are acceptabletoDEP: NOx: good combustionpractices andemissionlimitof0.035 lb/mrnBtu. Theemissionlimit is basedonvendor data. S02 andH2S04: use ofpipeline qualitynatural gas, and emissionlimits of0.002llb/mmBtu and 0.00048 lb/mmBturespectively, basedon0.68 gr/100 dscfmaximumsulfurinnatural gas verified bypurchase contract. CO andVOC: goodcombustionpractices and emissionlimits of0.05 lb/mmBtuand 0.005 lb/mmBturespectively, basedonvendordataand AP-42 emissionfactors. PM/PM!

### 0: good combustionpractices, use ofpipeline qualitynatural gas, and anemissionlimit of0.007 lb/mmBtu, based onAP-42 emissionfactors. 

### BACT!LAER/BAT forFuelStorage Tanks: Theonly applicablepollutantfor thefuel storagetanks isVOC. Basedonthe lowemissions and highcost ofcontrols for these sources, the applicantproposesthe following asLAER: conservationventvalves andemission limits of0.0007 tons/yr and0.0002 tons/yrrespectively for the 2K-gallonULSDtank and 500-gallonULSD tanks. These limits have beenplacedin SectionH ofthe draftplanapproval. 

### Verification of S02 limits: BerksHollowhastakenvolnntary emissionlimits for S02toremainunder 40 tpy. Thelimits on individualunits are:

CCUl CCU2 FuelPreheater AuxiliaryBoiler Emergency Generator FirePnmp Total GE7FA 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 withthe S02i'SOx limits establishedinthePlanApproval willbedemonstrated throughmonitoring ofthefuel sulfur content and the amonntoffuel burned. Theemission limits arebasedona fuel sulfur content of0.68 gr/100 dscffornatural gas and 15 ppmfor fuel oil. The fuel sulfur content ofthenatural gas will be determinedbasedona customfuel monitoringplan

### BerksHollowEnergy, PA06-05150A 

## 9 November7, 2013

as describedin SectionE, GroupName KKKK, Condition#015 ofthe PlanApproval. Fuel sulfurcontent data for natural gas and fuel oil willbeprovidedbyall fuel suppliersperiodically. AsrequiredbythePlanApproval, dailyrecords offuel consumptionwill bemaintained to ensure that 12-monthrollingtotal emissionlimits for S02 /SOx arenotexceeded. Fuel consumptionrecords for the CCUs, fuel heater, and auxiliaryboilerwillberecorded ona nearly continuous basisusing a calibratedmeter and data acquisition system. 

### Verification of PM2.5 limits: Berks Hollowhastakenvoluntary emissionlimits for PM2.5 to remainunder 100tpy. ThePlanApproval includes PM2.5 limits on a 12-monthrollingtotal for eachemissions source, whichtotalto lessthan 100 tpyfor all emission sources combined. SectionVIIofGroupName PM2.5 inSectionE ofthe PlanApproval sets fmihreshictions onfacility-wide PM2.5 emissions and requirements for demonstrating compliance withthePM2.5 limitfor eachemissions source. SectionC ofthePlanApproval includesrequirements of25 Pa. Code Ch. 135 regarding submission ofan annual emission statement, whichwould include calculations ofPM2.5 emissions from each source and facility-wide. Forpurposes ofcompliance demonstration, PM2.5 emissions from the combustionturbineswill bedeterminedfrom stack testing duringnormal operations andworst-caseemissionfactors based onOEMdatafor startup andshutdownperiods. Maximumpotential annual emissions ofPM2.5 from startup and shutdownoperations are approximately2% ofthefacility-wide PM2.5 emissions. SincePM2.5 emissions are a result offuel combustion andno post-combustion controls arenecessary, PM2.5 emissions are expected to beconsistent andproportionalto the amountoffuel bumed. CompliancewiththePM2.5 limits for theremaining sources will bedemonstrated inpartby vendorguarantees andrecords offuel consumptionofthe auxiliaryboiler, fuel heater and emergencyengines; and emissionfactors and monitoring ofTDS for the coolingtower. 

### GHGAnalysis Theoriginal draftPlanApprovalincluded an annual limitonC02eemissions for eachemissions source exceptfor the Fuel Heater. ThePlanApproval now includes a limitof2,779,224tons per year. The annual C02elimits account for emissions ofall GHGemissions including C02 , methane (CH4), nitrous oxide (N2 0) and sulfurhexafluoride (SF6). For all fuel burning sources, the emissions estimatesprovidedinTableA-13 ofAppendixA oftheApplicationarebased on heatinput andEPA -approvedemissionfactors and globalwarmingpotentialslistedin40 CFR 98. Equation G-4 from Appendix G of40 CFR75 wasused to calculate C02emissionsfor the CCUs, auxiliaryboiler andfuel heater. The C02elimits established inthePlanApproval ensure compliancewith all individual GHGemissions sinceheatinputis used as a basis for calculation ofemissionsfor individual GHGs. The GHGBACTlimitfor the CCUsis 1,000 lbs C02perMWhona 12-operatingmonthannual averagebasis. Thecompliance demonstrationwiththis standardincludes emissionsfrom all operatingmodesincluding stariup and shutdown.

### Berks HollowEnergy, PA06-05150A 10 November7, 2013

.A facility·wide C02

### e limit of2,779,224tons peryearhasbeenincludedinSectionE, Group GHG. Changes madeto the original draftplanapproval include the following: 

## 1.) add 121.7reference inCondition C.017 2.) addreferenceto ERCprovisions of 127.208 inCondition C.018 3.) add C02

### e facility limitin SectionE Group GHG Condition#001 4.) addvendor guarantee requirementfor cooling towerdrift eliminatorsinSectionD, Source 103, Condition#005 5.) increase ammoniatpylimits from 77.45 and 80.47 tpyfromthe GE 7FA and Siemens F units, respectively, to 104.46tpy for the GE 7FAand 107.92tpyfor the Siemens Fin SectionE Group CCU Condition#001 6.) changethe CO,NOx andammonia shortte1m emissionlimits from 3-hourrolling averagesto 1-hourblockaverages inSectionE, Group CCU, Condition#001 7.) impose short-termNOx stmtup limits in Section E, Group Startup & 

### Shutdown, Condition #001 8.) add differentiationofshutdown definitionbetween GE and Siemens turbine options in SectionE, Group Stmtup & 

### Shutdown, Condition#002 9.) reduce stacktestingfrequency for "ductburners on"option

### in SectionE, Group PM2.5, Condition#001 10.) add summarytable ofemissions standards inSection Gasrequestedby EPA Conclusions andRecommendations I recommend TitleV Plan approvalNo. 06-05150Aberedistributed backtoEPAfor their concunencewiththerevisions thathave beenmade. CC: Pennits ReadingDistrict SCRegion 06-05150A, B5

### Berks HollowEnergyAssociates, L.L.C.

April 5, 2013

Mr. Ken Hmtzler Air Quality Permitting DepmimentofEnvironmental Protection (DEP) Reading District Offi<;e I005 Crossroads Boulevard Reading, PA 19605
Re: Comments to DraftPlan Approval No.**06~05150A** 

### BerksHollowEnergyAssociates, LLC (BHEA)

DearMr. 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



### BHEAhas received the letter dated March II,2013 which transmitted the draft Plan Approval No. 06-05150A. BHEA would like to offerthe enclosed comments to cetiain conditions in the Plan Approval. Please feel free to contactme (636-534-3268) ifyou have any questions. Sincerely,

BradleyJ. Cooley Senior Environmental Engineer

Enclosures

CC: ThomasHanlon,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 BHEAthe draft Plan Approval No. 06-05150A requesting comments within 30 days. BHEA respectfully submits its comments, which are presented below. 

### Section C, SiteLevel Plan ApprovalRequirements Condition #006 ' BHEA Comment: The condition limits emissions ofHAPs to less than 4.8 tpyfor a single HAP

(formaldehyde) and 11.3 tpy of totalHAP. 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 and25 tpyof total HAP) theproposedlimit Is unnecessarily restrictive. BHEA requests that/he limits be changedIa 10 lpy of asingle HAP and25tpyof totalHAP to be consistent with the**d~finilion** 

### of an area source. 

### Section E, Source GroupPlan AppmvalRestrictions, GroupName: CCU Condition #001 BHEA Comment: The condition, inpart, limits emissions of ammonia (NH 3 ) 

### to 5

### ppmvd@ 15% 0 2, 

### and less than 77.45 and 80.47 tpyji'Oln the GE 7FA and Siemens F units, respectively. DEP based the annual limit on the maximum hourly emission ratesfor thefired (ie, duel burners on) and1111fired (ie, duel burners off) cases, which are presell/ed in Table A-13 and A-14 of Appendfr: A ofthe Application, andthe hours of operationfor each casepresentedin TableA-2. The hours of operation in Table A-2 were usedspecificallyfor calculating worst case emissionsfor pollutants which are products ofcombustion including emissions during startup and shutdown. Because NH 3 

### is not emitted during startup and shutdown operations, the approachfor calculating worst case annual emissions is different than thatpresented in Table A-2. Specifically, since the hoursforstartup (maximum of 500 hours) and shutdown (maximum of 60 hours) are upper bounds, the combined cycle units will 

### runfor more than the 8200 hours (7365 hours normal operation, 835 hours with duct burnersfired) presented in Table A-2, the absolute worst case annual emissions should be calculated by assuming the highest hourly emissionfor the maximum possible annual operating hours (8760 hours). Based on this approach the annual emission limit for NH3 shouldbe calculatedasfollows: AnnualPTE (tpy) 

### = Worst Case Emission rate (lblhr) x Maximum Annual Operating Hours (hr) x 1 ton/2000lbs
ForGE 7FA (see Table A-13, Case 1 for worst case NH 3 emission rate) AnnualPTE (tpy) 

### =23.851b/hrx 8760 hrx 1 ton/2000 lbs 

### = 104.46 tonsperyear(tpy) ForSiemens F (see Table A-14, Case 10 for worstcase NH 3 emission rate) AnnualPTE (tpy) 

### =24.641blhrx 8760 hrx 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 5ppm limit is includedaspart of Condition #001. 

## If DEP insists on including an annual limit, BHEA requests that theNHJ limits be set as 104.46tpy for the GE 7FA and 107.92 tpy for the Siemens F.



### Section E, Source Group Plan Approval Restrictions, GroupName: PM2.5 Condition #001 BHEA Comment: The condition requires annual stack testingfor PM2.5 (EPA Methods 202 and5) both with duct bumers off and on. Duct bumers will be operated typically duringperiods of peak powerdemandonly, making itdifficult topredictwhen duct bumers will be operated. Operatingduct bumers expressly for the purpose ofstack testing may result in significant costs to BHEA, particularly duringperiods of lowpowerprices. Because of this uncertainty, BHEA requests that the condition be changedto require stacktestingno more than onceper five (5) yearperiod.


### Section E, Source GroupPlan Approval Restrictions, GroupName: STARTUP & 

### SHUTDOWN Condition #002 BHEA Comment: The condition defines shutdown as "theperiodbeginning with loweringof unit load below 60% with the intent of ceasingoperation

... " The GE 7FA combustion turbines are capable of fuming down to 50% loadduring normal operation. Assuch, BHEA requests the condition be changedto read "theperiodbeginningwith lowering of unit loadbelow 50% with the intent of ceasingoperation

... "

Berks Hollow Energy Associates, LLC 2 

### 4/5/2013UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION Ill



### Mr. ThomasHanlon Chief, Air QualityPermitting Air QualityProgram 1650 Arch Street Philadelphia, Pennsylvania 19103·2029



### Pennsylvania DepartmentofEnvironmental Protection ReadingDistrict Office 1005 Crossroads Boulevard Reading, PA 19605 

## APR 092013

RE: ProposedPlanApproval for Berks HollowEnergy Associates, LLC OntelauneeTownship, Berks County PlanApprovalNo. 06-05150A DearMr. Hanlon: Thankyoufor the opporttmitytci reviewthePennsylvaniaDepattmentofEnvironmental Protection'sproposedplanapproval for BerksHollowEnergy Associates, LLC, a combined-cycle natural gasfired electric generating station, inBerks County, Pennsylvania. Basedonourevaluation of theproposed plan approval andTechnicalReviewMemo, wehave identified several commentsthatare included ihthe attachment. Weprovide these conunents to help ensure thattheprojectmeets all federal requirements, thatthepermitprovides all necessary informationso that itisreadily accessible to the public, andthattherecordprovides adequate supportforthepermitdecision. We lookfotward to workingwithyouinaddressing all the issuesraised. Ifyouhave questions, please do nothesitate to contactmeat215-814-2173 orMr. Himanshu Vyas ofmy staffat 215-814-2112.

ec: KenHartzler, PADEP Enclosure Sil.,rcly**y~,** 

### ,.,

# ~fu&(j**j(/,?.,y~"'~** 

# j}P-z_. KathleenCox AssociateDirector, Office ofPermits and AirTaxies (3AP10)



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### Comments on Plan Approval 1. Emission Offsets: Theproposed facility is subjecttotheNonattainmentNew Source Review (NNSR)requirementsbecausethefacility is located in an ozonetransportregion andhasthe potential to emit greaterthan 100tons ofNOxand 50 tons ofVOCs in any consecutive 12 monthperiod. Therefore, a purchase ofEmissionReduction Credits (ERCs) to offsetthe NOx and VOC emissions increases is required. According to Pa. Code 127.208, an owneror operatorofa facility shall acquireERCs for use as offsets from an ERCgenerating facility locatedwithinthe samenonattainmentarea. As NOxis considered aprecursorto PM2.5, the NOxERCs mustbeobtainedfrom withinthe PM2.5 nonattainment area that includes Berks County, Pennsylvania. 2. BACTILAERanalyses: EPA does notbelievethat the Technical ReviewMemo (TRM) and proposed planapproval sufficiently describetheBestAvailableControl Technology (BACT)!Lowest Achievable Emissions Rate (LAER) analysesthat wereperformed. Ina BACTanalysis, thereviewing authority should evaluatethe energy, environmental, economic and othercosts associated witheachalternative technology, and the benefit of reduced emissionsthatthetechnologywouldbring. Thereviewing authoritythen specifics emissions limitations for the source thatreflectsthe maximum degree ofreduction achievable for eachpollutantregulatedunderthe CleanAirAct. Theplanapproval conditions must reflect all operational limitations in orderto show compliancewiththese emissions limitations. TheTRMshouldprovidethetop-down BACT/LAERoptions and an analysis for whythechosen emissioncontrolsmeetthe BACT/LAER standard. 3. NOx controls: Therecordindicatesthattheuse ofdry low-NOx (DLN) combustors and Selective CatalyticReduction (SCR) would fulfill LAERfor NOx and BACT for 

### N02. 

### The analysis also indicates thatthe use ofoxidation catalysts would constituteLAERfor VOC emissions andBACTfor CO emissions. However, the plan approval does not appear to requirethe operation ofthesecontrols atall times whenthe combustionturbines and duct burners are operating. Sincethese control devices are necessaryto meetthe required emissionlimits, the plan approval shouldrequirethe operationofthe controls atall times. 4. Greenhouse Gas (GHG) pollutants: EPAhas thefollowing concerns: a. TheTRM andproposedplanapproval do notsufficientlyaddress all GHGpollutants. GHG emissionlimits should accountfor notonly COz, butfor all oftheGHGs that are emitted (methane, nitrous oxide, SF6). Please also clarify howcompliancewill be demonstrated for each ofthe GHGs. Theplanapproval, as cunentlywritten, does not include sufficientrequirements ormeans ofcalculationto ensure compliancewiththe COze limits. b. Itis unclearwhetherthe C02 

### emissionlimit applies for the turbhies duringtimes of stattup and shutdown. Please confirmthatthe limit applies during all periods of operation orindicate an altemate limitfor stmtup and shutdown.



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### 100% recycled/recyclablepaperw/t/1 100%post-consumer fiber a11dprocess clllorl11e free. 

