2700-PM-AQ0018
Addendum A
6/2003
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL PROTECTION
BUREAU OF AIR QUALITY
Addendum A: Source Applicable Requirements
Describe and cite all applicable requirements pertaining to this source.
Note: A Method of Compliance Worksheet (Addendum 1) must be completed for each requirement listed.
Citation Number
Citation Limitation
Limitation Used
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2700-PM-AQ0018
Addendum 1
6/2003
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL PROTECTION
BUREAU OF AIR QUALITY
Addendum 1
Method Of Compliance Worksheet
SECTION 1. APPLICABLE REQUIREMENT
Federal Tax Id:
Firm Name:
Plant Code:
Plant Name:
Applicable Requirement for: (please check only one box below)
The entire site
A group of sources, Group ID:
A single source, Unit ID:
Alternative Scenario, Scenario Name:
Citation #:
Compliance Method based upon:
Applicable Requirement
Gap Filling Requirement
Method of Compliance Type: (Check all that applies and complete all appropriate sections below)
Monitoring
Testing
Record Keeping
Work Practice Standard
Section 2:
Reporting
Monitoring
1. Monitoring device type (stack test, CEM, etc.):
2. Monitoring device location:
Describe all parameters being monitored along with the frequency and duration of monitoring each parameter:
3. How will data be
reported:
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Section 3:
Testing
1. Reference Test Method Description:
2. Reference Test Method Citation:
Section 4:
Record Keeping
Describe what parameters will be recorded and the frequency of recording:
Section 5:
Reporting
Describe what is to be reported and the frequency of reporting:
1. Reporting start date:
Section 6:
Work Practice Standard
Describe any work practice standards:
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Addendum 1
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Instructions for “Applicable Requirements”
Addendum A is only applicable to an existing Title V facility. The purpose of Addendum A, Applicable Requirements, is to
streamline the administrative requirements for the installation, construction, modification, or reactivation of a source or air
cleaning device to an existing Title V facility. Once the facility has a Title V operating permit, the applicable requirements
for the proposed project (new or modified source) can be incorporated into Title V operating permit through an
administrative amendment. The Department may publish a single notice to cover a plan approval application and
changes in the Title V Operating Permit.
The applicable requirements should include limitations and requirements, which would apply to a proposed project
covered by the plan approval application. A definition of applicable requirements is given in Glossary of Technical Terms
(Part C). Applicable requirements include both emission limitations and work practice standards. An example of this
would be the requirement of 25 Pa. Code § 123.1 that no fugitive emissions are allowed beyond the property line. When
identifying applicable requirements, applicant should consult 25 Pa. Code Chapter 121-145 and note many Federal
regulations are adopted by reference in these rules.
For each applicable requirement that is listed here and listed elsewhere within this addendum, a separate worksheet,
“Method of Compliance Worksheet” (Addendum 1) must be filled out. This is very important since all applicable
requirements must provide a description of or reference to any compliance method to achieve compliance with the stated
requirements. If the proposed project is a modification to an existing Title V facility, make correction on previously
submitted applicable requirements for the source(s). Submit Method of Compliance Worksheet (Addendum 1) for the
only new applicable requirements pertain to proposed project. If the proposed project makes a facility to a Title V facility,
contact appropriate Regional Office when the complete Title V application is required.
Citation Number: This would either be a federal, a state citation, or an existing permit condition, if applicable. Applicants
do not have to delineate which of these citations are federally enforceable. If needed, the Department will separate these
requirements in the permit itself.
Notes: Regulations cited in this column must be in a separate format. For Federal Citations, provide the Code of
Federal Regulations (CFR) and the appropriate sections and/or subsections. For example, New Source Performance
Standards (NSPS), Subpart Dc, would be listed as 40 CFR 60.43c for Particulate Matter.
For State Citation, list the appropriate chapters and sections. For example, a surface Coating Process subjected to an
allowable VOC content stated in Table 1 of Chapter 129.52, would enter 129.52(b)(1) in the column.
