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June 18, 1980 PSD Applicability: Coal Blending 10.19If two power plants were issued state construction permits in 1978, prior to PSD applicability, wish to increase their SO2 emissions by burning higher sulfur coal a SIP revision is necessary. The sources must obtain an amended Part 51.18 permit or a SIP revision. An amended permit will be enforceable under the applicable enforcement plan. PSD review of the change to higher sulfur coal is not required, but SIP revisions may only be approved upon showing that the revisions would not cause or contribute to a violation of the applicable increment.
Any change in the permitted emission limitation would require the permit either to be amended or the source to get a new permit. In either case, the source would be subject to the regulations in effect at the time of the new application. This would mean a BACT and air quality analysis would be required before the SO2 emission limitation could be altered.