### CustomerServiceHotl/11e: 1-800-438-2474

### c. Theproposed plan approval references the Tailoring Rule (40 CFRPatts 51 and 52) for calculating GHG emissions. This is incorrect. Thereference should be to the 40 CFR Part98 tables on global warmingpotential. 5. TheBACTILAERanalysis for the CoolingTower: TheBACT!LAER analysis for particulatematter emissions from the Cooling Tower indicates that theemission rates were determinedusing boththe driftrate limit and the total dissolved solids. Therefore, theplan approval should containrequirements to control and monitorthe drift rate and the total dissolved solids content ofthe cooling water. Theserequirements are necessary to ensure compliance with the emissions limits. 6. TheBACT/LAERanalysis for the Auxiliarv Boiler: TheBACT!LAER for AuxiliaryBoiler relies on4,600 hours/year ofoperationlimitandthe use ofonlypipeline quality natural gas as afuel. However, only the "expected operatinghours" is listed inthe plan approval, and thattoo in theMiscellaneous section and not inthe Source Level Requirements section. These operational requirements should be reflectedproperly inthe plan approval conditions to ensurecompliancewiththe emissions limits. Additionally, there is adiscrepancy in the description oftheexpectedoperatinghours ofthe Auxiliary Boilerinthe TRM. TheTRM notes onthat "Oncethe gas turbines are at steady-statethe auxiliary boilerwill be taken off line." Sincethe TRMandtheplanapproval define stmt-up and shut-down operations for the CCU andlimitthoseto 500 hours and 60 hours peryear each, it wouldmake sense that the AuxiliaryBoilerwould only operatefor 560 hours peryear. Please explainthe additional expectedhoms ofoperation for the Auxiliary Boiler. 7. S02 emission limitand monitoring: EPA has the following concerns:

a. The TRM notes thatBerks Hollow is taking voluntary emission limitfor S02ofless than 40 tpy. However,theTRM does notprovide exactlywhatthe permitlimit is, and how itwill bemonitoredto ensure the facility does notexceed this federally enforceablelimit. Forclarity, pleaseprovide this information 

### inthe TRM. b. Theplanapprovalprovides annual SOxemissionlimits ona rolling 12-monthbasis for the two turbine options that, whenincludingnormaloperations and startup and shutdown times, addup to 39.44 tpy. This limitisjustbelowthe SERthreshold for S02. IfS02is notpreciselymeasured during all operatingtimes, including stmtup and shutdown, this limitis highly suspect.

c. Theplanapproval applicationuses variable grains ofsulfurin the term "pipeline qualitynatural gas" that varyfi·om as high as 20 grains S per I00 scfto 0.68 grains S per l00 scf. Please specifY the quality ofnatural gas to beused at Berks Hollowand theemissions ofS02expectedfrom burningthatquality ofnatural gas. 8. PM2.5 emission limit and monitoring: EPAhas thefollowing concerns:

a: The TRMnotes thatBerksHollow is taking voluntaty emissionlimitfor PM2.5 of less than 100 typ. However, theTRMdoes notprovideexactlywhatthis limit is, and**~)** Pri11ted011 100% 

### recycled/recyclablepaperwltlt 100%

### post-consumer fiber and process clt/or/nefree. 

### CustomerServiceHotline: 1-800-438-2474

### howitwill bemonitoring to ensurethe facility does not exceedthis federally enforceable limit. For clarity, please providethis inf01mation inthe TRM. b. Theplan approval provides annual PM2.5 emission limits on arolling 12-monthbasis for thetwo turbine options as well as otherunits, whenincludingnormal operations and startup and shutdowntimes, add up to morethan 99.25 tpy. This limitisjust belowthemajor sourcethresholdfor PM2.5. IfPM2.5 is notprecisely measured during all operatingtimes,including startup andshutdown, this limitis highly suspect. 9. Missing Sectionfrom the proposedplanapproval: Theproposedplan approvalis missing Section Gfor listing "EmissionRestriction Summary"for allpollutants from all emission 

## units. Pleaseprovidethis section intheplan approval for easeofcompliance assurance. A similarfacility recentlypermittedbyPADEP, HickoryRunEnergy, LLC, has aplan approval draftedbyNorthwestRegional Officethat contains such a section. Theproposed plan approval is also missing SectionF,titled "Altemative Operating Scenario(s)" inthe table ofcontents. · 10. Missing SIP requirement: Pennsylvania's State ImplementationPlan (SIP) at 40 CPR 52.2020 includesthegeneral standard against airpollution codified at25 Pa. Code §121.7. This general standard states that"Nopersonmaypermitairpollution as thatterm is defined inthe act." Pa. Code 127.502(a)require.s thatapplicablerequirements for stationary air contamination sources shallbeincluded intheoperatingpermit. Thedefinition of "applicablerequirements" atPa. Code §121.1 includes any standardprovidedforinthe Commonwealth's SIP. InPennsylvania'smergedpermittingprogram, applicable requirements ofa planapproval are administrativelybroughtinto thetitleVpermit; however, since this is a newfacility, ithas no currenttitleV permit. We notethattheplan approval should includethe general standard in orderto facilitate thatrequirementbeingincluded in thetitleV permit, whenissuedto Berks Hollow, will have the general standard in it

.

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### Comments on ModelingReport Section2.1.1 Combined CycleUnits: 

### A7TACHf.l ft!T C**~PA ff\oOC~ING**  (e>N/IfN 

### 1S



### NOx controls onthe combined cycle combustionturbine generators imposed under PM-2.5 and/or ozone should beoperated year roundto ensure compliancewith the N02NAAQS. Section 2.3 Applicable Pollutants: PADEP should considerBerks Hollow's potential impactoncunentPM-2.5 concentrations in Berks County. While its PM-2.5 contributions may be minimal, Berks Hollowmay impactthe county's attainment status underthe 1997NAAQS and EPA'srevised PM-2.5 NAAQS. Section 3.6 ReceptorDataDescription: Model peaks inthe base loadtuns for the GEand Siemens combustionturbines occurred outside thefine Cartesianmodelreceptor gridthatextendedapproximately 1kmfrom theBerks Hollow facility. Itappears thatthe modelreceptor grid wasrevised intheN02NAAQS andIncrement Runs to examinethe area nearthehighestmodeled concentration. Itwould be helpful ifPADEP could addresshowthemodel receptor grids capturethemaximummodeled concentrations in accordance with section7.2.2 (a) ofAppendix W. Section 4.1 SignificantImpactAnalysis: Do the load scenarios described inthis section include ductfiring (described in Section3.5)? For example, canthe combustionturbines be fired at 100% with m· withoutductfiring and would the stackparameters and emissionrates change betweenthesetwo potential operatingmodes?

. Stackparameters for the GEand Siemens combustionturbines arequite similar. Did PADEP confirmthe similarity inemissions profiles for Berks Hollow's GE and Siemens combustion

.turbines for allpollutants? Section 4.1.3 NO, Significance: How long do startup/shutdown cyclestypically last and howlong does ittakefortheNOx controlequipmentto becomefully functional? Berks Hollowcould have usedPVMRM or aTier2 ambientratio in its significanceanalysis to reducetheradius ofinfluence usedto identifyoff-site sources for its cumulative analysis. The off-site inventorycould also havebeen reduced (innumber) co!)sideringthe closeness ofthe background monitoring siteto BerksHollow. Many ofthe smaller sources areprobably adequately accounted for intheN02backgroundconcentration. See section 8.2.3 ofAppendix W for additional guidance on this topic. Section 4.3.1 1-hrNO•NAAQS: The repottdiscussed themodeled 1-hrN02NAAQs violations notedinthe Berks Hollow modeling analysis. EPARegion 3 wouldlike PA DEP to addresstheseviolations inmore detail. Themodeling analysis adequately demonstrates thatBerksHollowis not causing orsignificantly contributingto anymodeled violations. EPARegion 3 conducted some additional analysis usingBerks Hollow'sNAAQS andIncrement N02runs. Itappearsthattwo sources are contributingto the modeledN02 violations. These 

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### sources are the Titus Station Generating Stationin CumtuTownship andLehigh Cementon Evansville Road. 

## Titus Station: This facility is slatedto close inthe next couple ofyears. This should eliminate any modeled violations attributable to this source once closure is confirmed and finalized. Lehigh Cement: 

### The modeled emissionrate usedby Berks Hollow was roughly 2,622.85 tpy (75.4 g/s). Actual NOx emissionrates from 2009-11 taken from PADEP's eFACTS systemranged from 1,146tpy in 2010 to 1,610tpy in 2009. NOx emissions priorto 2009 exceeded 2,000 tpy. Running Lehigh Cementusing 2009 actual (annual) emissionsreduces modeled concentrations from 224 J.tglm 3
, 

### which exceeds the standard of188 J.tg/m3

, 

### to 172 J.tg/m3 

### (withoutbackground). Reducing Lehigh Cement's allowable emissionrate to reflect actual emissions overthe last**thr~e** 

### (3) years may eliminatethe modeled violations. PADEP shouldinvestigate this possibility. Section 6.1 Air Quality Related Values (AQRVS): BerksHollow should include the Q/dvalues for each ofthe Class I areas in atable or appendix. Section 6.2 PSD Increment: PADEP shouldprovide more explanationwhy Berks Hollowwas exempted from the Class I incrementanalysis.



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### Berks Hollow EnergyAssociates, L.L.C.

May28,2013

Mr. Tom Hanlon Chief, Air Quality Permitting Air QualityProgram DepartmentofEnvironmentalProtection (DEP) ReadingDistrictOffice 1005 CrossroadsBoulevard Reading, PA 19605

Re: Responseto EPA Comments BerksHollow EnergyAssociates, LLC (BHEA) DraftPlan ApprovalNo. 06-0SlSOA

DearMr. Hanlon: c/o LS Power Development, LLC 400 Chesterfield Center, Suite 110 St. Louis, Missouri 63017 (636) 532-2200 ·Fax (636) 532-2250



### BHEAhas reviewedthe letterfrom EPA dated April 9, 2013 regarding comments to the draftPlanApproval No. 06-5150A. BHEArespectfully offers the enclosed responses for consideration byDEP. Please feel free to contactme (636-534-3268) ifyouhave any questions. Sincerely,

Bradley

### J. Cooley SeniorEnvironmental 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 tothe draft Plan Approval No. 06-0SlSOA issued forthe 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 ofthe 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 ofdry 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 ofoxidation catalysts.would constitute LAER for VOC emissions and BACT for CO emissions. Howevet·, the plan approval does not appear to require the operation ofthese 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 ofthe controls at all times. BHEA Response: BHEA will operatethe SCRand oxidation catalyst units ("post-combustioncontrol devices") at all times during normal operationincluding periods whenthe duct burners are fired. Post-combustioncontrol devices cannot be operated during periods ofstartup or shutdown since temperatures ofthe exhaustgases will

### be below the necessary range for proper operation ofthe control devices. ThePlanApproval includes Condition #005(c) under Section E, Group Name CCU, which requires operation ofthe airpollutioncontrol devices at all times during normal operation andreads as follows: "Thepermittee 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 believesthis condition satisfactorily addresses EPA's comment and does not believe anadditional 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 ofthe 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 ofcalculation to ensure compliance with the C02elimits. BHEAResponse: The Plan Approval includes an annual limit on C02e emissions for eachemissions source except for the Fuel Heater. BHEA proposes that the Plan Approval include a limit of4,996.3 tons C02eon a 12-month rolling basis for theFuel Heater (Source JD 

### 030). The armual C02elimits account for emissions ofall GHG emissions including C02,methane (CH4), nitrous oxide (N20)and sulfurhexafluoride (SF6). Forallfuel burning sources, the emissions estimates provided inTable A-13 ofAppendixA oftheApplication are based onheat input and EPA-approved emission factors and global warmingpotentials listed in 40 CFR98. Equation G-4 from Appendix G of40 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 inthe Plan Approval ensure compliance with all individual GHG emissions since heat input is used as abasis for calculationofemissions for individual GHGs. BHEA suggests thatDEP include in SectionE under Group Name GHG ofthe PlanApproval a condition for each source specifyingthat compliance mustbe demonstratedbased on the heat input ofthe source and emissionfactors and equations as described inthe Table A-13 ofAppendix Aofthe Application.

b. It

### is unclear whether the C02 

### emission limit applies for the turbines during times ofstartup and shutdown. Please confirm that the limit applies during all periods ofoperation orindicate an alternate limit for start np and shutdown. BHEAResQonse: The GHGBACT limit for the CCUs is 1,000 lbs C02perMWh 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 ofthe cooling water. These requirements are necessary to ensure compliance with the emissions limits. BHEAResponse: ThePlan Approval requires monitoring ofthe total dissolved solids contentofthe cooling tower water. Although the Plan Approval does not specify conditions relatedto the drift rate oruse ofdrift eliminators, Source 103 (CoolingWaterTqwer) is defined in Section Hofthe Plan Approval as follows: "Amulti-cell mechanical draft coolingtower with a water circulation rate of 162,206 gpm; with aTDS concentration of5,000 ppmv; and with an associated drift of0.0005%." Since driftrate cannot be monitored, BHEA proposesthatDEP add a condition to the PlanApproval requiring installation ofdrift eliminators with avendor guarantee of0.0005% or less drift.

6. The BACT/LAER analvsis for the Auxiliarv Boiler: TheBACT/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 notin 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 ofthe expected operating hours ofthe Auxiliary Boiler in theTRM. 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 peryear each, itwould make sense that theAuxiliary Boiler would only operate for 560 

### hours peryear. Please explain the additional expected hours ofoperation for the Auxiliary Boiler. BHEAResponse: BHEA believes EPA mayhave misunderstood the description in theTRM. The TRM neither Page 2

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### 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 operationofthe auxiliruy boilerwill be limited to startup and shutdown periods only. The auxiliary boiler will beused to providehighpressure steamwhen the combined cycle generatingunit is offline in order accommodate more rapid startup following extended shutdownperiods. Hence, the auxiliruy boilerwill primarily run duringthe period prior to initiation ofstrutup ofthe combustionturbines and during startup, and thus the number ofhours ofoperation will necessarily be greaterthanthat ofstartup operations (or 500 hours). A separate annual limit for hours ofoperation is notnecessary since 12-monthrollingtotal limits have been established for eachpollutant. lfDEPdetermines that a condition limiting hours ofoperation ofthe auxiliary boiler is necessary, BHEA is willingto accept an operating limit of4,600 hours.



### 7. S02 emission limit and monitoring: EPA has the following concerns:

a. The TRM notes that Berks Hollowis taking voluntary emission limit for 

### S02 ofless 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. BHEAResponse: S02limits are established inthe Plan Approval for each emissions source, andthesum ofthose limitations is less than 40 tpy for all sources combined. If

### further clarificationisneeded, a Source Group could be added in Section E ofthePlanApproval to reflect the facility-wide S02limit of40 tpy and the method for demonstrating compliance with S02emission limits for each emissions sourcewhichwould be based onthefuel sulfur contentand the runount offuel 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 isjust below the SER threshold for 

### S02. If

### S02is not precisely measured during all operating times, including startup and shutdown, this limit is highly suspect.

BHEA Response: Compliance with the S02/SOxlimits established inthe PlanApproval will bedemonstrated through monitoring ofthe fuel sulfur content and the runount offuel burned. The emissionlimits are based on a fuel sulfurcontent of0.68 gr/100 dscffornatural gas and 15 ppm for fuel oil. The fuel sulfurcontentofthe natural gas will be determined basedon a custom fuel monitoringplan as described in SectionE, Group Nrune KKKK, Condition# 015 ofthe PlanApproval. Fuel sulfurcontentdatafor natural gas and fuel oil will be provided by all fuel suppliers periodically. As required by the PlanApproval, daily records offuel consumptionwill be maintained to ensure that 12-monthrollingtotal emission limitsfor S02/S0xare not exceeded. In

### fact, fuel consumption records forthe CCUs, fuel.heater, and auxiliary boilerwill berecorded on a nearly continuous basis using a calibrated meter and dataacquisition system. Based on this approach, BlffiA does not believe any additional monitoring requirements are necessary to ensure compliance withthe S02/S0xemissionlimitations.

c. The plan approval application uses variable grains ofsulfur 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 ofnatural gas to be used at Berks Hollow and the emissions of 

### S02 expected from burning that quality ofnatural gas. Page 3 

### ofS

### ENCLOSURE RESPONSES TO EPA COMMENT LEITER DATED April9, 2013 REGARDING BERKS HOLLOW ENERGYASSOCIATES, LLC (BHEA} PLAN APPROVAL NO. 06-0SlSOA
BHEAResponse: The fuel sulfur content ofthe natural gas supplied will not exceed 0.68 gr/100 dscf. The referenceto 20 gr/100 dscfin Section 3 ofthe Applicationreflects the value which exempts stationary gas turbines from theNSPS S02standard (see 40 CFR §60.4330(f)). The expected project S02 emissions from combustion of the natural gas are presented in AppendixA ofthe Application for each emissions source. Thosevalues are calculated based on an expected fuel sulfur content.of:S0.68 gr/100 dscf. Thos calculated S02 emission values are reflected inthe S02emission limits established inthePlanApproval.