Citation Limitation: Indicate the standard or emission limitation associated with the citation number listed.
Limitation Used: This column is optional and is to be used only if a more stringent limitation is proposed.
Example: A steam generating unit constructed after June 8, 1989, with a maximum design heat input capacity of 85 MM
BTU/hr fueled by coal. Some applicable requirements would be:
Citation Number
Citation Limitation
40 CFR 60.43c
For PM: 0.05 lb/MM BTU
40 CFR 60.42c
For SOx: 1.2 lb/MM BTU and
90 % reduction
Limitation Used
(Optional)
For purpose of complying with the above requirement, the Method of Compliance worksheet (Addendum1) must be
completed, indicating that the compliance method for PM would be recording and maintaining of records, and Continuous
Emission Monitoring (CEM), Method 6B, will be used to show compliance for SOx.
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Addendum 1: Method of Compliance Worksheet (Mandatory)
To fulfill the requirement for determining compliance with all applicable requirements listed, a method of compliance
worksheet must be completed. A separate worksheet must be completed for each applicable requirement listed in the
application. Duplicate this worksheet as needed.
There are six (6) sections in this worksheet:
•
•
•
•
•
•
Section 1:
Section 2:
Section 3:
Section 4:
Section 5:
Section 6:
Applicable Requirement
Monitoring
Testing
Record Keeping
Reporting
Work Practice Standard
All six sections do not need to be completed. The completion of part or all of these sections will be determined by the
applicable compliance method checked in Section 1 of this Addendum. For example, if the compliance method for an
existing requirement involves monitoring, reporting, and record keeping, the applicant does not have to complete
Sections 3 and 6 relating to “Testing” and “Work Practice Standard”, respectively.
Section 1:
Applicable Requirement
This section cannot be omitted since it will identify the following important information. It will link an applicable
requirement to the entire site, to a group of sources, to an individual source, or to an alternative operating
scenario. It will also identify the basis and the method of compliance to each applicable requirement. The
following questions in this section must be completed.
•
Applicable requirement for: Check the appropriate box. (Only one should be checked).
⇒ The entire site means the applicable requirement listed in Section 2, “Applicable Requirements
for the Entire Site” of the Title V application.
⇒ A group of sources means for those applicable requirements identify in Section 4, “Source
Groups” of the Title V application.
⇒ A single source is for those requirements listed in this plan approval application relating to the
specific type of sources.
⇒ An alternative Operating Scenario refers to those requirements identified in Addendum 3,
“Alternative Operating Scenario”.
For group of sources, a single source, or an Operating Scenario, please provide the Group, Source, or
Operating Scenario ID accordingly.
•
Citation Number: Give the citation number associated with the applicable requirements.
•
Compliance Method based upon: Check the appropriate box that represents the compliance basis for
this applicable requirement. Again, do not check more than one box.
⇒ Applicable Requirement: This box should be checked when there exists a compliance method
in terms of monitoring, testing, and/or related record keeping and reporting for an applicable
requirement.
⇒ Gap Filling Requirement: This box is to be used for cases where the applicable requirement
does not contain or require a compliance method. It can also be used for future enhanced
monitoring requirements, if applicable.
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Addendum 1
•
6/2003
Method of Compliance Type: Check all boxes that are appropriate to this applicable requirement and
complete the corresponded sections. For example, if the “Monitoring” and “Reporting” boxes are marked,
only Sections 2 and 5 need to be completed.
Section 2:
Monitoring
In this section, provide the type of monitoring device(s) and its location. Also describe all parameters monitored,
the frequency, and the duration of monitoring for each monitor in the table provided. Explain how this data will be
reported to the Department.
Section 3:
Testing
List the reference test method citation as well as a description of this method in spaces provided.
Section 4 & 5: Record Keeping and Reporting
If one of the compliance methods involve record keeping and reporting requirements, answer the questions as
posed.
Section 6:
Work Practice Standard
List or describe any work practice standards used for purposes of determining compliance with the applicable
requirements.
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