Pennsylvania Proposes Amendments to Particulate Matter Testing Requirements

The Pennsylvania Environmental Quality Board (EQB) has proposed to amend 25 Pa. Code Chapters 121 and 139 with the purpose of updating and clarifying the sampling and testing methods used to demonstrate compliance with particulate matter (PM) emissions limits.  The proposed revisions include:

1. Amendments to 25 Pa. Code Chapter 121.1 to the definitions for the terms “condensable particulate matter” and “filterable particulate matter”. 
2. Clarification that the test procedures listed in 25 Pa. Code Chapter 139, for facilities complying with §123.11 – §123.13 (Standards for Containments), are to determine emissions of filterable PM only, and not condensable PM.  The facilities that this clarification would affect are combustion units, incinerators and ‘processes,’ including paint manufacturing, iron and steel making, lead reduction, roasting, melting, petroleum refining and Portland cement manufacturing.   [A full list of the affected ‘processes’ is located at §123.13(b)(1)]. 
3. Clarification that facilities subject to PM₁₀ and PM_2.5 emission limits or sources demonstrating compliance with 25 Pa. Code Chapter 127, including sources with PM emissions related to construction‚ modification‚ reactivation and operation, are required to demonstrate compliance for both filterable and condensable PM₁₀ and PM_2.5 emissions.  This clarification relates to facilities subject to prevention of significant deterioration (PSD) and new source review (NSR) regulations.
4. An addition to the rule stating that facilities currently operating under a permit that was issued prior to January 1, 2011 are ‘grandfathered’ with respect to this proposed change, and therefore do not have to comply with the condensable PM requirement, unless a condensable PM measurement is specifically required by the terms of a facility’s operating permit.
5.  An addition stating that all facilities are required to measure and report condensable PM.  This addition is the most puzzling because it requires facilities to measure and report both filterable and condensable PM even though condensable PM may not be required for compliance purposes.

EQB has indicated that the proposed rulemaking will not create additional requirements or compliance costs for the affected facilities because changes merely update and clarify existing regulations. Personally, I believe that this assumption is incorrect.  As currently proposed, facilities would now be required to measure both filterable and condensable PM and will therefore see an increase in emission testing costs associated with the new requirement.

ALL4 is currently seeking clarification from EQB regarding this proposal.  Public comments will be accepted by EQB through September 10, 2012.  Public hearings will be held in early August in Norristown, Harrisburg, and Pittsburgh, PA.