### 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 ofless 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. BHEAResponse: ThePlan Approval includes PM2.5 limits on a 12-monthrollingtotal for each emissions source, which total toJess than 100 tpy for all emission sources combined. Section VII ofGroup Name PM2.5 in SectionE ofthe Plan Approval sets forthrestrictions on facility-wide PM2.5 emissions and requirements for demonstrating compliance with the PM2.5 limit for eachemissions source. Section C ofthe Plan Approval includes requirements of25 Pa. Code Ch. 135 regarding submission ofan annual emission statement, which would include calculations of PM2.5 emissions from each source and facility-wide. Compliancewith thePM2.5 limits will be demonstrated in pattby stack testing for the CCUs duringnormal operation; worst-case emission factors based on original equipment manufacturer (OEM) data for startup and shutdown periods for the CCUs; vendor guarantees and records offuel consumption ofthe auxiliary boiler, fuel heater and emergency engines; and emission factors and monitoring of TDS for the coolingtower. Based onthe compliance demonstration and reporting requirements set forth in the Plan Approval, BHEA does not believe any additional monitoringorreportingrequirements are necessary to ensure compliance withthe 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 aswell as other units, when including normal operations and startup and shutdown times, add up to more than 99.25 tpy. This limit isjustbelow the major source threshold for PM2.5. 

### IfPM2.5is not precisely measured during all operating times, including startup and shutdown, this limit is highly suspect. BHEAResponse: Forpurposes ofcompliance demonstration, PM2.5 emissions from the combustion turbines will be determined from stacktestingduringnormal operations and worst-case emission factors based on OEM data for startup and shutdownperiods, which is also the basis for the emission estimates presented inTable A-2 ofAppendix A ofthe Application. Maximumpotential annual emissions ofPM2.5 from startup and shutdown operations is approximately 2% ofthe fucility-wide PM2.5 emissions, and actual annual emissions willtypically bemuch less thanpermitted since stattup and shutdown operations will typically occur less than the limit of500 annual hours. SincePM2.5 emissions are a result offuel combustion and no post-combustion controls are necessary, PM2.5 emissions are expected to beconsistent andproportional to the amount offuel burned. Forthis reason and the fact that fuel flow totheturbines will bemonitored continuously, direct continuous monitoring ofPM2.5 is not necessary orpracticable.
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### ENCLOSURE RESPONSES TO EPA COMMENT LETTER DATED April9, 2013 REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA 

### Becausethe PM2.5 limit for each emissions source represents the worst case emissionrate, compliancewith the PM2.5 limits for each emissions source will ensure that facility-wide emissions will be belowthe major source threshold for PM2.5 of 100tpy. As aresult, BHEA does not believe any additional conditions are necessary to ensure that facility-wide PM2.5 emissions are belowthe major source threshold.

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### April IS, 2013 ViaElectronic and First Class Mail Mr. Thomas Hanlon Facilities Permitting Chief PA DEP Air QualityProgram 909 Elmerton Avenue Harrisburg, PA 17110 

### Re: Berks HollowEnergyAssociates, LLC,BerksHollow Energy Station Plan ApprovalNo. 06-0SlSOA

Mr. Hanlon, Clean Air Council ("Council") hereby submits the following comments in response to the Pennsylvania Department ofEnvironmental 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 ofa combined-cycle natural gas fired electric generation station, BerksHollowEnergy Station ("Station") to produce up to 855 MW ofelectricity at 5662 LeesportAvenue in OntelauneeTownship, Berks County. Clean Air Council is a non-profit environmental organization headquartered at 135 South 19th Street, Suite 300, Philadelphia, Pennsylvania 19103. Formore 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 protecteveryone'srightto breathe clean air. Background/Introduction: On Aprill8, 2012, Berks Hollow submitted an application for the construction ofa natural gasfired combined cycle electric generation facility that is designed to generate up to 855 MW of electricity. The Station will generate electricityusing 2 combustion turbine generators and 2 heat recovery steam generators thatwill provide steam to drive a single steam turbine generator. Each


### I

### heatrecovery steam generatorwill be equipped with a ductburnerwhich may be utilized at time ofpeak powerdemands to supplement power output. The source is subject to Prevention of SignificantDeterioration ("PSD") and New Source Review ("NSR") requirements. Theproposed projectwill 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 ofplantequipment. This will be a Title V facility. On March 16,2013, PA DEP provided notice ofits intent to issue Plan Approval 06-05150A. 

### Comments: I. PA DEP may not issue the Plan Approval until it has determined thatthe sources comply with applicable regulations, which it cannot do without knowingthe make and model of the sources. Pennsylvania's plan approval regulations require an application to show "thatthe source will complywith applicable airrequirements of[25 Pa. Code, Att. III] and requirementspromulgated bythe Administrator ofthe [U.S. Environmental Protection Agency ("EPA")]

...." A source is any "place, facility orequipment, stationaryormobile, at, from orby reason ofwhich there is emitted into the outdooratmosphere any aircontaminant."2


### Berks Hollow has notprovided a make ormodel to PA DEP for the combustion turbines, at the very least. Without access to the application it is unclear whetherthere are other sources where the make and model have also not been provided. Theturbines, atthe very least, meetthe definition ofa "source" and mustcomplywith the "applicable requirements." Although Berks Hollowhas indicated thatthe Station will contain these sources, the precise pieces ofequipment have yet to be specified. The application thus omitted information crucialto showingthatthe sources would complywith applicable air requirements, meaning PA DEP may notapprove it.3 

### PA DEP should find the application incomplete and refrain from acting on it until Berks Hollow submits the make and model ofpollution sources to be installed. 2. 

### Itis illegal, arbitrary, and capricious for PA DEP to declare an undetermined source to be BACT. Applicants for aplan approval must show that "the emissions from a new source will be the minimum attainable through the use ofthe bestavailable technology."4 

### Best available control technology ("BACT") is an emissions limitation based onthe maximum degree ofreduction for each regulatedNSRpollutantwhich would be emitted from any proposed majorfacility 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) ("TheDepartmentwill 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 cleaningor treatment or innovative fuel combustion techniques for control ofthe pollutant.5 

### Although PA DEP noted that "[t]he facility is proposingtwo different supply options and will pick one option priorto construction," it nevetiheless recommended thatthey be considered BACT. BACTis a "systemic analysis."6

### Thus, it naturally involves comparisons among technologies. In conductinga BACT analysis, "onecannot look atparticularemissions parameters in a vacuum."7 

### Nevertheless, the whole ofthe PADEPs BACT analysis is done in a vacuum. PA DEP may notfind the plan approval to be complete without a BACTdetermination, which it cannot complete when it lacks the make and model ofthe sources. 8 

### Implicit in the requirement that an applicant demonstrate its source is BACTis that PADEP 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 notknowing the make or model ofthe sources. PA DEP goes so far as to provide separate emissions limits for each turbine that Berks Hollowmay choose. A BACT determination is 

## an emissions limit, not a series ofoptions. Berks Hollowhas failed to specifically identifythe turbines they intend to install and operate and PA DEP may not approve those sources as BACTuntil they are specifically identified and that information is made available for public comment. EPA has made clearthat ifan owner/operator makes changes that "lead to changes in emissions, impacts on airquality, or control technologies

...such changes require [the permitting agency] to conduct comprehensive analysis ofthe 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 PlanApproval's main flaw is the cursory review and blind acceptance ofBerks Hollow's proposedBACT. In a matter offour pages PA DEP accepts BACTlimits for six sourcetypes and tens ofpollutants. This is entirely insufficient and does notconstitute a properBACT analysis. PA DEP's reliance on the Hickory Run review does notexcuse it from performing a sufficient BACT analysis.

5 25 Pa. Code§ 121.1. 6

### Residents OpposedtoBlackBridge 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, 

### interalia, that the source will be BAT). 9 

### See Letter from Becky Weber, Director, Air and Waste ManagementDivision, U.S. EPA Reg. VII, to John Mitchell, Director, KS Dept. ofHealth and Envt. (Abengoa Bioenergy) (Apr. I, 2011). 

### 3

### BACT is a "case-by-case" analysis that takes "into accountenergy, environmental and economic impacts and other costs." 10 

### PA DEP mustperform this case-by-case analysis in the Review Memo and may not rely on HickoryRun or defer to Berks Hollow. 4. The Station should be required to use natural gas with a sulfur content of0.25 gr/100 scf. PA DEP has determined thatBACTfor sulfur oxide ("SOx'') and ("H2 S04") 

### is use ofpipeline quality natural gas with an emissions limitation of0.68 gr/100 scf. However, in a recent Plan Approval application for a similarnatural gas-fired powerplant, (41- 00084A) Moxie Patriot, LLC, indicated thatthe sulfur contentofthe gas they will use is 0.25 gr/100 scfaccordingto the specificationsprovided by the fuel supplier. Itis unclear why this Station will have a sulfur content limitnearly threetimes the available fuel supply. The Council requests that PADEP lowerthe sulfurcontent or provide an explanation. Further, itdoes not appearthat the proposedPlan Approval includes monitoringfor the sulfuric acid mist. The Plan Approval should include a method ofdemonstrating compliance with the fuel sulfur limit. 5. TheProposedPlanApproval must be revised to require that PMu_is limited and monitored separatelyfrom PM10• 

### Particulate Matter ("PM") is treated as two separate pollutants under the Clean AirAct: PM 10

### and PM2.s· EPAhas stated thatbecause PM2.s now has a separate and distinctNAAQS, PMto

### can no longerbetreated as a surrogate for PM25. 72 Fed. Reg. at 20,659. Therefore, consistent with the EPA's treatment ofemissions 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 variouspollutants on various sources at the Station. "Good combustion practices," however, are not defined. PA DEP should include a description ofthe various practices that will be required for each pollutanton 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"Subjectto regulation" in the greenhouse gase ("GHG") tailoringrule at 40 CFR 52.2l(b)(49)(i), andunder the definition of"RegulatedNSRpollutant" at 40 CFR 52.2l(b)(60)(iv), both ofwhich are incorporated by reference into State rules, the pollutant that is subjectto regulation, andtherefore a regulated NSRpollutant, is defined as GHG, not carbon dioxide ("C02 "). Therefore, the BACTemission limit should be expressed in terms oftotal GHG emissions, as COrequivalent ("C02 e"), and the Plan Approval should indicate how compliance will be demonstratedfor the two non-C02GHGs 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 compliancewith the emission limits for total GHGs, EPA recommends use ofemission factors from Table C-2 of40 CFRpatt98 and global warming potentials from Table A-1 of40 CFRpart 98, alongwith the actual measured heat input forthe combustion turbines. ThePlan Approval should also state that the results offuture stack tests canbe used to determine a source-specific emission factor to calculate GHG emissions from the Station. 8. ThePlan Approval must include a BACT limit for GHGs and may notrely solelyonthe NSPS. WhileNSPS TTTT is an applicable requirement, it is not a substitute for a GHG BACT analysis. Further, as discussed above, TTTTsets a standard ofI000 lbs C02 /MWh. A GHG BACT determination requires an enforceable limit on all GHGs. The largest source ofGHGs atthe Station will be C02from the combined cycle units. Generally, permitwriters compare thermal efficiencies ofvarious units to determine what BACT is and then regulate GHGs bysetting a lbs C02 e/MWh standard along with a net heat rate figure. The ReviewMemo should be able to showthatthe most efficientcombined cycle unit is chosen for the Station, or it shouldjustifywhy a unitwith a lower efficiencywas selected. PADEP must then go on to ensure thatBACT is setfor each source and for all GHGs including methane and nitrous oxide. The measures selected for BACThere are vague and unenforceable. PA DEP indicates that: The remaining GHG control option is the efficient use ofenergy. The turbines and duct burners will be designed for emissions of greenhouse gases that are less than 1000 pounds of C02 per megawatt-hour ofelectricity produced, in conformance with EPA's proposedNSPS mle for Electric Utility Generating Units (proposed 3/27/12). This would constitute BACTand BAT for GHGs. To adequately support a BACTdetermination, PA DEP must, at minimum, clarifywhether all available control options were considered, whetherthe option selected is the best-performing optionthat is known to be available andtechnically feasible, whether energy, environmental and economic impacts affected the selection ofthe control option, and ifthe best-performing option was notselected provide an explanation and suppmting basis for that selection. PADEP may not merely seta C02standard on the combined cycle units and "good combustion practices" on other sources. Each sourcethat emits GHGs must have an enforceable limit and the Station as awhole must have enforceable limits. A 1000 lbs C02 /MWh on the combined cycle units limitdoes notrepresentBACT.11

11 

### See e.g. Sumpter Power Plant with a GHGBACT limit of954 lb C02e/M\Vh and Palmdale Hybrid Power Project with a GHGBACT limitof774 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)(l0) in the Condition, however this section merelyprovides that an application must "[s]howthat the source and the air cleaning devices are capable ofbeing and will be operated and maintained in accordance with good airpollution control practices." Ifthere are engineering practices necessary to keep the air cleaningdevicesproperly operated and maintained those should be specifically included in the Plan Approval.

The Council encourages PA DEP to perform an independent evaluation ofthe Plan Approval application and to respond to all comments from the public to ensure that any final action is consistentwith 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 ofany future actions related to PlanApproval 37-337A. Sincerely,

Joseph Otis Minott, Esq. Executive Director



### 6

### Berks HollowEnergyAssociates, L.L.C.

May30, 2013

Mr. Tom Hanlon Chief, Air QualityPermitting Air QualityProgram DepartmentofEnvironmental Protection (DEP) Reading DistrictOffice 1005 Crossroads Boulevard Reading, PA 19605

Re: Responseto Comments from theClean Air Council BerksHollowEnergyAssociates,LLC (BHEA) DraftPlan ApprovalNo. 06-0SlSOA

DearMr. Hanlon: c/o LS Power Development, LLC 400 Chesterfield Center, Suite 110 St. Louis, Missouri 63017 {636) 532-2200
- Fax (636) 532-2250



### BHEAhas reviewedthe letterfrom 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 byDEP. Pleasefeel free to contactme (636-534-3268) ifyou have anyquestions. Sincerely,

Bradley

### J. Cooley SeniorEnvironmentalEngineer 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 ofthe Commenter's letteris provided below (with footnotes removed), with responses to each comment interspersed within the text in bold font. 

# ===================================================================================== 1. PADEP may notissue the PlanApproval until ithas determinedthatthe sources comply withapplicable regulations. which it cannotdo withoutknowingthe make and model ofthe sources. Pe1msylvania'splan approval regulations require an application to show "thatthe source will comply with applicable airrequirements of[25 Pa. Code, Art. III] andrequirements promulgated by theAdministratorofthe [U.S. Environmental ProtectionAgency ("EPA")]

...."Asource is any "place, facility or equipment, stationary or mobile, at, from orbyreasonofwhichthere is emitted into the outdoor atmosphere any aircontaminant." Berks Hollow has notprovided a makeormodel to PADEP for the combustionturbines, atthe very least. Without access to the application it isunclearwhetherthere are other sources where the make and model have notbeen provided. Theturbines, atthe very least, meetthe definition ofa "source" and must complywiththe "applicablerequirements." AlthoughBerks Hollowhas indicatedthatthe Station will containthese sources, theprecise pieces ofequipmenthave yet to be specified. The applicationthus omitted informationcrucialto showingthatthe sources would complywith applicable airrequirements, meaningPADEP may notapprove it. PADEP should find the application incomplete and refi·ain from actingonituntil Berks Hollow submits the make andmodel ofpollution sources to beinstalled. 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 ofthe 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,

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### 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 ofthe PA**Co~e** 

### and requirements promulgated by EPA underthe Clean Air Act. 1


### The Applicant requested the flexibility to select from the following combustion turbine generator ("CTG") options, whichwere evaluated in detail in theApplication:

• 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 bethoroughly 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 optionwas 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 ofthe Plan Approval establish the performance requirements based on

1 Refer to Section 3 of BHEA's Application for detailed discussions of such applicable requirements.
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### 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 ensurethat all applicable requirements will be met. In summary, the level ofdetail 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. Itis illegal, arbitrary. and capricious for PA DEP to declare an undetermined source to be BACT. Applicants for aplan approval must show that "theemissions from a new source willbethe minimum attainablethrough the use ofthe bestavailabletechnology."Best available control technology ("BACT") is an emissions limitation basedonthe maximum degree ofreductionfor each regulatedNSRpollutantwhich would be emittedfrom anyproposed major facility which PA DEP, on a case-by-case basis, taking into accountenergy, environmental andeconomic impacts and othercosts, determines is achievable for the facility through application of production processes ol' available methods, systems and techniques, including fuel cleaningor treatment or innovative fuel combustiontechniques for control ofthepollutant. Although PADEP notedthat "[t]he facility is proposingtwo different supply options and will pickone priorto construction," itnevertheless recommendedthat they be considered BACT. BACTis a "systemic analysis."Thus, itnaturally involves comparisons amongtechnologies. In 

