1. Concerning the Greek of 9:22: the phrase is ‘kata ton nomon’ which I think could be best translated “According to the [book of] law, nearly everything was cleansed by blood, [..].”

2. Instead of saying that Jesus’ blood provides the penalty required by the law, the author of Hebrews rather states that this blood cleases our hearts and makes it possible to enter God’s presence (10:19-22). The whole essence of the new covenant is changing the hearts of the believers, so that they become willing to live according the divine principles (v. 16). Only then forgiveness is added (v. 17) because only after the heart’s attitude is changed, forgiveness can make any sense. We are the object of atonement — not God, and not his law. It is our attitude that needs to be changed, not God’s.

3. I think the question is broader: DOES THE OLD TESTAMENT SACRIFICIAL SYSTEM TEACH PENAL SUBSTITUTION? Actually this requires a new discussion topic.

4. There is still another question: What and how many meanings does the term LAW have in the Bible? Is any of these equal to our modern understanding of law? (Penal Substitution theory definitely uses the modern understanding of this term.)