### conducting a BACT analysis, "onecannot look atpatticularemissionsparameters in a vacuum." Nevertheless, the whole ofPADEPs BACTanalysis is done in avacuum. PADEP may notfind thePlanApproval to be completewithout a BACT determination, which it cannot complete when it lacks the make and model ofthe sources. Implicit in the requirement that an applicant demonstrate its source is BACTis thatPADEP mustmake a determinationthat the source is actually BACT. In

### this case, PA DEP determines that good combustionpractices, oxidation catalysts, dry low nitrogen oxides ("NOx'') burners and selective catalyticreduction are BACTdespite notknowingthemake ormodel ofthe sources. PA DEP goes so far as to provide

·separate emissions limitsfor each turbinethatBerks Hollowmay choose. A BACT determination is 

### an emissions limit, nota series ofoptions. Berks Hollow has failed to specifically identifythe turbinesthey intendto install and operate and PA DEP may not approvethose sources as BACTuntilthey are specifically identified andthat information is made available for public comment. EPA has made clearthat ifan owner/operator makes changes that "leadto changes inemissions, impacts on air quality, or control technologies

...such changes require[thepermitting agency] to conduct comprehensive analysis

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### ENCLOSURE RESPONSES TO COMMENT LEDER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 REGARDING BERKS HOLLOW ENERGYASSOCIATES, LLC {BHEA) PLAN APPROVAL NO. 06-0SlSOA



### ofthe changes, andthepublic 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 ofthe available control options in the required "top-down" methodology. The BACT analysis was notconducted "in a vacuum" as the comment alleges. The comment is incorrect in asserting that DEP lacks the make and model ofthe 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 opportunityto reviewand 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 {NewJersey) • CPV Warren {Virginia) • Patillo Branch Power Company {Texas) • King Power Station (Texas) • La Paloma Energy Center (Texas) • WolfHollow 

### 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 

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### ENCLOSURE RESPONSES TO COMMENT LEDER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 REGARDING BERKS HOLLOW ENERGYASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA



### • Tenaska Arkansas Partners, LP (Arkansas} • Union GeneratingStation (Arkansas} • South Eastern Energy Corp. (Alabama} • Tenaska Alabama II Generating Station (Alabama} • Granite Power Partners (Florida} • Haywood Energy Center (Tennessee} • PortWestward (Oregon} • Klamath Generation, LLC (Oregon} It should be noted that EPA has reviewed the Plan Approval for BHEA and expressed no concerns overthe multiple CTG equipmentoptionsthat 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 orother impacts. As such, BHEA selected the lowestemission limitation achieved in practice for the class ofequipment 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 pollutantswas provided in the Application thatincluded both CCU options.

3. PADEPmust perform a full and independentBACTanalysis for each source and each pollutant. ThisPlanApproval's main flaw is the cursory review and blind acceptance ofBerks Hollow's proposed BACT. 

### In a matteroffourpages PADEP accepts BACTlimits for six sourcetypes andtens ofpollutants. This is entirely insufficient and does not constitute a properBACT analysis. PADEP's reliance ontheHickoryRunreviewdoes notexcuse it from performinga sufficientBACTanalysis. BACTis a "case-by-case" analysis thattakes "into account energy, environmental and economic impacts and other costs." PADEP mustperfotmthis case-by-case analysis in the ReviewMemo andmaynot rely on HickoryRun 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 theTechnical Review Memo. 4. The Station shonld berequiredto use natural gas with a sulfurcontent of0.25 gr/100 scf.
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### ENCLOSURE RESPONSES TO COMMENT LEITER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 REGARDING BERKS HOLLOW ENERGYASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA

PADEP has determinedthatBACTfor sulfur oxide ("SOx") and ("H2S04") is use ofpipeline quality natural gas with an emissions limitation of0.75 gr/100 scf. However, in a recentPlan Approval application for a similar natural gas-fired powerplant (41- 00084A) MoxiePatriot, LLC indicatedthat the sulfur contentofthe gas they will use is 0.25

.gr/100 scfaccordingto the specificationsprovided bythe fuel supplier. 

### Itis unclear why this plant will have a sulfurcontent limitthree times theavailable fuel supply. The Council requests thatPA DEP lowerthe sulfur content orprovide an explanation. Further, itdoes not appear thattheproposed Plan Approval includes monitoringforthe sulfuric acidmist. The PlanApproval should include a methodofdemonstrating compliance with the fuel sulfur limit. Response 4: The Project is not a major source of502 emissions and thus does not require a BACT analysis for S02 emissions. The limit of0.68 gr/100 dscfwas 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 testinginitially and again everytwoyears. 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. TheProposed Permitmust berevised torequire thatPM2.5 is limited and monitored separatelyfromPMlO. ParticulateMatter ("PM") is treated as two separate pollutants underthe Clean Air Act: PMIO andPM2.5. EPAhas statedthatbecausePM2.5 now has a separate and distinctNAAQS, PMIO canno longerbetreated as a surrogate for PM2.5. 

### 72 Fed. Reg. at20,659. Therefore, consistent withthe EPA'streatment ofemissions information for thesepollutants, the final plan approval for the Station mustinclude separate and distinct limitations and standards for PM!0 and PM2.5 emissions. Response 

### s:·· Neitherthe 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

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### ENCLOSURE RESPONSES TO COMMENT LETTER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 REGARDING BERKS HOLLOW ENERGYASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06-0SlSOA



### combined cycle units are numerically equivalent, PM2.5 and PMlO were addressed separatelyas appropriate in theApplication and the Plan Approval. Note thatthe 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 combustionpractices" mustbe defined and enforceable. PA DEP selected "good combustionpractices" as BACTand lowest achievableemissions rate for various pollutants onvarious sources at the Station. "Good combustionpractices," however, are not defmed. PA DEP should include a description ofthevarious practices thatwill be required for eachpollutanton each source and must incorporate them into the Plan Approval. Response 6: Good combustion practices generally means operation ofthe 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 tothe Plan Approval are warranted. 7. The greenhouse gas limitmust include methane and nitrous oxide and be based on C02e. Underthe definition of"Subjectto regulation" in the greenhouse gas ("GHG") tailoringrule at 40 CFR52.21(b)( 49)(i), and under the definition of"RegulatedNSRpollutant" at40 CFR 52.21(b)(60)(iv), both ofwhich are incorporate byreference into Staterules, the pollutant that is subject to regulation, and therefore a regulatedNSRpollutant, is defmed as GHG, notcarbon · dioxide ("C02''). Therefore, the BACTemission limit should be expressed interms oftotal GHG emissions, as C02-equivalent ("C02e"), andthe Plan Approvalrecord should indicatehow compliancewill bedemonstrated for the two non-C02GHGs to be emitted. To accountfor themethane and nitrous oxide emissions in detetmining compliancewiththe emission limitsfortotal GHGs, EPArecommends use ofemission factors from Table C-2 of40

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### ENCLOSURE RESPONSES TO COMMENT LEITER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 REGARDING BERKS HOLLOW ENERGYASSOCIATES, LLC (BHEA) PLAN APPROVAL NO. 06·051SOA



### CFRpart 98 and global warmingpotentials from Table A-1 of40 CFRpart 98, along with the aetna! measuredheat inputto the combustion turbines. The PlanApproval should also statethat theresults offuture stacktests can beused 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 mannerthat 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 ofGHG 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. 

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### ENCLOSURE RESPONSES TO COMMENT LEITER FROM CLEAN AIR COUNCIL DATED AprillS, 2013 REGARDING BERKS HOLLOW ENERGY ASSOCIATES, LLC {BHEA) PLAN APPROVAL NO. 06-0SlSOA



### ambienttemperature, loading, and otherfactors. 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 methodologyin 40 

### CFR Part 98. 8. The PlanApproval must include a BACT limitfor GHGs and maynot rely solely on theNSPS. WhileNSPS TTTTis an applicable requirement, it is not a substitute for a GHG BACT analysis. Fmther, as discussed above, TTTTsets a standard of

## i000 lb C021MWh. A GHG BACT determination requires an enforceable limit on all GHGs. The largest source ofGHGs at the Station will be C02from the combinedcycleunits. Generally, · permit writers compare thermal efficiencies ofvarious units to determine whatBACT is and then regulate GHGs by setting a lbs C02eiMWh standard along with a netheatrate figure. The ReviewMemo should be ableto showthatthe mostefficient combined cycleunit is chosenfor the Station, or it shouldjustifywhy a unitwith a lower efficiency was selected. PADEP must then go on to ensurethatBACTis setfor each source andfor all GHGs includingmethane and nitrous oxide. The measures selected for BACThere are vague and unenforceable. PADEP indicates that: The remaining GHG control option is the efficientuse ofenergy. The turbines and duct burners will be designed for emissions ofgreenhouse gases that are less than 1000 pounds ofC02permegawatt-hour ofelectricityproduced, in conf01mance withEPA's proposedNSPS rule for Electric GeneratingUnits (proposed 3/27/12). This would constituteBACTand BATfor GHGs. To adequately support a BACTdetermination, PA DEP must, at minimum, clarify whether all available control options were considered, whetherthe option selected is the best-performing optionthat is knownto beavailable andtechnically feasible, whetherenergy, environmental and economic impacts affected the selection ofthe control option, and ifthe best-performing option was not selectedprovide an explanation and supportingbasis for that selection. PA DEP may not merely set a C02standard onthe combined cycle units and "good combustion practices" on other sources. Each source that emits GHGs must have an enforceable limit and the

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### 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 awhole musthave enforceable limits. A 1000 lbs C02/MWh onthe combined cycle units limit does notrepresentBACT. Response 8: The comment appears to misperceive the process which wasfollowed 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 ofthe 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 ofinformation 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 ofan NSPS for a particular source category."4


### Based on this guidance, consideration of NSPS limits and supporting rationale is properly partofDEP's consideration in settingGHG BACT limits.
In this case, the applicant conducted a GHG BACT analysis for the proposed combined cycle unit options which can befound in Section 5.3.5 

### oftheApplication. An emissions limit of 1,000 lb C02/MWh was selected as BACT, which Is consistent with EPA's determination as part ofthe 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 

### PSDand Title VPermitting Guidancefar Greenhouse Gases, EPA EPA-457/B-11-001, March 2011. Page 10

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### 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 ambienttemperatures), 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 baseload 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 ofcontrolled GHG emissions resulting from use ofsuch 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 plantconsisting ofa 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 ofthe turbines, theabsence ofductfiring, and the absence of SCR controls (which tend to place an additional efficiency constrainton such a facility). Since the submission of the Application, EPA has added to the RBLC database GHG BACT information for certain new projects. Ofthe 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 ofthe permit for this facility showed that the GHG emission limitwas actually in units oflb C02/MWh (not C02e).
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### 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 comparableto 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 efficientfossil fuel-based electric generatingtechnology 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 operatingconditions. 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 appropriatefor the Project's CCUs for thefollowing 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 burneroperation; 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 comparabletothe 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 higherlevel ofcompliance 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 thatthe Plan Approval contains enforceable GHG limits setfor each source andfor the facility as a whole. 9. Specific engineeringpractices should be incorporated into the final permit. Condition #004 in the proposedpermit indicates that "[t]hepermittee shall maintain and operate the sources associated in accordancewith good engineeringpractices as described intheplan approval application submittedto the Department." This condition is vague and unenforceable. PADEP references 25 Pa. Code§ 127.12(a)(l0) in the Condition, however this section merelyprovides that an applicationmust "[s]howthatthe source and the aircleaningdevices are capable ofbeingand will be operated and maintained in accordance with good airpollution control practices." Ifthere are engineeringpracticesnecessaryto keep the air cleaning devices properly operated and maintained those shoulcl be specifically included in the PlanApproval. 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

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### 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 ofthe control devices are included for each emissions source in the Plan Approval.


# =====================================================================================

Page 14 of 14Dynllgy Oenerallon,ADivision ofOynegy 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 forthe Berks Hollow Energyfacility (06·05150A) that was noticed for public comment In the March 16, 2013 edition ofthe Pennsylvania Bulletin. The proposed Berks Hollow facility Is located Immediately adjacent to ourfacility, In Ontelaunee Township, Berks County. We are concerned that the proposed Air Plan Approval Is not protective ofthe recently-promulgated 1-hr national Ambient AirQuality Standard for NO,. Please feel free to contact me at 610·916-6531, or Larry Waite ofDynegy's environmental compliance group at 618·206-5928. Sincerely,

# ~cu.~ D,\Q_.g

. .., Martin Daley ) Vice President, GasCo Dynegy, Inc.

### Comments ofOntelaunee Power Operating Company Regardln DraftAir 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 Immediatelyadjacent and to the south ofthe 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 Hollowfacility will not cause or contribute to exceedances ofapplicable ambient air qualitystandards at or nearour facility. Ontelaunee Energy Center Is concerned thatthe proposed short-term NOx emission limits for the Combined Cycle Units (CCUs) detailed in Section E, Source Group

# ccu, condition #001 ofthe draft Plan Approval are Insufficient to assure compliance with the 1-hr National Ambient Air QualityStandard (NAAQS) for NO,. We believe the draft Plan Approval contains two specific deficiencies In NOx emission limitsthat must be corrected.

• Percondition 11001{c) ofthe 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 NOxone hour, 69lb NOx the following hour, and 5 lb NOxthe following hour, and still satisfy the 26.511b NOx/hr emission limit when calculated on a3-hr rolling average. We believe this scenario could easily occur Ifthe facility's ammonia supply system experienced amalfunction 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 Energyfacility fencellne when the two CCUs are each emitting NOxat the rate of69 lb/hr, and otherfacility combustion sources (such as the fuel gas heaterand auxiliary boiler) are In operation. Ifdispersion modeling ofsuch ascenario does predict an exceedance, PADEP must Impose 1-hraverage 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 ofboth a 1-houraveraging 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 lowto 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 hourofacold startup, and still be in compliance with all NOX emission limitations In the draftAirPlan 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 of70 lb/hr, and otherfacility combustion sources (such

### as the fuel gas heater and auxiliary boiler) are in operation. Ifdispersion modeling ofsuch astartup scenario does predict an exceedance, PADEP must impose a 1-hraverage NDx mass emission limit applicable during CCU startups at levels that modeling demonstrates no exceedances will occur. In summary, in orderto 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-houraveraging time, and also include a1-houraverage mass emission rate limitfor NOx that applies during CCU startups. The specific NOx emission rates for these addltlonal1-hour average limits should be based on the results ofair dispersion modeling that includes operation ofotherfacility combustion sources as appropriate, and Is performed using representative background concentrations.JERRY KNOWLES • MEMBER 124TH U!GI$lATIV€DISTRICT HARRISBURG OFFICE: ROOM 155 8 EASTWING 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 ofPennsylvania Harrisburg

TomSantanna,Director Office ofLegislativeAffairs DepartmentofEnvironmentalProtection 400MarketSt,P 

### 0 Box2063 Harrisburg, PA 17105-2063 DearMr. Santanna: April16, 2013 

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## rCOMMITTEES: COMMERCE GAMING OVERSIGHT LOCALGOVERNMENT 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 naturalgaspowerplantinOntelauneeTownship. My constituents would like the Department to hold a public hearing on their application beforeanypermitsareissuedto discuss theplantfunction andvoicetheirconcerns onthisproject. Because ofthe serious nature oftheir 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 schedulea publichearing. As always, thankyoufor yourattentiontothismatter. 

### I lookforward toyourresponse.

JPK:Ir 

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## 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 aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 purpleabe@hotmail.com Tuesday, April16, 2013 12:01 AM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate 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

Iam extremelyworried that PA DEP is preparingto issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. Iask thatyou post-pone your approval ofthis 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 plantwill create significant public health and environmental impacts. Air pollutants from thisfacility are detrimental to the health ofresidents who Jive in this region and downwind. My main reason in writing to the Departmentis to request that PA DEP hold a public meeting and hearingfor the Berks Hollow Power Plant air permit. This would allow more local residentsto learn aboutthe project, askquestions, and directly communicatewith representatives from Berks Hollow Energy Associates and PA DEP staff.The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, Istrongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, Iam also concerned aboutthe life-cycle impacts ofnatural 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 overthe nexttwo mostcritical decades. Compared to coal, the climate change footprint ofshale gas Is at least 20% greaterand possibly more than twice as great in a twenty yeartimeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that a warmerclimatewill increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, Iam very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of this power plant. Irequestthat PA DEP provide a copyofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis basedon specific makes and models to ensure the besttechnology is required.
Ialso requestthat PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality andjeopardize compliance with the National AmbientAir Quality Standards (NAAQs). Thank you for takingthe time to read and consider my comment, and please respond back with anydecisions 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingtothe 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 ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale 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 awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 majorityofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide acopy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 norberry@fast.net Monday, April15, 2013 5:00 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

My reason in writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe public does not always knowwhen a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. I also request that PA DEP ensure thatthe 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 mycomment, 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to. ensure the best technology is required. I also request that PA DEP ensure thatthe 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 inkless800@aol.com Monday, Apri115, 2013 4:48PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to Issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 mycomment, 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 needsto "protect Pennsylvania's air, land and waterfrom pollution and to provide for the health and safety ofits citizens through a cleaner environment" as per its mission. Clearly, the DEP's actions pertainingto fracking ofshale formations and the processing and distribution ofthe resulting natural gas, have been anything but protective of PA's environment and citizens. The prospective issuance by the PA DEP ofa permitfor the Berks Hollow natural gas-fired power plant is another step in the wrong direction. Thatthe DEP would permitthe environmental and health impacts thatwill result from the proposed power plant in OntelauneeTownship, Berks County, is unconscionable, Further, natural gas, which is mostly methane, has a significant impact on climate change. Methane is 105 times more potenta greenhouse gas than carbon dioxide overthe nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly morethan twice as great in a twentyyeartimeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that a warmer climate will increase thefrequency ofdays with unhealthy levels ofground-level ozone. The PA DEP should be including greenhouse gas analyses in theirreview ofpower plants and be ensuringthat methane as well as carbon dioxide emissions are notpermitted but should be promoting use ofsolar, wind, geothermal, microhydro and other sustainable production facilities. On a purelytechnical point, PA DEP should not be issuing a permit until Berks Hollow Energy Associates provides a make and model for all ofthe equipment listed in the permit application and PADEP has performed theirtechnology analysis based on specific makes and modelsto ensure the besttechnology is required. Can the PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality andjeopardize compliancewith the National Ambient Air Quality Standards (NAAQs}?. This power plantwill create significant public health and environmental impacts. Air pollutantsfrom this facility are detrimental to the health ofresidentswho live in this region and downwind. Natural gas itselfas well as production pollutant add to the global climate crisis. Iaskthatyou deny approval ofthis 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 thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome ofthe following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power plantwill 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 writingtothe 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate 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

Iam extremelyworried that PA DEP is preparingto issue a permit for the Berks Hollow natural gas-fired power plant. I have majorconcerns aboutthe environmental and health impacts thatwill resultfrom the proposed power plant in OntelauneeTownship, Berks County, PA. Iask thatyou post-pone your approval ofthis 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 plantwill create significant public health and environmental impacts. Air pollutants from thisfacility are detrimental to the health ofresidentswho live in this region and downwind. My main reason in writing to the Departmentis to requestthat PA DEP hold a public meeting and hearing for the Berks Hollow Power Plant air permit.This would allow more local residentsto learn about the project, askquestions, and directly communicatewith representatives from Berks Hollow Energy Associates and PA DEP staff.The majorityofthe 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, Istrongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, Iam also concerned aboutthe life-cycle impacts ofnatural gas pollution on acceleratingclimate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane is 105times more potenta greenhouse gas than carbon dioxide overthe nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greaterand possibly more than twice as great in a twenty yeartimeframe.The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that a warmer climatewill increasethe frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, Iam very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of this power plant. Irequestthat PA DEP provide a copyofthis information and ensure thatthis 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 ofthe equipment listed in the permitapplication. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required.
Ialso requestthat PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality andjeopardize compliance with the National AmbientAir Quality Standards (NAAQs). Thankyou for taking the time to read and consider my comment, and please respond back with anydecisions 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

Iwrite to requestthatthe Pa DEP hold a public meeting and hearing for the Berks Hollow Power Plant air permit.This would allow more local residents to learn aboutthe project, ask questions, and directly communicatewith representatives from Berks Hollow EnergyAssociates and PA DEP staff.The majority ofthe public does not always know when a project like this power plant is proposed andwould 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 peoplewho are most directly affected adequate time to prepare and research the effects. Certainly, if Pa. government is to be as transparentas yourgovernor claims it is, then more opportunityto research and learmn can not be a bad thing. Again, Istrongly recommend thatyou 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 extremelyworried that PA DEP is preparing to issue a permit forthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 ofthe public does notalways know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 mycomment, 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in OntelauneeTownship, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 acopy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate 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 aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe.The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingtothe 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 ofthe public does notalways know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the nexttwo most critical decades. Compared to coal, the climate change footprint ofshale 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 awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also requestthat PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thankyou 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in OntelauneeTownship, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 plantwill 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 ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty 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 ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe 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 thatthe 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 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 pollutantsfrom this facility are detrimental to the health of residents who live in this region and downwind. My main reason in writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase thefrequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards {NAAQs). Thank you for taking thetime 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 forthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome ofthe following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power plantwill create significant public health and environmental impacts. Air pollutants from this facility are detrimentalto the health of residents who live in this region and downwind. My main reason in writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe.The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I request that PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs).
Thankyou for taking the timeto read and consider mycomment, 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you fortaking 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 mberman116@hotmail.com Monday, April 15, 2013 2:59 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permitfor 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 thatyou post-pone your approval ofthis permit until aftersome 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 majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 timeto 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe life-cycle impacts of natural gas pollution on accelerating climate change. Natural gas, which is mostly methane, has asignificant impact on climate change. Methane is 105 times more potent a greenhouse gas than carbon dioxide overthe nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly morethan twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards {NAAQs). Thank you for taking thetime 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I request that PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you for taking thetime to read and consider mycomment, 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directlycommunicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou 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 agreenhouse gas than carbon dioxide over the nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 ?- 

## 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 majorityofthe 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 thatyou 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not in.clude agreenhouse gas analysis in their review of this power plant. I request that PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I askthatyou post-pone your approval ofthis permit until aftersome 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 tothe 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the nexttwo most critical decades. Compared to coal, the climate change footprint ofshale 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 awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir Quality Standards {NAAQs). Thankyou for taking thetime 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 extremelyworried 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 thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe.The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 copyofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 kelly.finanOB@alumnLjuniata.edu Monday, April 15, 2013 1:43 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 plantwill 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 mycomment, 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 ofthe 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 thatyou 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate 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 anydecisions 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns about the environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 plantwill 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 writingto 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 ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thankyou 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 extremelyworried that PA DEP is preparing to issue a permit forthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou 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 overthe nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards {NAAQs). Thankyou 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome ofthe following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power plantwill 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe life-cycle impacts ofnatural 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required.
I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (NAAQs). Thank you for taking the time to read and consider mycomment, 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I askthatyou post-pone your approval ofthis permit until aftersome 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 Jive in this region and downwind. My main reason in writingto 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 majorityofthe 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 thatyou 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 agreenhouse gas than carbon dioxide over the nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly morethan twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase thefrequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 

## 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required. I also request that PA DEP ensure thatthe approval ofthis 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 extremelyworried that PA DEP is preparing to issue a permit forthe Berks Hollow natural gas-fired power plant. I have major concerns about the environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I askthatyou post-pone your approval ofthis 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 detrimentalto 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 ofthe 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 thatyou 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 overthe nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase thefrequency ofdays with unhealthy levels ofground-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 acopy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 debbiezlambert@gmail.com Monday, April15, 2013 12:34 PM Hanlon, Thomas Comment regarding Title 

### V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permitforthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in OntelauneeTownship, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 majorityofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you for taking the timeto read and consider mycomment, 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou 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 ofshale gas is at least 20% greater and possibly more than twice as great in a twenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize / compliance with the National Ambient Air QualityStandards {NAAQs). Thankyou for taking the time to read and consider mycomment, 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome ofthe following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power plantwill 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe.The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide acopy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 

### :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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 ofthe public does notalways know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in a twenty yeartimeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 timeto 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 11:28AM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (NAAQs). Thankyou for taking the time to read and consider mycomment, 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 ofthe public does notalways know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards {NAAQs). Thank you for taking thetime 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, Istrongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (NAAQs). Thank you fortaking the time to read and consider mycomment, 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 Countyfor the past 23 years. During thattime, 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 fewyears, 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 ofthe Lehigh Valley for any lenght oftime, they disappear, upon returning, I can feel my sinuses close up as soon as we enterthevalley. 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 ifthe proposed gas plant is built! I am extremely worried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns about the environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly morethan twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required.
I also request that PA DEP ensure thatthe approval ofthis 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 timeto 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 

## '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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe.The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (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 extremelyworried 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 thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 aboutthe project, ask questions, and directlycommunicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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, Istrongly recommend thatyou 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 antz1919@ptd.net Monday, April15, 2013 8:32AM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale 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 ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you for taking the timeto 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

Iam extremelyconcerned to hearthatthere is a new natural gas power plant slated for Berks County. As a resident of Kutztown, Ialreadyworry about the potential adverse health effects associated with East Penn Manufacturing'svarious lead and sulfur-emitting industrial operations, the pollution caused by the Atlas Chemicalfacility in Mertztown, all mannerofcarcinogens 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 ofthese major polluters, the people of Berks alreadycontend with the noxious particulate pollution generated atthe existing natural gas power plant near the intersection of222 and 183. The EPA has repeatedlywarned that Berks' air quality ranks amongthe worst in the Northeast. But that's.not all. Many ofus 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 ofacres ofagricultural fields. If all ofthis weren't enough, tales abound of hastily-dug, 1950s-era batterydisposal pits which pockmarkthe fields ofnorthern Berks and leach a witches' brew ofacids and oxides into the watertable. 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, Iam also concerned aboutthe life-cycle impactsofnatural gas pollution on acceleratingclimate change. Natural gas, which is mostly methane, has a significant impact on climate change. Methane is 105 times more potenta greenhousegas than carbon dioxide overthe next two most critical decades. Comparedto coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in a twenty yeartimeframe.Thegas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that a warmer climatewill increase thefrequency ofdays with unhealthy levels ofground-level ozone. For these reasons, Iam very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of this power plant. Irequestthat PA DEP provide a copyofthis information and ensure thatthis analysis includes methane in addition to carbon dioxide. Also, PA DEP cannot issue a permit until Berks Hollow EnergyAssociates provides a make and model for all ofthe equipment listed in the permitapplication. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required.
Ialso requestthat PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality andjeopardize compliance with the National AmbientAir 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I askthatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 majorityofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thankyou 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns about the environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe life-cycle impacts ofnatural 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly morethan twice as great in a twenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate 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 extremelyworried 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 thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 plantwill 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you for taking thetimeto 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does notalways know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly morethan twice as great in a twenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 mycomment, 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 plantwill 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required.
I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (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 aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwentyyear timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I requestthat PA DEP provide a copy ofthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required.
I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you for taking the timeto 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards {NAAQs). Thank you for taking the time to read and consider mycomment, 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 extremelyworried tliat PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome ofthe following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power plantwill 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 writingto 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 ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe.The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required. I also request that PA DEP ensure thatthe 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 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in OntelauneeTownship, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 detrimentalto the health of residents who live in this region and downwind. My main reason in writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe 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 thatyou 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 agreenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir QualityStandards (NAAQs). Thank you for taking the timeto 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does notalways know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am veryconcerned 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 acopy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir Quality Standards (NAAQs). Thank you for taking the timeto 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in OntelauneeTownship, Berks County, PA. I askthatyou post-pone your approval ofthis permit until aftersome 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 majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly morethan twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe 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 thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you for taking thetime 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 extremelyworried that PA DEP is preparing to issue a permit forthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 plantwill 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou hold a meeting and hearing on this power plant. 

### (,?

Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate.will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 MTRApple@aol.com Sunday, April14, 2013 5:51 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I askthatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe public does notalways know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in a twenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs).
Thankyou for taking the time to read and consider mycomment, 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 ofmeeting consumer demands is obvious: reduce demand by sensible conservation, and an educational system thatteaches 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 withI Thank you for taking the time to read and consider mycomment, 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir Quality Standards (NAAQs). Thank you for taking the timeto 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 thatyou post-pone your approval ofthis 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 plantwill 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 ofthe 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 aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 mycomment, and please respond back with any decisions on public hearings or updates on this permit. Sincerely,

1 ' I L) ,-,

### 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 sendingyou a form letter. Like a lot of people, I am very busy, but I am also very concerned aboutthis 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 aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I askthatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required.
I also request that PA DEP ensure thatthe 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 lindakenepaske@aol.com Sunday, April14, 20131:30 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A 

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I am extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required. I also requestthat PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (NAAQs). Thank you for taking the time to read and consider mycomment, 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingtothe 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 majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom 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 aboutthe 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 agreenhouse gas than carbon dioxide overthe nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase thefrequency ofdays with unhealthy levels ofground-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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thankyou 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe life-cycle impacts ofnatural 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 ofshale gas is at least 20% greater and possibly more than twice as great In atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thankyou for taking the time to read and consider my comment, and please respond back with anydecisions 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 aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you for taking thetime 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 extremelyworried that PA DEP is preparing to issue a permitfor 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 thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase thefrequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir Quality Standards (NAAQs). Thankyou for taking the time to read and consider mycomment, 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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. Mymain reason in writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, Istrongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you for taking thetime 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I askthatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, Istrongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year time frame. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. 

## 7 '(

For these reasons, I am very concerned to see that PA DEP did not include agreenhouse 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 ofthe equipment listed in the permit application. PA DEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 mycomment, 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 ofthe 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 thatyou 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (NAAQs). Thank you for taking the time to read and consider mycomment, 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 aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval of this permit until aftersome ofthe following questions are answered and until PA DEP has hosted a public hearing and meeting on this facility. This power plantwill 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 writingtothe 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 ehsilverman@yahoo.com Saturday, April 13, 2013 9:44 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I askthatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I request that PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 Positivelytowles@yahoo.com Saturday, April 13, 2013 6:12 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 Jive in this region and downwind. My main reason in writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (NAAQs). Thank you for taking the time to read and consider my comment, and please respond back withany 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 extremelyworried that PA DEP is preparing to issue a permit forthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 Jive in this region and downwind. My main reason in writingtothe 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 majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 mycomment, 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 aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 pollutantsfrom 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir QualityStandards (NAAQs). Thank you for taking thetime 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 thatthe 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 importantthatyou take into consideration the environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou postpone your approval ofthis permit until aftersome 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 ofresidents who live in this region and downwind. My main reason in writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 ercoli93@me.com Saturday, April 13, 2013 3:47 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permitfor 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 thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe.The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns about the environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I request that PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next'two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase thefrequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I askthatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale 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 awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (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 writingto 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 permitfor a project as large as this one? A hearing is necessary to allow more local residents to learn aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou 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 ofshale gas is at least 20% greater and possibly morethan twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology 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 oscodaartist2013@yahoo.com Saturday, Apri113, 2013 12:58 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am writing on behalfofthe 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 permitfor the Berks Hollow natural gas-fired power plant. Our concerns are specific to the environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. We request thatyou post-pone your approval ofthis permit until afterthere has been serious research and inquiry into the impacts on human and environmental health that this plantwill create. The PA DEP should also host a public hearing on this intended action, accepting comments and questions from the people ofthe area, regarding the opening ofthis facility. People living in this region have the right to be informed of significant public health and environmental impacts thatwill effectthem 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 ofshale gas on climate change is thoughtto be at least 20% to 50% over atwentyyear time period. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, our members are very concerned thatthe PA DEP did not include agreenhouse gas analysis in their review ofthis power plant. We are requesting thatthe 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 ofthe equipment listed in the permit application. The PA DEP must perform atechnology analysis based on specific makes and models to ensure the safety and feasibility ofthe technology to be employed in this facility. We request thatthe PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (NAAQs). While our concerns apply specifically tothis proposed site in Pennsylvania, we are acutely aware ofthe danger presented by the shale gas industry across the entire region that has been charged with the care and well being ofthe Great Lakes. We currently have over 700 active members from all ofthe Great Lakes states, as well as members from other areas ofthe U.S. and the International community. The Great Lakes make up 1/5ofthe world's supply offresh water, and therefore are considered an asset belonging to all citizens ofthe world. Water and air qualitystandards throughout the region should recognize this importanttruth, 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 thetime 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.
1Sincerely,

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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 majorityofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon.dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 audreyjsimpson@gmail.com Saturday, April13, 201312:17 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permitfor 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 thatyou post-pone your approval ofthis 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 writingtothe 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe.The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe 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 thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you for taking the time to read and consider mycomment, 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 11:40AM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does notalways know when a project like this power plant is proposed and would greatly benefit from a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe.The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir 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 11:19AM 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 aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 kellamo@verizon.net Saturday, April13, 2013 11:09AM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremely worried that PA DEP is preparing to issue a permit forthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis Information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required.
I also request that PA DEP ensure thatthe 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 hpmt3@aol.com Saturday, April 13, 2013 10:45 AM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permitforthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe life-cycle impacts of natural gas pollution on accelerating climate change. Natural gas, which is mostly methane, has asignificant impact on climate change. Methane is 105 times more potent a greenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir QualityStandards (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 manytragedies will it take before we ban fracking? Right now money is calling the shots. Let democracytake its originally-intended course, allow the peopleto decide.
I am extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. Ihave major concerns aboutthe environmental and health impactsthatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. Iaskthatyou post-poneyour approval ofthis permit until after some ofthe following questions are answered and untilPA DEP has hosted a public hearing and meeting on this facility. This power plantwill create significant public health and environmental impacts. Air pollutantsfrom this facility are detrimental to the health of residentswho live in this region and downwind. My main reason in writing tothe Department is to requestthat PA DEP hold a public meeting and hearingforthe Berks Hollow Power Plant air permit.This would allow m'?re local residentsto learn aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff.The majority ofthe public does not always knowwhen a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, Istrongly recommend thatyou hold a meeting and hearing on this powerplant. Beyond the potential health impacts, Iam also concerned aboutthe life-cycle impacts ofnatural gas pollution on accelerating climate change. Natural gas, which is mostly methane, has a significant impacton climate change. Methane is 105 times more potenta greenhouse gas than carbon dioxide overthe nexttwo mostcritical decades. Compared to coal, the climate change footprint ofshale gas is at least20% greater and possibly morethan twice asgreat in a twentyyeartimeframe. The gas industryis the largest human-made source ofmethane emissions globally. Scientists estimatethata warmer climate will increase thefrequency ofdays with unhealthylevels ofground-level ozone. Forthese reasons, Iam very concerned to see that PA DEP did not include a greenhouse gas analysis in their review ofthis powerplant. Irequestthat PA DEP provide a copy ofthis information and ensure thatthis analysis includes methane in addition to carbon dioxide. Also, PA DEP cannot issue a permit until Berks Hollow EnergyAssociates provides a make and model for all ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and modelsto ensure the besttechnology is required.
I also requestthat PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality andjeopardize compliance with the National AmbientAir Quality Standards (NAAQs). Thankyou for taking thetime to read and consider my comment, and please respond backwith anydecisions 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 extremelyworried that PA DEP is preparingto issue a permitfor the Berks Hollow natural gas-fired power plant. Ihave major concerns aboutthe environmental and health impactsthatwill resultfrom the proposed power plant in Ontelaunee Township, Berks County, PA. Iaskthatyou post-poneyour approval ofthis 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 plantwill create significant public health and environmental impacts. Air pollutantsfrom thisfacility are detrimental to the health ofresidentswho live in this region and downwind. My main reason in writing tothe Department is to request thatPA DEP hold a public meeting and hearing for the Berks Hollow Power Plant air permit.This would allow more local residents to learn aboutthe project, ask questions, and directly communicatewith representativesfrom Berks Hollow EnergyAssociates and PA DEP staff.The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, Istrongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, Iam also concerned aboutthe life-cycle impacts ofnaturalgas pollution on accelerating climate change. Natural gas, which is mostly methane, has a significant impacton climate change. Methane is 

### 105 times more potenta greenhouse gas than carbon dioxide overthe next two mostcritical decades. Compared to coal, the climate change footprint ofshalegas is at least20% greaterand possibly morethan twice asgreat in a twentyyeartimeframe.The gas industry is the largesthuman-made source ofmethane emissions globally. Scientists estimate that a warmer climatewill increasethe frequency ofdays with unhealthylevels ofground-level ozone. For these reasons, Iam very concerned to see that PA DEP did not include a greenhouse gas analysis in their review ofthis power plant. Irequestthat PA DEP provide a copy ofthis information and ensurethatthis 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 ofthe equipment listed in the permitapplication. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required.
I also requestthat PA DEP ensure thattheapproval ofthis station will not deteriorate regional air quality andjeopardize compliancewith the National AmbientAir Quality Standards (NAAQs). Thankyou for taking the timeto read and consider my comment, and please respond backwith anydecisions 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 extremelyworried 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 thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou hold a meeting and hearing on this power plant. 

## 'I;

Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly morethan twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase thefrequency ofdays with unhealthy levels ofground-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 requestthat 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thankyou 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 extremelyworried that PA DEP is preparing to issue a permit forthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly morethan twice as great in a twenty yeartimeframe.The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I request that PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 mycomment, 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 widrose71 @yahoo.com Saturday, April 13, 2013 9:33AM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe.The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (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 forthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air QualityStandards (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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you for taking the time to read and consider mycomment, 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 extremelyworried that PA DEP is preparing to issue a permit forthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly morethan twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir Quality Standards (NAAQs). Thankyou 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 tothe health of residents who live in this region and downwind. My main reason in writingtothe 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 majorityofthe public does notalways know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, Istrongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology 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 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 aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis 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 majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe.The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 Scott@WeldonPiace.com Friday, April12, 2013 10:03 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A 

# r0**.~**

I am extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis 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 tothe health of residents who live in this region and downwind. My main reason in writingto 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 ofthe 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, Istrongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe.The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I request that PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thankyou fortaking 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 

### 1o 

### b

Natural gas is afossil fuel that is toxic to drill, frack and transfer. Methane migration and leakage is a primary greenhouse gas and cause ofglobal warming. I am extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you for taking thetime 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 aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis 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 Jive in this region and downwind. My main reason in writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does notalways know when a project like this power plant is proposed and would greatly benefit from a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly morethan twice as great in atwenty year timeframe.The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe 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 thatthe 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 katstoica@yahoo.com Friday, April12, 2013 9:14PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I askthatyou post-pone your approval ofthis 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe nexttwo most critical decades. Compared to coal, the climate change footprint ofshale 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 awarmer climate will increase thefrequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs}. Thankyou 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly morethan twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thankyou for taking the time to read and consider my comment, and please respond back with anydecisions 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 directlycommunicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe nexttwo most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe.The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe 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 requestthat PA DEP ensure thatthe approval ofthis station will notdeteriorate 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 extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 emilywurth@hotmail.com Friday, April12, 2013 8:46PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A 

## II;

I am extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis 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 ofresidents 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in a twenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. Forthese 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 keller.james.m@gmail.com Friday, April12, 2013 8:31 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

Iam extremelyworried that PA DEP is preparingto issue a permitfor the Berks Hollow natural gas-fired power plant. I have majorconcerns aboutthe environmental and health impacts thatwill resultfrom the proposed power plant in OntelauneeTownship, Berks County, PA. Iask thatyou post-poneyour approval ofthis 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 plantwill create significant public health and environmental impacts. Air pollutants from thisfacility are detrimentalto the health ofresidents who live in this region and downwind. My main reason in writing to the Department is to requestthat 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 communicatewith representatives from Berks Hollow Energy Associates and PA DEP staff.The majority ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, Istrongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, Iam also concerned aboutthe life-cycle impacts ofnatural 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 greenhousegas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in a twenty yeartimeframe.Thegas industry is the largest human-made source ofmethane emissions globally. Scientists estimate thata warmerclimatewill increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, Iam very concerned to see that PA DEP did not include a greenhouse gas analysis in their review of this power plant. Irequestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permitapplication. PADEP must perform theirtechnology analysis based on specific makes and modelsto ensure the besttechnology is required.
Ialso requestthat PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality andjeopardize compliancewith the National AmbientAir Quality Standards (NAAQs). Thankyou for taking the time to read and consider my comment, and please respond back with anydecisions 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 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 aboutthe environmental and health impacts thatwill result from the proposed power plantin Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis 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 majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe life-cycle impacts of natural gas pollution on accelerating climate change. Natural gas, which is mostly methane, has asignificant impact on climate change. Methane is 105 times more potent agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir 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 extremelyworried that PA DEP is preparing to issue a permit for the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis 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 writingtothe 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 ofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou 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 ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 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 itworse. 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 permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide over the next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty year timeframe.The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe 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 karen.feridun@gastruth.org Friday, April12, 2013 4:01 PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A 

## /17

Iam extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow naturalgas-fired powerplant. I have major concernsaboutthe environmental and health impacts thatwill resultfrom the proposed power plant in OntelauneeTownship, Westmoreland County, PA. Iask thatyou post-poneyour approval ofthis permit until after some ofthe following questions are answered and until PA DEP has hosted a public hearing and meetingon this facility. This power plantwill create significant public health and environmental impacts. Air pollutants from this facility are detrimental to the health ofresidentswho live in this region and downwind. My main reason in writing to the Departmentis to requestthat PA DEP hold a public meeting and hearingfor the Berks Hollow Power Plant air permit.This would allow more local residents to learn aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff.The majority ofthe 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, Istrongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, Iam also concerned aboutthe life-cycle impacts of natural gas pollution on acceleratingclimate change. Natural gas, which is mostly methane, has a significant impacton climate change. Methane is 105 times more potent a greenhousegas than carbon dioxide overthe nexttwo mostcritical decades. Compared to coal, the climate changefootprint ofshale gas is at least 20% greaterand possibly more than twice asgreat in a twenty yeartimeframe. The gas industry is the largest human-made source ofmethane emissionsglobally. Scientists estimate that a warmer climate will increasethe frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, Iam very concernedto see that PA DEP did not include a greenhouse gas analysis in their review of this power plant. Irequestthat 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the besttechnology is required.
Ialso request that PA DEP ensure thatthe approval ofthis stationwill not deteriorate regional airquality andjeopardize compliance with the National AmbientAir Quality Standards (NAAQs). Thankyou for taking the time to read and consider my comment, and please respond back with anydecisions on public hearings or updates on this permit. Sincerely,

1

### Wilkes, Dawne From: Sent: To: Subject:

Permitting ChiefThomas matthewblkwalker@gmail.com Friday, April12, 2013 3:39PM Hanlon, Thomas Comment regarding Title V Plan Approval No. 06-05150A

I am extremelyworried that PA DEP is preparing to issue a permitfor the Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Westmoreland County, PA. I ask thatyou post-pone your approval ofthis 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 tothe health of residents who live in this region and downwind. My main reason in writingto 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 ofthe 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 thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 overthe next two most critical decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source of methane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality and jeopardize compliance with the National AmbientAir 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 ofair inversion where moisture and air pollutants become trapped below a layer of cold air as the weather changes throughoutthe day and seasons. This air inversion puts southwest Pennsylvanians at risk ofground level ozone exposure in addition to the many toxins emitted by the plant. 

# rz 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 allowthis type offacilityto 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 ofthe required gas infrastructure and cumulative air quality impacts should be considered part ofthe permit application and review process. I also request that PA DEP ensure thatthe 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 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 permitforthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingto 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 aboutthe project, ask questions, and directly communicate with representatives from Berks Hollow Energy Associates and PA DEP staff. The majority ofthe public does not always know when a project like this power plant-is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe nexttwo most critiGal decades. Compared to coal, the climate change footprint ofshale gas is at least 20% greater and possibly more than twice as great in atwenty yeartimeframe. The gas industry is the largest human-made source ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 requestthat PA DEP provide a copy ofthis information and ensure thatthis 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 forall ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will not deteriorate regional air quality andjeopardize 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 extremelyworried that PA DEP is preparing to issue a permitforthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts thatwill result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis 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 writingtothe 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 majorityofthe public does not always know when a project like this power plant is proposed and would greatly benefitfrom a public hearing and meeting. Again, I strongly recommend thatyou hold a meeting and hearing on this power plant. Beyond the potential health impacts, I am also concerned aboutthe 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 agreenhouse gas than carbon dioxide overthe next two most critical decades. Compared to coal, the climate change footprint ofshale 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 awarmer climate will increase the frequency ofdays with unhealthy levels ofground-level ozone. For these reasons, I am very concerned to see that PA DEP did not include agreenhouse gas analysis in their review of this power plant. I request that PA DEP provide a copy ofthis information and ensure thatthis 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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required. I also request that PA DEP ensure thatthe approval ofthis station will notdeteriorate regional air quality and jeopardize compliance with the National Ambient Air Quality Standards (NAAQs). Thank you for taking thetime 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 10:29AM 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 ofour lands by international corporations who have no concern for the quality ofour lives. I am extremelyworried that PA DEP is preparing to issue a permit forthe Berks Hollow natural gas-fired power plant. I have major concerns aboutthe environmental and health impacts that will result from the proposed power plant in Ontelaunee Township, Berks County, PA. I ask thatyou post-pone your approval ofthis permit until aftersome 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. 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 ofthe 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 ofshale 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 ofmethane emissions globally. Scientists estimate that awarmer climate will increase the frequency ofdays with unhealthy levels ofground-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 ofthe equipment listed in the permit application. PADEP must perform theirtechnology analysis based on specific makes and models to ensure the best technology is required.
I also request that PA DEP ensure thatthe 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,
1Attachment H- Commentand 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 rocolvodfrom Berks Hollowvia Iotterdated415/13

1 C 006: The condition limits emissions of HAPs to less than 4.8 tpyfora single HAP (formaldehyde) and 11.3tpyof 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 HAPswhich can be emited from the fac!JJty. than 10tpy ofa single HAP and 25 tpy oftotal 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. thattho limits be changed to 10 tpy ofa single HAP and 25 tpy oftotal HAP to be consistentwith the definition ofan**aro:<:~** source. 2 ESG CCU 001: The condition, In part, limits emissions ofammonia (NH3) to 5 ppmvd@ 15% 02, and less than The condition has been changed. The NH31imits are 104.46 tpy forthe 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 forthe fired (ie, duct burners on) and unfired (ie, duct burners off) cases, which are presented in TableA-13 and A-14 ofAppendixA ofthe Application, and the hours ofoperation for each case presented in Table A-2, The hours ofoperation in TableA-2 were used specificallyfor 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 differentthan that presented in Table A-2. Specifically, since tho hours for startup (maximum of500 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 hourswith 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 limitfor NH3 should be calculated as follows:.[see comment letterfor 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 ESG PM2.5 001: The condition requires annual stacktesting 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 offand on. Duct burners will be operated typically during periods of peak powerdemand only, making it testing once everyfive years while the duct burners are operational. difficult to predictwhen duct burners will be operated. Operating duct burners expresslyforthe purpose ofstack testing may result in significant costs to BHEA, particularly during periods of low power prices. Because ofthis uncertainty, BHEA requests that the condition be changed to require stacktesting no more than once perfive (5) oar PEtriod 4 ESCSTARTUP & SHUTDOWN 002: The condition defines shutdown as 'the period beginning with lowering ofunit The condition has been changed to read: (c) Forthe GE 7F5A combustion turbin& shutdown is defin&das.

load below 60% with the Intent ofceasing operation

...' Tho GE ?FA combustion turbines are capable ofturning down thepl!ln'odbeginning with the lowering ofunitlosdbelow50"A with the Intentofceasing**o~ratlon** ofthe unit to 50% toad during normal operation. As such, BHEA requests the condition be changed to read 'the period andconcluding with the:tcessation ofcombustion in the turbine, limitedto a maximum ofone hourin beginning with lowering of unit load below 50% with the intent of ceasing operation duration. (d) Forthe Siemens Fcombustion turbinfl shutdownis definedas theperiodbeginning with the lowering ofunitloadbelow60% with the Intentofcessing**o~ratlon** ofth& unitendconcluding with the cessation ofcombustion in the turbin&, limitedto a maximum ofone hourIn duration. Comments rocoivod from EPA Ro lon Ill**vi~** lottcrdl!tod4/9113

5 1. Emission Offsets: Tho proposed facJIIty is subjectto 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 greaterthan comment. 100 tons of NO xand 50 tons ofVOCs in any consecutive 12 month period. Therefore, a purchase of Emission Reduction Credits (ERCs) to offsettho NOxand VOC emissions Increases is required. According to Pa. Code 127.208, an owner or operator of afacility shall acquire ERCs for use as offsetsfrom an ERC generating facJllty located within the same nonatt8inment areaAs NOx is considered a precursorto 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: EPAdoes not believethatthe Technical Reviaw Memo (TRM) and proposed plan The addendum memo (attached to this C&R document) Includes an expanded discussion ofthe

approvol sufficiently describe the BestAvailable 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, economicand othercosts associatad with each alternative technology, and the benefit ofraduced emissions thatthe technologywould bring, The revlawlng authority then specifies emissions limitations forthe source that reflects the maximum degree of reduction achievablefor each pollutant regulated underthe Clean AirAct. The plan approvol conditions must reflect all operatlonollimitations in orderto showcompliance with these emissions limitations.**The~~~~~~~~~~~~~!~~.**top..down BACTILAER options and an analysis forwhy the chosen emission controlo:: meet the A Tl an r . 7 3_ NOx controls: The record Indicates that the use ofdry 10w-NOx (OLN) combustors and Selective Catalytic The plan approval requires the use of control equipment during periods ofstartup, shutdown, and

Reduction (SCR) would fulfill LAER for NOxand BACTfor N02. Tho analysis also Indicatesthatthe use ofoxidation malfunctions as part of40 CFR 60.4333 (Subpart KKKK). Additionally, The Plan Approval includes catolysts would constitute LAER forVOC emissions and BACTfor CO emissions. However, the plan approval does Condition #OOS(c) underSection E, Group Name CCU, whiCh requires operation ofthe air pollution control not appearto require the operation ofthese controls at all times when the combustion turbines and duct burners are devices at all times during normal operotlon and reads asfollows: "Thepermittee shalloperate the control operating. Since these control devices are necessaryto meetthe required emission limits, the plan approval should devlce(s) atalltimes this source is in operation once operatingparameters (temperature, now, etc.) ara req1,1ire tho Qwration ofthe controls at all times sufficientforpropercontroldevice operation." 8 4, Greenhouse Gas {GHG) pollutants: EPA hasthefollowing concerns: a, The TRM and proposed plan approval The plan approval will be revised to include afacility wide GHG (C02e) limit. Compliance with thefacility

do not sufficiently address all GHG pollutants. GHG emission limits should accountfor not only C02, butfor all ofthe wide limit will be shown by using emissionfactors 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 howcompliance will be demonstrated for potentials In Table A·1 of part 98 along with the heat Inputforthe sources. SF6 emissions will be eaCh ofthe GHGs. The plan approval, as currentlywritten, does not include sufficient requirements or means of accounted forwheneverthe facility has to add SF6 dielectricfluid to each circuit breaker unit colculation to ensure com liancewith 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 EnergyAssociates, LLC Facility Proposed for Ontelaunee Township, Berks County

gas as afuel. 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 ofthe expected Auxiliary Boiler in theTRM. 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 peryear each, it would make sense thatthe only operate for 560 hours peryear. Please explain the additional expecte? hours ofoperation

operations and startup and shutdown times, add up to more than 

# l tpy. This limit isjust belowthe 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 startupfollowing extended shutdowns. Since 12-month rolling establishedfor each pollutant, we do not believe a condition limiting the hours of

the Plen Approve/will be offuelburned. The emission limits are basedon e fuelsulfurcontentof0.68gr/100 15ppm forfueloil, ThE! fuEl!sulfurcontentofthe naturalges willbe determ/nOO fuelmonitoringplan as describedIn Section E, Group Name KKKK, Condition# 015of

. . Fuelsulfurcontentdata fornaturalgas andfueloil willbeprovidedbyellfuftlsuppliers 

## I periodically. As re;quiredbythe Plem Approval, dailyrecords offuelconsumption willbe meintelnOO to ensure that 12-month rolling tote!emission limits forS021SOx ere notexceeded. In fact, fuelconsumption the CCUs, fuel heater, Mdauxiliarybolterwillbe recordedon a nearlycontinuousbesis using B enddate Bcquisition system. Basedon this approach, BHEA does notbelieveany ing re;quirements ere**n~SS8ry**to ensure compliance with the S02/SOxemission Jepartment concurs with this responsa.

during normBIoperations end on OEMdato forstBrtup Bndshutdown periods, which Is also the basis ldIn TobieA-2 of AppendixA oftheAppi!CEJtion. MBximumpotentiBI ofPM2.S from startupandshutdown opl!lrtltionsis approximBtely2% ofthe facility-wide PM2.Semissions, BndectuB/Bnnualemissions willtypiC811y be much !ftss thBn permittedsincestartup and shutdown opemtlons willtyp/ClJIIyoccurless than the limitof500 ennuB/hours. Since PM2,5 emissionsare a resultoffuelcombustion andnopost-combustion controls Bra necessery, PM2.Semissions ere expected to be consistentBndproportionBIto the amountoffualburned. Forthis reBson Bndthe fact thatfuelflow to the turbines willbe monitoredcontinuously, directcontinuous monitoring ofPM2.5is notnecesSf.lryor

- -··-- L •- &Jceusa tha PM2Slimitforeachemissions source represents the worstC8Sa amiss/on rate, with the PM2.5Jimits foreachemissions souf'C(J willensure thatfecJI/ty-wide emissions willbe threshold forPM2.5of 100 tpy. Asa result, BHEA does notbelieve BnyBddltlonBI yto ensure thBtfBc/1/ty-wide PM2.5emissionsBre belowthe majorSOUI'C(J The Department concurs with this response.

Page 2 of 11Attachment H**~Comment** and Response Document Regarding Draft Plan Approval No. 06-05150A

for Berks Hollow EnergyAssociates, LLC Facility Proposed for Ontelaunee Township, Berks County
#: : Comment· R&s onse •;;;

18 9. Missing Soctlonfromtho proposod plan approv.ml: Tho propoood pion approval Is missing Section Gfor listing Tho roquostod soction hos boen o.dded to the plan approval.

"Emission Restriction Summary"for all pollutantsfrom all emission units. Please providethis section in the plan approval for ease ofcompliance assurance. A similarfacility 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 Includesthe The requested requirement has boon added to the plan approval.

general standard against oir pollution**cod~ed** at25 Pa, Code § 121.7. This general standard states that ''No person may permit air pollution as thstterm 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 ofa plan approval are administratively brought into the title V permit; however, since this is a newfacility, it has no currenttitleV permit. We note that the plan approval should I**~~~~:a** the general**~~:nt~ard** In**ord e;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 ortfrom 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 CetalyticReduction) willbel operstedyesrroundandduring allperiods ofnormaloperations, but will notbe operstedduring periods ofstertup endshutdown as the temperature of the exhaustgss willbebelowthstrequlrodforopemtlon ofthe SCR system." Furthermore, Condition 005(c) in the CCU group ofthe plan npproval states "Thepermitteeshs/1 operste the cantroldevice(s) Btall times this source is In operotion once oporotJngparameters**(t~mpersture,** flow, etc.) are suffidentforproper controldevfce opemflbn. " 21 Soctlon 2.3 Appllcablo Pollutants: PADEP should consider Berks Hollow's potential impacton curront P¥-2.5 From a permitting perspective, the proposed Berks Hollowfacility 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 subjectto the Nonattainment New Source RoviGW requirements for PMcounty's mtainmont status underthe 1997 NAAQS and EPA's revised PM-2.5 NAAQS. 2.5. The projected PM-2.5 omissions from tho proposed Berks Hollowfacility are less than the major source threshold of 100 tons peryear (tpy). According to planning staff In the Division ofAlr Resource**Manag<:~ment,** the DEP can considerthe potential impact ofthe proposed Berks Hollowfacility on continued attainmentwith tho 1997 PM-2.5 NAAQS In tho process offinalizing tho mninton<mce plan fortho RMding, PA PM-2.5 area. The EPA allows states to use an emissions testfor maintenance. Maintenance is demonstrated when the total actual projected emissions ofthe area in the maintenance year (2025) and interim year (2017) do not exceed tho lovellp..tho attainmentyear (2007), In regard to the revised PM-2.5 NAAQS, the DEP is in tho process ofpreparing recommendations to the EPAfor area designations and can considertho proposed Berks Hollowfacility in making those recommendations, 22 Section 3.6 Receptor Data Description: Model peaks in the base load runs forthe GE ond Siemens combustion Initially, the Berks Hollow 1-hour N02 NAAQS analysis considered all receptors atwhich Berks Hollowwas

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 N02significance analysis), along with Hollowfacility. It appears that the modo! receptor grid was revised in tho N02 NAAQS and Increment Runs to additional receptors placed 100 meters apartaround distant Isolated significant receptors. The Berks oxamino tho area nearthe highest modeled concentration. Itwould be helpful if PADEP could address how the model Hollow 1-hour N02 NAAQS analysiswas 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) ofAppendixW. receptors placed 100 meters aport around the location ofthe controiilng 1-hour N02 NAAQS concentration, Section 4.1. The location ofthe controlling 1-hour N02 NAAQS concentration is approximately 8 kilometers (km) from the proposed Berks Hollowfacility. The DEP believes that a receptor spacing of 100 meters is sufficient to capture tho maximum 1-hour N02 modeled concentration atthis distance from the proposed facility

The Berks Hollow annual N02 NAAQS and increment analyses also considered all receptors atwhich Berks Hollowwa.s predicted to have a significant concentration (based on the annual N02 significance analysis). These significant receptors are located within afew hundred meters ofthe proposed Berks Hollowfacility, In an area where the receptorspacing In the significance analysiswa.s 50 meters. The DEP believes that a receptor spacing of50 meters is sufficientto capture the maximum annual N02 modeled concentration atthis distancefrom the proposed facility. 23 Significant Impact Analysis: Do the load scenarios described in this section include ductfiring {described In The lo.:Jd scenarios described in section 4.1 oftho Berks Hollow Modeling Report (January 30, 2013)

Section 3.5)? For example, can the combustion turbines bo fired at 100% with orwithout ductfiring and would the account forfiring ofthe duct burners. TobieA-2, Table A-14, and TableA-15 in Appendix Bofthe 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 forvarious opernting loads, with and withoutfiring ofthe duct burners, for both the GE and Siemens combustion turbines. As indicated bythese tables, the emission rates and associated stack parameters differ, forexample, when comparing tho combustion turbines at 100 percent load with and wlthoutfiring ofthe duct bumers. 24 Stack parameters forthe GE and Siemens combustion turbines are quite similar. Old PADEP confirm the similarity In DEP did confirm the similarity in emissions profilesfor Berks Hollow's GE and Siemens combustion

emissions profiles for Berks Hollow's GE and Siemens combustion turbines for all pollutants? turbines. Because ofthe similarsize and heat inputofthe two types ofturbines, the stack parameters aro similar. Tables A-14 and S-15 ofthe application present the emissions for each ooeratina scenario.

Page3of11 Chan eto·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 lastand how long does it takefor 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 fullyfunctional? conditions, temperoture ofthe equipmentendotherrectors. Itis anticipatedthattypicalstertups will/estless than 2hours, butstartup durotions meybe longerforcoldstarts end**short~rfor**hoVwsrm starts. Forthis reason, en ennuellimltof500 hours Isappropriate to accountforvarietions in startup frequencyend duretion. Shutdowns w/llusuDIIy/sstless than 30minutes, butmsybe shorterattimes. H The DEP accepts this response. According to a 9/13/13 email from SHEA "The NOx controlequipment (SCR) depends on twoperemrJf(Jrs to be fullyfunctional: 1) exhaustges temperature end2) ammonia injection. Ammonie Injection willbe initiatedby**th~** distributedcontrolsystem (DCS) when the exhausttempereturo roeches the minimum requiredoperating tempereture forthe SCR, etwhich po/ntNOx will**b~** convertedto nitrogen end wsterbythe action ofthe emmonia andcatalyst. Since the SCR is a staticcomponentofthe HRSG, there is no "startup"procedure forit. As apracticalmetteremmonis injection willcommence afterthe sterlupperiod at50% /oed forthe GE 7FA endat60% forthe Siemens F." The DEP acceptsthis response. 26 Berks Hollow could have used PVMRM ora Tier2 ambient ratio in its significance analysisto reduce the radius of In regard to the use ofthe Tier 3 Plume Volume Molar Ratio Method (PVMRM) ora Tier2 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 ofsignificant reduood (in number) considering the closeness ofthe background monitoring site to Berks Hollow. Many ofthe impact by using the Tier 1approach described in subsection 5.2.4 ofthe 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, AppendixW. This decision and the decision to include AppendixW foradditional guidance on this topic. many ofthe smaller NOX emission sources in the model likely yielded a more conservative estimate ofthe 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 ofthe 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 thatthe Berks Hollowair 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 3conducted some additional analysis using Berks Hollow's NAAQS and Increment N02 runs. significantly contribute to air pollution In violation ofthe 1-hour N02 NAAQS. That said, the DEP intends to It appears thattwo sources are contributing to the modeled N02violations. 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 ofSignificant Deterioration (PSD)." 28 Titus Station: Thisfacility 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 Hollowwas roughly 2,622.85tpy (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. NOxemissions priorto 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 overthe 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 ofthe Class According to section 3.2 (Initial Screening Criteria) ofthe 'Federal Land Managers' Air Quality Related

! areas in a table orappendix. 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 Iarea 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 bythe 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 Iarea is provided in the following table: Class IArea Barks Hollow Distance Q/D to Class IArea (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 Hollowwas exempted from the The DEP determined that Itwas not necessaryfor Berks Hollowto perform a Class I increment analysis for

Closs I increment analysis. N02and**PM~10** by executing AERMOD with Barks Hollow's proposed emissions of NOX and PM-10 (GE and Siemens combustion turbines), Class Iarea receptors provided by the FLMs, and 2006-2010 meteorological datafrom Reading Regional Airport (KRDG). Due to its steady-state assumptions, AERMOD should provide overly conservative estimates of Berks Hollow's N02and PM-1 0 Impact In Class I areas, all ofwhich are located well beyond AERMOD's ovaluated near-field range of50 km. The DEP compared Berks Hollow's estimated N02and PM-1 0 Impactsto 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 belowthe EPA's ro osed Class! area SILs. Comments rocolvodfrom tho Cfoan AirCouncil v/o fottordotod411.5113

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 thattho sources complywith applicable SHEA's Plan Approval Application contained all thatwas necessary to perform athorough technical

regulations, which it cannot do without knowing the make and model oftho sources
... Berks Hollow has not provided evaluation oftho aircontaminant aspects ofthe sources associated with the project as speclfled in the a make or model to PA DEP forthe combustion turbines, atthe very least. Without accessto the application It Is Department's draftTechnical Review Memo. Information regarding make and model ofthe air contaminant unclearwhetherthoro are other sources whore the make and model have also not boon provided. Theturbines, at souroos as woll as manufacturer con bo provided, but Is not nt'lcessarlly nooded bytht'l Departmt'lntto the very least, meetthe definition of a 'source' and must complywith the 'appllcable requirements." Although Berks perform athrough technical evaluation ofthe air contaminant aspects ofthe sources associated with the Hollow has Indicated thatthe Station will contain those sources, the precise pieces ofoqulpmont have yetto 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 ofthe 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 specificoperating performance criteria of such units. This infoi"IT\l'ltion is sufflciantto from acting on it until Berks Hollowsubmits the make and model ofpollution sources to be Installed. datermine tho operating characteristics, emission characteristics, and expected control performance of each ofthe emission units proposed forthe Facility. The Department requires BHEAto incorporate the engineering designsfortha aircontaminant aspects ofa source that are specified in the Plan Approval. BHEA has proposed two combustion turbine generator ('CTG') optionsforthis 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 manufacturerforthe model chosen. Using those emission profilesfor 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 ofthe two models. Each CTG option was evaluated separately in the air dispersion modeling analysis. The Plan Approval contains emission limits specificto the make and model. Tha Facilitywill be required to use control equipment that meets the design criteria they used in determining the emission limits. In summary, the level ofdetail In the Application was sufficientto make the required demonstration thatthe sources In the project will comply with aoolicablefoo'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 asfollows:

plan approval must showthat 'the emissions from a new source will bethe minimum attainable through the use Ofthe SHEA's Application and the Plan Approval include BACT limitsthatwere established In accordancewith the best available technology.' applicable PSD BACT requirements for each pollutant specificto each CTG unit. The application provided information sufficientforthe Department to considerthe expected emission characteristics ofeach emitting source and the systemic effects ofemissions control parameters. Each air emission source was detailed, allowing a consideration and analysis ofthe available control options in the required "top-down" methodology. Tho comment is incorrect In asserting thatthe Department lacks the make and model ofthe CTGs and therefore cannot make 3 BACT determination. Although the Department's regulations do not require the make and model of every piece ofequipment, in this case, the specific make and model Information for tha CTG units was provided in the Application. In turn, afterapplication ofthe top-down analysis ofcontrol methods, BACT limits were listed for each option, and the publicwas afforded an opportunity to review and provide comments on the proposed BACT limits. There is no EPA regulation, guidance, case law, or precedentthat 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 thatwere established forthe various CTG options. Recent PSD permit precedentsthat have authorized multiple CTG equipment options or do not specifythe exact model of CTG. In summary, the level ofdetail 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 ofreduction for See the Response to Comments 32 and 33

each regulatoo' NSR pollutantwhich would be emitted from any proposed majorfacility 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 oravailable methods, systems and techniques, including fuel cleaning ortreatment or innovativefuel combustion techniques for control ofthe pollutant 35 Although PA DEP noted that "[t]hefacility is proposing two different supply options and will pickone option priorto 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 avacuum." Nevertheless, the whole ofthe PA DEPs BACT analysis is done in avacuum. PA DEP may notfind tho plan approval to be complete without a BACT determination, which it cannot complete when it lacks the make and model ofthe 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 thatthe 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 ofthe sources. PA DEP goes so faras to provide separate emissions limits for each turbine that Berks Hollow may choose. 37 A BACT determination is an omissions limit not a series ofo lions. See the Res nSG to Comments 32 and 33 38 Berks Hollow has failed to specifically idenUfythe 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 NoAttachment H- Commentand 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 clearthat ifan 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 afull and independent BACTanalysisfor each source and each pollutant. This Plan The addendum to the TRM provides 3dditional detail into the analysis thatwas performed for

Approval's main flaw Is the cursory review and blind accaptance of Berks Hollow's proposed BACT. In a matter of LAERIBACT/BAT3nalyslsforthe project No substantive changes to the original LAERIBACT/BAT four pages PA DEP accepts BACT limitsforsix source types and tens ofpollutants. This is entirely insufficient and determlmrtionswere made. does not constitute a proper BACT analysis. 41 PA DEP's reliance on tho Hickory Run review does not excuse itfrom 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 ofS02emissions and thus does not require a BACT analysisfor S02

that BACTforsulfuroxide ('SOx") 3nd ('H2S04") is use of pipeline quality natural gaswith an emissions limitation of emissions. The limit of 0,68 gr/100 dscfwas 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 powerplant, (41- gas supplierTexas Eastem Transmission Company (TETCO). Different natural gas pipeline companies 00084A) Moxie Patriot, LLC, Indicated thatthe sulfur content ofthe gasthey will use is 0.25 gr/100 sdaccording to obtain natural gas from different sources. Consequently, the natural gas sulfurcontent associated with a the specifications provided by the fuel supplier. It is unclearwhy this Station will have a sulfur content limit nearly given pipeline company is not 3n Indicator ofthe sulfurcontent ofnatural gas provided by another pipeline throo times the available fuel supply. The Council requests that PA DEP lowerthe sulfur content or provide an company. Therefore, the commentator's comparison offuel sulfur limits Is not appropriate since the Moxie explanation. Patriotfacility (located In Clinton Township, Lycoming .county) will be supplied natural gas by Transco (a Williams compan 43 Further, it does notappearthat the proposed Plan Approval includes monitoring for the sulfuricacid mist. The Plan Plan Approval Section EGroup CCU Condition #003 requires stacktesting for sulfuric acid mist.

Approval should include a method ofdemonstratlno 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 separatelyfrom 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') istreated as two separate pollutants underthe Clean AirAct: 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. at20,659. Therefore, consistent with the EPA's treatment ofemissions information forthese pollutants, the final plan approval for the Station must include separate and distinct limitations and standards for PM1 0and PM2.5 emissions. 45 6. "Good combustion practices" must bedefined and enforce3ble. PA DEP selects "good combustion practices' as Good combustion practices are defined bythe manufacturerfor each CTG set and are specified in the Plan

BACT ond lowest achievable emissions rote for various pollutants on various sources utthe 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 ofthe various practices that specifications. The Plan Approval requires that SHEAshall muintain a copy ofthe 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 EGroup CCU Condition #005(d)). Additionally, the Plan Approval requires verification of proper operation and maintenance ofthe emission units in accordance with the daily operational inspections required bythe Plan Approval (Section EGroup CCU Condition #OOS(a). The Plan Approval raquires the recordkeeping ofpreventativa maintenance and operational inspectionsfor each emission unit in accordance with the Plan Approval (Section EGroup CCU Condition #004 (c) and(d). Additionally, demonstmting compliance with the emission limits In the Plan Approval will providefurther documentation ofthe implementation of good combustion practices. Therefore, the Plan Approval properly identifieswhat is considered good combustion practices and rovides mechanismsto 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 underthe 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 at40 CFR 52.21 (b)(60)(iv), both ofwhich 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 pollutantthat 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 BACTomission limit should be exprel'lsed In terms oftotal GHG emissions, as C02-oquivalent ("C02o"), and the Plan Approval should Indicate how compliance will be demonstrated forthetwo non-C02 GHGs to be emitted 47 To accountfor methane and nitrous oxide emissions and determine compliance with the emission limits fortotal In a response dated May 30, 2013 SHEA stated : "We note thatin recentlyevaluating C02, methene, and

GHGs, EPA recommends use ofemission factors from Table C-2 of40 CFR part 98 and global warming potentials nitrous oxide emissions from (1/fJCtn'c**gene~ratlng** units, EPA e>Xplainedas partofthepreambi<Jto the New from Table A-1 of40 CFR part 98, along with the actual measured heat Inputforthe combustion turbines. Source Performance Standards forgre<Jnhouse gas emissions from newelectricgenerstlng units that: "[tjh(fl estimatedemissions forN20 endCH4 from fossilfuel-firedEGUs (9.0 end0. 7Tg ofC02equivalent, respectively) is about0.4f)(flrcentoftotal C02 equivalentemissions from fossil**fU(fll~fired** electricpower generstlng units."Further, EPA hssrecentlyconcludedthstsufficientdsts is notava/lsbfe to estsblish sepsrste limits fornitrousoxide ormethane In terms oflb!MWh, ststing thst "[w]e sre notproposing sepsrste N20 orCH4 emission limits orsn equivalent C02 emission limitin todsy's action because ofs lackofsvallable data forthese efffJCtedsources." Given the relativelysmellcontribution ofnitrousoxides sndmethsne from such units, the C02(e) limitation set forth In the Pfsn Approvalplus the compliance cMcksprovidedare adequste to sssure controlofGHG emissions." The Department concurs with this

Page6of11 Chan ato'Permlt? ' No

• No

No

No

No No

No

No

NoAttachment H**~Comment** and Response Document Regarding Draft Plan Approval No.**06~05150A**

for Berks Hollow EnergyAssociates, 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 ofGHGs at the Station will be C02from the combined cycle units.

·:writers compare thermal efficiencies ofvarious units to determinewhat 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 shouldjustifywhy a unitwith a lower !efficiencywas selected. PA DEP must then go on to ensure that BACT Is sotfor 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 ofthe 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 ofothercontrol technologies. As presented In the Application, the GHG BACTanalysis performed forthe Project combined cycle units considered carbon capture and sequestration (CCS) and energy efficiency, which are recommended for consideration In EPA's PSD and TitleV Permitting Guidance for Greenhouse Gases dated March 2011. Since CCS was not selected, energy efficiencywas the only available option. As noted by EPA, combined cycle technology is the most efficient fossil fuel-based electricgenerating technology and the 'best system ofemission reduction for new basaload and Intermediate load EGUs" althoUgh efficiencies and emission rates among differentturbine 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 ofall GHG emissions from thefacility) 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 plantswhich was amassed in the range ofnew units whiCh commenced operation operating modes Including startup, shutdown, normal duct bumer operation. 3) The Information from the information available, given the lackofmore recent GHG that are comparable to the proposed Project. EPA's GHG V Permitting Guidancefor Greenhouse Gases, EPA EPA-457/B-11-001 th respect to consideration of NSPS information in determining GHG BACT limits: "The CAA specifies thatBACTcannotbe less stringentthen enyepplicable standardof performance underthe NewSource Performance Standards (NSPS)

.... To the extentEPA completes en 

## I NSPS fora relewmtsource category, BACTdeterminetions thatfoflow wfflneed to considerthe leW')/S ofthe GHGstandards andthe supporting rotlona/e forthe NSPS.... Thus, theguidance In this documentshould be viewedtaking Into consideration thepotentialdevelopmentof en NSPS forepert/eulersource catcgory."

• In terms ofdescribing best available control, EPA states the following as part of NGCC[naturalgas combined-cycle} facilityIs the bestsystem ofemission '!andintermediate toedEGUs." Thus, in its recent NSPS evaluation, EPA both

_ combined cycle technology asthe best system for emission reduction (basically, 

## I BACT), and also defined the performance obtained by such units in terms ofcontrolled GHG emissions resulting from use ofsuch 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 databasewas queried for determinations of "Carbon Dioxide' for Combined Cycle Fuel Combustion Units greater than 25 MW (I.e., ProcessType 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 differentfrom tho proposed SHEAfacility, representing a conversion ofan older, small simple cycle turbine with no SCR to combined cycle with the addition ofan 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 ofthe turbines, tho**a~sonce** of ductfiring,_and the absonco of SCR controls (which tend to place an additional efficiency constraint on such afacility). Similarly, the Palmdale project is not considered rolevant since It Is a hybrid plant consisting of a CCV, with a concontrated solar power (CSP) unitwhich supplies additional steam to the steam turbinefor supplomontal powergeneration. Since the submission ofthe Application, EPA has added to the RBLC database GHG BACT informationfor certain new projects. Ofthe projects listed in the RBLC database for C02, onlythe Moxie Uberty project is somewhat similarto 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 limitfound in Moxie Uberty's Plan Approval No. 08-00045A Is In terms oftons ofC02 a in any 12 consecutive month porlod. The proposed configuration ofthe CCUs for Moxie Liberty is a 1x1 (i.e., ono combustion turbino coupled to one steam turbine) which differsfrom the SHEA Project's2x1 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 loadfollowing profile, the ambient conditions, and tho hours of operation ofthe duct burners will vary from year-to-yoar, the GHG emissions intensitywill vary as well. Forthis 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 limitsforthe 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 ofGHGs from combined cycle plants (ostirrwted to be less than 0.4% ofemissions from such facilities), total annual C02(e) limits specificto each CTG option which accountfor 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 awhole. 51 The measures selected for BACT here are vague and unonforceable. PA DEP Indicatesthat The remaining GHG See the response to comments 49 and 50. No

controloption is the efficientuse ofenergy. The turbinesandductbumers writbe designedforemissions of greenhousegases thatere less than 1000pounds ofC02parmegawatt-hourofelectricityproduced, in conformanoo with EPA's proposedNSPS rule forElectn'c Utility Generating Units (proposed3127/12). This wouldconstitute BACT andBATfor GHGs. 52 To adequately support a BACT determination, PA DEP must, ot minimum, clarifywhetherall avoilable control options Soe the response to comments 49 and 50. No

wore considered, whetherthe option selocted is the best-porformlng option thot Is known to be available and technicallyfeasible, whetherenergy, environmental and oconomic impacts affected the selection ofthe control option, and ifthe best-performing option was not selected provide an explanation and supporting basisforthat 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**llm 1\~~** **!~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 Conditionsfor 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 thatthe 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)(10) in the Condition,, howeverthis section moroly provides that an application must "[s]howthattho source and tho air cleaning dovices aro capable ofbe!lng and will be operated and maintainod in accordance with good air pollution control practices." Ifthore 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 oftho Plan Approval application and to DEP has carefully reviewed the SHEAapplication and has responded to tho public comments. No

respond to all comments from tho publicto ensum that onyfinal action Is consistentwith applicable federal and state recuirements. 56 Further, the Council urges PA DEP to onsura that the bases fordecisions are transparent and thatthe record DEP believos thatthe rocord in this case is cloar, and supports DEP's rocommendation for conditions to No

lProvides adeouate suoOortforthe Plan Aotlroval decisions. · include In this plan approval. omm n roc Jv '' m n faun Pw' mtfn om an via lottordatod4116113 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 Hollowfacility will not Ye•

located lmmodiately adjacent and to tho south oftho proposed Barks Hollow**Ene~rgy** facility. Our goal In providing cause or contribute to exceedances ofapplicablo 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 EGroup CCV has been changed to clarify that shortterm NOx limits aro based on**1~hour** block pormlt record thattho proposed Berks Hollowfacility will not causa orcontribute to oxceedances of applicable averagos. ambient aircualitv standards at or noar ourfacilitv.
Page8of11# Attachment H**~Comment** and Response Document Regarding Draft Plan Approval No.**06~05150A**

for Berks Hollow EnergyAssociates, 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 NOxemission limits forthe Combined Cycle See the response to Comment Sf,

Units (CCUs) detailed in Section E, Source Group CCU, condition #001 ofthe 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) ofthe draft Plan Approval, the short-term emission limits for NOx (ppm and lbfhr) aro Condition #001 (c) In Section EGroup CCU has been changed to state ttwt emission limitaitonsfor 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 EGroup 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 Fleckto 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 NOxfhr emission limitwhen 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 airdispersion modeling analysis must clearly demonstrate !hotthe 1-hr N02, NAAQS will not be exceoded at See the response to Comment 57.

any point at orbeyond the Berks Hollow Energy facility fence line when the two CCUs are each emitting NOx atthe rate of69 lb/hr, and otherfacility combustion sources (such as tho fuel gas heaterand auxiliary boiler) are In operation. Ifdispersion modeling ofsuch a scenario does predict an exooedance, PADEP must impose 1·hraverage 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 ofboth a 1-houraveraging See the response to Comment 59.

time and a 3-hourovoraging time. We believe that PADEP should Impose short-term NOx emission limits on the Berks Hollow CCUs that are eouall roroteetivel. 64 We are also concerned thatthe 1-hr N02 NAAQS may beexceeded during CCU startups, when no shortterm mass See the response to Comment 60.

emission limits or concentration limitsfor NOx apply. 65 NOxemission 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 lowto effectively control NOx emissions In the CT exhaust. It Is also during this time when stack gas temperatures and flow are lowest, leadino to oooratmosoherlc dlsoersion conditions. 66 The Berks Hollow CCUs might conceivably emit 70 lb NOxduring the first hour ofa cold startup, and still be in See the response to Comment 57:

complinnce with all NOx emission limitations in the draftAir Plan Approval, Tho airdispersion modeling analysis must clearly demonstrate thatthe 1·hr N02 NAAQS will not beexceeded at any point at or beyond the Berks Hollow Energyfacilityfenceline when the two CCUs are each emitting NOxat tho rate of70 lbfhr, and otherfacility combustion**source~** /such asthefuel cas heater and auxiliarv boiler) are in oooration. 67 Ifdispersion modeling of such a startup scenario does predict an exceedance, PADEP must impose a 1·hraverage 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 orderto 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·houraveraging time, and also include a 1-houraverage mass emission rate limit for NOxthat applias during CCU startups. The specific NOx emission rates fortheso additional1-houraverage limits should be based on the results ofair dispersion modeling that includes operation of otherfacility combustion souroos as appropriate, and is performed using reoresontatlvo backaround concentrations. Commonts rtlcolvodfrom PA Stato Ro •Jo Knowlos vlu lottordutod4116113 69 I have received several complaints from constituents in Berks Countywho are upsetwith the application foran Air DEP hasfollowed the public comment provisions ofthe law in this case and has made a roasoned decision

Quality Permit submitted by Berks Hollow Power Plantto construct a natural gas power plant in Ontelaunee to not conduct aformal 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 forthis application, In reviewing requests for a public hearing in this case, DEP considered whether are issued to discuss the plantfunction and voice their conooms on this projoct. Because ofthe serious nature of there was significant, Identifiable local public interest. DEP was informed that only four people had theirconcerns, Iwanted to bring itto your immediate attention. Iam writing today to askthat the appropriate officials contacted Rep. Knowles with requests for a public hearing. DEP also tookthe extra step of contacting carefully reviewthis request to schedule a public hearing. Ontelaunee Township officials and was advised that no one had expressed any issues orconcerns atthe Board ofSu orvisors' montl')ly**meetin~s** orwith the**zonin~**and olanninq commission. During the publiccomment period, DEP also received 124 e-mail comments, many ofthem using an identical form letter, objecting to the proposed facility and requesting a public hearing. Nearly all ofthasa comment e·mails had no name orcontact information otherthan thee-moil address. Significant, identifiable local public Interest could not be substontlated duo to tho lackofcontact 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,

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IAttachment H- Commentand 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, Istrongly recommend thatyou hold a meeting and hearing on this power plant.

""''" "'"**"'10~"'""'** 11"" "'"'• '""' u "'"'u '""' !-'"''"'"'"" "'"'1 ..,., with devoloping lungs and seniorswith respiratory disorders are disproportionately at risk. this type offacility 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 nonItwas alleged thatthe 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 denywhetherthe allegations about itswebsite 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 notappropriate 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 ofthis Comment!

Page10of11Attachment H- Commentand 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 bythe Atlas Chemical focillty In Mertztown, ell mannerof carcinogens pumped into the olr ond waterfrom numerous local quarrlos, smelters, stool mills and foundries-the list goes on and on. In addition to all ofthese major polluters, the Berks already contend with the noxious particulate pollution generated at the existing natural gas power the intersection of222 and 183. Tho EPA has repeatedlywarned 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/hrt1mes 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/hrtimes 500 hr/8760